NRC-2016-0078, Comment (1) of Alan Harris on Behalf of Entergy Louisiana, LLC and Entergy Operations, Inc. on Entergy Operations, Inc; Waterford Steam Electric Station, Unit 3

Comment (1) of Alan Harris on Behalf of Entergy Louisiana, LLC and Entergy Operations, Inc. on Entergy Operations, Inc; Waterford Steam Electric Station, Unit 3

ML18277A240
Person / Time
Site:	Waterford
Issue date:	10/03/2018
From:	Harris A Entergy Louisiana, Entergy Operations
To:	Office of Administration
References
83FR42713 00001, NRC-2016-0078
Download: ML18277A240 (23)

Text

PUBLIC SUBMISSION As of: 10/4/18 12:53 PM Received:

October 03, 2018 Status: Pending_Post Tracking No.

1k2-95rw-72s2 Comments Due:

October 09, 2018

Submission Type:

Web Docket: NRC-2016-0078 Entergy Operations, Inc., Waterford Steam Electric Station, Unit 3 Comment On:

NRC-2016-0078-0004 Entergy Operations, Inc; Waterford Steam Electric Station, Unit 3Document:

NRC-2016-0078-DRAFT-0001 Comment on FR Doc # 2018-18173 Submitter InformationName: Alan Harris Submitter's Representative:

Alan Harris Organization:

Entergy Louisiana, LLC and Entergy Operations Inc General Comment Docket ID NRC-2016-0074, Entergy's Comments are provide d in the uploaded file (252 comments total) for Generic Environmental Impact Statem ent for License Renewal of Nuclea r Plants, Supplement 59 - Regarding Waterford 3 Steam Electric Station, Unit 3 (Draft Report for Comment)

Attachments NRC-2016-0078 Comments on WF3 Draft GEIS Page 1 of 1 10/04/2018https://www.fdms.gov/fdms/getcontent?objectId=090000648379337d&format=xml&showorig=fals e

Supplement 59 Comments

- 1 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 1 iii 5 NA Change "Supplement 58" to "Supplement 59."

2 iii 20 NA Change "Entergy Louisiana" to "Entergy Louisiana, LLC

" which is the correct legal name.

3 1-6 26 1.10 Change "Appendix F

" to "Appendix B" since "Appendix F

" deals with SAMA and not Federal statutes. 4 1-6 36 1.11 Change "Entergy 2016a" to "Entergy 2016b" to be more specific that the information came from the Applicants Environmental Report.

5 2-5 15 2.2.2 Change "WF3 is owned and operated by Entergy Corporation and" to "WF3, owned by Entergy Louisiana, LLC and operated by Entergy Operations, Inc.," since the reference here to "Entergy Corporation" in this sentence is not appropriate.

6 2-6 N/A Table 2-1 For "Cooling System" under the "New Nuclear Alternative," change the "NRC 2014a" cited reference to "NRC 2014" to reflect how it's shown in the list of references in "Section 2.5."

7 2-7 5 - 6 2.2.2.1 Change "nuclear generation currently provides approximately 14 percent of electricity generation in Louisiana" to "in 2015 nuclear generation provided approximately 14 percent of electricity generation in Louisiana" since that would be consistent with how it's stated in Section 2.2.2 (page 2-5, lines 27

- 30). For installed capacity based on Section 2.2.2 (page 2

-5, lines 22

- 25), the 2015 net summer generating capacity for nuclear is shown as 8 percent.

8 2-11 38 & 44 2.2.2.4 Change "Entergy 2015IRP" to only "Entergy 2015" for consistency with how other references are shown in this chapter.

9 2-12 22 2.3.1 Change the "EIA 2016b" reference cited here to "EIA 2016d" based on the list of references in Section 2.5. "EIA 2016b" is associated with Louisiana's profile whereas "EIA 2016d" is associated with California's solar generating capacity.

10 2-12 25 2.3.1 Change "Bolinger and Seel 2016" to "Bolinger and Seel 201 5" for consistency with how it's listed in the Section 2.5 references.

11 2-13 7 2.3.2 Typo: Change "become" to "became."

Supplement 59 Comments

- 2 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 12 2-13 11 2.3.2 There is no "EIA 2015b" reference listed in the Section 2.5 references. Based on the Section 2.5 references, I believe it be "EIA 2015e" since this reference is associated with offshore wind.

13 2-14 8 2.3.4 Change "Entergy 2015IRP" to only "Entergy 2015" for consistency with how other references are shown in this chapter.

14 2-14 39 2.3.5 Change the "NRC 2013a" cited reference to "NRC 2013" to reflect how it's shown in the list of references in "Section 2.5."

15 2-17 18 2.3.12 Change "Entergy 2015IRP" to only "Entergy 2015" for consistency with how other references are shown in this chapter.

16 2-17 39 - 40 2.3.13 Change "Entergy 2015IRP" to only "Entergy 2015" for consistency with how other references are shown in this chapter.

17 2-20 NA Table 2-2 In "footnote i" change "St. Charles County" to "St. Charles Parish" since Louisiana does not have counties but instead parishes.

18 2-21 15 2.5 Remove this reference as it was not cited anywhere in Chapter 2.0.

19 2-22 1 - 4 2.5 The "DOE 2017b" reference was not cited anywhere in Chapter 2.0.

20 2-23 23 2.5 Change "Entergy 2015IRP" to only "Entergy 2015" for consistency with how other references are shown in Section 2.5 and in the Chapter 2.0 discussion.

21 3-2 NA Figure 3-1 Need to remove the "USCB 2014c, USDOT 2014 and USGS 2014a

" references since they came from WF3's environmental report and are not listed in the Section 3.14 reference list.

