ML24150A203

License Renewal Scoping Summary Report

ML24150A203
Person / Time
Site:	Perry
Issue date:	07/31/2024
From:	Stephen Koenick NRC/NMSS/DREFS/ELRB
To:	Penfield R Energy Harbor Corp
Shared Package
ML24150A200	List: ML24150A202 ML24150A203
References
Download: ML24150A203 (1)

Text

Environmental Impact Statement Scoping Process

Summary Report

Perry Nuclear Power Plant, Unit 1 North Perry, Ohio

July 2024

U.S. Nuclear Regulatory Commission Rockville, Maryland Introduction

By letter dated July 3, 2023 (Agencywide Document Access and Management System (ADAMS)

ML23184A081), Energy Harbor Nuclear Corp. (Energy Harbor) submitted an application for license renewal of Renewed Facility Operating License No. NPF-58 for Perry Nuclear Power Plant Unit 1 (Perry Plant) to the U.S. Nuclear Regulatory Commission (NRC), 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.

Perry Plant is in North Perry Ohio, about 37 miles east of Cleveland, Ohio. In its application, Energy Harbor requests license renewal for a period of 20 years beyond the dates when the current renewed facility operating licenses expire. Specifically, the new expiration date, if approved, would be November 7, 2046, for the Perry Plant operating license.

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 input. This report briefly summarizes the issues identified by the environmental scoping process associated with the NRC staffs review of Energy Harbors license renewal application.

This report is structured in four sections:

A. The Perry Plant Public Scoping Period B. Scoping Process and Objective C. Summary of Comments Provided D. Determinations and Conclusions

A. The Perry Plant Public Scoping Period

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Background===

The Energy Harbor application, and all other public documents relevant to the Perry Plant license renewal, are available in the NRCs Web-based ADAMS ML23184A081, 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 website with specific information about the Perry Plant license renewal application at:

https://www.nrc.gov/reactors/operating/licensing/renewal/applications/perry.html. This website includes application information, the licensing review schedule, opportunities for public involvement, project manager information, and other relevant information. In addition, important documents are available at the Federal rulemaking Web site, https://www.regulations.gov/,

under Docket ID NRC-2023-0136.

As part of its application, Energy Harbor submitted an environmental report (ER) to the NRC, available at ADAMS ML23184A081. Energy Harbor prepared the ER in accordance with

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.

10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions, which contains NRCs requirements for implementing the National Environmental Policy Act of 1969, as amended (NEPA).

The NRC staff conducted a scoping process to gather information necessary to prepare a site-specific environmental impact statement (EIS) to evaluate the environmental impacts of license renewal for Pery Plant. The renewed operating license would authorize the applicant to operate Perry Plant for an additional 20 years beyond the period specified in the current license.

B. Scoping Process and Objectives

On October 10, 2023, the NRC published a notice of intent (NOI) to conduct a scoping process and prepare a draft EIS in the Federal Register (88 FR 69967). The NOI informed stakeholders about the NRC staffs intent to prepare a plant-specific supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear PlantsFinal Report (NUREG-1437, Revision 1) (the GEIS) and provided the public with an opportunity to participate in the environmental scoping process. The NRC sought public comment on the appropriate scope of the environmental review. The NRC staff requested input from members of the public, by providing scoping comments by November 9, 2023. In addition to written comments, oral comments were recorded at two public meetings. The first public meeting was held in person on October 19, 2023, in Perry OH, and the second public meeting was held virtually on October 25, 2023. 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 EIS and to highlight public concerns and issues. In accordance with 10 CFR 51.29(b), this scoping summary report provides a concise summary of the determinations and conclusions reached as a result of the scoping process. The objectives of the scoping process were to:

• Define the proposed action, which is to be the subject of the EIS.

• Gather data on the scope of the EIS 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 EISs that are being or will be prepared that are related to, but are not part of, the scope of the supplement to the EIS.

• 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 decision-making schedule.

• Identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completing the EIS to the NRC and any cooperating agencies.

• Describe how the EIS will be prepared, including any contractor assistance to be used.

The NRC staffs determinations and conclusions regarding the above objectives are provided in Section D below.

C.Summary of Comments Provided

Table A-1 provides a list of commenters who provided 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 of the source. The staff reviewed each comment submission, including the public scoping meeting transcripts, to identify individual comments. Each comment was marked with a unique identifier consisting of the correspondence ID (specified in Table A-1) and a comment number. For example, Comment 3-1 refers to the first comment within the document provided by correspondence ID 3. This unique identifier allows each comment to be traced back to the source where the comment was identified. Comments were consolidated and categorized according to a resource area or topic.

