ML13189A129

Comment (10) of Corinne Hanson on Behalf of Natural Resources Defense Council on Notice of Receipt and Availability of Application for Renewal of Limerick, Units 1 and 2

ML13189A129
Person / Time
Site:	Limerick
Issue date:	06/27/2013
From:	Christopher Hanson Natural Resources Defense Council
To:	Bladey C K Rules, Announcements, and Directives Branch
References
78FR2663 00010, NRC-2011-0166
Download: ML13189A129 (25)

Text

Page 1 of I RULES AND DIRECTIVES BRI2NCH9 2'T) Y! 2 PrI 1: 28 PUBLIC SUBMISSION As of.: July 02, 2013 Received:

June 27, 2013 Status: PendingPost Tracking No. ljx-8658-suwt Comments Due: June 27, 2013 Submission Type: Web Docket: NRC-2011-0166 I R -- .\-./ D Notice of Receipt and Availability of Application for Renewal of Limerick Generating Station, Units 1 and 2 Facility Operating License Comment On: NRC-2011-0166-0049 Exelon Generation Company, LLC, License Renewal of Nuclear Plants and Public Meetings for the License Renewal of Limerick Generating Station, Units 1 and 2 Document:

NRC-2011-0166-DRAFT-0050 Comment on FR Doc # 2013-10788 Submitter Information

-/ /Name: Corinne Hanson Address: 1152 15th ST, NW Suite 300 Washington, DC, 20005 Organization:

Natural Resources Defense Council General Comment NRDC Comments on NRC's Supplement 49 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEI S), NUREG-1437, regarding renewal of operating licenses for Limerick Generating Station, Docket ID NRC-2011-0166.

Attachments NRDC Comments Limerick Draft EIS 27 June 2013 SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add=/https ://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=0900006481347124&for...

07/02/2013 June 27, 2013 Via Electronic Mail issE BEST Ms. Cindy Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration Mail Stop: TWB-05-BOlM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Comments on NRC's Supplement 49 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GElS), NUREG-1437, regarding renewal of operating licenses for Limerick Generating Station, Docket ID NRC-2011-0166.

Dear Ms. Bladey:

The Natural Resources Defense Council (NRDC) writes today to comment on the Nuclear Regulatory Commission's (NRC) draft plant-specific supplement 49 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), NUREG-1437, regarding the renewal of operating licenses NPF-39 and NPF-85 for an additional 20 years of operation for Limerick Generating Station (the "draft GElS Supplement").

See 78 Fed. Reg.26663 (May 7, 2013). NRDC respectfully urges NRC to withdraw the draft GElS Supplement as the agency's actions fail to meet the requirements of the National Environmental Policy Act (NEPA) 42 U.S.C. § 4321, et seq., as described in detail below.NRDC Comments on GElS Supplement Section 1: "PURPOSE AND NEED FOR ACTION""The NRC makes the decision to grant or deny license renewal based on whether the applicant has demonstrated that the environmental and safety requirements in the agency's regulations can be met during the period of extended operation." (page 1-1, lines 12-14)NRDC COMMENT: The existing licenses for Units 1 and 2 of the Limerick Generating Station (LGS) expire on October 26, 2024, and June 22, 2029, respectively.

The current licenses for LGS do not expire for another 11 (Unit 1) and 16 years (Unit 2). Renewing these licenses for another 20 years would result in the licenses expiring in 2044 (Unit 1) and 2049 (Unit 2). Has the NRC defined when, in the course of an applicant's current license, that applicant can or should apply for a license extension?

If an applicant applies for a license extension early, as in this case more NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 1 of 24 than a decade before expiration of current licenses, then the NEPA analysis which supports the federal action has to be projected further out into the future and is therefore less certain and can be relied on with less confidence in the government's decision.

For example, as noted below, Section 3 of the GElS Supplement concerns the environmental impacts of refurbishment, including major refurbishment activities in a boiling water reactor (BWR) such as replacement of recirculation piping and pressurized water reactor steam generators.

The GElS Supplement for LGS did not include an evaluation of the environmental impacts of nuclear power plant refurbishment because "Exelon did not identify the need to undertake any major refurbishment or replacement actions" (page 3-2, lines 10-11). However after a further decade of operation the need to undertake major refurbishment could arise. In another example, Section 4 of the GElS Supplement for LGS discusses the fluctuations in measurements of tritium in groundwater at monitoring wells since 2006 (page 4-6, lines 27-33). As the LGS units age over another decade, tritium levels in groundwater could fluctuate further, necessitating additional environmental review under NEPA.NRDC recommends that, in order to reduce uncertainty, the federal government defer a final decision on license extension for LGS until a time period closer to the expiration of current licenses for these two reactors, for example within two years of expiration of current licenses.Reinforcing this position, the GElS Supplement asserts that: "The NRC has established a license renewal process that can be completed in a reasonable period of time with clear requirements to ensure safe plant operation for up to an additional 20 years of plant life" (page 1-3, lines 20-22). If the license renewal process can be completed in a reasonable time, then renewing licenses for LGS so far in advance is unwarranted, and forces NRC's analysis in support of the NEPA process to be significantly weakened, as the NRC must thereby predict events farther in the future in support of government decision making.NRDC Comments on GElS Supplement Section 3: "ENVIRONMENTAL IMPACTS OF REFURBISHMENT" NRDC COMMENT: GElS Supplement Section 3 "ENVIRONMENTAL IMPACTS OF REFURBISHMENT" does not, in fact, analyze the environmental impacts of refurbishment because: "Exelon did not identify the need to undertake any major refurbishment or replacement actions associated with license renewal to support the continued operation of LGS beyond the end of the existing operating license" (page 3-2, lines 10-12). NRDC requests that the NRC itself determine if Exelon's statement is reasonable in a final GElS Supplement.

A steam generator replacement will likely be needed to support operation in the extended license period, probably in conjunction with the planned, but now deferred, power uprate for Limerick.The GElS Supplement is deficient in this regard, as major refurbishment activities have occurred NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 2 of 24 at numerous reactors in the course of their operating life, and may or may not occur at LGS in the future. Given the length of time to the end of extended licenses for LGS Unit 1 and Unit 2, 31 and 36 years, respectively, how much certainty can the NRC have that major refurbishment will not be required after decades of continued operation?

Given the uncertainty in projecting aging effects so far forward in time, a conservative and robust approach to NEPA requirements in support of the government's decision should include an analysis of the environmental impacts of refurbishment at LGS.NRDC Comments on GElS Supplement Section 5: "ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS" NRDC COMMENT: (Section 5.3, pages 5-3 to 5-14) The NRC begins this section by recounting the reasons the Commission concluded in 1999 that future updating of the 1989 Severe Accident Mitigation Design Alternatives (SAMDA) analysis would be unnecessary-the basis for 10 CFR 51.53(c)(3)(ii)(L).