22 3-4 26 3.1.3.1 Either change "with" to "within" or delete "with the river." 23 3-4 27 3.1.3.1 Insert "in depth" after "(10.4 m)."

24 3-4 29 3.1.3.1 Delete "(16 ft)" since it is already shown on this line. 25 3-7 1 3.1.3.1 Need to add the "NRC 2017" cited reference to the list of references in Section 3.14 as it's currently not shown.

Supplement 59 Comments

- 3 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 26 3-8 29 3.1.3.1 Suggest removing "discharge" since the water is being withdrawn and it creates confusion.

27 3-16 36 3.1.4.3 Based on the 2014 WF3 ARERR, there were "15" shipments made. The number currently being shown is most likely associated with another plant.

28 3-16 36 3.1.4.3 Change "DCPP" to "WF3" since this is not the plant designation for Waterford 3. Also, recommend that "two" be changed to "three" since the EnergySolutions facilities in Utah and Tennessee would be separate licensed facilities.

29 3-18 7 3.1.5 Need to add "LAC 33:V" citation to the Section 3.14 list of references as it's not currently shown.

30 3-18 35 3.1.6.2 Since WF3 is a single unit, change "The WF3 nuclear units are" to "The WF3 nuclear unit is."

31 3-19 20 3.1.6.4 Change "Section 3.10.6" to "Section 3.10.5" as this section does not exist in the WF3 Draft SEIS.

32 3-19 25 & 29 3.1.6.4 Change "Entergy 2014FSAR" to "Entergy 2014a" for consistency with how it's shown in the Section 3.14 list of references.

33 3-21 NA Figure 3-5 Need to remove the "Entergy 2013a, ESRI 2014, USCB 2014c, and WF3 2009" references since they came from WF3's environmental report and are not listed in the Section 3.14 reference list.

34 3-23 5 3.2.1.3 Delete "and" so the sentence will flow better.

35 3-24 31 3.2.2 Change "Waterford 1 and 2" to "Waterford 1, 2 and 4" as there are three units

. 36 3-25 23 3.3.1 Change "Entergy 2016" to "Entergy 2016a" for consistency with how it's shown in the Section 3.14 list of references.

37 3-27 24 3.3.2 Need to add the "LAC 33:III.501" citation to the Section 3.14 list of references as it's currently now shown. 38 3-29 NA 3.3.2 As an observation, the "81 FR 68110

" cita tion in footnote 2 is not listed in the Section 3.14 list of references.

Supplement 59 Comments

- 4 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 39 3-31 5 - 12 3.3.3 In the Section 3.14 list of references, there is a "SCP Undated" shown that appears to coincide with the reference to Chapter 24 of Code, Parish of St. Charles.

The "SCP Undated" reference shown in Section 3.14 is not cited anywhere in the entire WF3 Draft SEIS. Should it be cited here somewhere in this discussion?

40 3-31 24 3.3.3 Need to add the "LP&L 1979" cited reference to the Section 3.14 list of references as it's currently not shown.

41 3-31 38 3.4.1 Change "Waterford" to "WF3."

42 3-34 NA Figure 3-7 Consider changing "Waterford Site" to "Waterford 3 Site" since Waterford 1, 2 and 4 are also located on this same property. 43 3-35 NA Figure 3-8 Consider changing "Waterford Site" to "Waterford 3 Site" since Waterford 1, 2 and 4 are also located on this same property.

44 3-36 3 Figure 3-9 Change "Entergy 2016" to "Entergy 2016a" for consistency with how it's shown in the Section 3.14 list of references.

45 3-37 12, 18 & 25 3.4.2 Change "Entergy 2016" to "Entergy 2016a" for consistency with how it's shown in the Section 3.14 list of references.

46 3-37 34 3.4.3 Insert a space between

"(3,950 km2)" and "of. 47 3-45 8 3.5.1.2 Change "Section 4.16.3" to "Section 4.16.3."

48 3-46 26 3.5.1.3 Change "EPA 2016" to "EPA 2016d" since this would be the correct cited reference based on the list of references shown in Section 3.14.

49 3-46 36 3.5.1.3 Change "LDEQ 2015a" to "LDEQ 2015b" since this would be the correct reference based on the Section 4.18 list of references. "LDEQ 2015a" is associated with the Section 401 WQC.

50 3-46 39 3.5.1.3 Delet e "including 9 internal outfalls (internal monitoring points)" since it could be misunderstood that WF3 has 22 outfalls based on the current wording and the fact that WF3 has 10 internal outfalls (refer to Table 3

-8 of the Draft SEIS).

Supplement 59 Comments

- 5 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 51 3-48 8 3.5.1.3 Change "Entergy 2016RAI" to "Entergy 2016b" only since it would be consistent with how it's shown in the Section 3.14 reference list.

52 3-50 NA Table 3-8 For the "Outfall 1001 Description," move the bottom two lines up to the previous sentence.

53 3-50 17 3.5.1.3 Change "EPA 2016c" to "EPA 2016e" since this would be the correct cited reference based on the list of references shown in Section 3.14.

54 3-51 30 3.5.1.3 Change "or intake" to "or discharge

." 55 3-51 36 3.5.1.3 Change "Entergy 2016RAI" to "Entergy 2016b" since it would be consistent with how it's shown in the Section 3.14 reference list.

56 3-52 37 3.5.2.1 There is no Figure 4 in Section 3.4.1. I believe the correct figure would be Figure 3

-9. 57 3-53 1 3.5.2.1 Would recommend deleting "near" since it appears to be out of place in this sentence.

58 3-53 21 & 28 3.5.2.3 Change "monitor" to "monitoring."