Table A-2 identifies the distribution of comments received by resource area or topic.

A summary of the comments and the NRC staffs responses are provided in Appendix B to this report. Comments were grouped based on being in scope or out of scope, and comments with similar themes were further sub-grouped 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.

D. Determinations and Conclusions

(1) Define the proposed action

The NRCs proposed action in this instance is to determine whether to renew the Perry Plant operating license for an additional 20 years.

(2) Identify the scope of the statement and significant issues to be analyzed in the EIS

The environmental consequences of license renewal include: (1) impacts associated with continued operations and refurbishment activities similar to those that have occurred during the current license term; (2) impacts of various alternatives to the proposed action; (3) impacts from the termination of nuclear power plant operations and decommissioning after the license renewal term (with emphasis on the incremental effect caused by an additional 20 years of operation); (4) impacts associated with the uranium fuel cycle; (5) impacts of postulated accidents (design basis accidents and severe accidents); (6) cumulative impacts of the proposed action; and (7) resource commitments associated with the proposed action, including unavoidable adverse impacts, the relationship between short-term use and long-term productivity, and irreversible and irretrievable commitment of resources.

The significant issues identified in this report will be considered in the development of the draft EIS, in accordance with 10 CFR 51.29, Scoping-environmental impact statement and supplement environmental impact statement, and 10 CFR 51.70, Draft environmental impact statement-general. The NRC also follows guidance in NUREG-1555, Supplement 1, ESRP for Operating License Renewal to ensure compliance with all applicable regulations and NRC policies and procedures.

The NRC staff delineated and grouped comments according to resource area/topic (see Appendix B). The comments will be addressed in the EIS, as appropriate, as discussed in Appendix B to this report.

The NRC staff reviewed all comments received and categorized each as general in nature, outside scope (beyond the scope of the license renewal environmental review), or in-scope (the comment is applicable to the environmental review). The NRC staff considered all relevant in-scope comments as part of this review and has determined that the following significant issue was identified during the scoping period: radioactive silt and sediment material from the essential service water system is stored at the Perry Plant site in the chemical lagoon and Unit 2 cooling tower suction bay.

With respect to greenhouse gasses and climate change, the NRC staff will consider the impacts of continued operations on climate change and the impacts of climate change on environmental resources (e.g., air quality, water resources) that may be directly impacted by continued operation during the license renewal term in Chapter 3 of the EIS. The EIS will consider greenhouse gas emissions impacts on climate change from continued operations associated with license renewal.

In addition, the NRC staff will describe, in Chapters 2 and 3 of the EIS, the following topics generally mentioned in the scoping comments:

• Accidents-SAMAs

• Alternatives-Replacement Power

• Ecology-Aquatic Resources

• Environmental Justice

• General Environmental Concerns

• Geologic Environment

• Greenhouse Gas Emissions and Climate Change

• Historic and Cultural Resources

• Human Health-Nonradiological

• Human Health-Radiological

• Hydrology-Surface Water Resources

• Meteorology and Air Quality

• Process-Licensing Action

• Process-NEPA

• Uranium Fuel Cycle

• Waste Management-Radioactive Waste

Other scoping comments will also be considered, as discussed below.

(3) Identify and eliminate from detailed study issues which are peripheral or are not significant or which have been covered by prior environmental review

As noted in the appendices, the NRC staff received several comments that were either general in nature or otherwise beyond the scope of the license renewal environmental review. These included comments from organizations and individuals generally in support of or against the Perry Plant license renewal.

Plant-specific design bases are not re-evaluated as part of license renewal. Site-specific environmental conditions are considered when siting nuclear power plants. This includes the

consideration of meteorological and hydrologic siting criteria, including Probable Maximum Precipitation (PMP) criteria, as set forth in 10 CFR Part 100, Reactor Site Criteria. NRC regulations require that plant structures, systems, and components important to safety be designed to withstand the effects of natural phenomena, such as flooding, without loss of capability to perform safety functions. Further, nuclear power plants are required to operate within technical specifications in accordance with the NRC operating license, including coping with natural phenomena hazards. The NRC conducts safety reviews prior to allowing licensees to make operational changes due to changing environmental conditions.

The NRC staff will not consider or evaluate any issues in the site-specific EIS which do not pertain to the staffs environmental evaluation or are beyond the scope of the license renewal review. Comments that have been designated as out of scope are identified in Appendix B of this report.