To the contrary, as shown here, subsequent events have proven that the Commission's earlier thinking was flawed. We begin by quoting from the GElS Supplement: "The staff has previously performed a site-specific analysis of severe accident mitigation in a NEPA document for LGS in the Final Environmental Statement Related to Operation of LGS, Units 1 and 2 in NUREG-0974, Supplement 1 (NRC 1989) ("1989 SAMDA Analysis")." (page 5-3, lines 13-15). The staff concluded that: "The risks of early fatality from potential accidents at the site are small in comparison with risks of early fatality from other human activities in a comparably sized population, and the accident risk will not add significantly to population exposure and cancer risks. Accident risks from Limerick are expected to be a small fraction of the risks the general public incurs from other sources. Further, the best estimates show that the risks of potential reactor accidents at Limerick are within the range of such risks from other nuclear power plants (emphasis added)." (page 5-3, lines 25-31). The last sentence in the quote above is false, in that the theoretical "best estimate" calculation of core damage frequency is orders of magnitude lower than the historical risk, when world data are used, as described below.The staff goes on to say: "However, in the LGS specific 1989 SAMDA Analysis, the staff acknowledged:

In the longer term, these same severe accident issues are currently being pursued by the NRC in a systematic way for all utilities through the Severe Accident Program described in SECY-88-147, "Integration Plan for Closure of Severe Accident Issues" (NRC 1988c).The plan includes provisions for an Individual Plant Examination (IPE) for each operating reactor, a Containment Performance Improvement (CPI) program, and an Accident Management (AM) program. These programs will produce a more complete picture of the risks of operating plants and the benefits of potential design improvements, including SAMDAs. The staff believes that the severe accident program is the proper vehicle for further review of severe NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 3 of 24 accidents at nuclear power plants, including Limerick." (page 5-3, lines 32-43, emphasis supplied).

Of course subsequent to the Fukushima Dai-ichi accident, the last sentence in the quote above turned out to be incorrect, in that the Staff and Commission have decided to address most of the Fukushima issues in separate venues.The staff then go on to observe: "In light of these studies, the Commission believed [in 1996] it was "unlikely that any site-specific consideration of SAMAs for license renewal will identify major plant design changes or modifications that will prove to be cost-beneficial for reducing severe accident frequency or consequences" (61 FR 28467)." (page 5-4, lines 5-8). Again, the Commission programs for addressing a wide range of safety issues requiring potential plant design changes as a follow up to the accident at Fukushima Dai-ichi have proven that the Commission's earlier conclusion was short sighted and in error.Beginning on page 5-7, the Staff correctly observes: "Additionally, both the applicant and the NRC must consider whether new and significant information affects environmental determinations in the NRC's regulations, including the determination in 10 CFR 51.53(c)(3)(ii)(L) and Table B-1 that the agency need not reconsider SAMAs at license renewal if it has already done so in a NEPA document for the plant." (page 5-7, lines 10-13). The Staff then sets a high bar: "New information is significant if it provides a seriously different picture of the impacts of the Federal action under consideration.

Thus, for mitigation alternatives such as SAMAs, new information is significant if it indicates that a mitigation alternative would substantially reduce an impact of the Federal action on the environment.

Consequently, with respect to SAMAs, new information may be significant if it indicated a given cost-beneficial SAMA would substantially reduce the impacts of a severe accident, the probability or consequences (risk) of a severe accident occurring." (page 5-7, lines 13-15, emphasis added).Having set the bar high, the Staff proceeds to analyze four issues, and does so individually, rather than collectively.

The Staff ignores an issue we raised in NRDC's intervention in the Limerick license renewal proceeding.

The Declaration of Thomas B. Cochran, Ph.D., Matthew G McKinzie, Ph.D., And Christopher J. Weaver, Ph.D. on behalf of the Natural Resources Defense Council, In the Matter of Exelon Generating Company, LLC, (Limerick Generating Station License Renewal Application)

Dockets No. 50-352-LR and 50-353-LR), November 22, 2011, namely, that the risk of a core damage accident at Limerick is likely to be much greater than the theoretical estimate based on the Limerick Probabilistic Risk Assessment (PRA). In the Cochran, McKinzie, Weaver declaration we stated: "The Limerick SAMDA analysis relies on a Core Damage Frequency (CDF) of 4.2 x 10s per year (NRC, 1989) and the Environmental Report submitted by the applicant cites an estimate of CDF, which only includes internal events, for Limerick Units 1 and 2 of 3.2 x 10-6 per year based on a Probabilistic Risk Assessment (PRA) (Exelon, 2011b). In a recent update to the licensee's IPEEE model to include internal fire risks as well as internal NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 4 of 24 events in its PRA, the license calculated a total CDF of 1.8 x 10' per year for these hazard groups (NRC, 2011b). Because the PRA is based on modeling assumptions that contain a large number of approximations, large uncertainties, and omissions, the absolute value of a CDF calculated using PRA is not a reliable predictor of the actual CDF value." Worldwide, NRDC calculates that there have been approximately 429 light water reactors (LWR) that have operated approximately 11,500 reactor-years, and that five of these LWRs (Three Mile Island Unit 2, Greifswald Unit 5, Fukushima Daiichi Units 1, 2, and 3) have experienced core damage as CDF is defined in NUREG-1150 Vol. 1, pg 2-3. Thus, for this class of nuclear power reactors, LWRs, the CDF is approximately 4.3 x 10-4 per reactor-year based on the historical record. I calculate that in the United States there have been approximately 116 LWRs that have operated approximately 4,100 reactor years. One of these LWRs (Three Mile Island Unit 2) experienced core damage as defined by NUREG-1150.

Thus, for this class of nuclear power reactors the CDF is approximately 2.4 x 10-4 per reactor-year based on the historical record. The Limerick reactors, BWRs with Mark 2 containments, are similar in many respects to Fukushima Daiichi Units 1, 2 and 3, BWRs with Mark 1 containments.

While no U.S.BWRs have experienced core damage as defined by NUREG-1150, I calculate that worldwide there have been approximately 117 BWRs that have operated approximately 3,300 reactor-years. Three of these BWRs (Fukushima Daiichi Units 1, 2, and 3) have experienced core damage as defined by NUREG-1150.

Thus, for this class of nuclear power reactors worldwide the CDF is approximately 9 x 10-4 per reactor-year based on the historical record.In sum, the global CDFs for all LWRs and the subset of BWRs based on historical data are much greater than the theoretical value calculated by the applicant for Limerick Units 1 and 2, as is the U.S. historical CDF for LWRs. If a larger CDF is assumed in a PRA, then the calculated cost of severe accidents within a SAMA analysis would be increased proportionally, and thus it would be more likely that the economic viability of the measures to mitigate such accidents would be cost-beneficial.

We do not argue that any of the above CDF estimates based on the historical evidence represent the most accurate CDFs for Limerick Units 1 and 2. In our judgment the most accurate values of CDF probably lie somewhere between the theoretical values calculated by the applicant and one or more of the U.S. or global values based on the historical record.However, the CDFs used in a Limerick SAMA analysis should be evidence based. The applicant's estimates of CDF are non-conservative and a Limerick SAMA analysis would benefit from a sensitivity analysis in which higher core damage frequencies are assumed. Given the historical operating record of similar reactors, we assert that it is simply not credible to assume the CDF for older BWR reactors in the United States, such as Limerick Units 1 and 2, to be as low as 1.8 x 10s per reactor year, i.e., about one core damage event per 55,000 reactor-years of operation.

NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 5 of 24 A range of CDF values including values close to those estimated from the global historical evidence should be used in the SAMA analyses for Limerick Units 1 and 2. This issue should be analyzed and discussed in the Limerick environmental report and the final environmental impact statement.