59 3-53 30 3.5.2.3 Change "radiological environmental operating" to "radioactive effluent release."

60 3-55 43 3.6.2 Need to add the "LP&L 1978" cited reference to the Section 3.14 list of references as it's currently not shown.

61 3-56 5 3.6.2 Need to add the "LP&L 1978" cited reference to the Section 3.14 list of references as it's currently not shown.

62 3-58 33 3.6.4 Change "occurs" to "exists" and "do not exist" to "have not been observed."

63 3-6 3 NA Table 3-9 Reference Sources:

(1) Need to add the "LP&L 1978" cited reference to the Section 3.14 list of references as it's currently not shown.

(2) Change "LNHP 2016sbp" for consistency with how it's shown in the Section 3.14 list of references.

64 3-66 31, 34, 35 & 43 3.7.2.2 Need to add the "LPL 1978" cited reference to the Section 3.14 list of references as it's currently not shown. For consistency on how it has previously been shown in other sections, show it as "LP&L 1978."

Supplement 59 Comments

- 6 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 65 3-67 4, 6, 8, &

14 3.7.2.2 Need to add the "LPL 1978" cited reference to the Section 3.14 list of references as it's currently not shown. For consistency on how it has previously been shown in other sections, show it as "LP&L 1978." "LP&L would be the correct designation for Louisiana Power & Light.

66 3-67 1 8 & 21 3.7.2.2 Change "LPL" to "LP&L" since this would be the correct designation for Louisiana Power & Light.

67 3-67 18 & 21 3.7.2.2 Change "WF" to "Waterford" since it is not shown in the Draft SEIS's acronym list.

68 3-69 NA Table 3-10 Footnote (d):

(1) Need to add the "LPL 1978" cited reference to the Section 3.14 list of references as it's currently not shown. For consistency on how it has previously been shown in other sections, show it as "LP&L 1978." "LP&L would be the correct designation for Louisiana Power & Light. (2) Change "WF1 and WF2" to "Waterford 1 and 2 since "WF" is not shown in the Draft SEIS acronym list.

69 3-69 NA Table 3-10 Reference Source: Need to add the "LPL 1978" cited reference to the Section 3.14 list of references as it's currently not shown. For consistency on how it has previously been shown in other sections, show it as "LP&L 1978." "LP&L would be the correct designation for Louisiana Power & Light.

70 3-70 3, 4, 9 & 27 3.7.2.2 Need to add the "LPL 1978" cited reference to the Section 3.14 list of references as it's currently not shown. For consistency on how it has previously been shown in other sections, show it as "LP&L 1978." "LP&L would be the correct designation for Louisiana Power & Light.

71 3-70 18 & 20 3.7.3 There is no "LDWF 2016" reference listed in the Section 3.14 references. Maybe it should be "LDWF 2016f" since this reference deals with LDWF's list of species by parish.

72 3-70 28 3.7.3 Change "WF1 and WF2" to "Waterford 1 and 2 since "WF" is not shown in the Draft SEIS acronym list.

Supplement 59 Comments

- 7 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 73 3-71 8 3.7.4 There is no "Nico et al. 2005

" reference listed in the Section 3.14 reference list. There is only a "Nico et al. 2016" reference listed in Section 3.14.

74 3-71 11 3.7.4 There is no "Nico et al. 20 13" reference listed in the Section 3.14 reference list. There is only a "Nico et al. 2016" reference listed in Section 3.14.

75 3-71 29 3.8 Change "Waterford" to "WF3."

76 3-74 43 & 45 3.8.1.2 Need to add the "LP&L 1979" cited reference to the Section 3.14 list of references as it's currently not shown.

77 3-76 3 3.9 May want to consider adding the "National Historic Preservation Act of 1966" to the list of references in Section 3.14.

78 3-76 13 3.9 May want to consider adding the "National Environmental Policy Act of 1969" to the list of references in Section 3.14.

79 3-76 15 3.9 Insert "site" after "WF3."

80 3-77 10, 18, 28 & 45 - 46 3.9.1 There is no "Neuman and Hawkins 2013" reference listed in the Section 3.14 references.

There is a "Neuman and Butler 1993" reference listed in Section 3.14, however this reference is not cited anywhere in the Draft SEIS.

81 3-78 4 - 5 3.9.1 There is no "Neuman and Hawkins 2013" reference listed in the Section 3.14 references. There is a "Neuman and Butler 1993" reference listed in Section 3.14, however this reference is not cited anywhere in the Draft SEIS.

82 3-79 14 3.9.2 Change "Entergy 2016" to "Entergy 2016a" since it would be consistent with how it's shown in the Section 3.14 reference list.

83 3-79 33 & 36 3.10.1 Change "Entergy 2016 ER" to "Entergy 2016a" since it would be consistent with how it's shown in the Section 3.14 reference list.

84 3-82 1 - 2 3.10.2 Difficult to determine based on Table 3-15 how the "12 percent" was determined for the Hispanic, Latino, or Spanish minority population.

85 3-83 5 3.10.2 Change "USCB 2017" to "USCB 2017c" since this would be the correct reference designation.

Supplement 59 Comments

- 8 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 8 6 3-86 NA Table 3-18 In "Footnote b" suggest inserting "(NASS 2014)

-" prior to "Table 7" to specify that this table came from the NASS 2014 reference and to avoid confusion on what's being shown in the footnote.

87 3-88 NA Table 3-20 Reference Source: Need to add the "EPA 2015" reference to the list of references in Section 3.14 as it's currently not shown.

88 3-93 1 3.11.5 Need to add "53 FR 43950" cited reference to the list of references in Section 3.14 as it's currently not shown.

