ML24240A023
| ML24240A023 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/20/2024 |
| From: | Stephen Koenick NRC/NMSS/DREFS/EPMB1 |
| To: | Gerfen P Pacific Gas & Electric Co |
| Shared Package | |
| ML24240A017 | List: |
| References | |
| EPID L-2023-LNE-0004 | |
| Download: ML24240A023 (1) | |
Text
Supplemental Environmental Impact Statement Scoping Process
Summary Report
Diablo Canyon Nuclear Power Plant, Units 1 and 2 License Renewal Application San Luis Obispo County, California
September 2024
U.S. Nuclear Regulatory Commission Rockville, Maryland
Enclosure 1 Introduction
By letter dated November 7, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23311A154), Pacific Gas and Electric Company (PG&E) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for renewal of Facility Operating License Nos. DPR-80 and DPR-82 for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon), respectively, pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for renewal of operating licenses for nuclear power plants. Diablo Canyon is located in San Luis Obispo County, California. In its application, PG&E requested the renewal of the Diablo Canyon operating licenses for an additional 20-year period beyond their current expiration dates.
Therefore, the new expiration dates, if approved, would be November 2, 2044, and August 26, 2045, for Diablo Canyon Units 1 and 2, respectively.
The purpose of this report1 is to provide a concise summary of the determinations and conclusions reached, including the significant issues identified, related to the scope of the NRC staffs environmental review of the Diablo Canyon license renewal (LR) application, incorporating stakeholder input. This report briefly summarizes the issues identified by the environmental scoping process and is structured in four sections:
A. The Diablo Canyon Public Scoping Period B. The Scoping Process and Objective C. Summary of Comments Provided D. Determinations and Conclusions
Appendix A to this report contains a list of commenters on the scope of the NRC staffs environmental review, and Appendix B to this report contains an analysis of the comments received from those commenters during the scoping period.
A. The Diablo Canyon Public Scoping Period
The Diablo Canyon LR application and all other publicly available documents relevant to Diablo Canyon license renewal are available online in the NRCs ADAMS Public Documents collection at https://www.nrc.gov/reading-rm/adams.html. To begin the search, select Begin Web-based ADAMS Search. For problems with ADAMS, please contact the NRCs Public Document Room (PDR) reference staff by telephone at 1-800-397-4209 or 301-415-4737, or by email at PDR.Resource@nrc.gov. For additional information, please see https://www.nrc.gov/reactors/operating/licensing/renewal/applications/diablo-canyon.html. This public website includes application information, the license renewal review schedule, opportunities for public involvement, and other relevant information. Finally, documents related to the Diablo Canyon LR application are also available at the Federal rulemaking website, https://www.regulations.gov/, under Docket ID NRC-2023-0192.
PG&E included an environmental report (ER) as Appendix E to the Diablo Canyon LR application. PG&E prepared the ER in accordance with 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions, which contains the NRCs requirements for implementing the National Environmental Policy Act of 1969, as
1 The NRCs requirements for conducting the scoping process and for preparing a scoping summary report are at 10 CFR 51.29, Scoping-environmental impact statement and supplement to environmental impact statement.
2 amended (NEPA). The NRC staff conducted a scoping process to gather information, in addition to that in the ER, necessary to prepare a supplemental environmental impact statement (SEIS) to evaluate the environmental impacts of the proposed action of Diablo Canyon LR.
PG&E had previously submitted an LR application and ER for Diablo Canyon on November 23, 2009 (ML093340086). As part of its review of this prior application, in 2010, the NRC staff published in the Federal Register (FR) a notice of intent (NOI) to conduct the scoping process and solicited public comments (75 FR 4427) and subsequently reopened the scoping process in 2015 (80 FR 37664). The comments received during these periods are outlined in an environmental scoping summary report dated March 2016 (ML16077A091) and were considered as part of the NRC staffs environmental review at that time. The NRC staff granted PG&Es request to withdraw this prior application and all associated correspondence and commitments effective April 23, 2018 (83 FR 17688). To the extent that the scoping comments on the prior application remain applicable to the current LR application, the NRC staff considered them during the current scoping process.