In our view a current-day SAMA analysis is required in the NEPA analysis of severe accidents-one that includes the cumulative impacts of a severe accident based on new and significant information, including a range of core damage frequencies between the very low frequency estimated by the theoretical PRA process and the high frequency estimated using historical world data.NRDC COMMENT: On page 5-4 of the GElS Supplement, the NRC discusses the Containment Performance Improvement (CPI) Program and the Individual Plant Examination (IPE), and in this discussion the GElS Supplement repeatedly states that the NRC relies on these programs in determining that Severe Accident Mitigation Alternatives (SAMAs) need not be performed at license renewal if the staff had already performed a SAMA review in an earlier NEPA document.The phrasing clearly implies that any new and significant information that may be discovered in the intervening years between initial licensing and the license renewal stage will have been adequately considered and should satisfy all requirements pursuant to NEPA, namely a thorough analysis of environmental impacts. However, the CPI, IPE, Individual Plant Examination of External Events (IPEEE), or any other accident management programs or processes, cannot substitute for NEPA review under the legal precedent United States v.Coalition for Buzzards Bay, 644 F.3d 26, 38 (1st Cir. 2011), which rejected arguments that alternative process can substitute for N EPA. In addition, the case Limerick Ecology Action, Inc. v.NRC, 869 F.2d 719, 729 (3rd Cir. 1989)) established that Atomic Energy Act procedures cannot substitute for compliance with NEPA.NRDC Comments on GElS Supplement Section 6: "ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS" NRDC COMMENT: In the GElS Supplement Section 6, the NRC states: "There are no Category 2 issues related to the fuel cycle and waste management." (page 6-1, line 19). The implications of this determination for the fuel cycle and solid waste management are that storage, transportation and offsite radiological risk associated with spent nuclear fuel are independent of the proximity and size of populations in the region of LGS spent nuclear fuel storage, or the sizes of populations along roads or rail lines if spent nuclear fuel is transported offsite from LGS.In Section 5 of the GElS Supplement, Exelon estimates that the population within 50 miles of LGS is projected to increase to 9,499,925 in the year 2030. (page 5-9, lines 7-8). This population NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 6 of 24 estimate, which includes portions of the Philadelphia metropolitan area, shows that LGS is an outlier among US nuclear power plants in terms of having large nearby populations.

Therefore fuel cycle and solid waste management issues cannot be analyzed generically for LGS. The draft GElS Supplement should re-analyze fuel cycle and solid waste management on a site-specific basis with respect to evaluating the risks and consequences of extending the operating licenses for LGS.NRDC COMMENT: Despite the fact that the NRC has determined that fuel cycle and solid waste management are category I issues, the NRC did examine site-specific impacts in the GElS Supplement with respect to the potential for new and significant information: "the staff did not find any new and significant information related to the remaining uranium fuel cycle and solid waste management issues listed in Table 6-1 during its review of the Limerick Generating Station environmental report (ER) (Exelon 2011), the site visit, and the scoping process.Therefore, there are no impacts related to these issues beyond those discussed in the GElS. For these Category 1 issues, the GElS concludes that the impacts are SMALL, except for the issue,"Offsite radiological impacts (collective effects)," which the NRC concluded are acceptable." (page 6-2, lines 8-14) As discussed in the GElS Supplement Section 1, "The NRC's standard of significance for impacts was established using the Council on Environmental Quality (CEQ)terminology for "significant." The NRC established three levels of significance for potential impacts: SMALL, MODERATE, and LARGE." (page 1-4, lines 6-8). NRDC notes that the impacts for the fuel cycle issue "Offsite radiological impacts (collective effects)" has not been evaluated using the three levels of significance which the NRC has established.

NRDC comments that the NRC should clarify the impacts of "Offisite radiological impacts (collective effects)" in terms of SMALL, MODERATE or LARGE impacts, and describe the basis for this categorization of the risk.NRDC COMMENT: Regarding the June 2012 U.S. Court of Appeals for the District of Columbia Circuit's decision to vacate the NRC's Waste Confidence Decision (WCD) Update (State of New York, et al. v. NRC, 681 F.3d 471 (D.C. Cir. 2012)) that has forced the NRC to develop an Environmental Impact Statement (EIS), in Section 6 of the GElS Supplement NRC states that: "If the results of the WCD EIS identify information that requires a supplement to this EIS, the NRC staff will perform any appropriate additional NEPA review for those issues before the NRC makes a final licensing decision." NRDC comments that the potential environmental impacts defined by a future WCD EIS could plausibly be LARGE and be a deciding factor in the federal government's decision as to whether or not to extend the operating licenses of the two reactors at LGS. Exelon's ER and the draft GElS supplement does not now include an analysis of the environmental impacts caused by the storage of nuclear waste at Limerick following the end of the requested operating license nor does it contain an analysis of the environmental effects of failing to establish a repository (and thus the necessity of a site specific review of indefinite storage of spent fuel). The absence of such an analysis violates NEPA and related NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 7 of 24 regulations.

Because neither the ER nor the GElS (NUREG-1437), nor the NRC in any other context has examined these impacts, and because, as reiterated in the GElS supplement, the United States Court of Appeals for the District of Columbia Circuit vacated the findings and regulations that NRC relied on to bar consideration of such impacts in license renewal, such analysis is now required to satisfy the requirements of NEPA for license extension at LGS.Furthermore, since these nuclear waste impacts are an intrinsic part of the NEPA analysis required to support a Commission decision on license renewal, and this analysis is missing from the draft circulated for public comment that we are commenting on today, this draft GElS Supplement should be reissued and recirculated for public comment when this missing analysis becomes available.

NRDC Comments on GElS Supplement Section 8: "ENVIRONMENTAL IMPACTS OF ALTERNATIVES" NRDC COMMENT: Section 8 of the GElS Supplement retains many of the factual, legal, and analytical errors in the Applicant's ER previously identified by NRDC. See Natural Resources Defense Council Combined Reply To Exelon And NRC Staff Answers To Petition To Intervene In the Matter of EXELON GENERATION COMPANY, LLC (Docket No. 50-352-LR, Docket No. 50-353-LR (Limerick Generating Station, Units 1 and 2)) January 6, 2012 (License Renewal Application), p. 46 -78. Furthermore the GElS Supplement for LGS fails to conform to the basic guidelines for consideration of the No Action Alternative outlined in the GElS (NUREG-1437, 1996). The Commission makes a distinction, as do all Federal agencies subject to NEPA, between the analysis of reasonable alternatives that satisfy the purpose and need for a proposed action -in this case meeting the future base load generating requirement currently being met by LGS via license extension or a reasonable alternative

-and the alternative of no action, which by definition would not satisfy the purpose and need for nuclear or equivalent "base load" capacity, but might offer other advantages, such as the preservation of important environmental equities and/or the avoidance of significant environmental risks -such as a severe accident at LGS affecting the health, property, and livelihoods of millions of people within a 50 mile radius of the plant -- which could be uncovered through a NEPA analysis.The Nuclear Regulatory Commission's (NRC's) environmental review regulations implementing the National Environmental Policy Act (NEPA) (10 CFR Part 51)require that the NRC consider all reasonable alternatives to a proposed action before acting on a proposal, including consideration of the no-action alternative.

The intent of such a consideration is to enable the agency to consider the relative environmental consequences of an action given the environmental consequences of other activities that also meet the purpose of the action, as well NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 8 of 24 as the environmental consequences of taking no action at all. GElS at 8-1 (emphasis added).Thus, as is clear from the preceding quotation, the Commission regards the "No Action Alternative" as distinct from, and therefore not interchangeable with, consideration of the"Proposed Action" and "reasonable alternatives" that "also meet the purpose of the action." Almost by definition, then, analysis of the "No Action Alternative" cannot be equated with satisfying the purpose and need for the proposed action, and therefore the required NEPA consideration of "No Action" cannot reasonably be equated with "replacing the generating capacity of LGS," or limited to an analysis of this particular problem. Instead, as we stated previously in our Contention 4E concerning the ER, absent LGS license extension, the likely evolution of electricity system resources

[in the PJM Interconnection]

is an empirical and analytical question...that necessarily involves making an informed projection of the likely portfolio of PJM electricity system resources available in the region served by LGS beginning 13 years and 18 years hence that could reasonably be expected to supply the energy services currently supplied by LGS." As we have stated previously, the "reasonably foreseeable system resources" available under no action include, in addition to those reviewed by Exelon as reasonable alternatives to extended operation of LGS, all forms of Demand Side Management (DSM), waste heat co-generation, combined heat and power, and distributed renewable energy resources (including rooftop and parking-lot PV solar, wind, small hydro,and gasified biomass feeding small combustion turbines and fuel cells). The draft GElS Supplement analysis of the No Action Alternative fails to consider the environmental impacts of this reasonably foreseeable portfolio of PJM system resources, and thereby fails to make the required comparison between the environmental impacts of No Action and the continued operation of LGS for an additional 20 years. Although now dated, the 1996 GElS clearly suggests and sanctions this approach to analysis of the No Action Alternative.