89 3-95 16, 35 & 40 3.12.3 Need to specify if the "USCB 2017" cited reference is "USCB 2017a, b, c, d, e, or f)" since there are several different designations listed in the Section 3.14 references.

90 3-96 3 3.12.3 Need to specify if the "USCB 2017" cited reference is "USCB 2017a, b, c, d, e, or f)" since there are several different designations listed in the Section 3.14 references.

91 3-97 4 Figure 3-14 Need to specify if the "USCB 2017" cited reference is "USCB 2017a, b, c, d, e, or f)" since there are several different designations listed in the Section 3.14 references.

92 3-98 4 Figure 3-1 5 Need to specify if the "USCB 2017" cited reference is "USCB 2017a, b, c, d, e, or f)" since there are several different designations listed in the Section 3.14 references.

93 3-99 7 - 8 3.13.2 Need to add the "Pollution Prevention Act (Public Law 101-508) and Resource Conservation and Recovery Act of 1976, as amended (Public Law 94-580)" to the list of references in Section 3.14.

94 3-99 22 3.13.2 Need to add "40 CFR Part 110" to the lists of references in Section 3.14 as it's currently not shown. 95 3-99 34 - 35 3.14 The "10 CFR Part 61" reference is not cited anywhere in the Chapter 3.0 discussion.

96 3-99 36 - 37 3.14 The "10 CFR Part 71" reference is not cited anywhere in the Chapter 3.0 discussion.

97 3-100 13 - 14 3.14 The "49 CFR Parts 171

- 178" reference is not cited anywhere in the Chapter 3.0 discussion.

98 3-101 4 - 7 3.14 The "81 FR 999" reference is not cited anywhere in the Chapter 3.0 discussion.

Supplement 59 Comments

- 9 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 99 3-101 21 - 23 3.14 Need to separate the "ACOE Undated" reference from the "AEC 1973" reference.

100 3-103 4 - 6 3.14 The "ENSR 2005" reference is not cited anywhere in the Chapter 3.0 discussion.

101 3-107 13 - 15 3.14 The "LAC 33:III.23.5" reference is not cited anywhere in the Chapter 3.0 discussion.

102 3-109 30 - 31 3.14 Please note a previous comment regarding the "LDWF 2016f" reference. I believe it belongs in "Section 3.7.3 (page 3

-70, lines 18 and 20)."

103 3-111 24 3.14 Need to insert "2016" prior to "Mississippi" since it's shown as "Nature Conservancy 2016" in Section 3.8.1.2.

104 3-111 31 - 34 3.14 There is no "Nico et al. 2016" reference sited anywhere in the Chapter 3.0 discussion. There are references to a "Nico et al. 2005" (Section 3.7.4, page 3-71, line 8) and "Nico et al. 2013" (Section 3.7.4, page 3

-71 line 11) but these two references were not included in Section 3.14.

105 3-111 35 - 38 3.14 The "Neuman and Butler 1993" reference is not cited anywhere in the Chapter 3.0 discussion. There are references to "Neuman and Hawkins 2013" on pages 3

-77 (lines 10, 18, 28, 45) and 3

-78 (line 4).

106 3-111 39 - 41 3.14 The "NEI 2007" reference is not cited anywhere in the Chapter 3.0 discussion.

107 3-113 22 - 27 3.14 The "USCB 2017f" reference is not cited anywhere in the Chapter 3.0 discussion. It may be associated with the discussion in Section 3.12.3 (page 3-95, lines 16, 35 and 40), (page 3

-96, line 3), Figure 3-14 (page 3-97) or Figure 3

-15 (page 3-98). 108 3-116 12 - 15 3.14 Remove the "White and Prakken 20

-15" reference as it's not cited anywhere in the Chapter 3.0 discussion.

109 4-1 26 4.1 Need to add the "NRC 1996 and 1999" cited references to the Section 4.18 reference list as they are currently not shown.

Also, change "2013d" to "2013a" since this is the correct reference to the 2013 GEIS based on the Section 4.18 references.

Supplement 59 Comments

- 10 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 110 4-3 37 - 38 4.2.3.2 Delete the sentence "Because of their height, the cooling towers may require aircraft warning lights, which would be visible at night." The cooling tower s will be mechanical draft cooling towers based on Table 2

-1 of the Draft SEIS and will not be that high, and RBS's mechanical draft cooling towers do not require aircraft warning lights.

111 4-6 34 4.3.1.2 Need to add the "NRC 1996" reference citation to the Section 4.18 reference list as it's currently not shown. 112 4-8 9 4.3.3.1 The "NRC 2013b" cited reference is incorrect for construction lead times. Unsure which NRC reference in Section 4.18 would be correct here , maybe "IEA/OECD/NEA 2005."

113 4-8 22 4.3.3.1 Change "Section 3.2" to "Section 3.3" since Section 3.2 addresses land use and visual resources.

114 4-8 31 4.3.3.2 Change "Section 3.2.2" to "Section 3.3.3" since Section 3.2.2 addresses visual resources.

115 4-14 37 4.3.6.1 Need to add the "NREL 1997" reference citation to the Section 4.18 reference list as it's currently not shown. 116 4-15 11 4.3.6.2 Change "Section 3.2.2" to "Section 3.3.3" since Section 3.2.2 addresses visual resources.

117 4-14 2 4.3.6.1 Suggest inserting the following sentence after "alternative": "The NRC staff does not anticipate air quality impacts from the DSM component of this combination alternative."

118 4-19 33 4.5.3.1 1. Need to add the "LAC 33:IX.2515" citation to the Section 4.18 reference list as it's currently not shown.