B. The Scoping Process and Objectives
On January 24, 2024, the NRC staff published an NOI to conduct the scoping process and to prepare a SEIS for the Diablo Canyon LR application (89 FR 4631). The NOI informed the public about the NRC staffs intent to prepare the SEIS as a supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear PlantsFinal Report (LR GEIS), and provided the public with an opportunity to participate in the scoping process. Specifically, the NRC staff sought public comment on the appropriate scope of its environmental review and requested this input by February 23, 2024. In addition to written comments, oral comments were accepted at two public meetings. The first public meeting was held virtually on February 1, 2024, and the second public meeting was held in-person on February 8, 2024, in San Luis Obispo, California. All comments, both written and oral, were considered in the scoping process.
The scoping process provided an opportunity for members of the public to propose environmental issues to be addressed in the SEIS and to highlight public concerns and issues.
In accordance with 10 CFR 51.29(b), this scoping summary report provides a concise summary of the determinations and conclusions reached, including the significant issues identified. The objectives of the scoping process were to:
- Define the proposed action that is to be the subject of the SEIS.
- Determine the scope of the SEIS and identify the significant issues to be analyzed in depth.
- Identify and eliminate from detailed study issues that are peripheral or are not significant or which have been covered by prior environmental review.
- Identify any environmental assessments and other environmental impact statements that are being or will be prepared that are related to but are not part of the scope of the SEIS.
- Identify other environmental review and consultation requirements related to the proposed action.
3
- Indicate the relationship between the timing of the preparation of the environmental analyses and the Commissions tentative planning and decision-making schedule.
- Identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completion of the SEIS to the NRC and any cooperating agencies.
- Describe the means by which the SEIS will be prepared, including any contractor assistance to be used.
The NRC staffs determinations and conclusions regarding the above objectives are provided in Section D below.
C.Summary of Comments Provided
Table A-1 in Appendix A to this report provides a list of commenters who provided comment submissions (i.e., non-form letter submissions) during the scoping comment period, identified by name, affiliation (if stated), the assigned correspondence identification (ID) number, the comment source, and the ADAMS Accession Number of the source. The NRC staff reviewed each comment submission, including the public scoping meeting transcripts, to identify individual comments. Each comment was marked with a unique identifier consisting of the correspondence ID (specified in Table A-1) and a comment number. For example, Comment 3-1 refers to the first comment within the document with correspondence ID 3. This unique identifier allows each comment to be traced back to the source where the comment was identified. Comments were consolidated and categorized according to resource area or topic.
Table A-2 in Appendix A to this report identifies the distribution of comments received by resource area or topic.
A summary of the comments and the NRC staffs responses to the comments are provided in Appendix B to this report. Comments were grouped based on being in scope or out of scope, and comments with similar themes were further sub-grouped to capture the resources concerned. Each comment submittal was uniquely identified and when a submittal addressed multiple issues, the submittal was further divided into separate comments with tracking identifiers.
D. Determinations and Conclusions
(1) Define the proposed action
The NRCs Federal action is to decide whether to renew the operating licenses for Diablo Canyon for an additional 20 years.
(2) Determine the scope of the SEIS and identify the significant issues to be analyzed in depth
The environmental consequences related to the proposed action include: (1) impacts associated with Diablo Canyon continued operations and refurbishment activities similar to those that have occurred during the terms of the current licenses; (2) impacts of reasonable alternatives to the proposed action; (3) impacts from the termination of nuclear power plant operations and decommissioning after the license renewal term (with emphasis on the incremental effect caused by an additional 20 years of operation); (4) impacts associated with the uranium fuel
4 cycle; (5) impacts of postulated accidents (design basis accidents and severe accidents); (6) cumulative effects of the proposed action; and (7) resource commitments associated with the proposed action, including unavoidable adverse impacts, the relationship between short-term use and long-term productivity, and irreversible and irretrievable commitment of resources. The significant issues identified in this report will be considered in the development of the draft SEIS, in accordance with 10 CFR 51.29 and 10 CFR 51.70, Draft environmental impact statement general. The NRC staff also follows guidance in NUREG-1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Operating License Renewal, to ensure compliance with all applicable regulations and NRC policies and procedures.
