ML21194A179
| ML21194A179 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/16/2021 |
| From: | NRC/NMSS/DREFS/ELRB |
| To: | |
| Clark, P.M, NMSS/REFS/ELRB, 301-415-6447 | |
| Shared Package | |
| ML21194A166&, #65533 | List: |
| References | |
| EPID L-2020-SLE-0002 | |
| Download: ML21194A179 (65) | |
Text
Supplemental Environmental Impact Statement Scoping Process Summary Report Point Beach Nuclear Plant Units 1 and 2 Town of Two Creeks, WI August 2021 U.S. Nuclear Regulatory Commission Rockville, Maryland
Introduction By letter dated November 16, 2020 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML20329A292), NextEra Energy Point Beach, LLC (NextEra, the applicant) submitted an application for subsequent license renewal of Renewed Facility Operating License Nos. DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach), respectively, to the U.S. Nuclear Regulatory Commission (NRC, the Commission). The application was submitted pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for renewal of operating licenses for nuclear power plants.
Point Beach is located in the Town of Two Creeks, WI, about 15 miles north-northeast of Manitowoc, WI. In its application, NextEra requests subsequent license renewal for a period of 20 years beyond the dates when the current renewed facility operating licenses expire.
Specifically, the new expiration dates would be October 5, 2030, for Point Beach, Unit 1, and March 8, 2033, for Point Beach, Unit 2.
The purpose of this report1 is to provide a concise summary of the determination of the scope of the NRC staffs environmental review of this application, incorporating stakeholder inputs. This report will briefly summarize the issues identified by the environmental impact statement scoping process associated with the NRC staffs review of NextEras subsequent license renewal application.
This report is structured in three sections:
A. The Point Beach Public Scoping Period B. Public Comments and Responses C. List of Commenters A. The Point Beach Public Scoping Period
Background
The NextEra application and all other public documents relevant to the Point Beach subsequent license renewal are available in the NRCs Web-based ADAMS, which is accessible at http://www.nrc.gov/reading-rm/adams.html. Persons who encounter problems in accessing documents in ADAMS should contact the NRCs Public Document Room (PDR) reference staff by telephone at 1-800-397-4209 or 301-415-4737, or by e-mail at pdr.resource@nrc.gov.
For additional information, the NRC staff has made available a Web site with specific information about the Point Beach subsequent license renewal application at https://www.nrc.gov/reactors/operating/licensing/renewal/applications/point-beach-subsequent.html. This Web site includes application information, the licensing review schedule, opportunities for public involvement, project manager information, and other relevant 1 The NRCs requirements for conducting the scoping process and for preparing a scoping summary report are found at 10 CFR 51.29, Scoping-environmental impact statement and supplement to environmental impact statement.
information. In addition, important documents, including public comments, are available at the Federal rulemaking Web site, https://www.regulations.gov/, under Docket ID NRC-2020-0277.
As part of its application, NextEra submitted an environmental report (ER) to the NRC, available at ADAMS Accession No. ML20329A248. NextEra prepared the ER in accordance with 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions, which contains the NRCs requirements for implementing the National Environmental Policy Act of 1969, as amended (NEPA).2 Renewal of a power reactor operating license requires preparation of a supplemental environmental impact statement (SEIS), which is a supplement to the NRCs NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS). The GEIS is available in two main volumes at ADAMS Accession Nos. ML13106A241 and ML13106A242 (ADAMS Package Accession No. ML13107A023).
In the GEIS, the NRC staff identified and evaluated the environmental impacts associated with license renewal of nuclear power plants. The NRC determined that several environmental issues were generic to all nuclear power plants (or, in some cases, to a distinct subset of plants that have specific characteristics, such as a type of cooling system). These generic issues were designated as Category 1 issues. An applicant for license renewal may adopt the conclusions contained in the GEIS for Category 1 issues without further evaluation unless there is new and significant information that may cause the conclusions for its plant to differ from those of the GEIS. Other issues that were not determined generically, and that require a site-specific review, were designated as Category 2 issues. They are required to be evaluated in the applicants ER.
Scoping Process and Objectives The first step in developing a SEIS is to conduct a public scoping process. On February 1, 2021, the NRC published a Federal Register (FR) notice describing the scoping process for the Point Beach subsequent license renewal application environmental review (86 FR 7747). This notice notified stakeholders about the NRC staffs intent to prepare a plant-specific supplement to the GEIS and provided the public with an opportunity to participate in the environmental scoping process. The notice invited members of the public to submit written comments by March 3, 2021. In addition to written comments, oral comments were recorded at the public meeting held on February 17, 2021, via Webinar. All comments, both written and oral, were considered in the agencys scoping process.
The scoping process provided an opportunity for members of the public to propose environmental issues to be addressed in the SEIS and to highlight public concerns and issues.
This scoping summary report provides a summary of what the NRC heard during the scoping process, including a summary of the determinations and conclusions reached during the scoping process. The NRCs stated objectives of the scoping process were to:
Define the proposed action, which is to be the subject of the supplement to the GEIS.
2 The NRCs requirements for an environmental report supporting a license renewal application are found at 10 CFR 51.53(c)(3).
Gather data on the scope of the supplement to the GEIS and identify the significant issues to be analyzed in depth.
Identify and eliminate from detailed study those issues that are peripheral or are not significant or were covered by prior environmental review.
Identify any environmental assessments and other environmental impact statements (EISs) that are being or will be prepared that are related to, but are not part of, the scope of the supplement to the GEIS.
Identify other environmental review and consultation requirements related to the proposed action.
Indicate the relationship between the timing of the preparation of the environmental analyses and the Commissions tentative planning and decisionmaking schedule.
Identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completing the supplement to the GEIS to the NRC and any cooperating agencies.
Describe how the supplement to the GEIS will be prepared, including any contractor assistance to be used.
The NRC staffs determinations and conclusions regarding the above objectives follow.
Define the Proposed Action The NRCs proposed action in this instance is to determine whether to renew the Point Beach operating licenses for an additional 20 years.
Scope of Review, Significant Issues, and Issues that are not Significant The scope of the SEIS includes an evaluation of the environmental impacts of and reasonable alternatives to Point Beachs subsequent license renewal. The Scoping Comments and Responses section of this report includes specific issues that the scoping comments identified.
The NRC staffs responses explain whether the issues will be addressed in the SEIS and, if so, where in the SEIS they will be addressed. Issues that are not significant, or otherwise out of scope (i.e., peripheral issues), are also identified.
For Point Beachs subsequent license renewal, the NRC staff will follow the structure provided in the GEIS. The GEIS evaluates 78 environmental issues related to plant operation and classifies each issue as either a Category 1 issue (generic to all or to a subset of nuclear power plants) or a Category 2 issue (specific to individual power plants). Unless new and significant information is discovered, the NRC will rely on the conclusions in the GEIS for all Category 1 issues. The NRC will reconsider generic impacts in the SEIS where there is new and significant information. The SEIS will discuss all Category 2 issues in depth.
The scoping comments were grouped into the following subject areas (the NRC staff has included in parentheses where the associated scoping comments are addressed in this report):
Aquatic Ecology and Special Status Species (Section B.1)
AlternativesReplacement Power and No-Action (Section B.2)
AlternativesTechnology and Mitigation (Section B.3)
Air Quality and Meteorology (Section B.4)
Climate Change (Section B.5)
Cumulative Impacts (Section B.6)
Decommissioning (Section B.7)
Environmental Justice (Section B.8)
General Environmental Concerns (Section B.9)
Geology and Soils (Section B.10)
Historic and Cultural Resources (Section B.11)
Human Health (Section B.12)
Postulated Accidents and Severe Accident Mitigation Alternatives (SAMA)
(Section B.13)
Radioactive Waste (Section B.14)
Socioeconomics (Section B.15)
Surface Water Hydrology and Quality (Section B.16)
Terrestrial Ecology and Special Status Species (Section B.17)
Uranium Fuel Cycle (Section B.18)
Transportation (Section B.19)
Support of License Renewal (Section B.20)
Opposition to License Renewal (Section B.21)
NEPA Process (Section B.22)
License Renewal Process (Section B.23)
Outside ScopeAging Management (Section B.24)
Outside ScopeEmergency Preparedness (Section B.25)
Outside ScopeEnergy Costs (Section B.26)
Outside ScopeNeed for Power (Section B.27)
Outside ScopeOther Non-License Renewal Actions (Section B.28)
Outside ScopeSafety Concerns (Section B.29)
Outside ScopeSecurity or Terrorism (Section B.30)
Outside ScopeOther Topics (Section B.31)
Identification of Related Environmental Assessments and Other Environmental Impact Statements The NRC staff did not identify any environmental assessments under preparation or soon to be prepared, which relate to, but are not within the scope of, the SEIS. Previously completed EISs will be used in the preparation of the Point Beach subsequent license renewal SEIS, as appropriate, including the GEIS and the SEIS for the initial license renewal of Point Beach (ADAMS Accession No. ML052230490).
Other Environmental Review and Consultation Requirements Concurrent with its NEPA review, the NRC staff is consulting with the U.S. Fish and Wildlife Service (FWS) under Section 7 of the Endangered Species Act of 1973 (ESA) to evaluate the potential impacts of the operation of Point Beach for an additional 20 years on endangered and threatened species and their critical habitat. Consistent with 36 CFR 800.8(c), the staff is also consulting with affected Indian Tribes and the Wisconsin State Historic Preservation Office (WSHPO) to fulfill its Section 106 obligations under the National Historic Preservation Act of 1966 (NHPA).
Timing of Agency Action and How the SEIS Will Be Prepared Upon completion of the scoping process and site audits, completion of its review of Point Beachs ER and related documents, and completion of its independent evaluations, the NRC staff will compile its findings in a draft SEIS. The staff will make the draft SEIS available for public comment. Based on the information gathered during this public comment period, the staff will amend the draft SEIS findings, as necessary, and will then publish the final SEIS. In accordance with 10 CFR 51.102 requirements, the NRC will prepare and provide a Record of Decision in accordance with 10 CFR 51.103. Concurrent with, but separate from this environmental review, the staff will document its safety review in a safety evaluation report (SER). The findings in the SEIS and the SER will be considerations in the NRCs decision to issue or deny the subsequent license renewal.
The NRC staff is currently scheduled to reach a decision on the subsequent license renewal by July 2022. Technical editing contractor assistance will be used to produce the draft SEIS and final SEIS. No technical contractor assistance will be used.
Identificaion of Cooperating Agencies No other Federal agencies are participating in the environmental review as a cooperating agency.
Future Opportunities for Public Participation The NRC staff plans to issue a draft SEIS (DSEIS) for public comment in October 2021. The DSEIS comment period will offer an opportunity for participants, such as the applicant; interested Federal, State, and local government agencies; Tribal governments; local organizations; and members of the public to provide further input to the agencys environmental review process. The DSEIS comments will be considered in the preparation of the final SEIS (FSEIS). Together, the FSEIS and the SER will identify the information considered and the evaluations that the staff performed and they will provide the basis for the NRCs decision on NextEras application for subsequent renewal of the Point Beach operating licenses.
Scoping Process Conclusion The comments provided during the environmental scoping process identified many important issues that the NRC staff will address in its DSEIS for Point Beachs subsequent license renewal. Issues not pertaining to the staffs environmental evaluation, or that are beyond the scope of subsequent license renewal, will not be considered in the DSEIS.
B. Public Comments and Responses During the scoping period (86 FR 7747), the NRC received scoping comments that provided input for the SEIS. The staffs responses to scoping comments are summarized in this section.
Comments were grouped based on being in scope or out of scope, and comments with similar themes were further subgrouped to capture the resources concerned.
Each comment submittal was uniquely identified and when a submittal addressed multiple issues, the submittal was further divided into separate comments with tracking identifiers.
Section C contains a table that identifies the commenters, their affiliation if provided, and the ADAMS Accession No. to locate the correspondence.
B.1 Aquatic Ecology and Special Status Species Comment: The following comments address the operational and cumulative impacts on aquatic species and habitats. Several commenters expressed concern that continued thermal discharges from Point Beach may be contributing to algal blooms or otherwise disrupting the ecology of the aquatic food chain from plankton to larger species, including threatened and endangered species. Other commenters requested information about how facility discharge is monitored to assess ecological impacts. One commenter recommended academic and state regulatory resources. Another commenter expressed concern about the potential for impacts from contaminants in the discharge and their effect on aquatic life and on humans from consumption of fish or during aquatic recreational activities. Another commenter expressed concern regarding the impact of water intake operations at Point Beach on aquatic species and about the loss of ecologically important species due to impingement and entrainment. Several commenters requested consideration of cumulative effects from past operations, climate change, erosion, non-native species, and accidents to aquatic species and habitats, including threatened and endangered species and habitats.
Comments: (2-5) (2-6) (11-7) (12-4) (12-5) (13-9) (13-11) (14-1) (14-2) (26-8-1) (26-8-4)
(26-8-5) (26-8-6) (26-11-4) (26-11-5) (33-6) (33-7) (94-2) (95-2) (107-4) (114-3) (115-7) (117-8)
(125-2) (135-3) (141-2) (144-18) (144-19) (145-1-3) (145-1-5) (145-3-3) (145-3-4) (145-3-5)
(145-3-7) (156-3) (158-2) (171-15) (171-16) (175-2) (175-3) (177-1-15)
Response: The NRC staff will describe the physical and ecological aquatic environment in SEIS Sections 3.7 and 3.8 to include protected species and habitats, presence of contaminants, thermal plumes, and how these have previously affected nearby biota and ecological function.
The staff will consider past, present, and reasonably foreseeable future operational impacts of Point Beachs subsequent license renewal on the ecological environment and protected species and their habitats near the plant.
B.2 AlternativesReplacement Power and No-Action Comment: The following comments are related to alternative energy sources. Commenters stated that the SEIS must address both the benefits and impacts of alternative energy sources, including alternative nuclear technologies that could be used to replace the power that Point Beach generates. Commenters also noted that the analysis of energy alternatives should include energy-efficient measures and energy storage options.
Comments: (2-17) (2-18) (2-23) (3-2) (5-5) (5-6) (12-2) (13-16) (15-3) (23-15) (24-1-2) (24-32-1)
(24-36-1) (24-37-1) (24-73-2) (24-77-1) (24-81-1) (24-82-1) (24-84-2) (24-94-2) (24-94-3)
(24-99-1) (24-105-1) (24-108-2) (24-108-4) (25-6) (26-8-7) (26-11-2) (26-13-7) (26-15-1) (30-4)
(32-4) (33-3) (37-5) (49-2) (49-4) (52-3) (57-3) (63-2) (70-3) (75-6) (79-1) (79-2) (79-5) (79-6)
(80-2) (81-2) (109-2) (113-2) (115-10) (120-3-8) (125-7) (131-2) (132-2) (133-6) (138-1)
(145-4-14) (145-4-17) (145-4-21) (146-8) (146-12) (149-2) (152-2) (154-3) (162-10) (162-12)
(170-1) (170-2) (170-3) (177-2-10) (177-2-11) (177-2-12) (177-2-15)
Response: In the SEIS, the NRC staff will evaluate the environmental impacts of the proposed action (i.e., subsequent license renewal for Point Beach), as well as a reasonable range of alternatives to the proposed action. The staff will identify alternatives in Chapter 2 and assess the impacts of the proposed action and alternatives in Chapter 3. The staff will also consider the feasibility of other technologies and approaches, including energy storage and demand-side management, as alternatives to subsequent license renewal.
B.3 AlternativesTechnology and Mitigation Comment: The following comments address alternative system designs. Commenters requested that the SEIS evaluate the environmental, economic, and safety impacts of continued operation of Point Beach Units 1 and 2, both separately and together. Commenters also requested that the SEIS consider license renewal terms for other than 20-year periods.
Comments: (2-22) (23-17) (25-7) (92-2) (98-1) (143-6) (145-1-16) (145-4-22) (177-2-16)
Response: The application before the NRC is for subsequent 20-year renewals of the operating licenses for Point Beach. The purpose and need for the NRCs proposed action is to provide an option to continue plant operations beyond the current licensing terms to meet future system generating needs, as such needs may be determined by the licensee, State, utility, system, and, where authorized, Federal (other than the NRC) energy policy decisionmakers.
Similarly, the decision to pursue continued operation of Point Beach as power generation sources is a decision that is made by other energy-planning decisionmakers and is outside the scope of this review.
In the SEIS, the NRC staff will evaluate a full range of reasonable alternatives to the proposed action, as well as mitigative measures. The staff will identify alternatives in Chapter 2 and assess their environmental impacts in Chapter 3. Applicable mitigation measures will be discussed in Chapter 4. However, it is not practical, nor reasonable, for the staff to evaluate the environmental impacts of operating each Point Beach unit separately, because environmental impact parameters are generally attributable to the plant as a whole. Similarly, the consideration of economic costs and benefits associated with operating each unit is outside the scope of subsequent license renewal (10 CFR 51.95(c)(2)) and, therefore, will not be evaluated further. Concerns relevant to Point Beachs operational safety are also outside the scope of the subsequent license renewal environmental review and will be addressed in the NRCs parallel safety review under 10 CFR Part 54.
Comment: The following comments address alternative system designs. Commenters requested that the NRC staff evaluate the alternative of replacing the existing once-through cooling water system at Point Beach with cooling towers.
Comments: (95-1) (95-3) (95-4) (120-2-13)
Response: The NRC staff will describe the cooling water system used at Point Beach in Chapter 2, and it will assess the operational impacts of that system in Chapter 3. Point Beachs current Wisconsin Pollutant Discharge Elimination System permit recognizes that the existing once-through cooling water system represents interim Best Technology Available (BTA) for minimizing adverse environmental impacts. Additionally, the State of Wisconsin water quality permitting authority has not imposed a cooling tower requirement on the plant. Further, the NRC has limited authority under the Federal Clean Water Act and does not have the authority to ensure compliance with other regulatory authorities requirements. Therefore, there is no reasonable basis for a SEIS analysis of a mitigation alternative of replacing Point Beachs existing once-through cooling water system with cooling towers. The NRC does not have the regulatory authority to require that NextEra implement an alternative cooling water system as a condition of Point Beachs subsequent license renewal.
B.4 Air Quality and Meteorology Comment: The Environmental Protection Agency (EPA) expressed concerns pertaining to air quality as a result of increases in air emissions from construction equipment used during refurbishment and recommended mitigation measures with respect to diesel equipment.