(4) Identification of related environmental Assessments and Other Environmental Impact Statements

The NRC has identified an environmental assessment (EA)/finding of no significant impact (FONSI) issued September 24, 2020, for the Perry Plant license amendment to recapture low-power testing time. The EA and FONSI can be found ADAMS (ML20213A742). The completed EA/FONSI will be used in the preparation of the Perry Plant license renewal draft EIS, as appropriate. Additionally, previously completed EISs will be used in the preparation of the Perry Plant license renewal EIS, as appropriate, including portions of the GEIS, Revision 0 (1996)

(ML040690705, ML040690738) and GEIS, Revision 1 (2013) (ML13107A023).

(5) 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 Perry Plant 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, the Ohio State Historic Preservation Office, and the Advisory Council on Historic Preservation to fulfill its Section 106 obligations under the National Historic Preservation Act.

Although the Ohio Historic Preservation Office recommended that the Secretary of the Interior Professional Qualification Standards in Architectural History evaluate the Perry Plant facility for its potential eligibility for listing in the National Register of Historic Places, no concerns regarding archaeological resources and historic properties in regard to the license renewal of the Perry Plant were expressed by that office (ML23317A370). EPA recommended including the Federal Environmental Justice (EJ) Interagency Working Group's Promising Practices for EJ Methodologies in NEPA Reviews1 to guide the EJ analysis and related elements. The NRC follows applicable regulations and guidance in the development of the draft EIS, including performing an EJ analysis in accordance with the NRCs Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions.

(6) Indicate the relationship between the timing of the preparation of environmental analyses and the Commission's tentative planning and decision-making schedule

The NRC staff plans to issue a draft EIS for public comment in August 2024. The 45-day 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.

Comments on the draft EIS will be considered in the preparation of the final EIS, which the NRC staff anticipates issuing in August 2025. The NRC staff is completing its safety review and will document findings in a safety evaluation report (SER) which is anticipated in December 2024.

The findings in the EIS and SER will be considerations in the NRCs decision to issue or deny Energy Harbors request for the license renewal of the Perry Plant license.

(7) Identification of Cooperating Agencies

During the scoping process, the NRC staff did not identify any Federal, State, local or Tribal agencies as cooperating agencies for this EIS.

(8) Describe how the environmental impact statement will be prepared, including any contractor assistance to be used

Upon completion of the scoping process, the NRC staff will compile its findings in a draft EIS.

The draft EIS will be made available for public comment. Once public comment period is complete, the NRC staff will amend the draft EIS, as appropriate, and will prepare and publish a final site-specific EIS. The NRC will then prepare and provide a Record of Decision in accordance with 10 CFR 51.102 and 10 CFR 51.103.

Appendix A

List of Commenters

Table A-1. Individuals Providing Comments During the Scoping Comment Period Commenter Affiliation Correspondence Comment ADAMS ID Source Accession Number Lee, M. Council on Intelligent 1 Email ML23317A365 Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE)

Gunter, Paul Beyond Nuclear 2 Email ML23317A367

Welling, Diana Ohio State Historic 3 Email ML23317A370 Preservation Office (SHPO)

DeMare Joseph 4 Email ML23317A372

DeMare, Joseph 7 Email ML23317A373

Gunter, Paul 5-1 Meeting ML23303A068 Transcript Drechsler, 5-2 Meeting ML23303A068 Jacquelyn Transcript DArrigo, Diane Nuclear Information and 5-3 Meeting ML23303A068 Resource Service Transcript Hadden, Karen Sustainable Energy & 5-4 Meeting ML23303A068 Economic Development Transcript Coalition Gunter, Paul 5-5 Meeting ML23303A068 Transcript Luse, Jeff 5-6 Meeting ML23303A068 Transcript Kline, Conne 5-7 Meeting ML23303A068 Transcript DArrigo, Diane Nuclear Information and 5-8 Meeting ML23303A068 Resource Service Transcript DeMare, Joseph Wood County Green 5-9 Meeting ML23303A068 Party Transcript Safer, Don 5-10 Meeting ML23303A068 Transcript Lee, Michel Council on Intelligent 5-11 Meeting ML23303A068 Energy & Conservation Transcript