The NRC staff delineated and grouped comments received according to resource area/topic (see Appendices A and B). The comments will be addressed in the SEIS, as appropriate, as discussed in Appendix B to this report. The NRC staff reviewed all comments received and categorized each as general in nature, outside of the scope of license renewal, or within the scope of license renewal. The NRC staff considered all relevant within-scope comments as part of this review. With respect to greenhouse gas emissions and climate change, the NRC staff will consider the impacts of the proposed action of Diablo Canyon LR on climate change as well as the impacts of climate change on environmental resources (e.g., air quality, water resources) that may be directly impacted by the proposed action. In addition, the NRC staff will describe, in Chapters 2 and 3 of the SEIS, the following topics generally mentioned in the scoping comments:
- Accidents-SAMAs
- Alternatives-No-Action
- Alternatives-Replacement Power
- Cumulative Impacts
- Ecology-Aquatic Resources
- Ecology-Terrestrial Resources
- Federal Protected Ecological Resources
- General Environmental Concerns
- Geologic Environment
- Historic and Cultural Resources
- Human Health-Nonradiological
- Human Health-Radiological
- Hydrology-Surface Water Resources
- Land Use and Visual Resources
- Meteorology and Air Quality
- Process-Licensing Action
- Process-NEPA
- Socioeconomics
- Uranium Fuel Cycle
- Waste Management-Radioactive Waste
(3) Identify and eliminate from detailed study issues that are peripheral or are not significant or that have been covered by prior environmental review
5 As noted in Appendices A and B to this report, the NRC staff received several comments that were either general in nature or otherwise outside the scope of the license renewal environmental review. These included comments from organizations and individuals generally in support of or in opposition to the proposed action of Diablo Canyon LR. Additionally, plant-specific design bases are not re-evaluated as part of license renewal. Site-specific environmental conditions are considered when originally siting nuclear power plants. This includes the consideration of meteorological and hydrologic siting criteria, including Probable Maximum Precipitation (PMP) criteria, as set forth in 10 CFR Part 100, Reactor Site Criteria.
NRC regulations also require that plant structures, systems, and components important to safety be designed to withstand the effects of natural phenomena, such as earthquakes and flooding, without loss of capability to perform their safety functions. Further, nuclear power plants are required to operate within technical specifications in accordance with the NRC operating license, including coping with natural phenomena hazards. The NRC conducts safety reviews prior to allowing licensees to make operational changes due to changing environmental conditions. Finally, the NRC evaluates nuclear power plant operating conditions and physical infrastructure to ensure ongoing safe operations through its Reactor Oversight Process. If new information about changing environmental conditions becomes available, the NRC will evaluate the new information to determine whether any safety-related changes are needed. In sum, the NRC staff will not consider or evaluate any issues in the SEIS that do not pertain to the staffs environmental evaluation or are beyond the scope of the license renewal review. Comments that have been designated as out of scope are identified in Appendix B to this report.
(4)Identify any related Environmental Assessments and Other Environmental Impact Statements
Previously completed environmental impact statements will be used in the preparation of the Diablo Canyon license renewal SEIS, as appropriate, including portions of the LR GEIS, Revision 0 (1996) (ML040690705, ML040690738); the LR GEIS, Revision 1 (2013)
(ML13107A023); and the LR GEIS, Revision 2 (2024) (ML24087A133). By letter dated March 9, 2022, PG&E submitted to the NRC an application for renewal of special nuclear material (SNM)
License No. SNM-2511 for the Diablo Canyon independent spent fuel storage installation for an additional 40 years (ML22068A189). The NRC staff is currently conducting an environmental review of that application in accordance with 10 CFR Part 51.