2. The "LDEQ 2016" citation appears to be the wrong reference for this sentence as "LDEQ 2016" is associated with facilities subject to 316(b) based on the Section 4.18 reference list. Would recommend deleting.

119 4-22 38 4.5.5.1 Change "NPDES" to "LPDES

." 120 4-25 23 4.6.1.2 1. Change "Table 3

-A" to "Table 3

-1." 2. "Section "3.6.3" is not correct. It should be "Section 3.2.1.1" since "Table 3-1" is included in this section.

Supplement 59 Comments

- 11 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 121 4-26 35 4.6.2 Need to add the "NRC 2002" citation to the Section 4.18 reference list as it's currently not shown. 122 4-31 24 4.7.1.2 Change "NRC 2013" to "NRC 2013a" since that would be the correct designation for the 2013 GEIS shown in the Section 4.18 reference list.

123 4-40 3 1 4.7.1.2 Need to add the "40 CFR 122" reference citation to the Section 4.18 list of references.

124 4-40 33 4.7.1.2 Need to add the "40 CFR 122" reference citation to the Section 4.18 list of references.

125 4-43 5 4.7.1.3 Insert "IX" after prior to "Section." Also may want to include "Title 33, Environmental Regulatory Code, Part IX

, Water Quality

" in the Section 4.18 list of references."

126 4-43 28 - 35 4.7.1.3 Need to delete this paragraph based on the discussion on Page 3

-45 (Lines 31

- 36) and replace with the following:

"WF3 is authorized to discharge various wastewater (effluent) streams including return circulating water and plant

-site stormwater under LPDES permit No. LA0007374, issued to Entergy on August 1, 2017 by LDEQ (LDEQ 2017). The renewed LPDES permit for WF3 was issued pursuant to Entergy's submittal of a permit renewal application on March 30, 2015 (Entergy 2015b) that LDEQ accepted as administratively complete on April 15, 2015 (LDEQ 2015a). The permit is valid until September 30, 2022."

Also add the following reference to the Section 4.18 list of references:

"[LDEQ] Louisiana Department of Environmental Quality. 2015

a. Letter from N. Larsen, Environmental Project Specialist 3, Permits Application Administrative Review Group, to M. Chisum, Site Vice President, Entergy Operations, Inc. RE: Waterford 3 Steam Electric Station Administrative Completeness Determination. April 15, 2015. ADAMS Accession No. ML17037D302.

" 127 4-44 4 4.7.1.3 Delete "administratively continued" since WF3 has received the renewed permit in 2017 (see Comment 126).

Supplement 59 Comments

- 12 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 128 4-45 6 - 10 4.7.1.3 Revise paragraph as follows since WF3 was issued a renewed permit in 2017 (see Comment 126): As described above in LOE 1, LPDES permit No. LA0007374 was issued to Entergy on August 1, 2017 by LDEQ (LDEQ 2017). The renewed LPDES permit for WF3 was issued pursuant to Entergy's submittal of a permit renewal application on March 30, 2015 (Entergy 2015b) that LDEQ accepted as administratively complete on April 15, 2015 (LDEQ 2015a). The permit is valid until September 30, 2022.

The NRC staff assumes that the 2017 LPDES permit would assure that the discharge meets all State water quality standards and that LDEQ would consider any environmental changes in the river since 1998, such as increases in temperature from climate change.

129 4-46 28 4.7.1.3 Insert a parenthesis close symbol ")" after invertebrates.

130 4-47 8 4.7.1.3 Suggest inserting "only" prior to "a" to make the sentence clearer. 131 4-47 3 5 - 38 4.7.1.3 Draft SEIS has already stated that WF3 was issued a permit in 2017 (see Comment 126). The "Entergy 2016b" reference on Line 36 is also incorrect and should've have been "Entergy 2015b" since it's associated with the permit renewal application based on the Section 4.18 list of references.

The suggestion is to delete the following sentences:

In 2015, Entergy submitted an application to renew its LPDES permit (Entergy 2015b). LDEQ has not yet renewed the LPDES permit, and therefore, has not yet evaluated whether and what mitigation measures would be required for compliance with the current Phase II Rule. 132 4-50 35 4.8.1 Change "Appendix C.1" to "Appendix C" to be consistent with how it's shown throughout the Draft SEIS. This is the only place in the Draft SEIS where it's shown like this.

Supplement 59 Comments

- 13 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 133 4-52 14 4.8.1.1 Would suggest verifying that the "FWS and NMFS 2009" reference is correct for this statement since the reference document is associated with Gulf Sturgeon and does not mention spawning for pallid sturgeon. 134 4-56 1 4.8.1.1 Remove the parenthesis close ")" after "sturgeons."

135 4-57 34 4.8.1.3 Delete "cumulative effects" since it makes the sentence fragmented.

136 4-58 6 4.8.1.4 Change "NRC 1995" to "NRC 1981" which corresponds with WF3's FES based on the Section 4.18 list of references.

137 4-61 13 4.8.6 Suggest inserting a statement such as follows: "DSM would have no effect on Federally listed species and critical habitats."

138 4-61 20 4.8.6 Suggest inserting a statement such as follows: "DSM would have no effect on EFH." 139 4-63 23 4.9.2 Need to add the "NRC 2002b" cited reference to the Section 4.18 list of references as it's currently not shown.

140 4-63 31 4.9.3 Insert "plants" after "WF3."

141 4-64 26 4.9.5 Insert "plants" after "WF3." 142 4-64 40 4.9.6 Remove the parenthesis close ")" after "components."

143 4-66 37 4.10.3.1 Need to add the "Times

-Free Press 2015" cited reference to the Section 4.18 list of references as it's currently not shown.