Section 8.1 of the GElS includes a brief, but highly instructive discussion of "conservation and power import alternatives:" Although these alternatives do not represent discrete power generation sources they represent options that states and utilities may use to reduce their need for power generation capability.

In addition, energy conservation and power imports are possible consequences of the no-action alternative.

GEIS at 8-2 (emphasis added).The GElS outlines the necessary scope of environmental analysis for the no-action alternative as follows:[T]he no-action alternative is denial of a renewed license. Denial of a renewed license as a power generating capability may lead to a variety of potential NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 9 of 24 outcomes.

In some cases denial may lead to the selection of other electric generating sources to meet energy demands as determined by appropriate state and utility officials.

In other cases, denial may lead to conservation measures and/or decisions to import power. In addition, denial may result in a combination of these different outcomes.

Therefore, the environmental impacts of such resulting alternatives would be included as the environmental impacts of the no-action alternative.

GElS at 8-2 (emphasis added).The draft GElS Supplement fails to take this integrated portfolio approach to its analysis of the No Action Alternative, and to a considerable extent, this deficiency also affects its analysis of reasonable alternatives for LGS replacement.

In particular, it fails to project how the current level of energy services supported by LGS "baseload capacity" within PJM could be supplied 10 and 15 years hence by a balanced portfolio of end-use energy efficiency improvements, avoidance/reduction of transmission losses, utility-scale wind power (both land and offshore), residential solar, institutional/industrial/commercial rooftop solar, parking-lot solar, small hydro, small wind, distributed geothermal, industrial waste-heat cogeneration, residential and commercial combined heat and power systems, landfill and agriculture biogas generation using fuel cells and/or small combustion turbines, emerging wave/tidal/ocean thermal technologies, utility scale NGCC, and if needed, power imports from outside PJM. Such balanced portfolios for replacing existing traditional large-scale baseload generating assets are objectively reasonable and are indeed the target of current explicit state and federal policies.NRDC COMMENT: (page 8-2, line 7) "The NRC ultimately makes no decision about which alternative (or the proposed action) to carry out because that decision falls to utility, state, or other Federal officials.

Comparing the environmental effects of these alternatives, however will help NRC decide whether the adverse environmental impacts of license renewal are so great as to deny the option of license renewal for energy-planning decisionmakers (10 CFR 51.95(c)(4)." The referenced regulation states, in pertinent part: "The Commission shall determine whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable." By failing to compare the environmental consequences of license renewal for the obsolescent LGS reactors-including the consequences of a low probability but severe LGS accident and the full life cycle consequences of LGS fuel production, storage, and disposal-with a reasonably projectable range of balanced electricity portfolios (comprised of energy efficiency and numerous distributed low-carbon energy resources) as outlined above, the draft GElS Supplement fails to supply the information necessary to a fully informed, NEPA-compliant comparison of the environmental risks and consequences of the Proposed Action with the NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 10 of 24 alternative of No Action, while also arbitrarily excluding such balanced low-carbon portfolios from its analysis of "reasonable" alternatives for LGS capacity replacement.

NRDC COMMENT: (page 8-2, line 25) "In evaluating alternatives to license renewal, the NRC considered energy technologies or options currently in commercial operation, as well as some technologies not currently in commercial operation but likely to be commercially available by the time the current LGS operating licenses expire." The GElS Supplement does not appear to take into account technology change at all in its analysis, and in fact appears to rely on sources for the cost and performance of alternative generating technologies that are dated (e.g. 2008, rather than 2012-13 when the GElS Supplement analysis was prepared) suggesting that the Staff has continued to lean heavily on the flawed and dated analysis in the Applicant's ER. For example, the discussion of solar technology alternatives for replacing LGS Units 1 and 2 in 2024 and 2029, respectively, is based on the technically dated 1996 GElS, a ten-year-old analysis by utility-dominated Electric Power Research Institute (EPRI) conducted in 2003, the Applicant's own hugely deficient ER, which examines central station solar deployment alternatives that are absurdly unsuited to the geographic area served by PJM, and a draft 2010 BLM-DOE PEIS for"Solar Energy Development in Six Southwestern States" (emphasis added), while failing to cite a single document describing the extensive distributed solar development occurring right next door to LGS in the states of New Jersey and New York. The current and projected technical characteristics, capacities, and costs of various plausible solar and alternative low-carbon technologies, and combinations of such technologies are nowhere described, so there is no empirical basis for ascertaining whether the few arbitrarily selected and misconceived"alternatives" compare favorably or unfavorably with LGS license extension or the other large central stations alternatives (Pulverized coal, IGCC gas, new nuclear, and onshore wind)arbitrarily deemed "reasonable" and therefore subjected to "detailed" analysis.

Nor does the draft GElS Supplement make any attempt to project the performance and cost of solar and other renewable energy technologies that could plausibly be available beginning 10-15 years hence as "reasonable" alternatives to LGS license extension, and potentially impose fewer environmental harms and risks than LGS and its supporting fuel cycle. Nor does the draft GElS Supplement project the performance and cost of energy storage technologies and related low-carbon technologies, such as fuel cells, that can "smooth" the output and extend the availability of "intermittent" renewable energy and thereby make it a round-the-clock dependable source of power on the grid. These vast gaps in the draft GElS Supplement analysis are impossible to ignore.NRDC COMMENT: (page 8-2, line 39) "Alternatives that cannot meet future system needs by providing amounts of baseload power equivalent to LGS's current generating capacity, and in some cases, those alternatives whose costs and benefits do not justify inclusion in the range of reasonable alternatives, were eliminated from detailed study." This statement abundantly NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 11 of 24 illustrates why this analysis does not begin to fulfill the requirements of NEPA: (a) Please explain why, if NRC believes it is precluded from making a "decision about which alternative

[including the proposed action] to carry out," it is nonetheless knows enough to both implicitly specify "future system needs" and then exclude alternatives that "cannot meet those needs by providing amounts of baseload power equivalent to LGS's current generating capacity?" (b) We note that the GElS Supplement contains no projections of "future system needs," nor does it contain any evidence whatsoever that various plausible combinations of DSM, reduced-carbon distributed generation, and renewable energy resources would prove incapable of meeting future customer demand for energy services now met by LGS, thus requiring future dependence on LGS license extension or a similar large "baseload" facility.Indeed, the analytical requirement that any "reasonable alternative" to LGS license renewal -with the exception of an exceptionally vague, barely considered "purchased power alternative" that is nonetheless deemed "reasonable" -must be comprised of a singular generating technology of equivalent effective generating capacity to LGS, is an unrealistic, unnecessary, arbitrary and capricious assumption.