Commenter Affiliation Correspondence Comment ADAMS ID Source Accession Number Policy and Promoting Health and Sustainable Energy Davis, Ms. 5-12 Meeting ML23303A068 Transcript Hadden, Karen Sustainable Energy & 5-13 Meeting ML23303A068 Economic Development Transcript Coalition Drechsler, 5-14 Meeting ML23303A068 Jacquelyn Transcript Keegan, Michael 5-15 Meeting ML23303A068 Transcript Marida, Pat Ohio Nuclear-Free 5-16 Meeting ML23303A068 Network Transcript Kline, Connie 5-17 Meeting ML23303A068 Transcript Davis, Ms. 6-1 Meeting ML23303A069 Transcript Wyatt, Michael 6-2 Meeting ML23303A069 Transcript McClain, Krystle U.S. Environmental 8 Regs.gov ML23326A040 Z. Protection Agency Spotts, Richard 9 Regs.gov ML23326A041

Marida, Patricia 10 Regs.gov ML23326A043

Davis, Daryl M. 11 Regs.gov ML23326A044

Table A-2. Distribution of Comments by Resource Area or Topic Subject Comments Accidents-SAMAs 5 Alternatives-Replacement Power 8 Ecology-Aquatic Resources 2 Environmental Justice 2 General Environmental Concerns 3 Geologic Environment 13 Greenhouse Gas Emissions and Climate Change 8 Historic and Cultural Resources 2

Human Health-Nonradiological 2 Human Health-Radiological 20 Hydrology-Surface Water Resources 2 Meteorology and Air Quality 4 Process-Licensing Action 17 Process-NEPA 3 Uranium Fuel Cycle 6 Waste Management-Radioactive Waste 9 Support-Licensing Action 3 Opposition-Licensing Action 15 Outside Scope-Aging Management 8 Outside Scope-Energy Costs 2 Outside Scope-Other Non-License Renewal Actions 5 Outside Scope-Safety 20 Outside Scope-Security and Terrorism 5

Appendix B

Analysis of Comments Received During the Scoping Period

B.1 Comments on the Resource Areas

B.1.1 Comments Concerning Accidents-SAMAs

Comment Summary: Commenters expressed concerns about the consequences of accidents at the Perry Nuclear Power Plant, Unit 1, including cost and loss of life. This commenter stated that plausible worst-case scenarios from a major accident or terrorist attack need to be disclosed to the public and that the costs be quantified by independent actors and reported in the EIS for Perry Nuclear Power Plant, Unit 1. Another commenter requested a full analysis of the consequences of a severe accident at Perry Nuclear Power Plant, Unit 1. A commenter stated that severe accidents not be discounted because they have been deemed unlikely.

Commenters stated that plausible worst-case scenarios should be evaluated the disclosed to the public. Another commenter expressed concern that nuclear accidents are dismissed as inconsequential to the environment and its inhabitants.

Comments: (1-8) (1-10) (5-10-3) (5-15-4) (11-1)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the SAMA resource area and/or supplemental applicable areas.

B.1.2 Comments Concerning Alternatives-Replacement Power

Comment Summary: Commenters expressed concern about the evaluation of alternatives to nuclear power in the EIS, stating that some replacement power alternatives can be less costly, more sustainable, and are not a danger to the public. Commenters requested NRC evaluate alternate energy sources to the continued operation of Perry Nuclear Power Plant, Unit 1, due to concerns that the nuclear plant is sinking, creates waste that is dangerous to the public, and that renewable power is cheaper. One commenter stated that renewable power can provide baseload power, it is more affordable, and doesn't create more waste. The U.S. Environmental Protection Agency requested the draft EIS includes discussion of a robust range of alternatives, including renewable technologies, in line with the Council of Environmental Quality NEPA regulations.

Comments: (1-25) (5-13-3) (5-13-4) (5-14-6) (5-15-3) (5-16-6) (8-2) (10-9)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the alternatives area and/or supplemental applicable areas.

B.1.3 Comments Concerning Ecology-Aquatic Resources

Comment Summary: One commenter expressed concern about the effects of cyanobacteria from global warming resulting in fish kill events in the area nearby Perry Nuclear Power Plant, Unit 1. Another commenter expressed concern about the potential uptake of radioactivity in the aquatic food web.

Comments: (1-16) (5-8-6)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the ecology-aquatic resource area and/or supplemental applicable areas.

B.1.4 Comments Concerning Environmental Justice

Comment Summary: A commenter stated that there are disproportionate environmental and health impacts on indigenous, lower income and communities of color and an increase in population would increase potential impacts. The U.S. Environmental Protection Agency recommends using the Federal Environmental Justice (EJ) Interagency Working Group's Promising Practices for EJ Methodologies in NEPA Reviews to guide EJ analysis.

Comments: (1-26) (8-5)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the environmental justice resource area and/or supplemental applicable areas.