Comments: (28-3) (28-4)
Response: The NRC staff will describe the affected environment on and around Point Beach relating to air quality and will address the impacts to air quality as a result of the proposed action (subsequent license renewal) in Section 3.3 of the SEIS. The staff notes that it is beyond the NRCs authority to require NextEra to implement the recommended mitigation measures to minimize diesel emissions. The NRCs authority is limited by statute to the protection of the public health and safety from the effects of radiation from nuclear reactors, materials, and waste facilities.
B.5 Climate Change Comment: Commenters requested that the SEIS consider climate change impacts. In particular, commenters requested that the SEIS include a discussion of the impacts of Lake Michigans water level changes and rising water temperatures. Commenters raised concerns about the impacts of rising Lake Michigan water levels and climate change on future nuclear plant operation.
Comments: (2-8) (5-2) (11-6) (13-4) (13-12) (13-13) (23-14) (25-4) (26-9-1) (33-8) (55-2) (75-2)
(75-5) (90-4) (100-1) (100-2) (107-11) (110-1-8) (110-1-9) (110-2-5) (110-2-6) (115-8) (122-3)
(125-4) (143-3) (144-21) (145-2-7) (145-2-11) (145-3-11) (145-3-13) (146-1) (148-7) (156-4)
(160-4) (162-3) (162-18) (168-3) (168-9) (168-11) (177-1-8) (177-1-19)
Response: In Section 3.15.3 of the SEIS, the NRC staff will discuss observed changes in climate and potential future climate changes during the subsequent license renewal term, based on climate model simulations under future global greenhouse gas emission scenarios. The staff will also consider the potential cumulative, or overlapping, impacts from climate change on environmental resources where there are incremental impacts of the proposed action. While the SEIS will consider the potential effects of climate change on environmental resource conditions, the effects of climate change on the safety of Point Beach structures, systems, and components are outside the scope of the staffs license renewal environmental review. Rather, an operating nuclear power plant is subject to continuous NRC oversight under the Reactor Oversight Process, wherein emerging safety and security issues are addressed. In the event action is needed to ensure public safety, the NRC would require it as part of its oversight of the operating license, outside the scope of license renewal.
Comment: The commenters requested that the SEIS consider life-cycle greenhouse gas emissions associated with nuclear power plants and compare greenhouse gas emissions from continued operation of Point Beach and replacement power alternatives.
Comments: (44-3) (49-1) (145-5-4) (145-5-6)
Response: The NRC staff will quantify direct greenhouse gas emissions under the proposed action of subsequent license renewal of Point Beach, and from alternatives to the proposed action, in Section 3.15.3 of the SEIS. The staff notes that Section 4.12.3.1 of the GEIS discusses life-cycle greenhouse gas emissions associated with nuclear power generation, natural gas power generation, coal power generation, and renewable energy sources.
B.6 Cumulative Impacts Comment: The following comments requested that the NRC staff conduct a thorough analysis of other past, present, and reasonably foreseeable future cumulative actions potentially impacting the quality of the human environment, including both short- and long-term impacts.
Commenters specifically requested analysis of potential cumulative impacts to surface water and groundwater resources.
Comments: (109-7) (141-11) (158-10) (171-14)
Response: Consistent with the NRCs NEPA regulations (10 CFR Part 51), the NRC staff will analyze all of the environmental impacts that are reasonably foreseeable and have a reasonably close causal relationship to the proposed action. In Chapter 3 of the SEIS, the impacts of the proposed action will be analyzed in conjunction with other past, present, and reasonably foreseeable future actions at Point Beach.
B.7 Decommissioning Comment: The following comments are concerned with the impacts of the no-action alternative, decommissioning, and the continued storage of nuclear waste and spent fuel at Point Beach. Commenters stated that, in the SEIS, the NRC must address the impacts of the no-action alternative, decommissioning, nuclear waste and spent fuel storage, and returning the Point Beach site to its original natural condition.
Comments: (2-20) (86-8) (109-5) (109-6) (110-2-18) (134-5) (144-2) (145-4-19) (155-1)
(177-2-13)
Response: The environmental impacts of no-action, decommissioning, and the continued storage of nuclear waste and spent fuel at Point Beach will be addressed during the environmental review. While the NRC will make its decision to renew the operating licenses on the basis of safety and environmental considerations, the final decision to continue plant operations will be made by the licensee, State, utility, system, and, in some cases, Federal (non-NRC) decisionmakers. Their decision will be based on economics, energy reliability goals, and other objectives over which they may have jurisdiction. The impacts of decommissioning nuclear plants are also evaluated in the Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (NUREG-0586, Supplement 1) (ADAMS Accession Nos.
ML023470327, ML023500228, and ML023500295). A separate environmental review will be conducted in response to the license termination plan, required to be submitted by the licensee at least two years before termination of the license, demonstrating, among other things, that the facility and site will meet the criteria for decommissioning in 10 CFR Part 20, Subpart E. The impacts from the continued storage of spent nuclear fuel after the termination of reactor operations are addressed in the Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NUREG-2157) (ADAMS Accession No. ML14198A440). The environmental impact of the no-action alternative, including the shutdown of Point Beach, will be discussed for each resource area in Chapter 3 of the SEIS.
Comment: The following comments are concerned with the financial viability of NextEra to completely decommission Point Beach, including maintaining the continued storage of spent nuclear fuel. Commenters requested assurance from the NRC that sufficient funds will be available to complete the decommissioning of Point Beach while maintaining spent fuel storage facilities.
Comments: (2-21) (26-15-3) (86-7) (110-1-21) (110-2-8) (110-2-10) (110-2-16) (145-4-20)
(177-2-14)
Response: The NRCs regulations at 10 CFR 50.75 require a nuclear power plant licensee to provide reasonable assurance that funds will be available for decommissioning the plant. To comply with this requirement, NextEra has established for Point Beach a Decommissioning Trust Fund in which the total amount of funds would be sufficient to pay decommissioning costs at the time permanent termination of operations is expected. NextEra is required to submit a biannual, publicly available status report that updates the Point Beach Decommissioning Trust Fund status. The status of the Point Beach Decommissioning Trust Fund is outside the scope of license renewal environmental reviews because it is a current operating, as opposed to an aging management, issue and, therefore, will not be evaluated further in the SEIS.
As explained in the GEIS, the NRC has developed regulations and guidance for the decommissioning of nuclear power plants. These include 10 CFR 50.82, Termination of license, Subpart E, Radiological criteria for license termination, to 10 CFR Part 20, Standards for protection against radiation, and Consolidated Decommissioning Guidance (NUREG-1757) (ADAMS Accession Nos. ML063000243, ML063000252, and ML12048A683).
At the end of decommissioning, the nuclear power plant site and any remaining structures can be released for unrestricted or restricted use. The radiological criteria for releasing nuclear power plant sites for unrestricted use are specified in 10 CFR 20.1402. The environmental impacts from radiological and nonradiological accidents during decontamination and decommissioning are evaluated in NUREG-0586.
B.8 Environmental Justice Comment: Several commenters recommended that the NRC meet with environmental justice communities, including low-income, minority, and Tribal populations, during the license renewal environmental review. Commenters also recommended that the environmental justice impact analysis consider a range of environmental impact pathways.
Comments: (23-13) (26-2-1) (49-5) (118-3) (127-3) (162-16) (166-2)
Response: The environmental justice impacts of license renewal, including spent fuel storage and postulated accidents during the renewal term, will be addressed in Chapter 3 of the SEIS.
All Tribes potentially affected by the continued operation of Point Beach will be contacted and consulted, if requested, during the environmental review. The environmental justice impacts of the uranium fuel cycle, including mining and milling, are addressed in separate NEPA documents associated with those facilities. The environmental justice impacts from the continued storage of spent nuclear fuel after the termination of reactor operations are addressed in NUREG-2157.
B.9 General Environmental Concerns Comment: Commenters expressed general concerns about the environment. Many commenters requested that the NRC staff conduct a thorough environmental impact assessment and evaluate issues including air quality, water supply and quality, waste generation, climate change, economic impacts, and ecological impacts on habitats and species.
Some commenters expressed concern about mitigation plans.
Comments: (2-24) (24-7-1) (24-9-1) (24-17-1) (24-26-1) (24-31-1) (24-35-1) (24-47-1) (24-51-1)
(24-91-2) (24-100-1) (24-102-1) (24-114-1) (26-11-1) (63-1) (100-7) (110-1-2) (110-1-6) (117-7)
(141-3) (141-6) (141-8) (141-10) (145-1-14) (145-4-18) (145-5-3) (148-2) (149-3) (158-3)
(158-7) (158-9) (168-1) (177-2-17)
Response: In the SEIS, the NRC staff will consider the issues identified in these comments, among other matters. The staff will describe the affected environment at Point Beach in Chapter 3 of the SEIS and will evaluate the environmental impact of renewing the operating licenses for Point Beach. Mitigation was considered for Category 1 issues in the GEIS. The staff will review any new and significant information not included in the GEIS, including appropriate mitigation for all Category 2 (i.e., plant-specific) issues.
B.10 Geology and Soils Comment: The following comment addresses the geology and soils of the Point Beach site and vicinity.
Comment: (145-1-12)
Response: The geologic environment and soils of the Point Beach site will be described in Section 3.4 of the SEIS. Impact issues related to geology and soils were evaluated in the GEIS and were determined to be Category 1 (i.e., generic) issues. Any new and significant information concerning geologic and soil impacts will be discussed in Section 3.4 of the SEIS.
Comment: The following comments address the occurrence and frequency of seismic events at Point Beach and the potential effects of a seismic event on the plant.
Comments: (86-3) (107-7) (107-14) (145-1-10)
Response: The seismic setting of the Point Beach site will be briefly summarized in Section 3.4 of the SEIS. However, the potential effects of seismic activity on Point Beach are outside the scope of the license renewal environmental review and, therefore, will not be evaluated further in the development of the SEIS. The potential effects of seismic activity on operating reactors are evaluated by the NRC in an ongoing process that is separate from the license renewal process.
B.11 Historic and Cultural Resources Comment: These comments are related to the NRCs request for Section 106 consultation under the NHPA (54 U.S.C. 300101 et seq.). The Nottawaseppi Huron Band of the Potawatomi stated that it did not object to the proposed project. The Miami Tribe of Oklahoma stated that it is not aware of any historic documentation that would link a specific Miami Tribe of Oklahoma cultural or historic site to the proposed site, but would like to be immediately consulted if any human remains or Native American cultural items pursuant to the Native American Graves Protection and Repatriation Act or archaeological evidence is discovered during any phase of the project. The Wisconsin State Historic Preservation Office (WSHPO) accepted the invitation to participate in consultation and requested that an architectural resources survey be conducted of Point Beach, including all ancillary buildings and structures, to identify all structures that meet the 50-year threshold for inclusion in the National Register of Historic Places. The WSHPO also requested that NextEra update its equivalent Historic Properties Management Plan to include architectural resources.
Comments: (29-1) (179-1) (180-1) (180-2)
Response: The NRC appreciates the responses from the Nottawaseppi Huron Band of the Potawatomi, the Miami Tribe of Oklahoma, and the WSHPO. The NRC is conducting Section 106 consultation through NEPA in accordance with 36 CFR 800.8(c). The regulations in 36 CFR Part 800, Protection of historic properties, require that the NRC consult with any Indian Tribe that attaches religious and cultural significance to historic properties that a proposed action/undertaking may affect. The NRCs ongoing Section 106 consultation with consulting parties will be described in Section 3.9 of the SEIS. This section will also identify and describe historic and cultural resources that subsequent license renewal may affect.
Comment: Commenters expressed concerns related to NextEras Tribal outreach efforts and information not mentioned in communications from NextEra to Indian Tribes regarding human health and waste management. Commenters requested that the NRC initiate Tribal interactions.
Comments: (145-4-10) (165-7) (167-4)
Response: The NRC is independently conducting NHPA Section 106 consultation through NEPA in accordance with 36 CFR 800.8(c). The regulations in 36 CFR Part 800 establish the requirements for the NRC to consult with any Indian Tribe that attaches religious and cultural significance to historic properties that the proposed action may affect. The NRC will describe ongoing Section 106 consultation for the Point Beach subsequent license renewal in Section 3.9 of the SEIS. Additionally, Sections 3.11 and 3.13 will describe human health and waste management impacts associated with the proposed action.
Comment: Several commenters requested that the SEIS consider the impacts to historic and cultural resources and that the NRC consult with Indian Tribes. Commenters expressed concerns related to: the fact that no cultural resource surveys were conducted before original construction or ongoing construction activities at the Point Beach site; impacts to unknown cultural resources that have yet to be identified on the Point Beach site in addition to those already identified; the fact that Point Beachs historic and cultural resource procedures are not publicly available; and consideration of treaty rights.
Comments: (110-1-11) (141-4) (145-1-13) (158-4) (165-1) (165-2) (165-3) (165-4) (165-6)
(166-3) (166-4) (166-5) (166-6) (167-1) (167-2) (167-3) (167-5)
Response: The NRC staff will identify and describe historic and cultural resources that may be impacted by subsequent license renewal in Chapter 3 of the SEIS. The SEIS will discuss cultural resource surveys that have been conducted within the Point Beach site boundary and NextEras onsite cultural resource protection procedures. The staff identified cession treaties affecting the location of the Point Beach site and immediate vicinity, but the treaties did not contain continuing hunting, fishing, or gathering rights that affect the Point Beach area (Treaty of Washington (7 Stat. 342) amended).
The NRC is independently conducting NHPA Section 106 consultation through NEPA in accordance with 36 CFR 800.8(c). The regulations in 36 CFR Part 800 require the NRC to consult with any Indian Tribe that attaches religious and cultural significance to historic properties that may be affected by a proposed action/undertaking. The NRC will describe its ongoing Section 106 consultation for the Point Beach subsequent license renewal in Chapter 3 of the SEIS.
B.12 Human Health Comment: Commenters expressed concern about the availability of radiological monitoring data and the risks to both plant workers and the public posed by radioactive releases in air and water from Point Beach Units 1 and 2.
Comments: (24-55-1) (26-7-4) (26-14-3) (30-1) (35-2) (35-4) (104-3) (110-1-16) (115-6) (119-1)
(119-2) (119-3) (119-4) (119-6) (120-1-18) (120-2-1) (120-2-2) (120-2-4) (120-2-15) (120-2-16)
(120-2-17) (120-2-18) (120-2-19) (120-2-20) (120-3-2) (120-3-9) (120-3-10) (125-1) (125-6)
(129-4) (133-5) (135-2) (143-5) (144-11) (144-17) (145-1-2) (145-1-7) (145-1-9) (145-3-16)
(145-3-17) (145-4-5) (148-4) (154-1) (156-1) (156-5) (156-11) (162-15) (162-17) (165-5) (171-2)
(171-7) (171-8) (171-11) (175-5) (176-2) (177-1-11) (177-1-17) (177-2-7)
Response: Nuclear power reactors routinely release radioactive gaseous and liquid effluents into the environment. The NRC requires these effluents to be monitored and controlled to protect the public health and safety in accordance with its radiation protection standards in 10 CFR Part 20. Each nuclear power plant has radiation monitoring instruments and procedures to control the release of these radioactive effluents and must submit an annual radioactive effluent release report to the NRC. This report summarizes the types and quantities of radioactive materials released into the environment. The annual radioactive effluent release reports for Point Beach are publicly available in the NRCs Web-based ADAMS, which is accessible at http://www.nrc.gov/reading-rm/adams.html. Links to these reports are also provided on the NRCs Web site for Point Beach (accessible at https://www.nrc.gov/info-finder/reactors/poin1.html and https://www.nrc.gov/info-finder/reactors/poin2.html under the Plant Environmental Report heading). Radiation exposure to workers and the public was evaluated in the GEIS, wherein the impacts were determined to be SMALL and a Category 1 (i.e., generic) issue if the releases and doses do not exceed the permissible levels in the NRCs regulations. The NRC staff will consider whether any new and significant information relative to human health has been identified; if so, it will evaluate this new information in applicable sections of Chapters 2 and 3 of the SEIS.
Comment: Commenters expressed concern about whether the SEIS will address risks to women, pregnant woman, children, and infants.
Comments: (26-14-1) (26-14-2) (30-2) (117-1) (120-3-11) (127-2) (156-10) (163-4) (171-1)
(176-3) (177-1-12)
Response: Current radiological limits that protect the public health and safety are carefully considered from the recommendations of national and international scientific review boards and are conservative to protect children as well as adults. Radiation exposure to the public was evaluated in the GEIS, wherein the impacts were determined to be SMALL and a Category 1 (i.e., generic) issue if the releases and doses do not exceed the permissible levels in the NRCs regulations. The NRC staff will consider whether any new and significant information relative to human health has been identified; if so, it will evaluate this new information in Section 3.11 and other applicable sections of the SEIS.
Comment: Commenters expressed concern about the risk to the public from radionuclides in Lake Michigan and the groundwater.
Comments: (1-3) (14-3) (71-6) (110-1-7) (110-1-13) (144-12) (145-1-4) (145-1-6) (145-1-8)
(145-3-9) (145-3-10) (168-13)
Response: Radiation exposure to the public was evaluated in the GEIS, wherein the impacts were determined to be SMALL and a Category 1 (i.e., generic) issue if the releases and doses do not exceed the permissible levels in the NRCs regulations. The NRC staff will consider whether any new and significant information relative to human health has been identified; if so, it will evaluate this new information in the appropriate sections of SEIS Chapters 2 and 3. The issue of radionuclides released to groundwater was evaluated in the GEIS and determined to be a Category 2 (i.e., plant-specific) issue. The staff will discuss groundwater hydrology and groundwater quality, including the presence of radionuclides, in and around the Point Beach site in Section 3.5.2 of the SEIS. The staff will also address the potential impacts of the proposed action (subsequent license renewal) on groundwater resources in Section 3.5.2 of the SEIS.
Comment: The commenters expressed concern regarding the presence of Carbon-14 in effluents from nuclear reactors.
Comments: (26-18-3) (145-5-5) (145-5-9)
Response: Carbon-14 is formed in nuclear reactors due to absorption of neutrons by carbon, nitrogen, or oxygen. These elements may be present as components of the fuel, moderator, or structural hardware, or they may be present as impurities. Air emissions, including emissions of radionuclides, were evaluated in the GEIS and were determined to be Category 1 (i.e., generic) issues. Any new and significant information concerning gaseous radionuclide emissions will be addressed in applicable sections of Chapters 2 and 3 of the SEIS.