This is particularly true given that electric power from LGS license renewal or alternative would be sold into a competitive wholesale power market 10 -15 years hence -allowing plenty of time for the Independent System Operator/Regional Transmission Organization (ISO/RTO) via competitive reverse auctions to "clear" the future capacity market represented by LGS's possible demise -and that DSM measures and all forms of utility-scale and distributed generation are free to compete in this marketplace to meet future demand.NRDC COMMENT: (page 8-3, line 14) "A three-level standard of significance -SMALL, MODERATE, or LARGE-is used to indicate the intensity of environmental effects for each alternative undergoing in-depth evaluation." This vague taxonomy of relative impacts conveys almost no meaningful information regarding the specific nature and ecological harms of the impacts thus described, but only that some are (supposedly) relatively larger or smaller than others, but often not even that much information is conveyed, as when a "qualitative" range is employed (e.g. "SMALL to LARGE") to characterize an impact area, and compared to the same environmental facet of alternatives likewise expressed as a range ("SMALL to MODERATE" or"SMALL to LARGE".) Thus, for example when the "Land Use" impact is given as SMALL for"License Renewal," but "SMALL to MODERATE" for "New Nuclear at an Alternate Site," and"SMALL to LARGE" for Solar PV, no useful information is conveyed, as it is entirely possible that the specific implementations of each of these alternatives could all be characterized as"SMALL." In fact, if the comparison had not encompassed a phony solar alternative focused on gargantuan utility-scale solar development on undisturbed lands, and focused solely on distributed rooftop and parking lot PV deployments, the net consumptive land use requirements of the "unreasonable" solar alternative would actually be zero, less than the NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 12 of 24 "SMALL" and "SMALL to MODERATE" impacts of the nuclear alternatives!

The failure to meaningfully quantify and compare impacts is a violation of NEPA, as "the analysis for all draft environmental impact statements will, to the fullest extent practicable, quantify the various factors considered." Only to the extent that there are "important qualitative consideration or factors that cannot be quantified" is it acceptable for NRC to discuss "considerations or factors in qualitative terms." See 10 C.F.R. 51.71(d);

see also 40 C.F.R. § 1502.22(a), "[i]f the incomplete information relevant to reasonably foreseeable significant adverse impacts is essential to a reasoned choice among alternatives and the overall costs of obtaining it are not exorbitant, the agency shall include the information in the environmental impact statement." NRDC COMMENT: (page 8-6, line 15) "In addition, because the natural gas-fired alternative derives much of its power from a gas-turbine cycle, and because it wastes less heat than the existing LGS unit, it requires significantly less cooling water." How much less? Please quantify this difference, both in terms of the consumptive uses of freshwater resources and the thermal loads discharged to receiving water bodies.NRDC COMMENT: (page 8-6, line 17-20) The draft GElS Supplement provides high capacity factors for LGS from 2003 to 2010. (a) Please provide the average capacity factors for these units before and after this time interval, and the average lifetime capacity factor achieved for each unit to date. (b) To what extent can the very high capacity factors achieved in this period be attributed to deferred maintenance and capital additions that must be recouped by higher downtimes in subsequent years? (c) To what extent might the very high capacity factors achieved for LGS from 2003 to 2010 reflect a higher degree of operating nuclear safety risk, due to the reluctance of regulators to interrupt economical operations to identify and rectify safety deficiencies? (d) In the more than two years since the Fukushima severe accident, and attendant increased regulatory attention, what has been the operating capacity factor of (a) the US nuclear fleet; (b) all reactors of the same design class as LGS (i.e. GE-BWR Mark I's); (c) all reactors in the PJM Connection?

NRDC COMMENT: (page 8-6, line 23) "...the NRC presumes that appropriately sized units could be assembled annually to produce electrical power in amounts equivalent to LGS." (a) Why is it rational to presume that Natural Gas Combined Cycle (NGCC) capacity must nearly or entirely replace LGS capacity, leading to excessive fuel consumption and C02 emissions, rather than examining supplemental NGCC use in a "firming" mode to support maximum achievable market penetration of clean renewable energy alternatives like wind and solar? (b) How much NGCC capacity would be required to firm and backstop sufficient wind, distributed PV, waste-heat cogeneration, and small hydro capacity to replace LGS Unit 1 in 2024 and Unit 2 in 2029, assuming a relicensed LGS capacity factor of 89% and implementation of DSM measures that shrink future PJM demand for LGS output by an average 1.5 % per year over 15 years? (c)NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 13 of 24 Please compare the "load-following" characteristics of LGS versus efficient modular Natural Gas Combined Cycle (NGCC) generation.

Which represents the better technology for load-following and "firming" high levels of market penetration for "intermittent" renewables?

NRDC COMMENT: (page 8-10, line 7) "The staff estimated that the consumptive water loss for an equivalent-sized combined cycle plant would be about one-third the LGS water use." Please quantify this comparison in gallons-per-day of consumptive use for each technology, and quantify the differences in thermal load discharged directly to receiving waters.NRDC COMMENT: (page 8-10, lines 10-16) (a) Please present this stream flow calculation as a comparison between the LGS and IGCC alternative. (b) What is the reduction in stream flow in units of cubic meters per second and expressed as a percentage of the mean annual stream flow in the Schuylkill River, caused by operation of LGS, and what is this stream flow compared to the NGCC alternative? (c) What level of reduction in stream flow from LGS operation triggers"the need for low-flow augmentation from either the Delaware River or the Wadesville Mine Pool?" (d) Please provide technical references for the data used to make this comparison.

NRDC COMMENT: (page 8-12, lines 39-40) "Most of this land requirement would occur on land where gas extraction already occurs. Some natural gas could come from within Pennsylvania or nearby states." (a) Please provide the factual basis and references for these statements. (b)What percentage of this supply for a replacement NGCC plant might reasonably be expected to come from "fracked" natural gas sources?NRDC COMMENT: (page 8-12, lines 41-44) Please provide the factual basis and references for the statement that satisfying the fuel requirement for an extended 20 year LGS operating life requirement would result in the disturbance of 1,640 acres. Upon what assumptions, regarding ore grade, mining and processing techniques, and enrichment tails assay, is this calculation based?NRDC COMMENT: (page 8-17, Section 8-2) "Supercritical Pulverized Coal-Fired Alternative":

Please provide the detailed scientific and technical basis for the draft GElS Supplement conclusion that, in light of the global scientific consensus surrounding coal power's outsized contributions to Global Warming, and the serious threat the latter presents to climate stability and species survival, a new Supercritical Pulverized Coal Plant with the approximate generating capacity of LGS is nonetheless a "reasonable" alternative to LGS license extension 10-15 years hence, while a low-carbon/renewable energy portfolio enhanced by DSM measures and another decade or more of technology improvements, as described earlier, is dismissed as"unreasonable." Take as much time as you like, as it will take you a long time to explain this assertion.

NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 14 of 24 NRDC COMMENT: (page 8-20, lines 25 -27) "Without CCS in place [i.e. the more likely deployment scenario]

the staff's projected C02 emissions for the SCPC alternative would be 18,363,843 tons (16,659,678 MT) per year. The overall impact from the releases of GHGs of a coal-fired alternative would be MODERATE." (a) Please describe the scientific and analytical basis for this statement?

What specifically about the emission of 16.66 million metric tons of C02, in addition to 559 MT of fine particulates and 1,118 MT of particulates qualifies as"MODERATE" in comparison to the air quality impacts of available and projected cleaner electricity portfolio alternatives? (b) Does this 16.66 million metric ton figure include the C02-equivalent emissions from all GHG gas sources involved in the coal mine-to-ash pond life cycle?If not, what would a more complete SCPC life cycle accounting amount to in metric tons of C02 equivalent per year?NRDC COMMENT: (page 8-28, line 11) "Several designs are possible for a new nuclear facility.However, a two-unit nuclear power plant similar to the existing LGS in output is most likely." (a)Please describe the "several designs" that NRC believes are not only "possible" but "reasonably foreseeable" -the relevant NEPA analytical standard -- as partial or complete replacements for the license-extended capacity of LGS. (b) Please provide analytical support for the assertion that construction and operation of "a two-unit power plant similar to LGS in output" is "likely" in the economically competitive wholesale power environment of PJM, given that such costly units would have to be in the detailed planning stages today to be on line when LGS Unit l's license expires in 2024. (c) Given the failure over the last 13 years of the ever impending"nuclear renaissance" to deploy a conventional gigawatt-class nuclear plant in a merchant power environment, please describe the set of economic and policy circumstances that NRC believes would make such a scenario "reasonably foreseeable" within the next 10-15 years. (d)Ironically, the draft GElS Supplement fails to consider the contribution that purportedly safer, load-following, and less environmentally-intrusive Small (50-300 MWe) Modular Reactors (SMRs) might make to a low-carbon/renewable energy portfolio to "replace" LGS, even though the Commission is actively considering the licensing of such reactors within the same timeframe as LGS license extension.