B.1.5 Comments Concerning General Environmental Concerns

Comment Summary: One commenter stated that relicensing the Perry Nuclear Facility, Unit 1 to run for 60 years or more warrants a comprehensive analysis of all factors relating to the environment and public wellbeing. This commenter identified specific hazards of concern, including (1) biota, temperature and water level changes in Lake Erie, (2) erosion, (3) earthquakes, (4) incidents associated with fracking in the area, and (5) climate change. Another commenter stated concern for seismic, erosion, tritium leaks, flooding, emergency planning, and aging reactors.

Comments: (1-1) (1-7) (5-4-4)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS.

B.1.6 Comments Concerning Geologic Environment

Comment Summary: Commenters expressed concern with the geologic environment at the Perry Nuclear Power Plant, Unit 1. Multiple commenters expressed concerns for seismic activity in the area, as the plant is located near geologic faults and recent earthquakes have been documented. Two commenters also noted that earthquakes have the potential to affect groundwater. In regard to seismic concerns, commenters requested seismic monitoring, additional analysis and evaluation of earthquakes and geologic faults, and consideration of and reporting on the gap under the Perry Nuclear Power Plant, Unit 1.

Multiple commenters also stated that there is erosion occurring at the Perry Nuclear Power Plant, Unit 1, specifically wave action on the shoreline. Other concerns include the geology of the area, subsidence, and the plant sinking, which may result in flooding at the Perry Nuclear

Power Plant, Unit 1. One commenter asked if permanent erosion control has been undertaken and if erosion at the toe of the bluff has receded.

Comments: (1-11) (5-7-1) (5-14-2) (5-14-11) (5-15-2) (5-15-6) (5-16-2) (6-1-6) (10-3) (10-4) (10-

5) (11-4) (11-5)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the geologic environment resource area and/or supplemental applicable areas.

B.1.7 Comments Concerning Greenhouse Gas Emissions and Climate Change

Comment Summary: Commenters requested that impacts of climate change be included in the environmental review and analysis of the Perry Nuclear Power Plant, Unit 1. One commenter stated that analysis in the EIS for the Perry Nuclear Power Plant, Unit 1 cannot rely on historic conditions as climate experts warn that future climate change conditions will present with surprises and that northeast Ohio can expect periods of drought and brushfire. Another commenter is concerned about Lake Erie becoming hotter, which may impact the cooling of Perry Nuclear Power Plant, Unit 1. The U.S. Environmental Protection Agency recommended that the DEIS for Perry Nuclear Power Plant, Unit 1 should apply the interim guidance provided by the Council on Environmental Quality to address potential climate impacts, mitigation, and adaptation issues. The EPA also stated that climate change analysis should consider the availability of water in sufficient quantities and temperatures for plant operations and if water temperature variants to the NPDES permit may be required.

Comments: (1-17) (5-1-1) (5-1-2) (5-4-2) (5-7-3) (5-12-3) (8-6) (8-7)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the greenhouse gas emissions and climate change resource area and/or supplemental applicable areas.

B.1.8 Comments Concerning Historic and Cultural Resources

Comment Summary: The Ohio State Historic Preservation Office expressed no concerns regarding archaeological resources or effects on historic properties but did recommend a meeting with the Secretary of the Interior Professional Qualification Standards in Architectural History for potential eligibility for listing in the National Register of Historic Places.

Comments: (3-1) (3-2)

Response: To the extent that these comments fall within the scope of license renewal, this comment will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the historic and cultural resources area and/or supplemental applicable areas.

B.1.9 Comments Concerning Human Health-Nonradiological

Comment Summary: The EPA recommended consideration of the Construction Emission Reduction Checklist, including controls for occupational health and recommendations to pay close attention for protection of children's health.

Comments: (8-13) (8-14)

Response: To the extent that these comments fall within the scope of license renewal, this comment will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the human health resource area and/or supplemental applicable areas.

B.1.10 Comments Concerning Human Health-Radiological

Comment Summary: Commenters expressed concerns about the human health effects of radioactivity from the Perry Nuclear Power Plant, Unit 1, specifically cancer and blood pressure impacts and the hazards from Tritium releases. Multiple commenters requested additional analysis of the radiological effects from reactors. One commenter is concerned about the extent of exposure of the allowable concentrations of tritium considering that releases to Lake Erie and Lake Ontario can affects plants, animals, and people. Another commenter provided information regarding recent research on the effects of low-level radiation and the effects on diabetes and cancer. This commenter provided links to the referenced research and requested that the NRC incorporate this new information into regulations.