Comment: The following comment expressed concerns about the accuracy of the Radiation Environmental Monitoring Program (REMP) at Point Beach and requested an expansion of the REMP.
Comment: (120-3-1)
Response: The REMP is designed to provide data on measurable levels of radiation and radioactive materials in the environment around a nuclear power plant. The results of the REMP are intended to supplement the results of the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive material and levels of radiation are not higher than expected, based on the effluent measurements and modeling of the environmental exposure pathways. The two programs work together as a check against each other. The REMP provides measurements of radiation and radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposure to members of the public. Separate from the NRCs license renewal environmental review, the NRC staff reviews Point Beachs REMP as part of its ongoing inspection program.
Radiation exposure to the public was evaluated in the GEIS, wherein the impacts were determined to be SMALL and a Category 1 (i.e., generic) issue if the releases and doses do not exceed the permissible levels in the NRCs regulations. The staff will consider whether any new and significant information relative to human health has been identified; if so, it will evaluate this new information in Chapters 2 and 3 of the SEIS. The staff will discuss the latest available results from the Point Beach REMP and effluent release monitoring program in Chapter 2 of the SEIS.
B.13 Postulated Accidents and Severe Accident Mitigation Alternatives (SAMA)
Comment: Several commenters expressed concern about postulated accidents, including those caused by tornados, earthquakes, or the embrittlement of the Point Beach reactor vessels. Specific concerns included such possible accident consequences as acute fatalities, radiation injuries, cancers (particularly thyroid cancers), environmental contamination, radioactive releases, spills, fire risks, impacts on drinking water and Lake Michigan, impacts on wildlife and forests, and the impacts of lake level rise. In addition, commenters inquired about the potential causes of accidents, citing the accidents that took place at nuclear power plants in Chernobyl and Fukushima. Commenters also expressed concerns about the impact on vulnerable populations, the potential economic impacts of accidents, and accidents involving multiple nuclear power generating units.
Comments: (2-3) (2-4) (4-2) (11-2) (12-3) (13-2) (15-5) (23-7) (23-8) (23-9) (23-10) (25-5)
(26-1-2) (26-7-1) (26-10-4) (26-10-6) (26-10-7) (26-11-3) (26-13-5) (26-15-2) (32-1) (33-4)
(77-2) (77-3) (77-5) (94-4) (109-1) (110-1-14) (111-6) (115-4) (116-2) (116-3) (116-5) (117-4)
(117-9) (120-1-14) (120-3-16) (120-3-17) (120-3-19) (125-3) (125-5) (125-13) (133-1) (144-10)
(145-3-15) (145-3-19) (145-5-13) (145-6-12) (146-3) (148-1) (148-6) (160-5) (163-3) (176-1)
(176-5) (177-1-10) (177-1-14)
Response: The GEIS determined that the environmental impacts of design basis accidents are SMALL for all plants. In addition, for severe accidents, the GEIS determined that the probability-weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are SMALL for all plants. The NRC staff will consider any new and significant information that could affect the environmental impacts related to postulated severe accidents or that could affect the results of a previous severe accident mitigation alternative assessment in Chapter 3 and Appendix F of the SEIS.
B.14 Radioactive Waste Comment: Commenters expressed concern about the additional nuclear waste to be generated over the additional 20 years of plant operation and questioned whether there is sufficient onsite storage capacity at Point Beach. Commenters also expressed concern with NextEras ability to finance additional onsite storage.
Comments: (1-2) (2-2) (5-1) (13-6) (26-4-1) (105-3) (110-1-19) (143-2) (145-2-5) (156-8)
(169-1) (177-1-6)
Response: NextEra indicates in its ER that an independent spent fuel storage installation (ISFSI) expansion may be needed to accommodate the additional spent fuel generated during the period of extended operation, and that the ISFSI expansion would occur generally west of the existing facility within the ISFSI-defined area. The environmental impacts of an ISFSI expansion to accommodate additional spent fuel will be addressed as part of the cumulative impacts analysis in Chapter 3 of the SEIS. Regarding costs, in 10 CFR 72.22(e), the NRC requires licensees to demonstrate the financial qualifications to cover the estimated operating costs over the planned life of the ISFSI. The financial qualifications of the applicant are outside the scope of license renewal environmental reviews because they are not an aging management issue and, therefore, will not be evaluated further in the development of the SEIS.
Comment: Commenters stated that NextEra should provide assurance of its financial resources to store spent nuclear fuel during the licensing period without compromising the ability to fund decommissioning. Commenters also expressed concern regarding who will be responsible for the costs of removing spent fuel from the site and transporting it to a permanent repository.
Comments: (110-2-1) (110-2-2) (110-2-3) (110-2-12) (110-2-13) (125-12) (145-3-1)
Response: The regulations in 10 CFR 72.22(e) require licensees to demonstrate their financial qualifications to cover the estimated operating costs over the planned life of the ISFSI for both the storage of spent nuclear fuel and the estimated decommissioning costs. The financial qualifications of the applicant and the costs for transportation of spent fuel are outside the scope of the environmental review and, therefore, will not be evaluated further in the development of the SEIS.
Comment: The following comments suggested that the SEIS should include an assessment of low-level radioactive waste.
Comments: (70-2) (110-1-12)
Response: The generation of low-level radioactive waste by operating nuclear power plants was evaluated in the GEIS and determined to be a Category 1 (i.e., generic) issue applicable to all plants. The GEIS evaluated all impacts associated with the low-level radioactive waste for all nuclear power plants, including Point Beach, and determined that the impact was SMALL. Any new and significant information concerning low-level radioactive waste will be addressed in Chapters 2 and 3 of the SEIS.
B.15 Socioeconomics Comment: Commenters suggested that the SEIS should address the socioeconomic impacts associated with property values being adversely affected by continued Point Beach operations.
One commenter stated that there was a measurable population flight away from the Point Beach reactors in the short time period after the first 20-year license renewal.
Comments: (26-8-8) (70-1) (109-3) (115-11) (145-1-18)
Response: The socioeconomic impacts of license renewal will be discussed in Chapter 3 of the SEIS. However, the economic costs and benefits of renewing an operating license are outside the scope of the environmental review. The regulation, 10 CFR 51.95(c)(2), states, in part, 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 or of alternatives to 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."
While the NRC makes its decision whether to renew an operating license on the basis of safety and environmental considerations, the final decision to continue operating Point Beach is made by the licensee, State, utility, system, and, in some cases, Federal (other than NRC) decisionmakers based on considerations such as economics, energy reliability goals, and other objectives over which they may have jurisdiction.
Comment: Several commenters asked that the SEIS address the social and economic impacts on the human environment from the proposed action, both positive and negative, including impacts to housing, aesthetics, business climate, property values, noise, and other concerns.
Comments: (2-19) (141-5) (141-9) (145-1-15) (158-5) (158-8)
Response: Community services and education, population and housing, aesthetics, and noise are evaluated in the GEIS. Any new and significant information at Point Beach concerning the socioeconomic impacts of license renewal will be addressed in Section 3.10 of the SEIS.
Comment: Several commenters asked that the NRC address the impacts of the no-action alternative in the SEIS and suggested that various alternatives to the continued operation of Point Beach might result in beneficial socioeconomic impacts or less adverse impacts.
Commenters also expressed concern over the cost effectiveness and impacts of nuclear power compared to alternative means of power generation.
Comments: (2-11) (23-16) (30-5) (145-4-2) (146-5) (163-9) (177-2-3)
Response: The socioeconomic impacts of the no-action alternative, including plant closure, will be addressed for each resource area in Chapter 3 of the SEIS and the impacts of nuclear plant closure have been evaluated in NUREG-0586. The impacts of various alternative means of power generation will also be addressed in Chapter 3 of the SEIS. While the NRC makes its decision whether to renew an operating license on the basis of safety and environmental considerations, the final decision to continue operating Point Beach is made by the licensee, State, utility, system, and, in some cases, Federal (other than NRC) decisionmakers based on considerations such as economics, energy reliability goals, and other objectives over which they may have jurisdiction.
B.16 Surface Water Hydrology and Quality Comment: Several commenters expressed concern about Point Beachs use of water from and its subsequent discharge to Lake Michigan. These concerns related to the volume of water withdrawn, surface water use conflicts, impacts to lake water quality (including thermal impacts),
and monitoring requirements.
Comments: (11-5) (23-5) (23-6) (24-44-3) (25-3) (100-5) (107-5) (107-16) (120-2-12) (120-2-14)
(120-3-3) (125-10) (135-1) (145-3-8) (148-3) (171-13) (175-1) (175-4) (177-1-16)
Response: The NRC staff will describe Point Beachs cooling and auxiliary water systems in Section 2.1.3 of the SEIS. Section 3.5.1 of the SEIS will describe the plants cooling water withdrawals and the existing monitoring of the plants cooling water discharges. The impacts of license renewal and the continued operation of Point Beach on surface water resources and aquatic resources will be considered in Sections 3.5 and 3.7 of the SEIS, respectively.
Surface water use conflicts at operating nuclear power plants with once-through cooling systems were evaluated in the GEIS and were determined to be a Category 1 (i.e., generic) issue. Altered thermal stratification of lakes was evaluated in the GEIS and was determined to be a Category 1 issue. At operating nuclear power plants, the effects of thermal stratification from plant cooling water discharge were found to be limited to the vicinity of discharge structures. Any new and significant information concerning these issues will be discussed in Sections 3.5 and 3.7 of the SEIS.
Comment: Several commenters expressed concerns that Point Beachs discharges could cause erosion, impacting site soils, the shoreline, the lake bottom, and the aquatic environment.
Comments: (2-7) (13-10) (26-8-3) (145-3-6) (177-1-18)
Response: The NRC staff will consider the impacts of continued operation of Point Beach on surface water resources and aquatic resources, including the discharge of cooling water, in Sections 3.5 and 3.7 of the SEIS. Scouring caused by discharged cooling water was evaluated in the GEIS and was determined to be a Category 1 (i.e., generic) issue. Any new and significant information concerning scouring and other effects caused by plant water discharge will be discussed in the SEIS.
B.17 Terrestrial Ecology and Special Status Species Comment: One commenter requested that the SEIS include an assessment of potential impacts to migratory birds that may result from replacing Point Beach with an alternative, non-thermal plant.
Comment: (49-3)
Response: The NRC staff will address the impacts of various alternative means of power generation on terrestrial resources, including migratory birds, in Section 3.6 of the SEIS.
Comment: One commenter described a number of threatened and endangered species and a critical habitat that the FWS has listed as being in the vicinity of the Point Beach site and expressed concern for these species. The same commenter suggested that the SEIS should include how these threatened and endangered species and other nearby species that may be at risk will be protected.
Comment: (144-20)
Response: Threatened and endangered species and critical habitat on the plant site will be addressed as a Category 2 (i.e., plant-specific) issue in Chapter 3 of the SEIS. The NRC staff will also conduct appropriate consultation under the Endangered Species Act.
B.18 Uranium Fuel Cycle Comment: The following comments address the uranium fuel cycle. Commenters stated that the SEIS should consider the environmental impacts of the uranium mining and processing required to provide fuel for Point Beach for an additional 20 years of operation. Commenters also expressed concern about the environmental impacts from energy use in the uranium fuel cycle.
Comments: (12-6) (23-11) (23-12) (26-11-6) (33-10) (109-4) (156-9)
Response: Uranium fuel cycle issues were evaluated in the GEIS and were determined to be Category 1 (i.e., generic) issues. The NRC staff will consider whether any new and significant information relative to the uranium fuel cycle has been identified; if so, it will evaluate this new information in Section 3.15 of the SEIS.
Comment: Several commenters expressed concern about the safety of storing spent nuclear fuel on site and about where the spent fuel will be stored long-term. Commenters also expressed concerns about the integrity of spent fuel storage casks and how such casks are monitored. Commenters requested that the SEIS include information on the movement and onsite storage of spent fuel.
Comments: (1-1) (2-1) (4-1) (15-2) (19-1) (23-2) (25-2) (26-2-2) (26-9-3) (33-9) (56-2) (60-7)
(75-1) (75-4) (90-2) (100-8) (100-12) (104-6) (104-7) (105-1) (105-2) (110-1-18) (110-2-14)
(115-3) (126-1) (129-1) (133-3) (144-4) (145-1-19) (145-2-2) (145-2-3) (145-2-6) (145-2-12)
(145-2-13) (145-2-15) (145-2-16) (145-2-18) (146-4) (146-6) (177-1-4) (177-1-5)
Response: Onsite storage of spent nuclear fuel was evaluated in the GEIS, as reaffirmed by the NRCs 2014 Final Rule on Continued Storage of Spent Nuclear Fuel (79 FR 56238). It was determined to be a Category 1 (i.e., generic) issue. For the period after the licensed life for reactor operations, the impacts of onsite storage of spent nuclear fuel during the continued storage period are discussed in NUREG-2157 and, as stated in 10 CFR 51.23(b), shall be deemed incorporated into the SEIS. The NRC certifies casks approved for storage of spent nuclear fuel in accordance with 10 CFR Part 72, Licensing requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related greater than Class C waste. The NRC requires the evaluation of natural hazards, including storms and flooding, on the safety of spent fuel storage as part of its oversight of the current operating license and, therefore, this issue is outside the scope of license renewal. The NRC staff will consider whether any new and significant information relative to spent nuclear fuel storage has been identified; if so, it will evaluate this new information in the applicable sections of Chapters 2 and 3 of the SEIS.
Comment: Commenters expressed concern about safe storage, as well as the long-term (permanent) storage and disposal, of high-level waste and spent nuclear fuel.
Comments: (10-1) (11-4) (12-8) (23-4) (24-1-1) (24-3-1) (24-4-1) (24-13-1) (24-20-1) (24-29-1)
(24-37-2) (24-43-3) (24-44-1) (24-60-2) (24-84-3) (24-91-1) (24-107-1) (24-107-2) (24-111-1)
(26-1-1) (26-11-7) (26-13-2) (26-13-3) (26-15-6) (26-15-7) (30-3) (32-2) (80-1) (90-5) (94-1)
(100-11) (107-12) (120-3-7) (121-1) (131-1) (134-4) (135-6) (139-1) (144-6) (145-2-1) (145-3-2)
(145-5-10) (145-6-7) (160-7) (162-14) (162-24) (163-7) (169-2) (172-2)
Response: Regarding spent fuel storage during the licensed life of reactor operations including the subsequent license renewal termthe NRC evaluated the onsite storage of spent nuclear fuel in the GEIS. As the NRCs 2014 Final Rule on Continued Storage of Spent Nuclear Fuel (79 FR 56238) reconfirms, onsite storage during the license renewal term was determined to be a Category 1 (i.e., generic) issue applicable to all plants with SMALL environmental impacts. The NRC staff will describe the management of radioactive waste in Chapters 2 and 3 of the SEIS and will consider any new and significant information regarding radioactive waste impacts from renewing the operating licenses for Point Beach in Section 3.13 of the SEIS.
For the storage period after the licensed life of reactor operations, the impacts from onsite storage of spent nuclear fuel during the continued storage period are discussed in NUREG-2157 and, as stated in 10 CFR 51.23(b), shall be deemed incorporated into the SEIS.
This issue will not be evaluated further in the development of the SEIS.
Regarding permanent storage and disposal, the Nuclear Waste Policy Act of 1982 authorized the U.S. Department of Energy (DOE) to dispose of high-level radioactive waste (HLW) and spent nuclear fuel. Siting and construction of a high-level waste storage facility is the responsibility of the DOE. The NRCs role is to serve as the independent regulator for the design, construction, operation, and eventual decommissioning of the repository.
Offsite radiological impacts of spent nuclear fuel and HLW disposal are discussed in Section 4.11.1.3 of the GEIS. This is a Category 1 issue with no specific level of significance assigned. Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states that, The Commission concludes that the impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR [P]art 54 should be eliminated. This issue will not be evaluated further in the development of the SEIS.
Comment: The following comments relate to waste management. Commenters questioned the energy requirements of onsite storage of spent nuclear fuel in pools, the capacity of the spent fuel pools to store additional fuel, the potential disruption from extreme weather events, and what portion of the stored fuel would be high burn-up fuel.
Comments: (13-3) (26-13-4) (146-14) (162-20) (177-1-7)
Response: Onsite storage of spent nuclear fuel was determined in the GEIS, as reaffirmed by the NRCs 2014 Final Rule on Continued Storage of Spent Nuclear Fuel (79 FR 56238), to be a Category 1 (i.e., generic) issue with SMALL environmental impacts during the license renewal term. The NRC staff will describe the management of radioactive waste in Chapters 2 and 3 of the SEIS and will consider whether any new and significant information regarding radioactive waste impacts from renewing the Point Beach licenses has been identified; if so, it will evaluate this new information in Chapter 3 of the SEIS. The NRC requires evaluation of natural hazards, including storms and flooding, on the safety of spent fuel storage as part of its oversight of the current operating license. Therefore, the evaluation of natural hazards is outside the scope of license renewal and will not be evaluated further in the development of the SEIS.
Comment: Several commenters expressed support for the safety of onsite storage of spent fuel and the uranium fuel cycle.
Comments: (37-4) (40-2) (65-2) (86-5) (96-2) (106-5)
Response: Onsite storage of spent nuclear fuel was determined in the GEIS, as reaffirmed by the NRCs 2014 Final Rule on Continued Storage of Spent Nuclear Fuel (79 FR 56238), to be a Category 1 (i.e., generic) issue with SMALL environmental impacts during the license renewal term. For the period after the licensed life of reactor operations, the impacts from onsite storage of spent nuclear fuel during the continued storage period are discussed in NUREG-2157 and, as stated in 10 CFR 51.23(b), shall be deemed incorporated into the SEIS. The NRC staff will consider whether any new and significant information relative to spent nuclear fuel storage and the uranium fuel cycle has been identified; if so, it will evaluate this new information in Chapter 3 of the SEIS.
B.19 Transportation Comment: Several commenters expressed concern about the transportation of unirradiated fuel, spent nuclear fuel, and radioactive waste. Specific concerns included barge transport of radioactive material on Lake Michigan, transportation accidents and spills, transportation doses and risks, numbers of shipments, impacts of transportation accidents on Lake Michigan, the potential for nuclear criticality after a transportation accident on Lake Michigan, transportation cask recovery from Lake Michigan, and the transport of large components, such as steam generators, on Lake Michigan.