(5)Identify Other Environmental Review and Consultation Requirements
Concurrent with its NEPA review, the NRC staff is consulting with the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS), as appropriate, under Section 7 of the Endangered Species Act of 1973 (ESA) to evaluate the potential impacts of the proposed action of Diablo Canyon LR on endangered and threatened species and their critical habitat. Consistent with 36 CFR 800.8(c), the NRC staff is also consulting with affected Indian Tribes, the California Office of Historic Preservation, and the Advisory Council on Historic Preservation to fulfill its Section 106 obligations under the National Historic Preservation Act of 1966.
(6) Indicate the relationship between the timing of the preparation of environmental analyses and the Commissions tentative planning and decision-making schedule
The NRC staff plans to issue a draft SEIS for public comment in October 2024. The 45-day comment period will offer an opportunity for participants, such as the applicant; interested Federal, State, and local government agencies; Tribal governments; local organizations; and
6 members of the public to provide further input to the agencys environmental review process.
Comments on the draft SEIS will be considered in the preparation of the final SEIS, which the NRC staff anticipates issuing in June 2025. The NRC staff is completing its safety review and will document its safety findings in a safety evaluation report (SER), which is anticipated in June 2025. The findings in the SEIS and the SER will be considerations in the NRCs decision regarding whether to renew the operating licenses for Diablo Canyon for an additional 20 years.
(7) Identify any Cooperating Agencies
During the scoping process, the NRC staff did not identify any Federal, State, local or Tribal agencies as cooperating agencies for this SEIS.
(8) Describe the means by which the environmental impact statement will be prepared, including any contractor assistance to be used
Upon completion of the scoping process, the NRC staff will compile its findings in a draft SEIS.
The draft SEIS will be made available for public comment. Once the public comment period is complete, the NRC staff will revise the draft SEIS, as appropriate, and will prepare and publish a final SEIS. Finally, the NRC will prepare and provide a Record of Decision in accordance with 10 CFR 51.102 and 10 CFR 51.103. As a contractor to the NRC, Pacific Northwest National Laboratory is providing technical support throughout the development of the SEIS in addition to technical editing and document production tasks.
7 Appendix A
List of Commenters
Table A-1. Individuals Providing Comments During the Scoping Comment Period Commenter Affiliation Correspondence Comment ADAMS (if provided) ID Source Accession Number Schwarz, Robert 1-1 Email ML24025A140
Piper, Derrell 2-1 Email ML24025A154
Rochte, Tim 3-1 Email ML24029A290
Cochran, June 4-1 Email ML24031A640
Russom, Caren Ray Arroyo Grande 5-1 Email ML24035A001 City Council Marderosian, Ara Sequoia 6-1 Email ML24050A003 ForestKeeper Taylor, Edward 7-1 Email ML24037A329
Spotts, Richard 8-1 reg.gov ML24030A037
ZamEk, Jill 9-1 reg.gov ML24038A403
Winholtz, Betty 10-1 Email ML24040A000
Goetz, Tony 11-1 Email ML24040A001
Oakley, Benjamin 12-1 Email ML24040A002
Kravchinsky, Laird 13-1 Email ML24040A003
ZamEk, Jill 14-1 Email ML24041A001
Banks, Tony 15-1 Email ML24042A002
Nelson, Gene Californians for 16-1 Email ML24043A140 Green Nuclear Power Mercer, Kristen 17-1 Email ML24046A021