Comments: (1-18) (1-20) (1-22) (4-1) (5-4-1) (5-7-4) (5-8-3) (5-8-4) (5-9-1) (5-9-2) (5-9-4) (5 4) (5-11-2) (5-12-1) (5-14-4) (5-16-3) (5-16-8) (6-1-3) (7-1) (10-7)

Response: To the extent that these comments fall within the scope of license renewal, this comment will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the human health resource area and/or supplemental applicable areas.

B.1.11 Comments Concerning Hydrology-Surface Water Resources

Comment Summary: One commenter expressed concern with flooding, erosion, water levels and temperature issues in Lake Erie, how these issues may increase because of climate change, and how they can affect the Perry Nuclear Power Plant, Unit 1. The U.S. Environmental Protection Agency recommended identifying, assessing, and disclosing potential impacts of operations on water quality and habitat in nearby wetlands and streams.

Comments: (1-15) (8-9)

Response: To the extent that these comments fall within the scope of license renewal, this comment will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the surface water resource area and/or supplemental applicable areas.

B.1.12 Comments Concerning Meteorology and Air Quality

Comment Summary: The U.S. Environmental Protection Agency stated that if relicensing of the Perry Nuclear Power Plant, Unit 1 would lead to any future construction activities, the NRC should consider whether those activities would be NEPA-connected actions. If potential

construction activities would occur, the EIS should include potential air emissions. The EPA recommended consideration of opportunities to minimize emissions, including best practices listed in the Construction Emission Reduction Checklist. This checklist includes mobile and stationary source diesel controls and fugitive dust source controls.

Comments: (8-3) (8-10) (8-11) (8-12)

Response: To the extent that these comments fall within the scope of license renewal, this comment will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the meteorology and air quality resource area and/or supplemental applicable areas.

B.1.13 Comments Concerning Process-Licensing Action

Comment Summary: Multiple commenters provided comments associated with the licensing action for the Perry Nuclear Power Plant, Unit 1. Commenters provided comments regarding the public scoping comment period, requesting an extension to the public comment period, asking about a hearing, and requesting NRC to consider all comments provided during scoping. Other commenters were concerned with the lack of transparency related to nuclear power. One commenter discussed the need for informed consent from the public on license renewal and requested that the NRC research recent studies that connected low-level radioactivity with diabetes, and present results and potential future health to the public. Two commenters stated that the NRC has yet to turn down a reactor license renewal application.

Comments: (5-2-2) (5-3-1) (5-8-7) (5-9-7) (5-10-2) (5-10-5) (5-12-2) (5-13-6) (5-14-7) (5-14-10)

(5-16-1) (5-16-7) (5-17-1) (5-17-2) (5-17-3) (5-17-4) (10-1)

Response: Comments that fall within the scope of license renewal will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS. Comments pertaining to the license renewal process will be considered as part of the NRC staffs implementation of that process.

B.1.14 Comments Concerning Process - NEPA

Comment Summary: One commenter stated that for the Perry Nuclear Power Plant, Unit 1, the NRC must use up-to-date knowledge and not rely on outdated reports. This commenter also stated that the NRC may not cite regulations as an evidentiary basis for any finding or assertion. One commenter thanked the NRC for providing information on how the public can be engaged. The U.S. Environmental Protection Agency recommends that future NEPA analyses include explanations of NRC-designated categories (e.g., small, moderate, large) and to prescriptively describe efforts to ensure impacts are avoided, minimized, or mitigated.

Comments: (1-27) (5-2-1) (8-4)

Response: Comments that fall within the scope of license renewal will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS. Comments pertaining to the license renewal process will be considered as part of the NRC staffs implementation of that process.

B.1.15 Comments Concerning the Uranium Fuel Cycle

Comment Summary: Multiple commenters expressed concern about radioactive waste, nuclear safety, and stated that there is no long-term solution for the storage of radioactive waste. One commenter stated that the risk burden of the transportation and safeguarding of nuclear waste and any accident is born by the public and a catastrophic accident could render areas uninhabitable. One commenter discussed whether waste would remain at the Perry Nuclear Power Plant, Unit 1 or be transported elsewhere as there is no permanent repository. One commenter stated that radioactive exposure may occur to members of the public through transportation activities and should be addressed in the EIS. Another commenter stated that uranium mining causes environmental impacts.

Comments: (1-3) (1-4) (1-21) (1-23) (9-1) (9-3)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the uranium fuel cycle resource area and/or supplemental applicable areas.