Comments: (1-4) (2-9) (13-5) (26-16-1) (31-2) (94-3) (100-9) (115-9) (133-4) (136-1) (136-3)
(137-1) (137-2) (137-3) (144-5) (145-2-8) (145-2-9) (145-2-10) (145-3-14) (155-2) (155-3)
(162-21) (177-1-9) (177-2-1)
Response: Transportation of unirradiated fuel, spent nuclear fuel, and radioactive waste was analyzed in Section 4.12.1.1 of the GEIS. In the GEIS, the NRC staff evaluated the impacts from transporting unirradiated fuel; spent nuclear fuel, including high burn-up fuel; and radioactive waste to and from nuclear power plants on workers, the public, and the environment.
As discussed in the GEIS, Table S-4 in 10 CFR 51.52 forms the basis for analysis of these impacts in evaluating the applications for license renewal from owners of light water reactors.
Transportation by truck, rail, and barge was analyzed in WASH-1238, which serves as the basis for Table S-4. The applicability of Table S-4 for license renewal applications was studied extensively in the 1996 GEIS and its Addendum 1. The impacts were found to be SMALL, and a Category 1 (i.e., generic) issue. The staff will consider whether any new and significant information relative to the uranium fuel cycle has been identified; if so, it will evaluate this new information in Section 3.15 of the SEIS.
B.20 Support of License Renewal Comment: The following comments express support for nuclear power, NextEra, or the renewal of the operating licenses for Point Beach. The commenters cited various reasons for their support, including the clean energy and grid reliability provided by nuclear power, NextEras environmental record, the safe operation of Point Beach by NextEra, and the positive impact on the community by NextEra and its employees.
Comments: (3-1) (7-1) (8-1) (16-1) (16-2) (16-3) (16-4) (26-6-1) (26-6-2) (26-6-3) (26-6-4)
(26-6-5) (26-6-6) (34-1) (36-1) (37-1) (37-2) (37-3) (37-6) (38-1) (39-1) (40-1) (40-3) (41-2)
(41-3) (41-4) (41-6) (42-1) (44-1) (44-4) (45-1) (46-1) (47-1) (47-2) (48-1) (50-1) (50-2) (50-3)
(51-1) (52-1) (52-2) (53-1) (54-1) (55-1) (57-1) (57-4) (57-5) (58-1) (59-1) (59-2) (59-3) (61-1)
(61-2) (61-3) (61-4) (61-5) (61-6) (62-1) (64-1) (64-2) (65-1) (66-1) (67-1) (68-1) (69-1) (72-1)
(73-1) (74-1) (76-1) (76-2) (76-3) (81-1) (81-3) (81-4) (83-1) (83-2) (84-1) (85-1) (86-1) (86-2)
(86-4) (86-6) (86-9) (87-1) (87-2) (87-3) (87-4) (88-1) (88-2) (88-3) (89-1) (92-1) (92-3) (93-1)
(93-2) (96-1) (96-3) (97-1) (98-3) (99-1) (99-2) (99-3) (99-5) (99-6) (99-7) (99-8) (99-9) (99-11)
(101-1) (101-2) (101-3) (102-1) (102-2) (102-3) (102-4) (103-1) (106-1) (106-2) (106-3) (106-6)
(108-1) (142-1) (142-2) (142-3) (142-4) (142-5) (142-6) (142-7) (142-8) (142-9)
Response: These comments are general in nature and provide no new and significant information. Therefore, they will not be evaluated further in the development of the SEIS.
However, the NRC staff will describe in Chapter 3 of the SEIS the environment around Point Beach as it pertains to the following topics generally mentioned in these comments: (1) the alternatives to license renewalincluding the impacts of not renewing the Point Beach licenses; (2) the impacts to greenhouse gases and the effects of climate change; and (3) the programs in place at Point Beach to protect public health, safety, and the environment. The staff will also consider the resource-specific environmental impacts from renewing the Point Beach licenses and alternatives to license renewal, within the scope of the NRCs environmental review, in the applicable sections of Chapter 3.
B.21 Opposition to License Renewal Comment: The following comments express opposition to nuclear power, NextEra, or the renewal of the operating licenses for Point Beach. The commenters cited various environmental concerns, the age of the reactors, and a preference for other energy sources.
Comments: (4-3) (6-1) (9-1) (11-3) (11-8) (12-1) (12-10) (13-1) (17-1) (18-1) (19-2) (20-1)
(21-1) (22-1) (24-2-1) (24-5-1) (24-6-1) (24-8-1) (24-10-1) (24-11-1) (24-12-1) (24-14-1)
(24-15-1) (24-16-1) (24-18-1) (24-19-1) (24-20-2) (24-21-1) (24-22-1) (24-23-1) (24-24-1)
(24-25-1) (24-27-1) (24-29-2) (24-30-1) (24-33-1) (24-34-1) (24-38-1) (24-39-1) (24-40-1)
(24-41-1) (24-42-1) (24-43-1) (24-43-2) (24-43-4) (24-44-2) (24-45-1) (24-48-1) (24-48-2)
(24-49-1) (24-50-1) (24-52-1) (24-53-1) (24-54-1) (24-54-2) (24-56-1) (24-57-1) (24-57-2)
(24-58-1) (24-59-1) (24-60-1) (24-61-1) (24-62-1) (24-63-1) (24-64-1) (24-65-1) (24-66-1)
(24-67-1) (24-68-1) (24-69-1) (24-70-1) (24-71-1) (24-72-1) (24-73-1) (24-74-1) (24-75-1)
(24-76-1) (24-78-1) (24-79-1) (24-80-1) (24-83-1) (24-84-1) (24-85-1) (24-86-1) (24-87-1)
(24-88-1) (24-89-1) (24-90-1) (24-92-1) (24-93-1) (24-94-1) (24-95-1) (24-96-1) (24-97-1)
(24-101-1) (24-103-1) (24-104-1) (24-106-1) (24-108-1) (24-108-3) (24-109-1) (24-112-1)
(24-113-1) (24-115-1) (24-116-1) (24-117-1) (24-118-1) (24-119-1) (24-120-1) (24-121-1)
(26-10-9) (26-11-9) (26-13-1) (26-16-4) (26-18-1) (30-6) (31-1) (31-3) (32-5) (35-5) (43-1) (43-3)
(56-1) (75-3) (77-6) (78-3) (79-3) (82-1) (90-1) (90-7) (91-1) (94-5) (95-5) (100-3) (100-4)
(100-6) (107-1) (107-15) (107-17) (107-18) (111-1) (111-4) (112-1) (113-1) (114-1) (114-4)
(116-1) (120-1-1) (120-1-12) (120-1-17) (120-2-3) (120-3-12) (120-4-1) (120-4-4) (122-2)
(123-1) (124-1) (128-1) (132-1) (136-2) (139-2) (140-1) (143-1) (143-4) (144-1) (145-2-4)
(145-5-7) (145-6-2) (147-1) (149-1) (149-4) (152-1) (153-3) (156-2) (157-1) (159-2) (159-3)
(160-1) (160-3) (160-8) (161-1) (161-2) (162-2) (163-1) (163-10) (164-1) (169-3) (169-4) (173-4)
(177-1-1) (177-1-3) (177-2-18) (178-1)
Response: These comments are general in nature and provide no new and significant information. Therefore, they will not be evaluated further in the development of the SEIS.
However, the NRC staff will describe in Chapter 3 of the SEIS the environment around Point Beach as it pertains to the following topics generally mentioned in these comments: (1) the alternatives to license renewalincluding the impacts of not renewing the Point Beach licenses; (2) the impacts to greenhouse gases and the effects of climate change; (3) waste generation; and (4) the programs in place at Point Beach to protect public health, safety, and the environment . The staff will also consider the resource-specific environmental impacts from renewing the Point Beach licenses and alternatives to license renewal, within the scope of the NRCs environmental review, in the applicable sections of Chapter 3.
B.22 NEPA Process Comment: The EPA requested that the NRC improve the transparency of its license renewal NEPA documents and include a better explanation of the NRC-designated impact categories of SMALL, MODERATE, and LARGE. Further, the EPA requested the citation of specific locations within references (rather than citing full documents), clearly outlining methodologies for analysis (including mitigation measures unrelated to the NRCs safety and security responsibilities), and employing analyses going beyond regulatory requirements.
Comments: (28-2) (28-5)
Response: The NRC staff uses the SMALL, MODERATE, and LARGE significance levels to clearly communicate the results of its analysis of the potential environmental impacts of the proposed action (license renewal) and the environmental impacts of the alternatives to the proposed action, as documented in each site-specific supplement (SEIS) to the GEIS. The criteria for determining the significance levels were based on the Council on Environmental Quality (CEQ) guidance and on discussions with the CEQ and the EPA when the significance levels were first implemented for nuclear power plant licensing actions. Definitions of the three significance levels are provided in the GEIS and codified in the NRCs regulations in the footnotes to Table B-1 of Appendix B to Subpart A of 10 CFR Part 51.
In conducting license renewal environmental reviews and preparing SEIS documents, the staff follows the evaluation procedures and methodologies contained in staff guidance, Standard Review Plans for Environmental Reviews for Nuclear Power Plants Supplement 1: Operating License Renewal (NUREG-1555, Supplement 1, Revision 1) (ADAMS Accession No. ML13106A246). In each SEIS, the staff describes its consideration of any new and significant information for Category 1 (i.e., generic) environmental issues in comparison to the findings documented in the GEIS. For each applicable Category 2 (i.e., plant-specific) environmental issue addressed in the SEIS, the staff describes its evaluation and explains the methods it used to evaluate the resource-specific environmental impacts of the proposed action.
These discussions include the associated significance level of each potential impact.
The staff will describe NextEras compliance with applicable environmental quality standards and permits at Point Beach in Chapter 3 of the SEIS, including associated mitigation and monitoring requirements that State or other Federal regulatory agencies impose. The staff may identify additional mitigation measures associated with its analysis of the potential environmental impacts of the proposed action, or alternatives to the proposed action, which could further reduce impacts; however, these measures are NRC recommendations and are not legally binding. Nor do they require the applicant to take any specific action. Mitigation measures specific to the NRCs safety and security responsibilities are enforced through periodic NRC inspections and reporting. These are not generally discussed in the SEIS or considered by the staff as part of its license renewal environmental review.
B.23 License Renewal Process Comment: Several commenters questioned the NRCs license renewal process and requested descriptions of the NRCs licensing process and its authority to regulate NextEras compliance with various aspects of the Point Beach licenses, including requiring authorizations and permits from outside the NRC prior to relicensing.
Comments: (2-16) (26-8-2) (28-1) (57-2) (110-1-3) (110-1-5) (110-1-17) (110-1-20) (110-2-17)
(120-1-7) (120-2-8) (141-7) (145-5-14) (145-5-18) (146-15) (146-16) (146-18) (158-6) (177-2-9)
Response: The NRC staff conducts both an environmental review and a safety review of each license renewal application to determine if the standards for issuance of renewed operating licenses set forth in 10 CFR 54.29 have been met. The staffs safety review is conducted in accordance with 10 CFR Part 54, and the results of the staffs evaluation are documented in a SER issued separately from the SEIS. The license renewal application includes general information and technical information in compliance with 10 CFR Part 54, including a description of the plant and any planned modifications. In accordance with the NRC regulations cited at 10 CFR 51.16, the applicant is permitted to withhold from public disclosure proprietary information, such as trade secrets, privileged or confidential commercial, or financial information.
At the start of an environmental review, a scoping process is conducted to, in part: (1) define the proposed action, (2) determine the scope of the SEIS, and (3) identify any significant issues to be analyzed in depth. This SEIS is intended to supplement and tier from the GEIS. The NRC acknowledges the potential for significant environmental impacts associated with the proposed action and has, therefore, identified a SEIS tiering from the GEIS as the appropriate NEPA mechanism. This approach is consistent with the NRCs environmental protection regulations in 10 CFR Part 51, which implement Section 102(2) of NEPA. The NRC has issued 59 initial renewal and 3 second renewal SEISs, which tier from the GEIS and are all available at https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/index.html.
In the SEIS, the staff will identify any new and significant information related to the renewal and continued operation of Point Beach that might require reconsideration of an environmental issue classified as a Category 1 (i.e., generic) issue in the GEIS.
To operate a nuclear power plant, licensees must obtain and maintain compliance with various environmental permits and approvals to minimize impacts to the environment. Agencies other than the NRC grant, administer, and enforce these authorizations. In Chapter 3 of the SEIS, the staff will describe NextEras compliance with applicable environmental quality standards and permits at Point Beach, including associated mitigation and monitoring requirements that the State or other Federal regulatory agencies impose.
Comment: Numerous commenters expressed concern about the public comment opportunities, especially during the Coronavirus Disease 2019 (COVID-19) public health emergency. These included technical difficulties with submitting scoping comments, the unavailability of relevant documents, issues with Internet access, the general openness and extent of the NRCs public participation process, and publishing the SEIS in languages other than English. These commenters requested increased notification opportunities for the public, an extension of the comment period, longer time periods to provide comments during public meetings, an e-mail address dedicated to receiving public comments, assurances that the NRC will consider public comments received via mail after the end of the comment period, and additional public meetings.
Comments: (2-12) (2-13) (2-14) (2-15) (23-1) (24-46-1) (24-70-2) (24-98-1) (25-1) (26-5-1)
(26-5-2) (26-8-9) (26-10-1) (26-10-2) (26-13-8) (26-18-5) (27-1) (58-2) (60-3) (60-5) (60-8)
(99-10) (104-1) (104-2) (110-1-1) (110-1-4) (110-2-15) (115-1) (115-2) (116-6) (118-1) (118-2)
(127-1) (145-1-1) (145-4-3) (145-4-4) (145-4-6) (145-4-7) (145-4-8) (145-4-9) (146-17) (153-1)
(162-1) (171-17) (174-1) (174-2) (174-3) (174-4) (174-5) (177-2-4) (177-2-5) (177-2-6) (177-2-8)
(181-1) (181-2) (181-3) (181-4) (181-5) (181-6) (181-7) (181-9)
Response: The NRC staff understands the concerns raised by the commenters and will continue to look for ways to improve public notifications and opportunities to comment. The NRC established the time period and methods for receiving comments on the scope of the environmental review for the Point Beach subsequent license renewal application to balance its goal of ensuring openness in the regulatory processes with its goal of ensuring that its actions are effective, efficient, realistic, and timely.
The NRC attempts to notify all stakeholders of all upcoming licensing reviews. This includes Federal, State, and local agencies, as well as the applicants staff, and members of the public or citizen advocacy groups that have previously expressed an interest in the regulatory activities related to a specific nuclear power facility. Specifically, the staff used a number of methods to inform the public about the February 17, 2021, virtual scoping meeting, the availability of supporting information, and the prescribed methods for submitting scoping comments. The NRCs Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; NextEra Energy Point Beach, LLC, Point Beach Nuclear Plant, Units 1 and 2 was published in the Federal Register on February 1, 2021 (86 FR 7747). In addition, the NRC provided public notice through local newspaper ads (which ran in the Manitowoc Herald Times Reporter on February 7, 10, 14, and 17, 2021), a press release, NRC social media, and posting on the NRC Web site, Public Meetings Schedule page. Members of the public who do not have access to the Internet can contact the NRCs PDR staff for information on scheduled meetings at 1-800-397-4209 or 301-415-4737, or by e-mail at pdr.resource@nrc.gov.
Separately, the staff responded to correspondence from environmental interest groups, which included the Physicians for Social Responsibility Wisconsin and the Sierra Club Wisconsin Chapter. These groups asked the NRC to extend the scoping period and hold additional meetings. The staff responded to these groups by letter (ADAMS Accession Nos.
ML21056A621, ML21084A258, and ML21094A003) and provided its reasons for concluding that the requests did not provide a sufficient basis for extending the established comment period.
While the staff believes that the 30 days provided were sufficient for the environmental scoping comment period, to the extent practicable, it considered additional comments after the close of the comment period.
Additionally, members of the public will have a further opportunity to participate in the NRCs evaluation of the environmental impacts of the proposed action by submitting comments concerning the NRC staffs DSEIS following its publication. Tentatively, the public meeting on the DSEIS is scheduled to be held in November 2021. The meeting date, time, and means for the public to participate will be advertised in advance of the meeting, in accordance with agency public participation procedures, via the Federal Register, the NRCs public meeting notification system, and local newspaper advertisements.
The NRC staff will conduct an independent analysis in preparing the SEIS, using information from a variety of sources, including NextEras ER. The staff will verify the accuracy of the information used in the SEIS. Documents received from the public will become part of the official record in support of this subsequent license renewal review. The NRC agrees that public participation and a thorough analysis of the potential environmental impacts of the proposed action (subsequent license renewal), and alternatives to the proposed action, are critical to the NRCs decisionmaking process. The NRC staff will perform its environmental review and develop the SEIS in accordance with NEPA and the NRCs requirements implementing NEPA in 10 CFR Part 51.
With respect to the comments suggesting that the NRC publish the SEIS in languages other than English, the staff is not aware of any requests for language services. The NRC does not have the resources to translate a document the size of a SEIS into multiple languages. The NRC does not require applicants to provide license application documents in languages other than English. However, the NRC implements its Limited English Proficiency Plan for its licensing and other regulatory activities. As appropriate, and on a case-by-case basis, the NRC staff will provide language services or written translation services for background or supporting documents associated with its public meetings.
Comment: The following comments express disagreement with the timing of the license renewal process. The commenters stated that NextEra should not be able to submit a license renewal application so far in advance of the expiration dates of its current licenses (2030 for Unit 1, and 2033 for Unit 2) and that the NRC should delay its environmental review until closer to those dates.
Comments: (33-1) (33-2) (162-5) (181-8)
Response: The NRC regulation, 10 CFR 54.17(c), allows licensees to submit license renewal applications up to 20 years before the expiration of the licenses currently in effect. The NRC established this earliest date for the submission of license renewal applications after soliciting and considering public comments. In the 1991 statements of consideration for the Nuclear Power Plant License Renewal rule (56 FR 64943), the NRC rejected the suggestion that 20 years of operational and regulatory experience with a particular plant was an insufficient period in which to accumulate information on plant performance. The NRC also rejected suggestions that a 5-year or even a 15-year time limit for filing renewal applications would be adequate. The NRC stated that, in establishing the earliest date for license renewal applications, it considered the time necessary for utilities to plan for replacement of retired nuclear plants. The NRC found that the lead time for building new electric generation facilities is 10-14 years, depending on the technology. When the license renewal rule was revised in 1995, the NRC again solicited comments on the earliest date for filing license renewal applications.