Becker, Linda 18-1 Email ML24046A022
Battat, Kathy 19-1 Email ML24047A097
Pomerantz, Ron 20-1 Email ML24047A098
Linney, Joan 21-1 Email ML24050A004
Taylor, Joan 22-1 Email ML24051A105
1 Commenter Affiliation Correspondence Comment ADAMS (if provided) ID Source Accession Number Hisasue, Carol 23-1 Email ML24052A363
Elvin, Mark U.S Fish & 24-1 Email ML24053A019 Wildlife Service Unknown Fission 25-1 reg.gov ML24046A079 Transition Martin, Ronald 26-1 Email ML24052A362
Weed-Pomerantz, Jane 27-1 Email ML24053A022
Pierson, Lucy 28-1 Email ML24053A415
Highfill, Debbie 29-1 Email ML24053A416
Everett, Patricia 30-1 reg.gov ML24054A003
Hafley-Kluver, Haila 31-1 reg.gov ML24054A004
Smith, Andrew American 32-1 Email ML24054A005 Nuclear Society Wells, Gerard 33-1 Email ML24054A016
Stewart, Jim 34-1 Email ML24054A110
Van Fleet, Linda 35-1 reg.gov ML24054A444
Ortiz-Legg, Dawn County of San 36-1 Email ML24054A848 Luis Obispo Howard, Dolores 37-1 Email ML24054A849
Abernathy, William 38-1 Email ML24054A850
Campbell, Bruce 39-1 Email ML24054A851
Campbell, Bruce 40-1 Email ML24055A002
Ullcott, John 41-1 Email ML24055A003
Feher, Rick 42-1 Email ML24055A004
Terwilliger, John 43-1 Email ML24056A001
Vujovich-LaBarre, MilaSierra Club 44-1 reg.gov ML24053A143
Bender, David 45-1 reg.gov ML24055A004
Brown, Tony Nuclear Energy 46-1 reg.gov ML24058A005 Institute Nelson, Chloe U.S. 47-1 reg.gov ML24058A006 Environmental Protection Agency
2 Commenter Affiliation Correspondence Comment ADAMS (if provided) ID Source Accession Number Kubitz, Kermit 48-1 reg.gov ML24058A007
Kohlen, Patricia 49-1 Email ML24108A053
McAdams, Allison Santa Ynez 50-1 Email ML24108A054 Band of Chumash Indians Gibbons, Tori yak tityu tityu 51-1 Email ML24109A029 yak tilhini Northern Chumash Tribe Russell, Amy Paso Robles 52-1 Meeting ML24108A145 and Templeton Transcript Chamber of Commerce Weisman, David Alliance for 52-2 Meeting ML24108A145 Nuclear Transcript Responsibility Kelvsen, Dylan International 52-3 Meeting ML24108A145 Brotherhood of Transcript Electrical Workers (IBEW) 639 Johnson, Jack IBEW 52-4 Meeting ML24108A145 Transcript ZamEk, Jill San Luis Obispo 52-5 Meeting ML24108A145 Mothers for Transcript Peace Alvarez, Renelle 52-6 Meeting ML24108A145 Transcript Harmon, Barbara Former Arroyo 52-7 Meeting ML24108A145 Grande Council Transcript Member Bohanna, Jordan IBEW 52-8 Meeting ML24108A145 Transcript Simental, Jason 52-9 Meeting ML24108A145 Transcript Brown, Mike 52-10 Meeting ML24108A145 Transcript Lathrop, Scott yak tityu tityu 52-11 Meeting ML24108A145 yak Tilhini tribe Transcript Johnson, Molly San Luis Obispo 52-12 Meeting ML24108A145 Mothers for Transcript Peace
3 Commenter Affiliation Correspondence Comment ADAMS (if provided) ID Source Accession Number Swanson, Jane San Luis Obispo 52-13 Meeting ML24108A145 Mothers for Transcript Peace Heller, Jeff 52-14 Meeting ML24108A145 Transcript Lewis, Sherry San Luis Obispo 52-15 Meeting ML24108A145 Mothers for Transcript Peace Ripley, Ellie 52-16 Meeting ML24108A145 Transcript Jordan, Randall Republican 52-17 Meeting ML24108A145 Party of San Transcript Luis Obispo County Baldwin, David Local 403 52-18 Meeting ML24108A145 Plumbers and Transcript Pipefitters Union Hoff, Heather Mothers for 52-19 Meeting ML24108A145 Nuclear Transcript Cooper, Gregg IBEW 639 52-20 Meeting ML24108A145 Transcript Conner, Vicki 52-21 Meeting ML24108A145 Transcript Seastrand, Andrea Central Coast 52-22 Meeting ML24108A145 