Please either justify or rectify this omission.NRDC COMMENT: (page 8-31, lines 16-17) (a) Please offer quantitative technical support for the conclusion that "the overall impacts on surface water use and quality from construction and operations under the new nuclear alternative would be SMALL, and for the referenced determination (in 4.3.2) that "the impacts of LGS operations on surface water resources are SMALL" relative to other LGS license extension alternatives. (b) Please reconcile this conclusion with the finding on page 8-10, lines 3 to 16, that the "NGCC alternative would require much less cooling water than LGS Units 1 and 2, and consumptive water use would be much less...about one-third the LGS water use." (c) Since a gigawatt class nuclear power plant sets the top of the scale for power plant heat loading of aquatic environment and/or consumptive use of water NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 15 of 24 (i.e. it poses an unattractive tradeoff between two environmental harms) please explain how both the nuclear plant and an NGCC plant of equivalent capacity can, relative to each other, both have surface water impacts assessed as "SMALL"? (d) Are the harmful groundwater impacts of ISL uranium mining and natural gas "fracking" included in the assessment that the groundwater impacts of the LGS, New Nuclear, and NGCC alternatives are also "SMALL?" Please provide the empirical basis for this conclusion.

NRDC COMMENT: (page 8-33, lines 23-25) "According to GElS estimates

[that are now 17 years old], an additional 1000 ac (400 ha) of land would be affected by uranium mining and processing during the life of the new nuclear power plant." (a) Please clarify the comparison being attempted here -does the figure of 1000 ac affected by uranium mining and processing"during the life of the new nuclear plant" refer to the 20 year life of the new plant that is comparable to the 20 year license extension of LGS, or to the anticipated 60 year licensed lifetime of both plants. (b) If the latter, does this mean that NRC is asserting that fueling 2350 MW of nuclear capacity at LGS (or a new plant with similar specifications) for 20 years at > 90%capacity factor would only require the disturbance of 1000/3 = 333.33 acres of land for mining, processing, conversion, enrichment, waste storage, fuel fabrication, and disposal? (c) Please provide the complete technical assumptions and methodology used in making this calculation, including the ore grade, mining technology, enrichment tails assay, and fuel burnup assumed in the original GElS analysis and any updates that may be justified in light of new information after the passage of 17 years.NRDC COMMENT: (page 8-46 to 8-48, Section 8.5: Purchased Power) Despite its alleged status as a "reasonable alternative" subjected to "detailed analysis" in the draft GElS Supplement, this section is exceptionally brief (2.5 pages) and notably devoid of any quantitative or even qualitative analysis.

The projected mix(es) of "purchased power," including DSM resources, that could reasonably "replace" LGS Unit 1 in 2024 and Unit 2 in 2029 are nowhere specified, not even qualitatively, and the various broad "area impact" discussions consist of a single paragraph each and carry the usual meaningless labels made worse by in most cases embracing a fuzzy qualitative range. You can't get much further than that from an accountable quantitative analysis that can be objectively evaluated and assessed for accuracy.Thus we are told, for example, that impacts from this unspecified mix of purchased power would be "Small to Moderate" for "Air Quality" and "Terrestrial and Aquatic," but "Small to Large" for "Land Use" and "Socioeconomics, Transportation, and Aesthetics." How these and other environmental conclusions were arrived at is a mystery, as the analysis is unmoored from any factual or analytical foundation.

The potential role of DSM resources receives a backhanded acknowledgement

-"At some times, some portion of replacement power needs may be addressed by PJM's demand NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 16 of 24 response program" -but this nod literally begs the questions "when" and "what fraction" of LGS replacement power needs could be met by DSM resources?

PV solar and other distributed low carbon generation (e.g. small wind, small hydro, industrial waste heat co-gen, combined heat and power, landfill/water-treatment/agricultural bio-gas) appear to be excluded from the"analysis," which merely refers to the Staff's "assessment" that "purchased power" 10 and 15 years hence "would likely come from one or more of the other types of alternatives considered in this chapter," but the analysis refers by name only to "the new nuclear, coal, and natural gas, and wind alternatives described in previous sections," and the mix of even this limited menu of resources that qualifies as "reasonable" (by virtue of its comparative environmental consequences) is never specified.

In other words, this section fails to meet the minimum standard for analysis required under NEPA and the NRC's own implementing regulations.

NRDC COMMENT: (page 8-49, Section 8.6: Alternatives Considered but Dismissed)

This section is plagued by a dearth of technical data and analysis to support its conclusions, and therefore not surprisingly its environmental conclusions range from misguided to false.NRDC COMMENT: (page 8-49, lines 17-20) "Although some aspects of solar generation result in few environmental impacts, solar technology requires substantial land areas." This statement is misleading, and should be revised to say: "Although most (but not all) aspects of solar generation result in little or no harmful environmental impacts, and even net environmental benefits -for example the shading and weather protection afforded by solar parking structures, and the avoidance of long-range transmission impacts afforded by electricity production on or near the site of electricity consumption

-some large utility-scale implementations of solar technology require substantial land areas, and some CSP technologies require roughly the same amount of water for cooling of the steam cycle as most other thermoelectric technologies." NRDC COMMENT: (page 8-49, line 21) "The potential for solar technologies to serve as reliable baseload power alternative (sic) to LGS depends on the value, constancy, and accessibility of the solar resource." But who is insisting that solar serve as a "reliable baseload power alternative." This is about as sensible as asserting, "The potential of Roger Federer to serve as a reliable quarterback in the NFL depends on the constancy of his throwing arm and his accessibility to the defense." It's asking current solar technologies to forgo what they do well -serving daytime intermediate and peaking power loads -and forcing them to do what everyone knows they can't (yet) do (until the advent of economical large scale electrical storage technologies

-provide 24-7 round the clock power to the grid in "discrete baseload applications." Forcing solar technologies into the irrelevant straitjacket of "discrete baseload applications" is a none too subtle device to tilt the analytical playing field away from the applications that maximize solar's advantages and toward those that maximize the strengths of nuclear power, NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 17 of 24 coal, and gas central-station alternative.