After considering the comments, the NRC concluded that there was no new information warranting a change in the earliest date for license renewal applications, either to make it earlier or later (60 FR 22461).
Comment: Several commenters requested additional consideration of the scientific methodology and analysis associated with NEPA analyses. This included identifying which analyses the NRC staff will undertake and which analyses will rely on NextEras staff or consultants, ensuring that the SEIS relies upon a strict process of scientific methods, transparency, and peer review, and consideration of safety-related issues associated with the operations of the reactor.
Comments: (120-3-13) (145-5-15) (145-5-17) (162-6) (162-9)
Response: The NRC staff conducts both an environmental review and a safety review of each license renewal application to determine if the standards for issuance of renewed operating licenses set forth in 10 CFR 54.29 have been met. The staffs safety review is conducted in accordance with 10 CFR Part 54, and the results of the staffs evaluation are documented in an SER issued separately from the SEIS. The staff conducts its environmental review in accordance with the regulations contained in 10 CFR Part 51, and the results will be documented in the SEIS.
Relevant to the NRCs environmental review, the staffs methodology and its approach to evaluating the environmental impacts of license renewal follow the guidance and environmental information considered common to all nuclear power plants in the GEIS. In accordance with NEPA, the SEIS will take into account available information and will consider new and significant information to analyze the environmental impacts of Point Beach license renewal for each potentially affected environmental resource area. Further, in accordance with NRC and CEQ regulations, the SEIS incorporates into the analysis, by reference, information from many other sources. The NRC invited commenters to submit additional information for consideration in the SEIS during the scoping comment period and will consider those comments in preparing the SEIS. This factual and scientific information, which will be the basis for the staffs environmental review, will be sufficient to make the environmental impact determinations in the SEIS.
B.24 Outside ScopeAging Management Comment: Several commenters expressed concern about aging components at Point Beach or the ability to effectively manage aging during the period of extended operation. Several commenters specifically cited reactor pressure vessel embrittlement as a concern.
Comments: (9-2) (15-1) (24-28-1) (24-110-1) (26-7-2) (26-10-3) (26-10-5) (26-12-1) (26-12-7)
(26-15-4) (26-17-1) (26-18-4) (32-3) (41-1) (43-2) (44-2) (51-2) (60-6) (71-1) (71-2) (71-3) (71-8)
(77-1) (77-4) (78-2) (90-6) (105-4) (106-4) (107-2) (107-13) (110-1-10) (110-2-11) (111-2)
(114-2) (117-2) (117-3) (120-1-13) (120-1-16) (120-2-5) (120-2-11) (120-3-6) (120-3-14)
(120-3-15) (120-3-18) (120-4-3) (122-1) (124-2) (134-3) (135-4) (144-8) (144-9) (145-3-20)
(145-6-4) (145-6-10) (146-13) (148-5) (150-1) (156-6) (159-1) (160-2) (162-4) (162-7) (162-8)
(163-2) (166-1) (168-2) (168-4) (171-9) (173-1) (173-2) (173-3) (177-1-2) (178-2)
Response: The NRC staff conducts both an environmental review and a safety review of each license renewal application. The staffs safety review is conducted in accordance with 10 CFR Part 54, and the results of the staffs evaluation are documented in an SER issued separately from the SEIS. Operational safety issues related to the management of aging structures, systems, and components are outside the scope of the environmental review conducted under 10 CFR Part 51. To be granted renewed licenses, NextEra must demonstrate that aging effects will be adequately managed such that the intended functions of the systems, structures, and components within the scope of license renewal will be maintained consistent with the current licensing basis for the period of extended operation. In accordance with 10 CFR Part 54, the staff will conduct a review of the licensees aging management programs and document the results in the SER. This issue will not be evaluated further in the development of the SEIS.
Comment: Several commenters expressed concern about aging components at Point Beach and requested that the NRC inspect aging components, in addition to computer modeling. They also asked the NRC to examine other, similar reactors when evaluating embrittlement and other aging management issues.
Comments: (120-4-5) (120-4-6) (168-5) (168-6) (168-7) (171-10)
Response: The NRCs environmental review is confined to environmental matters relevant to the extended period of operation requested by the applicant. To the extent that the comments pertain to the safety of equipment and aging within the scope of license renewal, these issues will be addressed during the NRC staffs parallel safety analysis review performed under 10 CFR Part 54 and the results will be documented in a SER. Operational safety issues are outside the scope of 10 CFR Part 51 and will not be evaluated further in the development of the SEIS.
B.25 Outside ScopeEmergency Preparedness Comment: The following comments address emergency planning or security-related issues.
On the topic of emergency planning, various commenters expressed skepticism that emergency plans at Point Beach are adequate. On the topic of plant security, one commenter expressed the need for security plans at Point Beach to be updated regularly. Commenters specifically mentioned their concerns about the theft of nuclear material and cybersecurity.
Comments: (5-3) (13-7) (26-12-4) (26-12-5) (26-12-6) (26-14-4) (26-14-5) (26-16-2) (26-16-3)
(35-1) (71-7) (104-4) (104-5) (107-8) (110-1-15) (117-5) (119-5) (133-2) (144-13) (144-14)
(145-3-18) (154-2) (163-8) (171-3) (171-4) (171-5) (171-6) (176-4) (177-1-13)
Response: Emergency preparedness and security are applicable to the current operating licenses and are subject to the NRC oversight of the existing or future renewed operating licenses. However, these issues are outside the scope of the environmental review for license renewal and, therefore, will not be evaluated further in the development of the SEIS.
Emergency preparedness and physical security plans are required at all nuclear power plants and require specified levels of protection from each licensee regardless of plant design, construction, or license date. Requirements related to emergency planning are set out in the NRCs regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50. Requirements related to physical security are set out in the NRCs regulations in 10 CFR Part 73, Physical protection of plants and materials. These requirements apply to all operating licenses and will continue to apply to facilities with subsequent renewed licenses. The NRC has regulations in place to ensure that emergency preparedness and security plans are updated throughout the life of all plants. For example, under Appendix E to 10 CFR Part 50, nuclear power plant licensees are required to update their evacuation time estimates after every U.S. Census, or when changes in population would increase the estimate by either 25 percent or 30 minutes, whichever is less.
Additionally, the NRC assesses the capabilities of the nuclear power plant licensee to protect the public by requiring the performance of a full-scale exercise, including the participation of various Federal, State, and local government agencies, at least once every 2 years. These exercises are performed to maintain the skills of the emergency responders and to identify and correct weaknesses. In addition, in 2009, the NRC issued cybersecurity requirements for licensees under 10 CFR 73.54, Protection of digital computer and communication systems and networks. This regulation requires licensees to provide a high assurance that digital computer and communication systems and networks are adequately protected against cyber-attacks, up to and including the design basis threats as described in 10 CFR 73.1, Purpose and scope.
B.26 Outside ScopeEnergy Costs Comment: Commenters expressed concern over the cost effectiveness and impacts on tax and ratepayers of nuclear power compared to alternative means of power generation.
Comments: (12-9) (26-11-8) (26-17-2) (117-11) (125-9) (144-3) (145-5-2) (145-5-8) (145-6-6)
(145-6-8) (162-11) (171-18)
Response: The economic costs and benefits of renewing an operating license are outside the scope of the environmental review. The NRC regulation, 10 CFR 51.95(c)(2), states, in part, 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 or of alternatives to 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 purpose and need for the proposed action is to provide an option to continue nuclear power plant operations beyond the current licensing term to meet future system generating needs, as such needs may be determined by the licensee, State, utility, system, and, where authorized, Federal (other than NRC) decisionmakers. The NRC does not make license renewal decisions or recommendations regarding the impacts on tax and ratepayers. The regulatory authority over licensee economics falls within the jurisdiction of the State and, to some extent, the Federal Energy Regulatory Commission. Therefore, these comments will not be evaluated further in the SEIS.
B.27 Outside ScopeNeed for Power Comment: Commenters questioned the need for Point Beach and whether there is sufficient electricity demand justifying the renewal of the operating licenses, especially when considering other energy projects proposed in the region. Commenters also expressed concerns over the centralized power grid and power grid reliability.
Comments: (26-13-6) (145-4-11) (145-4-12) (145-4-13) (145-5-1)
Response: The purpose and need for the proposed action is to provide an option to continue nuclear power plant operations beyond the current licensing term to meet future system generating needs, as such needs may be determined by the licensee, State, utility, system, and, where authorized, Federal (other than NRC) decisionmakers. The NRC does not make license renewal decisions or recommendations regarding the need for power or electric grid reliability.
The regulatory authority over licensee economics (including the need for power and grid reliability) falls within the jurisdiction of the State and, to some extent, within the Federal Energy Regulatory Commission. Therefore, these comments will not be evaluated further in the development of the SEIS.
B.28 Outside ScopeOther Non-Licensing Renewal Actions Comment: One commenter expressed concern that NextEra is relying on the two Consolidated Interim Storage Facility (CISF) projects currently under review by the NRC for storage of spent nuclear fuel.
Comment: (172-1)
Response: A CISF is an away-from-reactor ISFSI, licensed under 10 CFR Part 72, for the interim storage of spent nuclear fuel. Whether NextEra transfers its spent fuel to a CISF, if one is available, is a business decision outside the scope of the NRC staffs environmental review.
Regardless, the staffs environmental review assumes that, for the period after the licensed life of reactor operations, the impacts from onsite storage of spent nuclear fuel during the continued storage period are as discussed in NUREG-2157 and, as stated in 10 CFR 51.23(b), are deemed incorporated into the SEIS.
Comment: One commenter expressed concern about the use of accident tolerant fuel (ATF) in the Point Beach reactors during the period of extended operation.
Comment: (162-23)
Response: ATF is not currently used in the Point Beach reactors and the NRC has not approved an ATF design for unrestricted use. Any proposed ATF design would have to meet the stringent requirements detailed in 10 CFR Part 50 and would be subject to environmental review. Therefore, this issue is not within the scope of the license renewal environmental review and will not be evaluated further in the development of the SEIS.
Comment: Two commenters addressed the issue of reprocessing spent nuclear fuel; one was in favor of allowing this, the other was opposed.
Comments: (98-2) (100-10)
Response: In SRM-SECY-13-0093, Reprocessing regulatory frameworkstatus and next steps, the Commission directed the NRC staff to pursue a new reprocessing-specific rule, contained in a new part of the NRCs regulations, for a regulatory framework for licensing a reprocessing facility. However, on March 5, 2021, in SECY-21-0026, Discontinuation of rulemakingspent fuel reprocessing, the staff requested approval from the Commission to discontinue the spent fuel reprocessing rulemaking based on the limited interest expressed or expected from industry to build any type of facility involving reprocessing technologies in the near term. This issue is not within the scope of the license renewal environmental review and will not be evaluated further in the development of the SEIS.
B.29 Outside ScopeSafety Concerns Comment: The following comments express concerns about the impacts of external events and natural hazardsprimarily lake-level rise, storm surge, earthquakes, and hurricaneson Point Beach and spent fuel storage. Many commenters stated that climate change would increase the rate of lake-level rise and the frequency and intensity of storm events. Some stated that there was new information that should be considered. Commenters expressed concerns about the vulnerability of the plant to damage by such events, the adequacy of existing protections, and whether additional protection would be needed. Several commenters expressed concern about the potential for an accident resulting from external events. Some requested that the risk to and integrity of plant structures be analyzed with respect to lake-level rise and extreme storm events.
Comments: (1-5) (13-14) (24-110-2) (26-7-3) (26-9-2) (26-12-2) (26-12-3) (60-4) (71-4) (71-5)
(79-4) (117-6) (120-1-15) (125-11) (135-5) (145-2-14) (145-2-17) (145-2-19) (145-3-12) (146-2)
(156-7) (158-1) (162-19) (168-10) (168-12)
Response: The NRC addresses potential hazards to the safe operation of a nuclear power plant, including external hazards, through its ongoing oversight of operating licenses. Such oversight will continue during the term of any renewed license. In addition, the NRC staffs review of the subsequent license renewal application takes into consideration external hazards, such as storm surge and rising lake level, in two ways. First, the risks from external hazards were considered as part of the staffs review of the severe accident mitigation alternative (SAMA) analysis, performed for the initial license renewal of Point Beach. For subsequent license renewal, the staff will consider any new and significant information that is identified as relevant to SAMAs. SAMAs are potential ways to reduce the risk or potential impacts of uncommon, but potentially severe accidents. SAMAs may include changes to plant components, systems, procedures, and training. Second, the external hazard licensing basis for the plant helps to inform the scope of the subsequent license renewal safety review.
Systems, structures, and components (SSCs) that are relied upon to remain functional during and after design-basis events are within the scope of subsequent license renewal. The staff review considers whether an applicant will adequately manage the effects of aging on these SSCs, such that there is reasonable assurance that the activities authorized by the renewed licenses will continue to be conducted in accordance with the plants current licensing basis, and that any changes to the plants current licensing basis for license renewal are in accordance with the Atomic Energy Act and NRCs regulations. The results of the staffs safety review will be documented in the SER for license renewal and will not be evaluated further in the development of the SEIS.
Comment: The following comments outline the operating history and safety of Point Beach and express general concerns about the safe operation of Point Beach for an additional 20 years.
Comments: (5-4) (11-1) (26-3-1) (26-3-2) (26-3-3) (26-10-8) (26-15-5) (78-1) (107-3) (120-1-2)
(120-1-3) (120-1-4) (120-1-5) (120-1-6) (120-1-8) (120-1-9) (120-1-10) (120-1-11) (120-2-6)
(120-2-7) (120-2-9) (120-2-10) (120-3-4) (120-3-5) (120-4-2) (130-1) (130-2) (130-3) (130-4)
(134-1) (134-2) (144-7) (145-1-11) (145-5-16) (145-5-23) (145-6-3) (151-1) (153-2) (160-6)
(162-22) (163-5) (168-8)
Response: Plant safety culture and operational safety matters are outside the scope of the NRC staffs environmental review and will not be evaluated further in the development of the SEIS. The NRC conducts a separate safety review for the license renewal period.
B.30 Outside ScopeSecurity or Terrorism Comment: The following comments address security issues at nuclear facilities, including terrorist-initiated events and concerns over the security of the electric power grid.
Comments: (12-7) (23-3) (41-5) (99-4) (107-9) (145-4-15) (145-4-16) (145-5-11) (145-5-12)
(145-5-20)
Response: Security-related issues are addressed as a current operating issue, rather than a license renewal issue. As a result of the terrorist attacks of September 11, 2001, the NRC conducted a comprehensive review of the agencys security program and made further enhancements to security at a wide range of NRC-regulated facilities. These enhancements included significant reinforcement of the defense capabilities for nuclear facilities, better control of sensitive information, enhancements in emergency preparedness to further strengthen the agencys nuclear facility security program, and implementation of mitigating strategies to deal with postulated events that could potentially cause loss of large areas of the plant due to explosions or fires, including those that an aircraft impact might create.
The NRC routinely assesses threats and other information provided by a variety of Federal agencies and sources. The NRC also ensures that licensees meet appropriate security-level requirements. The NRC will continue to focus on prevention of terrorist acts for all nuclear facilities and will not focus on site-specific evaluations of speculative environmental impacts resulting from terrorist acts. While these are legitimate matters of concern, the staff will continue to address them through the ongoing regulatory process as a current and generic regulatory issue that affects all nuclear facilities and many of the activities conducted at nuclear facilities. The issue of security and risk from malevolent acts at nuclear power facilities is not unique to facilities that have requested renewal of their licenses.
With regard to malevolent acts or sabotage, it is the NRCs position that malevolent acts or sabotage are speculative and beyond the scope of NEPA environmental review and, therefore, will not be evaluated further in the development of the SEIS. The NRC believes that the consequences of events initiated by malevolent acts or sabotage would be comparable to or bounded by the severe accidents considered in the GEIS.
B.31 Outside ScopeOther Topics Comment: The following comments address issues relating to the consideration of economic costs associated with normal operations of Point Beach, maintenance of aging components, or an accident.
Comments: (2-10) (13-15) (33-5) (60-1) (60-2) (90-3) (107-6) (107-10) (110-2-7) (110-2-19)
(115-5) (115-12) (117-10) (125-8) (129-2) (129-3) (144-15) (144-16) (145-3-21) (145-6-5)
(145-6-9) (146-7) (146-9) (146-10) (146-11) (148-8) (163-6) (171-12) (177-2-2)
Response: The consideration of economic costs and benefits is outside the scope of the NRCs license renewal environmental review (10 CFR 51.95(c)(2)) and will not be evaluated further in the development of the SEIS. The purpose and need for the proposed action (i.e., issuance of a subsequent renewed 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 other energy-planning decisionmakers. Similarly, the decision to pursue nuclear power as a power generation source is a decision that is made by other energy-planning decisionmakers and is outside the scope of this review. The environmental effects of continued operation of Point Beach will be described in Chapter 3 of the SEIS.
Comment: Commenters expressed concern about NextEras liability as plant owner and operator, compensation following an accident, and the need to establish contingency funds to cover unforeseen events.
Comments: (13-8) (15-4) (26-18-2) (35-3) (110-2-4) (110-2-9) (111-3) (111-5) (116-4) (133-7)
(145-1-17) (145-4-1) (145-5-19) (145-5-21) (145-5-22) (145-6-1) (145-6-11)
Response: The consideration of liability is outside the scope of the NRCs license renewal environmental review. However, regulations are in place to minimize the occurrence and consequences of accidents and to respond to them if they occur. The mission of the NRC includes the protection of the public health and safety and the environment. The comments provide no new information and will not be evaluated further in the development of the SEIS.
Comment: The following comment addresses NextEras business practices and compliance with Title VI of the Civil Rights Act of 1964.
Comment: (141-1)
Response: The NRCs authority to regulate the applicants business practices is limited to activities affecting nuclear safety. The comment does not implicate nuclear safety and is otherwise outside the scope of the NRCs license renewal environmental review and, therefore, will not be evaluated further in the development of the SEIS.