144 4-67 5 4.10.3.1 Need to add the "Times

-Free Press 2015" cited reference to the Section 4.18 list of references as it's currently not shown.

145 4-6 7 18 & 28 4.10.3.2 Need to add the "Times

-Free Press 2015" cited reference to the Section 4.18 list of references as it's currently not shown.

146 4-67 38 & 42 4.10.4.1 Need to add the "NRC 1996" cited reference to the Section 4.18 list of references as it's currently not shown. 147 4-68 2 4.10.4.2 Remove "the" after 'be."

Supplement 59 Comments

- 14 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 148 4-68 16 & 19 4.10.5.1 Need to add the "NRC 1996" cited reference to the Section 4.18 list of references as it's currently not shown. 149 4-69 10 4.10.6.2 Remove "the" after 'be."

150 4-70 13 4.11.1.1 Need to add the "NIEHS 1999" cited reference to the Section 4.18 list of references as it's currently not shown.

151 4-71 30 4.11.1.2 Remove the word "current."

152 4-72 4 4.11.1.2 Change "CDC 2015a" to "CDC 2015" for consistency with how it's shown in the Section 4.18 list of references.

153 4-72 10 4.11.1.2 Change "NRC 2016" to "NRC 2016g" since this would be the appropriate reference based on the Section 4.18 list of references.

154 4-73 5 4.11.1.3 The reference to "and Section 4.11" appears to be incorrect. 155 4-73 21 4.11.1.3 Need to add the "10 CFR 54" citation to the Section 4.18 list of references as it's currently not shown. 156 4-74 33 4.11.1.3 Consider changing the number of SAMAs remaining for further evaluation after the initial screening to 74 to be consistent with the conclusions in Section F.8. The total number of SAMAs evaluated became 75 after one was added in response to an RAI.

157 4-77 39 4.11.1.3 Description of SAMA 8 should be, "Use fire water system as a backup source for diesel cooling." 158 4-81 24 - 25 4.12.1 Reword sentence as follows since impacts to aquatic resources were also SMALL as shown in Table ES-1 of the Draft SEIS

"The analyses of impacts for all environmental resource areas indicated that the impact from license renewal would be SMALL."

159 4-81 30 4.12.1 Change "4.11.1.2" to "4.11.1.3" since "Section 4.11.1.2" addresses microbiological hazards.

160 4-82 29 4.12.1 Suggest deleting "annually" since it insinuates that samples are collected only once per year.

161 4-83 28 4.12.2 Need to add the "NRC 1996" cited reference to the Section 4.18 list of references as it's currently not shown.

Supplement 59 Comments

- 15 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 162 4-85 N/A Table 4-19 Need to change the GEIS Section number for "Nonradioactive waste storage" from "4.11.1.4" to "4.11.1.5" which would be the correction section number in the GEIS.

163 4-85 N/A Table 4-19 In footnotes "a" and "b," need to change the "NRC 2014a" reference to "NRC 2014" to be consistent with how it's shown in the Section 4.18 list of references.

164 4-86 9 4.13.1 Need to change the "NRC 2014a" reference to "NRC 2014" to be consistent with how it's shown in the Section 4.18 list of references.

165 4-90 26 4.15.2.1 Need to add the "NRC 2002" cited reference to the Section 4.18 list of references as it's currently not shown. 166 4-92 21 4.15.3.1 Change "Table 3

-7" to "Table 3

-4" since this is the correct table showing emission sources.

167 4-93 NA Table 4-22 On "Footnote (b)" change "Table 3

-6" to "Table 3

-4" since this is the correct table showing emission sources. 168 4-93 7 4.15.3.1 Need to add the "NRC 2002" cited reference to the Section 4.18 list of references as it's currently not shown. 169 4-93 27 4.15.3.1 Change "Section 3.2.1" to "Section 3.3.2" since this section addresses WF3's emission sources. Section 3.2.1 addresses land use.

170 4-94 NA Table 4-23 Need to add the "NREL 1997" cited reference in Footnote (e) to the Section 4.18 list of references as it's currently not shown.

171 4-95 4 & 15 4.15.3.2 Change "EPA 2016" to "EPA 2016a" for consistency with how it's shown in the Section 4.18 list of references.

172 4-96 8 4.15.3.2 There is no "IPCC 2007c" reference shown in the Section 4.18 list of references. Maybe it should be "IPCC 2007b" which is shown in the Section 4.18 list of references.

173 4-97 26 4.15.3.2 Need to add the "Dale 1997" cited reference to the Section 4.18 list of references as it's currently not shown. 174 4-97 44 4.15.3.2 Change "EPA 2016" to "EPA 2016a" for consistency with how it's shown in the Section 4.18 list of references.

Supplement 59 Comments

- 16 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 175 4-97 45 & 48 4.15.3.2 Need to add the "NMFS 2016" cited reference to the Section 4.18 list of references as it's currently not shown.

176 4-98 38 4.15.3.2 Need to add the "Chen et al. 2011" and "Thuiller 2007" cited references to the Section 4.18 list of references as they are currently not shown.

177 4-98 44 4.15.3.2 Need to add the "Fraser et al. (2013)" cited reference to the Section 4.18 list of references as it's currently not shown.

178 4-99 32 4.15.3.2 Need to add the "Ganser et al. 2013" cited reference to the Section 4.18 list of references as it's currently not shown.

179 4-99 43 4.15.3.2 Need to add the "NCADAC 2013" cited reference to the Section 4.18 list of references as it's currently not shown.

180 4-100 26 4.15.3.2 Need to add the "DHS 2011" cited reference to the Section 4.18 list of references as it's currently not shown. 181 4-101 6 & 8 4.15.3.2 Need to add the "Coastal Louisiana Tribal Communities 2012" cited reference to the Section 4.18 list of references as it's currently not shown.