Get rid of the "standalone baseload" assumption, and embed solar energy in a portfolio of other renewable and low-carbon electricity resources with complementary characteristics, and there is basically no limit to the reliable integration of solar energy into the future electricity grid. Such a system will necessarily be organized somewhat differently than the present system, allowing a far greater degree of autonomy, resilience, and reliability than the current central-station, hub and spoke model of electric power production and distribution that fails with virtually every intense summer thunderstorm or winter ice storm. In some areas of the country, some people are already meeting their entire electric power needs from off-grid solar applications, including round-the-clock availability via battery storage.NRDC COMMENT: (page 8-50, line 10) "Because PV does not produce electricity at night and produces diminished amounts of power during particular weather conditions, the staff does not consider solar PV to provide a viable standalone alternative to license renewal." Again, no one save the NRC Staff and the Exelon is insisting that solar, in order to serve a portion of the load now served by LGS, must by itself provide a "viable standalone alternative to license renewal." This is an arbitrary hurdle confected by the Applicant and Staff that bears no resemblance to reality.In the real world of wholesale power markets and emission controls, there is no "standalone" baseload alternative to a 2.3 GW twin-unit nuclear plant save another 2.3 GW (or larger) twin-unit nuclear plant. As the draft GElS Supplement tacitly acknowledges by its acceptance of an undocumented random mix of "purchased power" on the wholesale power market as a reasonable alternative to LGS license extension, in the real world there are few if any"standalone" baseload options for LGS replacement power, and by far the likeliest LGS replacement option is a portfolio of resources, which by 2024 and 2029 will include a wide range of "reasonably foreseeable" electricity resources, including a significant rooftop and parking lot PV solar component.

NRDC COMMENT: (page 8-50, line 35) Contrary to Exelon's absurd portrayal in its ER of a virgin land-based 98,900 acre solar PV replacement for LGS license extension, "the Staff notes that much of the solar capacity installed in PJM is likely to be in the form of rooftop installations," and acknowledges that "this type of installation minimizes land disturbance, can provide electricity to end-users, and minimizes the modifications necessary to the transmission system" Unfortunately, the draft GElS Supplement does not follow through on the logical implications of these (already widely understood) beneficial characteristics of distributed PV solar, nor explore the likelihood that 100% of all solar PV "land-based installations" could also be undertaken on already disturbed land areas, such as parking lots, freeway embankments, abandoned military bases, and urban -industrial "brownfields, meaning that solar deployment in the densely NRDC COMMENTS ON.draft GElS Supplement 49 June 27, 2013 page 18 of 24 populated PJM connection area would not require any conversion of current land in open space uses (e.g. farm land, wildlife habitat, forest areas) to PV solar power production.

NRDC COMMENT: (page 8-53, line 40) "The footprint of a utility scale standalone PV solar installation would be quite large. Based on Exelon's local PJM territory estimates, approximately 98,900 ac (40,000 ha or 155 mi 2 [400 km 2] of land would be needed to support a solar PV alternative to replace the LGS (Exelon 2011)." Why does the draft GElS Supplement bother to repeat this absurd canard when the Staff has already acknowledged on previous pages that its premises are false? No utility executive would seek to deploy such a massive solar facility on previously undeveloped land in the heavily populated PJM, nor would they obtain the environmental permits to do so, or the financing to purchase or lease that much land, and build the necessary transmission.

It's a technical and economic non-starter.

This farcical land-based"standalone" alternative distorts the range of solar PV environmental impacts reported in the draft GElS Supplement (there is insufficient direct normal solar radiation in the PJM Connection area to support concentrating solar thermal power plants (CSP) plants).Without this spurious alternative, the Land Use impacts of the "Solar PV Alternative" would be assessed as "SMALL" rather than "SMALL TO LARGE." "Terrestrial Ecology" impacts would likewise be "SMALL" rather than "SMALL TO MODERATE," and so on right down the list. If confined to existing structures and paved over areas in the already built urban and suburban environments, the PV solar alternative would have "SMALL" environmental impacts that would put it on par with the alleged assessed impacts of "continued operation of LGS," which are likewise deemed SMALL in all impact areas.NRDC COMMENT: (page 8-57, line 16) "Because this alternative

[i.e. a combined 2300 MWe of installed wind capacity, 3000 MWe of solar PV capacity, and 400 MWe of NGCC capacity]

many[may] not (sic) be able to generate 2,340 MWe because of the variable wind and solar PV resources, the staff does not consider the wind, solar, and NGCC combination alternative to provide a viable standalone alternative to license renewal. The staff considers a standalone alternative here, however, because Exelon includes a wind, solar, and NGCC combination alternative in its range of alternatives to license renewal in the ER." This is a problematic and self-contradictory paragraph.

First, it documents the fact that, for reasons that are not disclosed, the Staff's choice of reasonable alternatives is influenced not by the technical, environmental and economic performance of real world alternatives, by rather dictated by Exelon's earlier choice of alternatives in the ER, no matter how irrational these alternatives turn out to be when subjected to even a minimal review of relevant facts.Second, it provides no analytical basis in the above alternative for truncating the fully dispatchable generation and storage components before attaining an aggregate capacity sufficient, with or without DSM measures, to reliably replace the energy services now NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 19 of 24 supported by LGS. Of course, never mentioned is the fact that LGS itself must be and is backed up by excess grid "reserve capacity" (largely coal and gas-fired) for those times when one or both units are down for maintenance or even unplanned and possibly extended "outages," an inherent operational risk of nuclear plants.Conceptually, this "load following" reserve capacity is no different from the intermediate generation resources needed to "firm" a combination of wind, solar and other renewable resources to whatever level of reliability is believed to be required.

It is capricious to truncate this portfolio at some arbitrarily reduced level of readily dispatchable and responsive generation capacity (e.g. at 400 MW of NGCC, as in this example) when it could just as easily include not only more natural gas NGCC capacity but also other distributed but reliably dispatchable resources, such as bio-gas, waste-heat cogen, pumped storage, battery storage, fuel cells, and small and large hydro, which together could reliably cover the range of integrated output fluctuations experienced by a geographically and technologically dispersed portfolio of renewable energy resources.

For example, why not include in this firming portfolio the 703 MWe of hydro potential (a 1997 number!) that the draft GElS Supplement (p. 8-75, line 19) says is distributed across 104 sites in Pennsylvania, only one of which is larger than 100 MWe? Small hydro technologies have improved over the last 16 years, making it likely than more than 703 MWe could be extracted today from the state's hydro resources.

NRDC COMMENT: (page 8-78, line 18) "In the GELS, the NRC indicated that technologies relying on a variety of biomass fuels had not progressed to the point of being competitive on a large scale or being reliable enough to replace a baseload plant such as LGS...the staff finds biomass-fueled alternatives are still unable to replace LGS capacity and are not considered feasible alternatives to LGS license renewal (emphasis added)." Once again, the draft GElS Supplement employs an arbitrary and capricious construct

-that each electricity technology considered must alone be sufficient to "replace LGS capacity" -to ignore the contribution that "biomass fuels" -including fuel cells and microturbines running on captured methane from landfills, animal husbandry operations, and water treatment plants -could play in an integrated low-carbon electricity portfolio to provide the energy services that would otherwise be supplied by LGS license extension.

NRDC COMMENT: (page 8-79, lines 8 -18) The fuel cell costs given in this paragraph are dated, and in any event, vary widely and should be expressed as a range based on the specific application and the value of the avoided costs arising from that specific application.

For example, highly (70%) efficient distributed fuel cells running 75% on biogas and 75% in CHP mode offer significant avoided costs -e.g. vastly reduced GHG emissions, and reduced transmission, fuel, and HVAC costs -that add up to a substantial value proposition that can NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 20 of 24 more than offsets their relatively high installed cost-per-kilowatt.

NRDC believes that installed costs of fuel cell systems will go down significantly with the increased market penetration and higher production volumes of fuel cell systems in the time period leading up to the possible retirement of LGS Unit 1 in 2024.The draft GElS Supplement's unsupported assumption that "fuel cells are not economically or technologically competitive with other alternatives for electricity generation" may or may not hold true in 2024 -2029. It thus merits closer analysis, given that distributed fuel cell power plants in the multi-megawatt range and smaller residential/commercial CHP systems are now being installed around the world, including by leading businesses in the U.S. These units have a high availability that approximates "baseload" power applications and could be employed to"firm" renewable energy output and render it "dispatchable" on the grid. As onsite-generated power at the point of consumption, they can also be employed to shed load from the transmission and distribution grid at peak times, and thus represent a potential DSM resource that would tend to reduce the need for extension of the full LGS plant capacity.NRDC COMMENT: (page 8-79, line 12) Likewise, the installed cost of solar PV ($6,171/kW) given in the draft GElS Supplement is wildly out of date, seemingly reflecting solar installed costs as of 2008, and thus suggests an lack of due diligence in preparation of the draft GElS Supplement.