Taxpayers Transcript Association Seeley, Linda San Luis Obispo 52-23 Meeting ML24108A145 Mothers for Transcript Peace Singh, Suzanne Santa Maria 52-24 Meeting ML24108A145 Valley Chamber Transcript of Commerce Whittaker, David 52-25 Meeting ML24108A145 Transcript Parks, Linda 52-26 Meeting ML24108A145 Transcript Triggs, Frank 52-27 Meeting ML24108A145 Transcript Dodd, Sylvia 52-28 Meeting ML24108A145 Transcript Hatcher, Lindy Home Builders 52-29 Meeting ML24108A145 Association of Transcript the Central Coast Burkhead, Elizabeth 52-30 Meeting ML24108A145 Transcript
4 Commenter Affiliation Correspondence Comment ADAMS (if provided) ID Source Accession Number Spinello, Nina Cuesta College 52-31 Meeting ML24108A145 Transcript Klay, Jennifer Mothers for 52-32 Meeting ML24108A145 Nuclear Transcript Highfill, Deb 52-33 Meeting ML24108A145 Transcript Medrano, Joshua Tri-Counties 52-34 Meeting ML24108A145 Building Trades Transcript Byrne, Peter 52-35 Meeting ML24108A145 Transcript Howell, Erik 52-36 Meeting ML24108A145 Transcript Duffy, Patrick IBEW 1245 52-37 Meeting ML24108A145 Transcript Rouleau, Joe 52-38 Meeting ML24108A145 Transcript Burnham, Chris IBEW 1245 52-39 Meeting ML24108A145 Transcript diPeri, Kathi 52-40 Meeting ML24108A145 Transcript Flom, Michele 52-41 Meeting ML24108A145 Transcript Becker, Linda 52-42 Meeting ML24108A145 Transcript Swanson, Jane San Luis Obispo 52-43 Meeting ML24108A145 Mothers for Transcript Peace Schalk, Vidya 52-44 Meeting ML24108A145 Transcript Rouleau, Joe 52-45 Meeting ML24108A145 Transcript Pease, Andy City of San Luis 53-1 Meeting ML24108A146 Obispo Transcript Boswell, Josh REACH 53-2 Meeting ML24108A146 Transcript Altergott, Randy 53-3 Meeting ML24108A146 Transcript Dantona, Jim San Luis Obispo 53-4 Meeting ML24108A146 Chamber of Transcript Commerce Hopf, James Generation 53-5 Meeting ML24108A146 Atomic Transcript Schroder, Madison Generation 53-6 Meeting ML24108A146 Atomic Transcript Osborne, Jenelle City of Lompoc 53-7 Meeting ML24108A146 Transcript
5 Commenter Affiliation Correspondence Comment ADAMS (if provided) ID Source Accession Number Bausch, Chris City of Paso 53-8 Meeting ML24108A146 Robles Transcript Kirkland, Gary 53-9 Meeting ML24108A146 Transcript Peschong, John San Luis Obispo 53-10 Meeting ML24108A146 County Transcript Bird, Peter Consultant to 53-11 Meeting ML24108A146 San Luis Obispo Transcript Mothers for Peace Mauer, Andrew Nuclear Energy 53-12 Meeting ML24108A146 Institute Transcript Baker, Sheila 53-13 Meeting ML24108A146 Transcript Severance, Bruce 53-14 Meeting ML24108A146 Transcript Robert, Robert City of Grover 53-15 Meeting ML24108A146 Beach Transcript Nunez, Guido 53-16 Meeting ML24108A146 Transcript Brennan, Jocelyn 53-17 Meeting ML24108A146 Transcript Brown, Marty 53-18 Meeting ML24108A146 Transcript McNally, Alice Coalition for 53-19 Meeting ML24108A146 Nuclear Safety Transcript Stewart, Jim 53-20 Meeting ML24108A146 Transcript Schmidt, Mark 53-21 Meeting ML24108A146 Transcript Lane, Thomas Local Union 403 53-22 Meeting ML24108A146 Transcript Arnold, Debbie County of San 53-23 Meeting ML24108A146 Luis Obispo Transcript Kasper, Benjamin 53-24 Meeting ML24108A146 Transcript Pauls, Karl 53-25 Meeting ML24108A146 Transcript Burnham, Chris 53-26 Meeting ML24108A146 Transcript Moreno, Heather City of 53-27 Meeting ML24108A146 Atascadero Transcript Bright, Karen City of Grover 53-28 Meeting ML24108A146 Beach Transcript Duffy, Patrick IBEW 1245 53-29 Meeting ML24108A146 Transcript