182 4-101 27 4.15.3.3 Change "EPA 2016" to "EPA 2016a" for consistency with how it's shown in the Section 4.18 list of references.

183 4-101 33 4.15.3.3 Need to add the "Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.)" cited reference to the Section 4.18 list of references as it's currently not shown.

184 4-104 25 4.16.1.2 Change "WF3" to "WF3's."

185 4-107 5 4.16.3.1 Should "Section 3.10.3" which is associated with housing and community services, be changed to "Section 3.10.2" which addresses demographic characteristics?"

186 4-114 16 4.16.5.3 Change "NPDES" to "LPDES" since this is LDEQ's designation.

187 4-114 16 4.16.5.3 The Draft SEIS does not contain a "Section 4.12.3.1."

188 4-114 18 4.16.5.3 Change "NPDES" to "LPDES" since this is LDEQ's designation.

Supplement 59 Comments

- 17 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 189 4-115 42 4.16.7 Based on Table 3

-11, change St. John the Baptist" to "Jefferson" and change "7" to "15."

190 4-116 9 4.16.7 Change St. John the Baptist" to "Jefferson

." 191 4-117 19 - 21 4.16.9 Reword sentence as follows since impacts to aquatic resources were SMALL and for historic resources would not adversely affect any known historic properties as shown in Table ES

-1 of the Draft SEIS:

"As previously discussed in this chapter, the analyses of impacts for all environmental resource areas (e.g., land, air, water, and human health) were determined to be SMALL." 192 4-118 1 4.16.10 Change "the WF3 license

" to "WF3 license renewal." 193 4-122 ------ 4.18 The references on the lines shown below were not cited anywhere in Chapter 4.0:

26 - 29 30 - 32 36 - 38 39 - 41 194 4-123 ------ 4.18 The references on the lines shown below were not cited anywhere in Chapter 4.0:

1 - 2 3 - 5 6 - 8 14 - 16 17 - 18 30 - 32 195 4-124 ------ 4.18 The references on the lines shown below were not cited anywhere in Chapter 4.0:

1 - 2 26 - 28 196 4-126 ------ 4.18 The references on the lines shown below were not cited anywhere in Chapter 4.0:

24 - 2 6 40 - 42 197 4-127 8 4.18 ADAMS Accession No. for the SAMA Round 2 RAIs should be ML17114A432.

Supplement 59 Comments

- 18 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 198 4-128 ------ 4.18 The references on the lines shown below were not cited anywhere in Chapter 4.0:

18 - 2 2 26 - 28 199 4-129 ------ 4.18 The reference on the lines shown below was not cited anywhere in Chapter 4.0:

7 - 8 200 4-130 11 4.18 Change "2015" to "2015b" as a result of a new reference being added (LDEQ 2015a) based on Comment 126 above.

201 4-131 ------ 4.18 The reference on the lines shown below was not cited anywhere in Chapter 4.0:

15 - 17 202 4-133 14 4.18 Change "2015a" to "2015b" to coincide on how it's cited in Section 4.7.1.2 (page 4

-31, line25).

203 4-133 ------ 4.18 The reference on the lines shown below was not cited anywhere in Chapter 4.0:

4 - 6 204 7-3 ------ Table 7-1 Just for your records, "Bruce Fielding" with the LDEQ Water Permits Division is no longer with the LDEQ and has been replaced by "Christa Clark."

205 B-1 19 B Need to add the "LDEQ Undated" cited reference to the Section B.3 list of references as it's currently not shown.

206 B-4 NA Table B-1 Need to add the five "LAC citations" to the Section B.3 list of references as they are currently not shown. 207 B-4 NA Table B-1 Need to add the "Tennessee Department of Environment and Conservation Rule 1200 10-32" citation to the Section B.3 list of references as it's currently not shown.

208 B-5 NA Table B-2 For the Hazardous Materials Certification Registration, change the number from "060115551059X" to "060618550383A" and the date from "June 30, 2018" to "June 30, 2019" since this permit has been renewed.

Supplement 59 Comments

- 19 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 209 B-6 NA Table B-2 In Footnote (a), change "in September" to "prior to the end of." Based on input from the site, the permit was expected to be issued in October; however, issuance of the permit has been delayed past October.

210 B-6 10 - 11 B.3 The "40 CFR Part 122

" reference was not cited anywhere in Appendix B.

211 B-7 4 B.3 The "Fish and Wildlife Coordination Act of 1934" reference was not cited anywhere in Appendix B.

212 B-7 5 B.3 The "Marine Mammal Protection Act of 1972" reference was not cited anywhere in Appendix B.

213 C-5 10 - 14 C.6 The "FWS and NMFS 1998" reference was not cited anywhere in Appendix C. 214 E-2 NA Table E-1 Under the "Status" column for the "Waterford Steam Electric Station, Units 1 and 2" project, replace "comma" with a "semicolon" between "EIA 2016a" and "Entergy 2016a" for consistency with how this is done throughout Table E

-1 and the Draft SEIS.

215 E-2 NA Table E-1 For the "A.M. Agrigen Industries" project, change the "Griggs et. al. 2015" reference under the "Status" column to "Griggs et. al. 201 6" based on how it's shown in the Section E.2 list of references.

216 E-2 NA Table E-1 For the "Castleton Commodities International LLC" project, change the "Griggs et. al. 2015" reference under the "Status" column to "Griggs et. al. 2016" based on how it's shown in the Section E.2 list of references.