B.1.16 Comments Concerning Waste Management-Radioactive Waste

Comment Summary: Commenters expressed concern with the generation of radioactive waste at the Perry Nuclear Power Plant, Unit 1. One commenter expressed concern about the amount of waste that will be produced with the relicensing of the Perry Nuclear Power Plant, Unit 1, and stated that the relicensing could double the amount of waste at the reactor on the shores of Lake Erie. This commenter also expressed concern that the Perry Plant could be a permanent storage location. Another commenter stated that there is a cumulative risk for radioactive waste when combined with additional production. One commenter discussed storage of radioactive waste at the Perry Nuclear Power Plant, Unit 1 and the possibility of cracking in waste storage canisters. This commenter stated that most storage canisters cannot be opened and there is no way to transfer the fuel rods back to the fuel pool in the event of canister issue; this commenter recommended a hot cell at the Perry Nuclear Power Plant, Unit 1. One commenter expressed concern about tritium leaks from the Perry Nuclear Power Plant, Unit 1 and requested that the radioactive silt being stored be identified and removed. Another commenter asked if the EIS should postulate the removal of spent fuel from the Perry Nuclear Power Plant, Unit 1, as well as waste transportation, security, emergency planning, and training costs. One commenter is concerned with storage of high-level radioactive waste in thin canisters at the Perry Nuclear Power Plant, Unit 1. This commenter expressed concern about the safety of canisters and that radiation levels are kept from the public. Another commenter expressed concerned about the history of unplanned leaks and corrosion of buried pipes and stated that these additional exposure risks to the public be addressed.

Comments: (1-19) (1-24) (5-8-2) (5-13-5) (5-14-8) (5-16-9) (6-2-2) (10-10) (11-2)

Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs technical review and analysis during the development of the DEIS within the waste management resource area and/or supplemental applicable areas.

B.2 Non-Technical and Comments Outside the Scope of the Environmental Review

B.2.1 General Comments in Support of the Licensing Action

Comment Summary: Commenters provided support for continuation of operation and renewal of the license for the Perry Nuclear Power Plant, Unit 1. One commenter stated that in order to reduce emissions and address climate change, nuclear energy can provide base load carbon free power. One commenter expressed respect for the people who work at the Perry Nuclear Power Plant, Unit 1.

Comments: (5-6-1) (6-1-1) (6-2-1)

Response: These comments are outside scope of the Environmental Review and will not be discussed in the DEIS.

B.2.2 General Comments in Opposition to the Licensing Action

Comment Summary: Multiple commenters expressed opposition to the extension of the license for the Perry Nuclear Power Plant, Unit 1. Reasons for opposition stated include: (1) lack of trustworthiness and character due to the recent House Bill 6 corruption, (2) failure to provide baseload nuclear, which resulted in a grid blackout in 2021, (3) renewable power is more affordable and produces less waste, (4) militarism in nuclear power, (5) that Perry Nuclear Power Plant, Unit 1 was designed for a world that no longer exists, (6) new research connecting radiation and diabetes is not in NRCs regulations, (7) Americans contracting cancer, and (8) sea level rise and deterioration of the Perry Nuclear Power Plant, Unit 1. One commenter requested the NRC to review history, not accept the claims of the applicant at face value, and recheck every fact provided.

Comments: (1-6) (5-4-7) (5-8-1) (5-9-3) (5-9-5) (5-9-6) (5-9-8) (5-13-2) (5-14-1) (5-14-5) (5-14-9)

(5-15-7) (5-16-10) (9-4) (10-13)

Response: These comments are outside scope of the Environmental Review and will not be discussed in the DEIS. However, comments germane to NRCs work will be passed along to appropriate NRC staff.

B.2.3 Comments Concerning Outside Scope - Aging Management

Comment Summary: Commenters expressed concern about the aging facilities at the Perry Nuclear Power Plant, Unit 1. One commenter cautioned again pushing aging machines past their limits. Two commenters expressed concerns about how much embrittlement is occurring. Multiple commenters discussed age-related deterioration and the need for repair, as well as the associated costs required for continued operation. Commenters also stated that there are parts at the Perry Nuclear Power Plant, Unit 1 that are not able to be inspected and are past their engineered lifespan. One commenter asked how the NRC can extend the license for the Perry Nuclear Power Plant, Unit 1 beyond the engineered lifespan. Another commenter stated that the NRC has failed to mandate harvesting and analysis of aging components from U.S. nuclear site and that instead materials are being sold for scrap or sent out for disposition. This commenter stated that computer models used to rationalize continued running of plants beyond their planned lifetime have not been validated. This commenter also stated that NRC must not rely on its Maintenance Rule as a means to evade recognition that components age.