As shown in the following chart, PV module prices have dropped 80% since 2008!PV EXPERIENCE CURVE, 1976-2012 2012 W 100 ,~2006 .1988 FA0E 80%,. 20NE000 1202 IN 201LN 10 10 .00.000 10,00 100.0 lO ..... .... ... .. ... .. ....% .. ... ... ... .. ...... ..... ... ..... ......... ... ..... ... ...... ....................

.. ..-.e ..........

..............

.. ..... ........... .... ..........

... ..2 o ..... ............

-....1 !,.= _ -'" ._ --'. = 2012"" -_'... ... .................................

.. ........I 10 100 1,000 10,000 1O,00,D 1,000,000* historic prices (Maycock)

--Experience cue MW C Chinese c-Si module prices (BNEF) -Thin-film experience curve* First Solar tiln-fOm module cost Note: Prices inflation i~ndeed to US Phi. Sourse; Pau Moinoci. Blaofobero Ness Energy Firense B loomber //// MICHAEL LIEBREICH, Delhi. 17 April 20813 TWITTER: laMUebretch 8 According to a December 2012 report from DOE's NREL and Lawrence Berkeley Laboratory, for utility-scale solar, the capacity-weighted average installed price declined from $6.2/W for projects installed during 2004-2008, to $3.9/W for projects installed during 2009-2010, and to$3.4/W for projects installed in 2011. (See http://emp.lbl.gov/sites/all/files/LBNL-5919e.pdf).

NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 21 of 24 The draft GElS Supplement analysis of solar alternatives appears to be predicated not only on faulty consumptive solar land use assumptions, but on erroneous cost assumptions as well, suggesting that the entire solar alternatives analysis must be redone.NRDC COMMENT: (page 8-81, line 18, Comments on Section 8.7, No-Action Alternative)

This section, which supposedly considers the environmental impacts of the "No Action Alternative" of not renewing the operating licenses of LGS Units 1 and 2 when they expire at the end of their current license terms, in 2024 and 2029, respectively.

The section is only 3 pages long, including a half-page summary table, and thus constitutes a mere proforma pretense at presenting a NEPA-compliant analysis of the environmental consequences

-both harmful and beneficial

-- of"No Action." In fact, the analysis is impermissibly truncated because it addresses "only those impacts that arise directly as a result of plant shutdown," not including "the environmental impacts from decommissioning and related activities," which this section claims "have already been addressed in other documents," and other connected and reasonably foreseeable impacts.This leaves prompt and direct "shut-down effects" as the only subject for analysis, and in all impact areas save one ("Socioeconomics," which may be "Small to Moderate")

these are each assessed in a single paragraph as SMALL, making (absurdly) the impacts of "No Action" environmentally equivalent to the effects of "Continued Operation of LGS," which are likewise all assessed as being "SMALL." The vacuity of this analysis is readily apparent.

How can the environmental consequences and risks of operating 2340 MWe of aging and technologically obsolescent nuclear capacity for an additional 20 years have no discernible difference in impacts when compared with not operating this capacity over the same time period?Instead of reducing the required analysis of No Action to such meaningless comparisons, the draft GElS Supplement must address the reasonably foreseeable range of real world consequences from implementing the No Action Alternative, such as potential increases in C02 emissions and other pollution arising from increased reliance on fossil-fueled generation, to an increased reliance within PJM on DSM measures and low-carbon distributed generation, including vastly greater reliance on clean renewable energy solutions, to the less tangible benefits for citizens of the Philadelphia metro area of living with a reduced risk of being harmed by a severe nuclear accident.

This section as currently drafted fails to comply with NEPA. Few potential impacts are examined, and none are quantified in a manner that admits meaningful comparison, as required by law.NRDC COMMENT: (page 8-84, line 2, Alternatives Summary) The discussion under this heading presents conclusions that are based not on reasoned analysis supported by facts, but rather on the mere application of three vague qualitative labels -"SMALL," "MODERATE," and "LARGE," which are associated with no discernible quantitative measures of impacts, and are themselves NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 22 of 24 frequently employed in combination

-e.g. "SMALL to MODERATE," "SMALL to LARGE,""MODERATE to LARGE -in a manner that further deprives the required comparison of environmental impacts among alternatives of any substantive meaning.The lack of accurate up-to-date information on the environmental impacts and installed costs of various alternatives to LGS license extension deprives the analysis -and therefore the deciding agency, other federal agencies, state and local governments, and individual citizens --of any meaningful ability to weigh the environmental benefits and risks of these alternatives against their costs. The selection of alternatives deemed "reasonable" for detailed analysis is further biased by the imposition of an arbitrary screen that only "standalone baseload alternatives" capable of "replacing" LGS generating capacity in toto can meet the underlying purpose and need for LGS license renewal. Imposition of this screen excludes from detailed consideration a wide range of potential low-carbon/DSM/distributed generation/renewable energy portfolios that could plausibly provide the same level of energy services that would be otherwise be provided by a 20 year LGS license renewal. In so doing, the draft GElS Supplement ignores the clear requirement of NEPA to examine "all reasonable alternatives" to the Proposed Action -which courts have subsequently interpreted as requiring analysis of the full range of reasonable alternatives

-including the environmental consequences of "No Action." Conclusion As we noted at the outset, rather than comply with well-established NEPA requirements, the draft GElS Supplement for license extension of the two reactors at LGS does not provide required analysis and data for a host of issues, including severe accident mitigation, refurbishment, fuel cycle and solid waste disposal and energy alternatives.

In addition license renewal for LGS is premature, given the more than a decade of operation remaining under Exelon's current licenses.

For these reasons, NRDC respectfully urges the NRC to withdraw the current draft GElS Supplement, and prepare a more informed and perceptive document that presents up-to-date information and makes meaningful environmental comparisons between the impacts of a full range of reasonable alternatives.

Sincerely,/s/ (electronic signature)

/s/ (electronic signature)

Geoffrey H. Fettus Matthew G. McKinzie, Ph.D.Senior Attorney, Nuclear Program Director, Nuclear Program Natural Resources Defense Council Natural Resources Defense Council 1152 15th St., NW # 300 1152 15th St., NW # 300 NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 23 of 24 Washington, D.C. 20005 (202) 289-6868 gfettus@nrdc.org

/s/ (electronic signature)

Christopher E. Paine Senior Senior Policy Advisor, Nuclear Program Natural Resources Defense Council 1152 15th St., NW # 300 Washington, D.C. 20005 (202) 289-6868 cpaine@nrdc.org Washington, D.C. 20005 (202) 289-6868 mmckinzie@nrdc.org

/s/ (electronic signature)

Christopher (Jordan) Weaver, Ph.D.Project Scientist, Nuclear Program Natural Resources Defense Council 1152 15th St., NW # 300 Washington, D.C. 20005 (202) 289-6868 iweaver@nrdc.org

/s/ (electronic signature)

Thomas B. Cochran, Ph.D.Consultant, Nuclear Program Natural Resources Defense Council 1152 15th St., NW # 300 Washington, D.C. 20005 (202) 289-6868 tcochran@nrdc.org NRDC COMMENTS ON draft GElS Supplement 49 June 27, 2013 page 24 of 24