217 E-2 NA Table E-1 For the "Yuhuang Chemical Inc." project, change the "Griggs et. al. 2015" reference under the "Status" column to "Griggs et. al. 2016" based on how it's shown in the Section E.2 list of references.

218 E-3 NA Table E-1 For the "Williams Partners LP Ethane Cracker" project, change the "Griggs et. al. 2015" reference under the "Status" column to "Griggs et. al. 2016" based on how it's shown in the Section E.2 list of references.

Supplement 59 Comments

- 20 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 219 E-3 NA Table E-1 Under the "Status" column for the "ArcelorMittal Bayou Steel" project, replace "parenthesis symbol ")" with a "semicolon" between "Bloomberg 2016

" and "Entergy 2016c" for consistency with how this is done throughout Table E

-1 and the Draft SEIS.

220 E-3 NA Table E-1 Under the "Status" column for the "BeAed Corporation" project, insert a "semicolon" between "SCP 2017" and "Entergy 2016 b" for consistency with how this is done throughout Table E

-1 and the Draft SEIS.

221 E-4 NA Table E-1 For the "Monsanto" project, remove the parenthesis symbol "(" prior to "Entergy" under the "Status" column.

222 E-4 NA Table E-1 For the "Sunbelt" project, insert a space between "2016" and "(Entergy" under the "Status" column.

223 E-4 NA Table E-1 Under the "Status" column for the "Valero" project, replace the "semicolon" between "Entergy 2016b; 2016c" with a comma for consistency with how this is done throughout Table E

-1 and the Draft SEIS. 224 E-6 NA Table E-1 Under the "Status" column for the "Bayou Segnette State Park, replace the "comma" between "BTNEP 2016" and "LDCRT 2016" with a "semicolon" for consistency with how this is done throughout Table E

-1 and the Draft SEIS.

225 E-6 NA Table E-1 For the "Jean Lafitte National Historical Park

- Barataria Preserve," need to add the "NPS 2016" under the "Status" column to the Section E.2 list of references as it's currently not shown.

226 E-7 NA Table E-1 For the "Houma

-Thibodaux to LA

-3127 connection" project, change the "LaDOTD 2016" reference under the "Status" column to "LaDOTD 2015" based on how it's shown in the Section E.2 list of references.

227 F-2 18-19 F.2 Sections F.2.1 and F.2.2 are cited, but the information appears to be in sections F.3 and F.3.2. It appears from the numerous citations within the document that these sections were intended to be F.2.1 and F.2.2.

The numbering and citations for subsequent sections should also be confirmed.

Supplement 59 Comments

- 21 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 228 F-2 28 F.3 The word "This" is in a different font than the rest of the text.

229 F-4 Table F-2 M/L The Offsite Economic Cost Risk for Release Mode M/L should have an exponent; i.e. 1.6 x 10

2. 230 F-8 Table F-3 Note 1 Suggest changing reference to (Entergy 2016) to (Entergy 2017a). The statement in this note was provided in response to RAI 2.a in Entergy 2017a.

231 F-13 20 & 24 F.3.2.2 Lines cite (NRC 2012a) and (NRC 2012b). These references are not included in Section F.9.

232 F-17 20 F.3.2.3 Close parenthesis is missing at the end of the sentence. 233 F-25 37 F.4.2 Quotes are missing at the end of "Install an additional CCW pump.

234 F-26 33 & 36 F.5 Table F-5 is cited, but the associated table is F

-4. 235 F-26 42-43 F.5 The changes made to the model to quantify the impact of SAMAs are detailed in Section D.2.3 of Attachment D to the ER. 236 F-31 Table F-4 Case 7 PDR reduction for case 7 is shown to be 0.9% in (Entergy 2017a).

237 F-31 Table F-4 Case 10 Consider adding SAMA 49, Install automatic containment spray pump header throttle valves, with an implementation cost of $2,500,000 to the list of SAMAs evaluated in Case 10.

238 F-34 Table F-4 Case 27 Consider adding "diesel" at the end of the SAMA 51 description.

239 F-35 Table F-4 Case 28 Consider Adding SAMA 46, Increase depth of the concrete base mat

-, with an implementation cost of $10,000,000 to the list of SAMAs evaluated in Case 28. 240 F-38 Table F-4 Final item (Entergy 2011) is cited, but does not appear in Section F.9. Consider citing the revised NFPA

-805 LAR in (Entergy 2014b).

241 F-39 Table F-4 Note (c) Consider adding SAMA 11 and SAMA 41 to note (c). 242 F-40 2 F.6 Table F-5 is cited, but the associated table is F

-4. 243 F-40 6 F.6 (Entergy 2011) is cited, but does not appear in Section F.9. Consider citing the revised NFPA

-805 LAR in (Entergy 2014b).

Supplement 59 Comments

- 22 Entergy Comments to Draft Supplement 59 of the GEIS Item Page Line Section Comment 244 F-42 28 F.7.1.2 Citation (Entergy 2011) should be Entergy (2016).

245 F-44 20 F.7.1.5 Table F-5 is cited, but the associated table is F

-4. 246 F-44 27 F.7.1.5 Description of SAMA 8 should be, "Use fire water system as a backup source for diesel cooling."

247 F-46 37 F.8 Table F-5 is cited, but the associated table is F

-4. 248 F-46 43 F.8 SAMA 177 should be SAMA 77.

249 F-48 25 & 29 F.9 Quotes are missing at the end of the reference's subject. 250 F-49 41 F.9 Quotes are missing at the end of the reference's subject. 251 F-50 4, 9 & 13 F.9 Quotes are missing at the end of the reference's subject. 252 F-9 11 F.3.2.1 Change section reference from "F.2.2.2" to "F.3.2.2".