Comments: (1-2) (1-14) (5-4-5) (5-12-4) (5-14-3) (5-16-4) (5-16-5) (10-8)

Response: These comments are outside scope of the Environmental Review and will not be discussed in the DEIS. However, aging management will be addressed in the NRCs safety review of the license renewal application.

B.2.4 Comments Concerning Outside Scope-Energy Costs

Comment Summary: One commenter discussed the Price-Anderson Act and how the act absolves nuclear plant operations of most of the liability for damages in the event of a major accident. As industry and insurers are not willing to shoulder the financial risks, this commenter states that accident risk should be incorporated in the scoping process and the EIS for the Perry Nuclear Power Plant, Unit 1. Another commenter discussed alternative energy options and the related cost of operation.

Comments: (1-13) (5-8-5)

Response: These comments are outside scope of the Environmental Review and will not be discussed in the DEIS. However, comments germane to NRCs work will be passed along to appropriate NRC staff.

B.2.5 Comments Concerning Outside Scope-Other Non-License-Renewal Actions

Comment Summary: Multiple commenters expressed concern that the NRC does not have the resources, funding, or expertise to complete the analyses required for the Perry Nuclear Power Plant, Unit 1 EIS. One commenter requested that the NRC push back internally on political pressure. One commenter expressed concern about the rapid switching of ownership of the Perry Nuclear Power Plant, Unit 1 over a four-to-five-year period and is concerned that the associated responsibility has been lost. Another commenter is concerned about the connection between commercial and military nuclear power and waste.

Comments: (5-10-1) (5-11-1) (5-11-5) (5-15-5) (10-12)

Response: These comments are outside scope of the Environmental Review and will not be discussed in the DEIS. However, comments germane to NRCs work will be passed along to appropriate NRC staff.

B.2.6 Comments Concerning Outside Scope - Safety

Comment Summary: Multiple commenters expressed concern about safety aspects of relicensing the Perry Nuclear Power Plant, Unit 1. Concerns included the cost of repairs, monitoring of the inaccessible parts of the plant, safety of the people who work at the plant and the community, competence of the operator, increase in wind and rain events, flooding, and embrittlement of the steel and other materials of the plant that continue to be exposed to radioactivity. Other commenters expressed concern about the impacts of climate change on the operation of a nuclear power plant. One commenter requested that the NRC incorporated scientific updates in looking at weather and the influences of climate changes. One commenter requested a full analysis of the safety aspects before the licensing process occurs. Another commenter stated that it is not a valid assumption that the necessary level of access or emergency response capability will be available in the future based on the impact of the

changing climate. The U.S. Environmental Protection Agency recommends a safety and structural integrity assessment of the Perry Nuclear Power Plant, Unit 1 given the frequency and severity of storm events expected due to climate change. The U.S. Environmental Protection Agency also requested that the EIS for the Perry Nuclear Power Plant, Unit 1 include a description of the current structural integrity of the Perry Nuclear Facility, Unit 1, any needs for upgrades or future infrastructure projects, and the environmental impacts of such project.

Comments: (1-12) (2-1) (2-2) (5-4-3) (5-4-6) (5-5-1) (5-5-2) (5-7-2) (5-11-4) (5-13-1) (5-15-1) (6-1-2) (6-1-4) (6-1-5) (6-1-7) (8-1) (8-8) (10-2) (10-6) (11-3)

Response: These comments are outside scope of the Environmental Review and will not be discussed in the DEIS. Aging management issues will be addressed in the NRCs safety review of the license renewal application. Other safety issues are addressed under the current licensing basis for the Perry Plant.

B.2.7 Comments Concerning Outside Scope - Security and Terrorism

Comment Summary: Multiple commenters expressed concerned about security and terrorism. Concerns stated include utilities being hacked by terrorists, threats from the cyber realm, drones, and emerging AI. One commenter stated that risks resulting from sabotage and terrorism need to be recognized in the Perry Nuclear Power Plant, Unit 1 EIS and are not legitimately deemed out-of-scope. One commenter requested that the NRC acknowledge what is unknown, unassessed, and beyond NRCs realm of expertise and to complete a full-scale risk analysis of each phenomenon. Another commenter stated that low-probability, high consequences events such as pandemics, terrorism, and natural disasters must be taken into consideration in cost and technical capability calculations.

Comments: (1-5) (1-9) (5-11-3) (9-2) (10-11)

Response: These comments are outside scope of the Environmental Review and will not be discussed in the DEIS. However, comments germane to NRCs work will be passed along to appropriate NRC staff.