Comment: A commenter expressed concern about prioritizing government spending to focus on climate change.
Comment: (162-13)
Response: The NRC regulates the nuclear industry to protect the public health and safety and the environment within existing laws and regulations. Issues related to government spending and priorities are outside of the NRCs authority and, therefore, will not be evaluated further in the development of the SEIS.
C. List of Commenters The following tables present the comments received by the NRC and identify the commenters.
Table C-1 provides a list of commenters who provided unique comment submissions (i.e., non-form letter submissions) identified by name, affiliation (if stated), the correspondence identification (ID) number, the comment source, and the ADAMS Accession Number. Table C-2 lists the commenters who submitted all or part of the form content from Beyond Nuclear. Table C-3 lists the commenters who submitted the form content from Sierra Club Wisconsin. In cases where commenters submitted both unique and form content, they are listed in more than one table.
Table C-1. Individuals Providing Comments during the Scoping Comment Period Commenter Affiliation (if stated) Comment Source and Correspondence ADAMS Accession No. ID Agee, Will Regulations.gov 24-78 (ML21069A250)
Alberts, Karen Regulations.gov 24-11 (ML21069A250)
Allekotte, Joan Regulations.gov 24-29 (ML21069A250)
Alsvig, Mary Regulations.gov 92 (ML21064A317)
Ancel, Nadine Regulations.gov 24-26 (ML21069A250)
Anonymous, Regulations.gov 39 Anonymous (ML21062A037)
Anonymous, Regulations.gov 42 Anonymous (ML21062A040)
Anonymous, Regulations.gov 56 Anonymous (ML21062A128)
Anonymous, Regulations.gov 58 Anonymous (ML21062A131)
Anonymous, Regulations.gov 64 Anonymous (ML21062A140)
Anonymous, Regulations.gov 69 Anonymous (ML21063A057)
Anonymous, Regulations.gov 74 Anonymous (ML21063A068)
Anonymous, Regulations.gov 84 Anonymous (ML21063A095)
Anonymous, Regulations.gov 90 Anonymous (ML21064A303)
Anonymous, Regulations.gov 121 Anonymous (ML21064A511)
Anonymous, Regulations.gov 161 Anonymous (ML21069A041)
Anonymous, Detroit Hamtramck Regulations.gov 141 Anonymous Coalition for (ML21069A017)
Advancing Healthy Environments Anonymous, Nukewatch Regulations.gov 130 Anonymous (ML21069A005)
Aron, Sissy Regulations.gov 24-10 (ML21069A250)
Aul, Greta Regulations.gov 24-75 (ML21069A250)
Baggentos, John Regulations.gov 24-4 (ML21069A250)
Bailey, Nancy Regulations.gov 24-21 (ML21069A250)
Barbeau, Jim Regulations.gov 70 (ML21063A058)
Barnes, Kathy Regulations.gov 100 (ML21064A332)
Barr, Marsha Regulations.gov 24-100 (ML21069A250)
Becerril, Ingrid Regulations.gov 24-31 (ML21069A250)
Becker, Elaine Regulations.gov 24-25 (ML21069A250)
Becker, Theresa Regulations.gov 76 (ML21063A070)
Behrmann, Ann Regulations.gov 171 (ML21069A051)
Behrmann, Ann Physicians for Social E-mail (ML21056A561) 27 Responsibility Wisconsin Behrmann, Ann Physicians for Social E-mail (ML21084A213) 181 Responsibility Wisconsin Behrmann, Ann Physicians for Social Meeting Transcript 26-14 Responsibility (ML21062A192)
Wisconsin Benedum, Herb Regulations.gov 88 (ML21064A244)
Benson, Andrew Regulations.gov 16 (ML21050A118)
Berland, Paul Meeting Transcript 26-1 (ML21062A192)
Bernard Schaber, Regulations.gov 114 Penny (ML21064A356)
Bernstein, Laura Regulations.gov 24-112 (ML21069A250)
Bittner, Mark Regulations.gov 85 (ML21063A096)
Black, Shirley Regulations.gov 24-44 (ML21069A250)
Blankenship, Joan and Regulations.gov 24-88 Darren (ML21069A250)
Bosch, Patricia Nortown Community Regulations.gov 162 Development (ML21069A042)
Corporation Bosold, Patrick Regulations.gov 20 (ML21050A131)
Boudart, Jan Regulations.gov 173 (ML21069A053)
Boudart, Jan Nuclear Energy Regulations.gov 127 Information Service (ML21064A519)
Bowman, Bill Regulations.gov 126 (ML21064A518)
Boyer, Dennis Regulations.gov 128 (ML21064A520)
Brangan, Mary Beth Ecological Options Regulations.gov 162 Network (ML21069A042)
Bronchella, Marcie Regulations.gov 148 (ML21069A026)
Bruechert, Don Regulations.gov 86 (ML21063A097)
Bruhaug, Gerrit Regulations.gov 36 (ML21062A033)
Bryan, D Regulations.gov 24-119 (ML21069A250)
Buckley, Gregory Two Rivers City Regulations.gov 142 Council (ML21069A018)
Buetow, Kurt Regulations.gov 158 (ML21069A037)
Buttry, Daniel Regulations.gov 147 (ML21069A025)
Carbino, Rosemarie Regulations.gov 133 (ML21069A008)
Carney, Cheryl Regulations.gov 24-84 (ML21069A250)
Carpenter, Charles Regulations.gov 175 (ML21064A354)
Cassebaum, Anne Regulations.gov 24-61 (ML21069A250)
Champkin, Mary Regulations.gov 24-109 (ML21069A250)
Chennault, Raye Regulations.gov 24-22 (ML21069A250)
Clark, Cherryl Regulations.gov 24-111 (ML21069A250)
Clark, Maynard Regulations.gov 24-3 (ML21069A250)
Collins, Peggy S. Regulations.gov 24-64 (ML21069A250)
Commenters, Multiple Regulations.gov 25 (ML21069A250)
Connour, Randy Holy Family Memorial Regulations.gov 7 (ML21050A088)
Cowles, Robert State of Wisconsin Regulations.gov 97 2nd Senate District (ML21064A326)
Cramer, Barry Regulations.gov 154 (ML21069A033)
Davie, Adam Regulations.gov 98 (ML21064A328)
DeLuca, Theresa Regulations.gov 6 (ML21050A086)
DeRuyter, Randall Regulations.gov 81 (ML21063A088)
Devrell, Julia Regulations.gov 24-113 (ML21069A250)
Dittrich, Karen Regulations.gov 24-14 (ML21069A250)
Doran, Pam Regulations.gov 24-105 (ML21069A250)
Dorn, Kathryn Regulations.gov 24-1 (ML21069A250)
Draska, Kenneth Regulations.gov 65 (ML21062A141)
Dressen, Mark Regulations.gov 24-90 (ML21069A250)
DuBois, Lee Regulations.gov 45 (ML21062A042)
Duffield, Dave Regulations.gov 131 (ML21069A006)
Duffin, John Regulations.gov 11 (ML21050A102)
Dums, Dennis Regulations.gov 116 (ML21064A361)
Dwight, Eleanor Regulations.gov 135 (ML21069A010)
Dwight, Eleanor Regulations.gov 135 (ML21069A011)
Eggers, J. Regulations.gov 24-53 (ML21069A250)
Eiesland, Nora Regulations.gov 24-95 (ML21069A250)
Eilenberg, Alisa Regulations.gov 24-8 (ML21069A250)
English, Rich Regulations.gov 24-42 (ML21069A250)
Fahrenkrug, Rick Regulations.gov 24-82 (ML21069A250)
Fisher, Michael Regulations.gov 109 (ML21064A345)
FitzGerald, Charlanne Regulations.gov 144 (ML21069A022)
Flanagan, Rian Regulations.gov 53 (ML21062A119)
Frisch, Ann Meeting Transcript 26-16 (ML21062A192)
Fromm, Wayne Regulations.gov 62 (ML21062A138)
Frueauf, Lori Regulations.gov 24-46 (ML21069A250)
Fuller, Ernest Regulations.gov 33 (ML21062A027)
Fussell, Jill Regulations.gov 24-98 (ML21069A250)
Gadzala, Jack Regulations.gov 49 (ML21062A046) ganMoryn, Croitiene Regulations.gov 22 (ML21050A139)
Gann, Alan Regulations.gov 123 (ML21064A515)
Garcia, Angel Regulations.gov 24-116 (ML21069A250)
Gardiner, Sandra Regulations.gov 24-96 (ML21069A250)
Gaul, Michael Regulations.gov 24-13 (ML21069A250)
Gehrke, David Regulations.gov 87 (ML21063A099)
Gehrke, Rita Regulations.gov 24-15 (ML21069A250)
Gervais, Claire Regulations.gov 30 (ML21062A015)
Giese, Mark Regulations.gov 105 (ML21064A335)
Giese, Mark Regulations.gov 124 (ML21064A516)
Giordano, Ruth Regulations.gov 24-85 (ML21069A250)
Glatter-Judy, Susan Regulations.gov 24-34 (ML21069A250)
Goodall, Doug Regulations.gov 24-55 (ML21069A250)
Gordon, Nanette Regulations.gov 24-80 (ML21069A250)
Gould, Robert San Francisco Bay Regulations.gov 162 Physicians for Social (ML21069A042)
Responsibility Graffagnino, Mary Ann Regulations.gov 24-115 and Frank (ML21069A250)
Greenwood, Adrianne Regulations.gov 34 (ML21062A030)
Greenwood, Dale Regulations.gov 99 (ML21064A329)
Gregg, Louise Regulations.gov 24-70 (ML21069A250)
Grillo, Robert Regulations.gov 176 (ML21064A362)
Gromoll, Norda Regulations.gov 24-74 (ML21069A250)
Gylden, Cynthia Regulations.gov 24-54 (ML21069A250)
Hancock, Johnathan Regulations.gov 24-77 (ML21069A250)
Hanka, Ladislav Regulations.gov 91 (ML21064A305)
Hansen, Jan Regulations.gov 24-81 (ML21069A250)
Hanson, Art Regulations.gov 24-89 (ML21069A250)
Hardesty, Susan Regulations.gov 24-32 (ML21069A250)
Hardy, Raymond Regulations.gov 1 (ML21040A223)
Hartjes, Donald Regulations.gov 47 (ML21062A044)
Hartman, Jonathan Regulations.gov 24-104 (ML21069A250)
Harvey, Robert Regulations.gov 55 (ML21062A124)
Hasselman, Katherine Regulations.gov 108 (ML21064A340)
Healingline, Regulations.gov 122 Helgaleena (ML21064A513)
Healingline, White Rabbit Grove Regulations.gov 122 Helgaleena RDNA (ML21064A514)
Hirt, Alice Dont Waste Regulations.gov 162 Michigan (ML21069A042)
Hoffman, Ace Meeting Transcript 26-15 (ML21062A192)
Holm, Gary Regulations.gov 24-58 (ML21069A250)
Hormel, Michael Regulations.gov 24-108 (ML21069A250)
Horton, Tyler Regulations.gov 24-47 (ML21069A250)
Houtakker, C Regulations.gov 24-24 (ML21069A250)
Howe, Tyler Wisconsin State E-mail (ML21069A220) 179 Historic Preservation Office Huddy, Paul Regulations.gov 24-118 (ML21069A250)
Hughes, Jan Regulations.gov 24-86 (ML21069A250)
Hunter, Diane Miami Tribe of E-mail (ML21069A224) 29 Oklahoma Hurd, Jan Regulations.gov 24-102 (ML21069A250)
Immerfall, Phil Regulations.gov 24-28 (ML21069A250)
Jacoby, Barry Regulations.gov 24-9 (ML21069A250)
Jacquart, N Regulations.gov 66 (ML21062A106)
Jacque, André State of Wisconsin Regulations.gov 97 1st Senate District (ML21064A326)
Jacques, Karen Regulations.gov 24-68 (ML21069A250)
James, HJ Regulations.gov 104 (ML21064A333)
Jeffery, Layne Regulations.gov 67 (ML21063A054)
Jensen, William Regulations.gov 51 (ML21062A049)
Jessessky, Tom Regulations.gov 61 (ML21062A135)
Joedeman, Karee Regulations.gov 24-87 (ML21069A250)
Johnson, Keith Regulations.gov 140 (ML21069A016)
Jones, Robert Regulations.gov 93 (ML21064A319)
Judson, Tim Nuclear Information Regulations.gov 162 and Resource (ML21069A042)
Service Kamps, Kevin Beyond Nuclear Regulations.gov 26-10 (ML21069A250)
Kamps, Kevin Beyond Nuclear Regulations.gov 77 (ML21063A080)
Kamps, Kevin Beyond Nuclear Regulations.gov 78 (ML21063A084)
Kamps, Kevin Beyond Nuclear Regulations.gov 79 (ML21063A085)
Kamps, Kevin Beyond Nuclear Regulations.gov 80 (ML21063A087)
Kamps, Kevin Beyond Nuclear Regulations.gov 95 (ML21064A322)
Kamps, Kevin Beyond Nuclear Regulations.gov 136 (ML21069A012)
Kamps, Kevin Beyond Nuclear Regulations.gov 137 (ML21069A013)
Kamps, Kevin Beyond Nuclear Regulations.gov 138 (ML21069A014)
Kamps, Kevin Beyond Nuclear Regulations.gov 150 (ML21069A028)
Kamps, Kevin Beyond Nuclear Regulations.gov 151 (ML21069A029)
Kamps, Kevin Beyond Nuclear Regulations.gov 130 (ML21069A030)
Kamps, Kevin Beyond Nuclear Regulations.gov 153 (ML21069A032)
Kamps, Kevin Beyond Nuclear Regulations.gov 155 (ML21069A034)
Kamps, Kevin Beyond Nuclear Regulations.gov 159 (ML21069A039)
Kamps, Kevin Beyond Nuclear Regulations.gov 165 (ML21069A045)
Kamps, Kevin Beyond Nuclear Regulations.gov 166 (ML21069A046)
Kamps, Kevin Beyond Nuclear Regulations.gov 167 (ML21069A047)
Kamps, Kevin Beyond Nuclear Regulations.gov 169 (ML21069A049)
Kamps, Kevin Beyond Nuclear Regulations.gov 170 (ML21069A050)
Kamps, Kevin Beyond Nuclear Regulations.gov 172 (ML21069A052)
Katz, Deb Citizens Awareness Regulations.gov 162 Network (ML21069A042)
Keegan, Michael J. Coalition for a Regulations.gov 162 Nuclear Free Great (ML21069A042)
Lakes Keeley, James Regulations.gov 24-45 (ML21069A250)
Kellum, Leonard Regulations.gov 18 (ML21050A138)
Kemps, Kevin Regulations.gov 24-43 (ML21069A250)
Killeen, Kevin Regulations.gov 60 (ML21062A133)
King, Kevin Regulations.gov 24-60 (ML21069A250)
Kitchens, Joel State of Wisconsin Regulations.gov 97 1st Assembly District (ML21064A326)
Klopp, Chris Meeting Transcript 26-13 (ML21062A192)
Koch, David Regulations.gov 68 (ML21063A055)
Koenig, Kevin Regulations.gov 59 (ML21062A132)
Koeslin, Thomas Regulations.gov 54 (ML21062A126)
Kopetsky, Brian Regulations.gov 96 (ML21064A324)
Kopp, John Regulations.gov 149 (ML21069A027)
Kosowicz, Aleks Regulations.gov 24-18 (ML21069A250)
Kosowicz, Aleks Regulations.gov 115 (ML21064A359)
Kraft, David Nuclear Energy Regulations.gov 146 Information Service (ML21069A023)
Kraft, David Nuclear Energy Regulations.gov 146 Information Service (ML21069A024)
Kraft, David Nuclear Energy Regulations.gov 162 Information Service (ML21069A042)
Krause, Sarah Regulations.gov 83 (ML21063A092)
Krawisz, Bruce Regulations.gov 5 (ML21050A083)
Kuglitsch, Mike State of Wisconsin Regulations.gov 97 84th Assembly District (ML21064A326)
Kurland, Miriam Regulations.gov 31 (ML21062A024)
Lane, Debbie Regulations.gov 24-114 (ML21069A250)
Lauer, Patricia Regulations.gov 24-62 (ML21069A250)
Le Fevre, Dale Regulations.gov 24-59 (ML21069A250)
Leannah, Geralyn Regulations.gov 4 (ML21050A082)
LeClair, Eugene Regulations.gov 52 (ML21062A118)
LeMahieu, Devin State of Wisconsin Regulations.gov 97 9th Senate District (ML21064A326)
Lembitz, Bre Regulations.gov 129 (ML21069A004)
Lembitz, Deanne Regulations.gov 125 (ML21064A517)
Lemmon, Cassandria Regulations.gov 24-40 (ML21069A250)
Leque, Sally Regulations.gov 75 (ML21063A069)
Lewison, Linda Sierra Club Nuclear Meeting Transcript 26-4 Free Campaign (ML21062A192)
Lichtenwalter, Wendy Regulations.gov 24-37 (ML21069A250)
Lienau, Tim Regulations.gov 143 (ML21069A019)
Lionarons, Ken Regulations.gov 41 (ML21062A039)
Lippman, Robert Regulations.gov 24-57 (ML21069A250)
Lish, Christopher Regulations.gov 177 (ML21064A510)
Luchsinger, James Regulations.gov 73 (ML21063A067)
Luna, Marie Regulations.gov 14 (ML21050A116)
Lundeen, Kelly Nukewatch Meeting Transcript 26-3 (ML21062A192)