6 Commenter Affiliation Correspondence Comment ADAMS (if provided) ID Source Accession Number Greening, Eric 53-30 Meeting ML24108A146 Transcript Severance, Bruce 53-31 Meeting ML24108A146 Transcript Seely, Linda San Luis Obispo 53-32 Meeting ML24108A146 Mothers for Transcript Peace Adam, Peter 53-33 Meeting ML24108A146 Transcript Viola, Francesco 53-34 Meeting ML24108A146 Transcript Nelson, Gene 53-35 Meeting ML24108A146 Transcript Purcell, Leslie 53-36 Meeting ML24108A146 Transcript Lewis, Sherri San Luis Obispo 53-37 Meeting ML24108A146 Mothers for Transcript Peace Martin, Ronald 53-38 Meeting ML24108A146 Transcript Hoffman, Ace 53-39 Meeting ML24108A146 Transcript Taylor, Dee 53-40 Meeting ML24108A146 Transcript
Table A-2. Distribution of Comments by Resource Area or Topic Resource Area/Topic Number of Comments Received Accidents-SAMAs 3 Alternatives-No-Action 2 Alternatives-Replacement Power 32 Alternatives-System Design 2 Cumulative Impacts 1 Ecology-Aquatic Resources 21 Ecology-Terrestrial Resources 2 Environmental Justice 3 Federal Protected Ecological Resources 2 General Environmental Concerns 11 Geologic Environment 12 Greenhouse Gas Emissions and Climate Change 14 Historic and Cultural Resources 12 Human Health-Nonradiological 1 Human Health-Radiological 2
7 Resource Area/Topic Number of Comments Received Hydrology-Surface Water Resources 13 Land Use and Visual Resources 1 Meteorology and Air Quality 2 Opposition-Licensing Action 40 Outside Scope-Aging Management 25 Outside Scope-Emergency Preparedness 4 Outside Scope-Energy Costs 24 Outside Scope-Miscellaneous 10 Outside Scope-Need for Power 51 Outside Scope-Offsite Fuel Storage 1 Outside Scope-Other Non-LR Actions 15 Outside Scope-Safety 91 Outside Scope-Security 1 Process-Licensing Action 32 Process-NEPA 7 Socioeconomics 23 Support-Licensing Action 88 Uranium Fuel Cycle 1 Waste Management-Radioactive Waste 24
8 Appendix B
Analysis of Comments Received During the Scoping Period
B.1 Comments on the Resource Areas
B.1.1 Comments Concerning Accidents - Severe Accident Mitigation Alternatives (SAMAs)
Comment Summary: Commenters expressed concerns about the general consequences of many types of nuclear accidents and specifically accidents at Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon), including cost and loss of life.
Comments: (53-11-2) (53-39-3) (53-39-16)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the U.S. Nuclear Regulatory Commission (NRC) staffs review and analysis during the development of the draft supplemental environmental impact statement (SEIS) within the Postulated Accidents resource area and/or supplemental applicable areas.
B.1.2 Comments Concerning Alternatives - No-Action
Comment Summary: Commenters requested that the NRC staff evaluate both the environmental benefits and impacts of not renewing the licenses for Diablo Canyon.
Comments: (40-6) (53-6-3)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis of the no-action alternative in the draft SEIS.
B.1.3 Comments Concerning Alternatives - Replacement Power
Comment Summary: Commenters requested that the NRC staff address in the SEIS both the benefits and impacts of alternative energy sources that could be used to replace the power generated by nuclear power in general and by Diablo Canyon in particular. Commenters also noted that the analysis of replacement power alternatives should include renewable or sustainable energy options, energy-efficient measures, and energy storage options.