Macks, Vic Michigan Stop the Regulations.gov 162 Nuclear Bombs (ML21069A042)
Campaign Macraith, Bonnie Regulations.gov 24-71 (ML21069A250)
Maloney, Jason Regulations.gov 139 (ML21069A015)
Matson, Patrick Regulations.gov 46 (ML21062A043)
McArdle, Ed Regulations.gov 156 (ML21069A035)
McBride, Linda Regulations.gov 24-107 (ML21069A250)
Mcclintock, Mary Regulations.gov 24-69 (ML21069A250)
Mcclure, Lee Regulations.gov 24-83 (ML21069A250)
Mccomb, Shawn Regulations.gov 134 (ML21069A009)
McCullough, Kimberly Regulations.gov 24-7 (ML21069A250)
McGee, Jamie Regulations.gov 94 (ML21064A321)
McGee, Nettie Regulations.gov 157 (ML21069A036)
Mcglocklin, Lecil Regulations.gov 24-41 (ML21069A250)
Mehorczyk, Bob Regulations.gov 40 (ML21062A038)
Mercier, Christina Regulations.gov 63 (ML21062A139)
Mercier, Christina Regulations.gov 63 (ML21084A078)
Merrick, Mitchell Sierra Club Regulations.gov 26-17 (ML21069A250)
Meyer, Alfred Regulations.gov 168 (ML21069A048)
Meyer, Alfred Physicians for Social Regulations.gov 26-9 Responsibility (ML21069A250)
Meyer, Joe Regulations.gov 113 (ML21064A353)
Michetti, Susan E-mail (ML21074A269) 145 Michetti, Susan Meeting Transcript 26-18 (ML21062A192)
Michetti, Susan Meeting Transcript 26-5 (ML21062A192)
Michetti, Susan Regulations.gov 118 (ML21064A366)
Michetti, Susan Regulations.gov 119 (ML21064A367)
Michetti, Susan Regulations.gov 120 (ML21064A369)
Michetti, Susan Regulations.gov 120 (ML21064A372)
Michetti, Susan Regulations.gov 174 (ML21069A054)
Mochnek, Cecile Regulations.gov 24-23 (ML21069A250)
Molly, Molly Regulations.gov 89 (ML21064A302)
Morrison, Amy Regulations.gov 24-117 (ML21069A250)
Mortensen, Hannah Physicians for Social E-mail (ML21056A561) 27 Responsibility Wisconsin Mortensen, Hannah Physicians for Social E-mail (ML21084A213) 181 Responsibility Wisconsin Mortensen, Hannah Physicians for Social Meeting Transcript 26-8 Responsibility (ML21062A192)
Wisconsin Mortensen, Hannah Physicians for Social Regulations.gov 2 Responsibility (ML21040A228)
Wisconsin Muhich, Mark Regulations.gov 110 (ML21064A346)
Murdock, Lewis Regulations.gov 24-33 (ML21069A250)
Murphy, Dave State of Wisconsin Regulations.gov 97 56th Assembly District (ML21064A326)
Mursau, Jeffrey State of Wisconsin Regulations.gov 97 36th Assembly District (ML21064A326)
Nadreau, Patricia Regulations.gov 24-121 (ML21069A250)
Nelson, Pam Regulations.gov 19 (ML21050A127)
Newgent, Eric Regulations.gov 8 (ML21050A089)
Neylon, Adam State of Wisconsin Regulations.gov 97 98th Assembly District (ML21064A326)
Nishiura, JoAnn Regulations.gov 15 (ML21050A117)
Owens, John Regulations.gov 112 (ML21064A352)
Painter, Brenda Regulations.gov 24-6 (ML21069A250)
Pajewski, Michael Regulations.gov 48 (ML21062A045)
Palacek, Diane Regulations.gov 9 (ML21050A092)
Peltekian, Elizabeth Regulations.gov 24-50 (ML21069A250)
Perkins, Mickey Regulations.gov 24-120 (ML21069A250)
Peuse, Keevin Regulations.gov 164 (ML21069A044)
Pierce, Meghan Regulations.gov 24-63 (ML21069A250)
Pomeday, Carol Regulations.gov 24-91 (ML21069A250)
Poppe, Dorothy Regulations.gov 24-12 (ML21069A250)
Powers, MaryAnn Regulations.gov 24-72 (ML21069A250)
Ramthum, Timothy State of Wisconsin Regulations.gov 97 59th Assembly District (ML21064A326)
Readance, Lisa Regulations.gov 24-56 (ML21069A250)
Remy, Linda Regulations.gov 24-92 (ML21069A250)
Rhoden, Bud Regulations.gov 102 (ML21064A311)
Richard, Pamela Regulations.gov 13 (ML21050A109)
Rivera, Ethyl Regulations.gov 163 (ML21069A043)
Roddy, Steve Regulations.gov 17 (ML21050A121)
Rogers, Ann Regulations.gov 10 (ML21050A099)
Rogge, Paula Meeting Transcript 26-12 (ML21062A192)
Rogge, Paula Regulations.gov 71 (ML21063A059)
Rosenberry Chase, Regulations.gov 24-48 Joy (ML21069A250)
Rousu, Dwight Regulations.gov 32 (ML21062A026)
Ruesch, Scott Regulations.gov 57 (ML21062A130)
Rushman, Janice Regulations.gov 24-67 (ML21069A250)
Schaber, Dale Regulations.gov 111 (ML21064A347)
Schaber, Dale Regulations.gov 111 (ML21064A349)
Scheer, David Regulations.gov 24-93 (ML21069A250)
Schellin, Steven Regulations.gov 106 (ML21064A338)
Schleifer, Robert Regulations.gov 24-52 (ML21069A250)
Schlies, Allen Regulations.gov 50 (ML21062A048)
Schulz, Amy Physicians for Social E-mail (ML21056A561) 27 Responsibility Wisconsin Schulz, Amy Physicians for Social E-mail (ML21084A213) 181 Responsibility Wisconsin Schulz, Amy Physicians for Social Meeting Transcript 26-7 Responsibility (ML21062A192)
Wisconsin Schulz, Amy Physicians for Social Regulations.gov 117 Responsibility (ML21064A363)
Wisconsin Schwab, Avery Regulations.gov 37 (ML21062A034)
Schwab, David Regulations.gov 160 (ML21069A040)
Schwerma, Bill Regulations.gov 72 (ML21063A066)
Shapiro, Susan LEAF of Hudson Regulations.gov 107 Valley (ML21064A339)
Shapiro, Susan Promoting Health and Regulations.gov 162 Sustainable Energy (ML21069A042)
Sheley, Thomas Regulations.gov 44 (ML21062A041)
Sielaff, Willard Regulations.gov 3 (ML21048A036)
Slocum, Jody Regulations.gov 158 (ML21069A037)
Smith, Edith Regulations.gov 24-35 (ML21069A250)
Songalia, Elizabeth Regulations.gov 24-101 (ML21069A250)
Sortwell, Shea State of Wisconsin Regulations.gov 97 2nd Assembly District (ML21064A326)
Springstube, Nate Regulations.gov 103 (ML21064A316)
Steele, Danae Regulations.gov 35 (ML21062A031)
Stewart, Mark Regulations.gov 152 (ML21069A031)
Stoleroff, Debra Vermont Yankee Regulations.gov 162 Decommissioning (ML21069A042)
Alliance Strope, Michael Point Beach Nuclear Meeting Transcript 26-6 Power Plant (ML21062A192)
Stuckey, Richard Regulations.gov 24-36 (ML21069A250)
Sullivan, Juliana Regulations.gov 24-30 (ML21069A250)
Sutton, Brian K. Regulations.gov 24-106 (ML21069A250)
Taylor, Douglas R Nottawaseppi Huron E-mail (ML21077A197) 180 Band of the Potawatomi Taylor, Gigi Regulations.gov 24-97 (ML21069A250)
Tedtmann, Edward Regulations.gov 24-16 (ML21069A250)
Thirion, Thomas Regulations.gov 24-76 (ML21069A250)
Thiry, Jackie Regulations.gov 24-51 (ML21069A250)
Touchstone, Lana Regulations.gov 24-110 (ML21069A250)
Troshynski, Larry Regulations.gov 178 (ML21062A018)
Turnbull, Clay New England Meeting Transcript 26-2 Coalition (ML21062A192)
Valihura, John Regulations.gov 24-73 (ML21069A250)
Vlasiadis, Chrisanthos Regulations.gov 24-66 (ML21069A250)
Vorpagel, Tyler State of Wisconsin Regulations.gov 97 27th Assembly District (ML21064A326)
Waak, Kevin Regulations.gov 82 (ML21063A091)
Walhood, Megan Regulations.gov 24-99 (ML21069A250)
Wallander, Dawn Regulations.gov 38 (ML21062A035)
Ward, Elizabeth Sierra Club Regulations.gov 23 Wisconsin (ML21069A250)
Ward, Robert Regulations.gov 24-38 (ML21069A250)
Warren, Barbara Citizens' Regulations.gov 24-5 Environmental (ML21069A250)
Coalition Warren, Barbara Citizens Regulations.gov 162 Environmental (ML21069A042)
Coalition Weber, Lore Regulations.gov 24-94 (ML21069A250)
Webster, Ty Regulations.gov 132 (ML21069A007)
Weeden, Mary Regulations.gov 24-65 (ML21069A250)
Werda, Ed Regulations.gov 24-39 (ML21069A250)
Werner, Shahla Meeting Transcript 26-11 (ML21062A192)
Werner, Shahla Regulations.gov 12 (ML21050A105)
Wery, Susan Regulations.gov 24-17 (ML21069A250)
Westlake, Kenneth U.S. Environmental E-mail (ML21069A228) 28 Protection Agency Wheatley, Marie Regulations.gov 24-19 (ML21069A250)
Wheeler, Carolyn Regulations.gov 24-27 (ML21069A250)
White, Doug Regulations.gov 24-79 (ML21069A250)
Wilkening, Iassic Regulations.gov 24-103 (ML21069A250)
Willems, Scott Regulations.gov 101 (ML21064A308)
Wilson, Karen Regulations.gov 43 (ML21062A016)
Wimberger, Eric State of Wisconsin Regulations.gov 97 30th Senate District (ML21064A326)
Wineman, Marian Regulations.gov 24-20 (ML21069A250)
Wolfe, Brian Regulations.gov 24-2 (ML21069A250)
Yarbrough, Jim Regulations.gov 21 (ML21050A134)
Zabrowski, Jayne Regulations.gov 24-49 (ML21069A250)
Table C-2. Individuals Submitting All or Part of the Form Content from Beyond Nuclear with Correspondence ID 77 and ADAMS Accession No. ML21063A080, Correspondence ID 78 and ADAMS Accession No. ML21063A084, Correspondence ID 79 and ADAMS Accession No. ML21063A085, Correspondence ID 80 and ADAMS Accession No. ML21063A087, or Correspondence ID 95 and ADAMS Accession No. ML21064A322 Name ADAMS Accession No.
Ellen Atkison ML21050A125 Sandra Couch ML21050A132 Mark Giese ML21050A133 Stephen Kent ML21064A312 Karen Kirschling ML21062A028 Karl Koessel ML21050A128 Kristina Mageau ML21050A122 Philip Ratcliff ML21050A159 Dennis Schaef ML21050A129 Satya Vayu ML21062A029 Kristin Womack ML21062A023 Table C-3. Individuals Submitting the Form Comment with Correspondence ID 5 and ADAMS Accession No. ML21069A250 (page # is the page count in the attachment)
Commenter Page# David Armington 589 Kristine A. 435 Andrew Arneson 309 James Abendroth 572 Carlos Arnold 962 Michael Abrams 361 Cara Artman 444 Melissa Abreu 533 George and Marilyn Ash 614 Inger Acking 225 Catherine Atherton 907 Anne Ackley 940 Mahleen B 816 Evelyn Adams 468 NB 191 Darley Adare 1105 Barri Baas 882 Barbara Addis 675 Therese Babineau 338 Hallie Adolf 1046 Palmeta Baier 772 Roy Adsit 238 John Baker 1000 Crystal Agape 655 Alleia Bakker 785 Angelica Aguilar 144 Robert Baldwin 913 Terry Akana 875 Paula Bandt 575 Madeline Akers 260 Diana Banducci 873 Dawn Albanese 852 Ashton Baney 263 Cheryl Albert 200 Ingrid Bangers 984 Dara Alexander 576 Nancy Barbieri 603 Fjsdakfl Alfsdjkfla 590 Nick Barcott 738 Kyle Alhart 1065 Karyn Barry 983 Lynn Allen 845 Marge Barry 804 Mary Allen 805 Adrienne Barton 1072 Willow Alleon 269 Jacqueline Baruch 985 Joan Altemose 374 Sue Batchelor 930 Kenneth Althiser 865 James Bates 163 Selena Ambush 662 Ruth Bauzo 1035 Celeste Anacker 350 Michael Bayouth 524 Richard Anderson 318 Heidi Bean 297 Jessica Andrews 851 Bonita Beard 981 Penelope Andrews 659 Linda Beers 934 Penelope Andrews 1042 Leigh Begalske 616 Tina Ann 982 Leigh Begalske 698 Sylvana Arguello 824 Barbara Beierl 487 Bernadette Belcastro 134 John Brim 618 Ramon Bello 323 Flavia Brizio-Skov 538 Sylvain Beloin 424 Ey Bro 329 Sharon Belson 156 Eric Brooker 868 Daniel Bembenek 757 Regina Brooks 787 Doug Bender 546 Sandy Brooks 613 Audrey Benedict 840 Anita Brown 335 Devin Benson 621 Francine Brown 909 Leah Berman 391 Gabriella Brown 493 Leah Berman 393 Ingrid Brown 711 Lisa Bey 628 Monica Brown 159 Rama Bharadwaj 702 Pam Brown 171 Kim Bigley 701 Susan Brown 276 Nyla Bissram 728 Sandra Brubaker 317 Nyla Bissram 1027 Neville Bruce 279 Helen Black 280 Anita Bryant 520 Paul Blackburn 944 Richard Buchholz 815 Mark Blandford 370 Linda Buckingham 1016 Resa Blatman 799 Joseph Buhowsky 455 Melissa Bletsian 319 Christina Bulskov 915 Katherine Blevins 1017 Barbara Burke 251 R Bloom 717 Maureen Burke 716 Sydney Bobrow 1033 John Burridge 206 Lawrence Bogolub 784 Patty Buttliere 553 Matthew Boguske 286 Susan Bye 856 Virginia Bottorff 725 Sheila Calderon 745 Kimberly Bouchard-Shapiro 1019 Kathleen Caldwell 768 Bettina Bowers 401 Morella Camejo 1066 Annita Bowman 383 J Mike Campbell 673 Jocelyn Boyce 409 Mary Campion 502 Gloria Boyd 321 Ken Canty 158 David Boyer 211 Carol Carley 226 Regena Bradeen 324 Cheryl Carney 579 Richard Brei 822 Colleen Carroll 796 Tina Brenza 185 Debra Carter 719 Charles Brexel Sr. 40 Kimm Carter 677 William Briggs 328 Suzanne Caruso 997 Eric Casey 488 Thomas Cope 722 Eric Casey 742 Kathleen Corby 178 Chris Casper 622 Leonard Cork 535 Susan Chakmakian 950 Jayne Costa 1053 Philippe Chambadal 1058 Mardene Costa 457 Gregory Chandler Jr 651 Gayle Countryman-Mills 564 Jeanie Chang 727 Anna Cowen 334 Sandra Chapman Burson 769 Caryn Cowin 294 Rutherford Charlot 806 Adrienne Cox 160 Nancy Chasteen 670 John Crahan 281 Alan Chen 427 Aleasa Crary 653 Rob Cherwink 351 Bruce Cratty 809 M Chessin 296 Kristin Crawford 461 William Chevalier 674 Robert Crenshaw 834 Laura Chinofsky 521 Scott Crockett 668 Katherine Christensen 1055 Edith Crowe 1080 Yvonne Christison 608 Brooke Crowley 1008 Jan Church 192 J. Cuci 420 Pamela Ciaccio 380 Kristin Cucolo 1062 Robert Claesson 414 Kermit Cuff 749 Steph Clarke 326 Kristin Culpepper 1012 Patricia Close 1004 Peter Curia 808 Sandra Cobb 987 Cody Curtis 440 Delores Coe 682 Joseph Dadgari 1002 Brian Cohen 499 Katherine Dander 371 Jennie Cohen 523 Cheryl Dare 566 Phylis Cohen 378 Carrie Darling 504 Geri Collecchia 463 Gary Davis 513 Carol Collins 734 Mary Davis 1099 Charles Collins 657 Ryan Davis 154 James Colman 1071 Sylvia De Baca 554 Terry Condon 353 Maria De La Rosa-Young 602 Vira Confectioner 817 Kathleen Dear 1096 Ronda Conner 648 Deborah Dearing 1112 John Consentino 1095 Therese Debing 957 Jim Coogan 593 Shirley Dechant 1049 Carol Cook 1020 Rosemary Deflorio 695 Emily Degn 288 Liz Dyer 1073 Linda Delaney 1103 Pamela Dymesich 501 Carmen Dello Buono 540 Susan Eckstein 478 Theresa Deluca 379 Lynn Eland 1059 Gennaro Delucia 548 Penny Elia 161 Asphodel Denning 1007 Linda Ellsworth 577 Randy Derhammer 685 James Emrich 607 James Derzon 307 Eric Ericson 508 David Dexter 429 V. Evan 494 J Diamond 454 Brenda Evans 786 Meredith Diamond 912 Susan Evilsizer 1107 Berry Dilley 1009 RF 530 Sheila Dillon 660 Marjorie Falk 891 Boris Dirnbach 331 Dave Fallow 617 Caroline Divoky 224 Rosemary Fandel 1056 Nicole Dixon 678 Stu Farnsworth 141 Sheila Dixon 344 Jean-Francois Fauconnier 610 Janice Dlugosz 466 Nathaniel Feis 1061 Jeffrey Doerfer 366 Suzanna Feitler 898 Adrienne Doherty 555 Mark Feldman 451 Stephan Donovan 795 Max Feldman 289 Patricia Doran 270 Joanne Fetting 647 Patricia Doran 901 Jamie Fillmore 776 Christopher Dowling 1047 Nannette Finkel-Rebach 1044 Deirdre Downey 581 Chris Finzer 977 Carol Drake 190 Robert Fischoff 929 Janet Draper 731 William Fisk 465 Craig Drew 528 Gerry Fitzgerald 360 Julie Dubois 671 Heather Florian 864 Gregory Dudley 697 Susan Foley 798 Joseph Dudzik 203 Eileen Fonferko 382 Susie Duff 212 Jane Forbes 425 Judy Dugan 636 Thomas Force 866 Robin Dumler 179 Angela Ford 585 Tom Dunlea 130 Judy Fore 459 Dirk Durant 24 Rosemary Fore 994 Cho Dwyer 1006 Eric Fournier 1013 Jordan Fouts 452 Stephanie Glatt 558 Stephanie Fox 1086 Patricia Gleason 347 Tess Fraad 1083 Nancy Godwin 308 Nadia Franco 221 Cody Goin 1093 L Franklin 993 Daniel Goldberg 201 L Franklin 1036 Peter Goldman 1088 Bryn Frederickson 690 Susan Goldman 1098 Mark Freitag 132 Frank Gonzales 627 Lawrence Frey 233 Gaetane Gonzales 442 Joyce Frohn 644 Elimaris Gonzalez 661 Lynn Fuerst 490 Vanessa Gonzalez-Green 988 Lynn Fuerst 837 Mark Goodman 1050 Peggy Fugate 510 Patricia Goodson 557 Kristina Fukuda-Schmid 925 Kevin Goodwin 591 Ken Funabashi 788 Mark Gorsetman 384 Kevin Gallagher 267 Robert Grace 182 Kristin Gallanosa 150 Jeremiah Graff 492 Armando Garcia 213 Leslie Graff 527 Kristen Garcia 287 Jennifer Ann Gralinski 372 Rosemarie Garczynski 849 Emily Grandy 600 Alice Gard 743 Robert Graver 231 Sydney Garner 989 Hod Gray 503 Louisa Gauerke 811 Margery Gray 250 Linda Gazzola 365 Rose Greco 155 Karen Geahlen 402 Arden Green 635 Terrillyn Geer 387 Mary Green 170 Carol Gentry 482 Tonya Green 687 Richard Gentry 631 Bert Greenberg 484 Sherril Gerell 708 Stephen Greenberg 153 Mary Germain 1113 Mark Grenard 736 Jody Gibson 252 Elizabeth Gricus 921 Mark Giese 947 Debbie Griffin 1064 T Gilbert 500 Julie Griffith 259 Ellyn Gillespie 730 Crystal Grillo 748 Phyllis Ginsberg 532 Peter Gunther 446 Larry Gioannini 516 Linda Guthrie 1018 Nicola Giorgio 1100 Perry Gx 844 Reem Haddad 264 Marylois Hilton 215 Reem Haddad 265 Robert Hinely 291 Dave Hadden 676 Andrew Hinz 162 Sarah Hafer 881 Larz Hitchcock 299 Michele Hall 1029 Cynthia Hobart 823 Paul Halliday 759 Maggie Hodges 876 Susan Hall-Taylor 640 Bud Hoekstra 959 Pamela Hamilton 741 Tim Holder 408 Richard Han 870 Barbara Holowczak 412 Patrick Hanahan 1085 Pamela Hoogerhyde 892 Noah Hanmer 142 Karen Hoover 300 John Hanna 569 Terry and Martin Horwitz 820 Angela Hansen 1041 Denise Hosta 219 Thomas Harbaugh 193 Denise Hosta 970 Peter Haroutian 992 Joshua Houdek 1040 Clarence Harris 136 Alex Howe 441 Marie Harrison 1032 Zana Hristic 946 Paula Hartgraves 411 Winston Huang 760 Jim Hartung 363 Winston Huang 761 Mark and Judy Harvey 320 Linda Huggins 854 Molly Hauck 974 Lisa Hughes 1043 David Haug 683 Stephen Humphrey 529 Jess Haven 643 Myles Hunt 480 Caroline Havens 1039 Margie Hunter 436 Jennifer Hayes 560 Marc Hutchinson 1022 Mildred Headdy 703 Beebe Iii 207 Sarah Hearon 794 Norman Illsley 407 Donna Heimlich 1052 Linda Infante 980 Charles Heinrichs 829 Michael Ireland 131 Christine Hemphill 733 Kim Irvin 469 Donald Henrich 771 Nancy Irvine 180 Beth Herndobler 826 John Isham 914 Laura Herndon 199 Steven Iszauk 348 Ana Herold 1084 Karen Jackson 349 John Heyneman 924 Natalia Jacobs 918 Liz Hickerson 699 Claire Jacobsen 204 Lynda Higson 1109 Jolie June Jacobus 652 Brenda James 694 Catherine Kittle 445 Jon Jarvis 491 Hunter Klapperich 641 Alan Jasper 654 Kristin Kline 574 Nathan Jimenez 869 Linda Klouzal 1005 Annie Jo 665 Lindsay Knights 406 Ann Johnson 916 Lotti Knowles 1106 Donna Johnson 737 Diana Koeck 151 Keith Johnson 183 David Koeller 639 Donald Jones 990 Ellen Koivisto 886 Donna Jones 1038 Stephanie Koons 735 Eleanor Jones 450 Meher Kovoor 1051 Cliff Joseph 681 Susan Kozinski 601 Stephen Josephson 893 James Kozlik 526 Brian Joslyn 145 Deborah Kramer 680 R Kadden 965 Jeffrey Kramer 397 Peter Kahigian 559 Robin Kratschmer 541 Helena Kashleva 966 Barry Krieger 247 Kathryn Kassner 773 Ira Kriston 777 D C Katten 871 Kelly Kroske 1082 Sara Katz 428 Michelle Krueger 963 Katherine Kaufman 836 Keith Krupinski 1102 Elizabeth Kavcak 218 Roger Kulp 475 Arthur Keller 41 Maya Kurtz 968 Thomasin Kellermann 392 Mike Kutilek 245 Steven Kellman 812 Elise L 740 J Kelly 1091 Kay L 434 Rachel Kelton 302 Earl Labuga 1101 Diane Kent 706 David Lafond 443 B Kern 127 Joseph Lakner 315 Arin Keshishian 462 Stephanie Laman 460 Ramona Kime 887 Barbara Lamb 298 Tyler Kindschuh 724 Maree Lamb 292 Christine King 1025 Dmitry Landa 405 Norm King 1031 Doug Landau 1087 John Kirchner 223 Hazel Landers 1023 Jesse Kirkham 862 Jacob Lang 423 Kaitlyn Kittell 650 Katarina Lang 470 Norbert Langer 547 Virgene Link-New 835 Richard Langstaff 341 Tim Lippert 567 Drena Lapointe 137 Marilyn Livingston 262 Kenneth Large 860 Jennifer Lockett 688 Audrey Lasse 261 Jennifer Lockett 689 Audrey Lasse 1001 Donna Logan 612 Jes Laufenberg 143 Michael Lombardi 790 Jes Laufenberg 146 Sharon Longyear 173 Liina Laufer 746 Covi Lopez 165 Marianne Lazarus 709 Rachel Loui 758 Meaghan Leavitt 883 DeLorse Lovelady 357 Edward Leblanc 272 Paul Lucas 715 Pamela and Carl Lechner 763 Lane Lucht 543 Ernest Lee 236 Gary Ludi 531 Gerald Lee 739 Walt Luerken 781 Sandra Lee 421 Karen Lull 850 Sara Lee 634 Jimmie Lunsford 1089 Nancy Leech 960 Julie Lyne 649 Theresa Lehman 168 CM 184 Theresa Lehman 604 Monica Mabry 841 Stephan Lehmann 588 June and Ronald MacArthur 311 Donald Leisman 928 George Mackison 712 Michelle Lemp 563 Jack Mahrt 1003 Pamela Lenck Bradford 242 Paul Malkin 900 Brendalee Lennick 197 Daniel Manobianco 976 Virginia Leslie 580 Mc Manus 147 Ellen Levine 339 Lee Margulies 316 Serena Levingston 544 Aida Marina 174 Brenda Lewis 831 Christel Markevich 843 Frank Lewis 342 Bryer Marnin 285 Marjorie Lewis 542 Crystal Marshall 583 Susan Lewis 271 John Martin 246 Bob Lichenbert 885 Patrick Martin 879 Suzanne Licht 905 Juan Martinez 517 Steven Lichtenbert 337 Brennor Masters 437 Glenda Liling 256 Brennor Masters 775 Rachel Lindsey 254 Paulina Mastryukov 1108 Carole Matthews 800 William Moody 352 Michael Maxwell 275 Anne Morales 793 Michael Maxwell 971 Joy Morgen 626 Lana May 389 Daniel Morneau 496 Richard Maynard 364 Ali Morse 941 Brandi Mccauley 1011 Elizabeth Moseman 780 Richard Mccombs 828 Sue Mossman 1037 B. Mcclintock 814 Denise Motta 258 Tamara Mccready 872 Edward Mrkvicka 400 Michelle Mcdowell 847 Tara Mudry 696 Sierra Mcelyea 705 Karsten Mueller 951 Robert McFarland 897 Marilyn Mueller 853 Mary McGilvra 714 Bernardo Mujica 537 Joanne Mcgrath 133 James Mulcare 290 Dennis Mcintyre 241 Cynthia Murphy 172 Mary Mckay 938 Donna Murphy 587 John Mckee 511 Linda Murphy 177 Darrin Mckeehen 755 Eric Murrock 362 Cynthia Mckeen 489 Ann Mutschler 750 Patty McKinnon 234 Jay Myers 477 Mary Mcmanus 249 Wayne Myers 582 Lisa McWhorter 896 Zach Myones 1026 David Meade 764 David Nardo 570 Lee Meadows 830 Utkarsh Nath 268 Rachele Mechem 333 John Naylor 483 Barbara Meis 439 Darrell Neft 313 Redelisa Mendoza 196 Jordan Neiman 861 Ann Metcalf 919 Christa Neuber 332 Diane Meyer 594 Robert Newman 373 Leeallen Meyer 910 Amy Newton 473 Robert Meyer 448 Christopher Lee Nguyen 410 Sandra Middour 874 Ron Nieberding 240 Mitzi Miles 210 Meg Nielsen 884 Jenna Miller 597 Mike Nielsen 449 Lester Miller 619 Nancy Niemeir 550 Ji Montgomery 642 Derinda Nilsson 205 Ji Montgomery 1028 Lynne Nittler 624 Thomas Nooney 266 Shelly Peterson 216 Susan Norton 284 Beverly Pettway 991 James Notestine 904 Julie Phalen 658 Linda Nyberg 1094 George Phillips 514 Robert Oberdorf 789 Karen Phillips 1078 Karen Obrien 1021 Diane Pierce 188 Annie O'Connor 880 Jan Pierson 278 Martha O'Connor 346 Ina Pillar 139 Dawn Odonnell 766 Dolores Pino 596 Geoffrey Ogden 973 Tina and David Pirazzi 848 Bonnie Oliver 969 Nancy Pirtle-Connelly 592 Loretta Olsen 438 Teresa Pitts 1014 Lawrence Olson 273 Helmut Platzer 314 Robert Olson 1045 Bobette Plendl 732 Victoria Olson 720 Jeffrey Plotnik 952 Maureen O'Neal 509 Tim Pokela 167 Melissa O'Rourke 239 Daurie Pollitto 149 Mark Osborn 931 Penny Porter 821 Ned Overton 751 Heath Post 922 Jo Pa 135 Earl Poteet 863 Cindy Page 632 Jimmy Powell 217 Melissa Paige 818 Jimmy Powell 791 Joanne Painter 1077 Grant Power 390 Lowell Palm 433 D Price 235 David Palos 255 Karen Price 399 Stephen Parisi 1070 Susan Proietta 398 Claudia Parker 293 Diana Prola 497 Ellen Parker 625 Patricia Pruitt 157 Lori Parkinson 562 Barbara Puett 458 Pamela Paul 282 Yessenia Quintero 578 Greg Paxton 244 Colleen Radbill 176 Debra Pedersen 667 Rachel Rakaczky 571 Scout Perry 888 Kay Randall 129 Judith Peter 169 Margaret Rasmussen 833 Dale Peterson 584 Jeff Reagan 979 Karen Peterson 148 Maryellen Redish 964 Linda Peterson 645 Matthew Reid 1048 Jo Remy 237 Mark Rowe 471 Aileen Renner 684 Kyle Ruedinger 1024 Christine Resch 355 Michael Rumple 568 Keith Rhinehart 939 Bart Ryan 507 Katherine Rhoda 765 Juanita Ryan 686 Rachael Riccobene 1092 Karen Ryan 565 Tracy Richards 1076 Michael Rynes 301 Claudia Richner 481 Michael Rynes 937 Kathi Ridgway 431 Mohan Sakhrani 923 David Rieckmann 664 Britt Salazar 356 Roseli Rinaldo 1110 Dorothy Salvato 723 David Ringle 778 Feliz Samson 926 Ronald Ringler 456 Dana Sanchez 1067 Bill Rither 39 Valerie Sanderson 710 Catherine Rivera 693 Mary Sandstrom 536 Suzan Robbins 754 Veronique Sanson 229 Ed Robertson 345 Roseann Santangelo 418 Kenneth Robertson 375 Roseann Santangelo 549 Brooks Robinson 995 James Sarelas 426 Patriciaroche Roche 713 John and Michele Saridan 1081 Lenore Rodah 464 Britton Saunders 646 Debby Roegner 637 C. Saunders 274 Mary Rojeski 367 Adam Savett 744 John Rokas 967 Jason Saville 586 Lynn Ronconi 903 Crystal Schaffer 303 Joanne Rose 152 Amaryntha Schalin 859 Barbara Rosen 243 Ted Scherff 842 Richard and Carolyn 453 Eric Schill 629 Rosenstein Gisela Schloss-Birkholz 819 John Rosing 1068 Diana Schmidt 486 Jean Ross 672 Roger Schmidt 534 Lilli Ross 999 Linda Schrader 599 Ann Rossman 545 Steve Schueth 422 Ann Rossman 932 Margaret Schulenberg 972 Brit Rosso 857 Brett Schultz 1074 Gregory Rost 556 Monica Schuster 917 Steven Rostermundt 920 Anna Schwadron 474 Jill Rothe 927 Elizabeth Schwartz 1079 Elori Smile 936 Nancy Schwartz 996 Anne Smith 890 Jeff Schwefel 945 Fran Smith 257 Kraig Schweiss 354 J. Smith 956 Gordon Scott 753 Kelly Smith 961 Joan Scott 417 Kim Smith 803 Paula Scudere 181 Mary Smith 396 Dave Searles 810 Tiffany Snyder 718 J. Seborowski 638 Elin Soderquist 404 Jana Segal 598 Louisa Solari 707 Donna Selquist 186 Sharon Sootin 752 Mary Sena 1010 Kathy Spera 953 Charlotte Serazio 605 Diane St Angelo 1111 Sandra Serazio 330 Emily St. Onge 656 Sandra Serazio 606 Steven Stake 877 Janice Seybold 1114 Gabriel Stanley 1057 Paula Shafransky 933 John Stanton 388 Hyacen Shaktilove 164 Carl Stapler 220 Barbara Sheard 779 Jack Stapleton 416 Flint Sheffield 792 Louise Stark 277 Stan Sheggeby 1090 Alex Stavis 858 Danny Shelley 669 Ken Stein 447 Arlene Sherman 430 Dixie Stevens 394 Chuck Shiebler 623 Summer Stevens 615 Jane Shippy 666 Paula Stober 467 Lynn Shoemaker 340 Joyce Stoffers 948 Marla Shrock 797 Lauren Stone 472 Gary Sibley 126 Susanna Stone 595 Grace Silva 498 Maryann Stork 327 Kevin Silvestris 506 Chris Storter 611 Kevin Silvey 187 Jocelyn Stowell 1015 Drew Simrin 867 Pam Strom 878 Michael Sivulich 1069 Elizabeth Struthers Malbon 770 Priscilla Skerry 552 Laurie Sudol 935 Vivian Slade 208 Melinda Svastisalee 381 Susan Sloan 899 Eric Swan 485 Tracey Smallwood 343 Cherie Swann 322 Marla Swanson 140 Pamela Vasquez 419 Elak Swindell 1097 Stephen Vaughan 783 Rick Swope 522 Marcelo Vazquez 721 Freddie Sykes 476 Brigid Vele 782 Maria Szokolai 762 Sue Velez 209 Jorge Tamargo 413 Margaret Verellen 846 Rosemary Tann 505 Scott Vickers 832 Shannon Tausch 726 Charmaine Villadonga 138 Michael Teague 175 Emma Vinciguerra 700 Jacob Thomas 902 Mary Ann Viveros 679 Barty Thompson 376 Sharon Vorwalske 620 Kate Thompson 369 Carol Wagner 518 Mark Thompson 954 Eileen Wagner 911 Susan Thompson 377 Regina Wagner 336 D P Thornton 827 Linda Waine 663 Jennifer Thornton 978 Susan Wald 1030 Mary Tober 214 Deborah Walden 551 Janice Tomlian 943 Janice Waldron 232 Carol Torchia 304 Marilyn Waltasti 955 Fred Torney 519 Peggy Walters 512 Crystal Tracy 1104 Luwana Wanaisie 230 Dat Tran 166 Francis Wanderlich 253 Dat Tran 1063 Marvin Ward 1054 Stephanie Trasoff 894 Sheila Ward 415 Tom Tripp 692 Laura Waterworth 801 Bj Trivedi 525 Claire Watson 310 Michelle Trosper 633 Kathy Watson 1034 Michael Tucker 479 D Weamer 704 Carolyn Turner 305 Dean Webb 839 Dena Turner 561 Michael Webb 368 Edward Turner 895 Dana Weintraub 949 Jim Turner 986 Edmund Weisberg 975 Kristi Turner 194 Naomi Weisman 774 Ralph Tuscher 198 Linda Weitzer 609 Charles Unger 227 Marian Wenink 312 Supporter Unknown 807 Patti Wermeling 228 Victoria Urias 283 Nora Wesley 729 Meredith West 813 Jill Woodmansee 573 Jill Wettersten 432 Cathy Wootan 942 Bruce Wheeler 756 Blake Wu 128 Vicki Wheeler 295 Judson Wynne 359 Douglas Whitehead 802 Sabina Yates 189 Joan Wilce 395 Teri Yazdi 825 Cathy Williams 306 Mary Yeomans 855 Terrie Williams 386 Sally Yost 495 William Wilson 403 Noah Youngelson 539 Lori Wilson-Hopkins 691 Ruth Yurchuck 1060 Thomas Windberg 767 Charles Zarett 747 Paul and Shannon Wiseman 385 Alexandra Zeledon 515 Wendy Wish 325 John Zeman 358 Wendy Wish 908 Carina Zevely 630 Emily Withnall 248 Jenny Zickefoose 998 Izabela Wnuk 222 Russ Ziegler 906 Nanlouise Wolfe 958 Russell Ziegler 838 Matthew Wolff 889 Pam Zimmerman 202 Debra Wollesen 195 Ruth Zowader 1075