Comments: (3-2) (7-3) (11-4) (16-5) (19-6) (21-5) (32-6) (32-8) (46-7) (47-3) (52-9-2) (52-32-2)
(52-38-1) (52-38-3) (53-3-3) (53-4-1) (53-5-1) (53-13-3) (53-14-2) (53-14-6) (53-15-2) (53-16-3)
(53-16-5) (53-17-2) (53-19-9) (53-25-2) (53-26-3) (53-27-5) (53-36-12) (53-36-15) (53-37-3) (53-39-10)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis of replacement power alternatives in the draft SEIS.
1 B.1.4 Comments Concerning Alternatives - System Design
Comment Summary: Commenters expressed concerns related to the continued operation of Diablo Canyon Unit 1, and discussed considerations related to the potential operation of Unit 2 in isolation.
Comments: (53-14-3) (53-30-1)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the alternatives area and/or supplemental applicable areas.
B.1.5 Comments Concerning Cumulative Impacts
Comment Summary: A commenter requested that the NRC staff conduct a thorough analysis of other past, present, and reasonably foreseeable future cumulative actions potentially impacting the quality of the human environment, including both short-and long-term impacts and focusing on resources of concern.
Comments: (47-16)
Response: Consistent with the NRCs NEPA regulations (10 CFR Part 51), the NRC staff will analyze all of the environmental impacts that are reasonably foreseeable and have a reasonably close causal relationship to the proposed action. In Chapter 3 of the draft SEIS, the impacts of the proposed action will be analyzed in conjunction with other past, present, and reasonably foreseeable future actions at Diablo Canyon.
B.1.6 Comments Concerning Ecology - Aquatic Resources
Comment Summary: Several commenters expressed concern about the effect of Diablo Canyon on aquatic resources, including concerns regarding the plants once-through cooling system and proposed mitigations.
The U.S. Environmental Protection Agency (EPA) stated that the licensee should work with the Central Coast Regional Water Quality Control Board (CCRWQCB) to conduct new impingement and entrainment studies and incorporate ongoing entrainment monitoring during power plant intake operation, as well as consider implementing best available technology and identifying mitigation measures. The EPA also recommended that the draft SEIS describe aquatic habitats in the project area, evaluate impacts to aquatic resources in terms of the aerial or linear extent, and describe the types, location, and estimated effectiveness of best management practices to minimize and mitigate impacts to aquatic resources.
Comments: (6-3) (10-3) (14-6) (37-6) (39-5) (40-4) (44-3) (44-4) (44-5) (44-6) (47-6) (47-7) (52-5-3) (52-24-5) (53-16-2) (53-24-3) (53-30-2) (53-30-7) (53-32-7) (53-36-3) (53-36-4)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the aquatic resources area and/or supplemental applicable areas.
2 B.1.7 Comments Concerning Ecology - Terrestrial Resources
Comment Summary: A commenter provided recommendations for the draft SEIS regarding the prevention of invasive species and avoiding the use of pesticides and herbicides. Another commenter stated that limiting access to lands surrounding Diablo Canyon protects local wildlife.
Comments: (25-5) (47-9)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the terrestrial resources and/or supplemental applicable areas.
B.1.8 Comments Concerning Environmental Justice
Comment Summary: A commenter requested that the draft SEIS evaluate potential impacts to environmental justice (EJ) communities in accordance with Executive Orders 12898 and 14096.
Specific recommendations included the following:
- Include a robust environmental justice section to analyze potential disproportionate and adverse impacts to minority and low-income populations.
- Use EJScreen or other U.S. Census Bureau data to identify low-income and minority populations.
- Identify the presence of linguistically isolated populations and medically unserved areas.
- Supplement data with state and county level reports and local knowledge.
- Use specific guidance and resources to identify environmental justice communities and evaluate potential effects, including the report of the Federal Interagency Working Group on Environmental Justice and NEPA Committee titled, Promising Practices for EJ Methodologies in NEPA Reviews.
Another commenter expressed concerns regarding the effects of transportation and storage of radioactive waste on low-income communities and indigenous areas in Oregon, Idaho, and Utah.
Comments: (47-13) (47-20) (53-30-5)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the environmental justice resource area and/or supplemental applicable areas.
B.1.9 Comments Concerning Federally Protected Ecological Resources
Comment Summary: The U.S. Fish and Wildlife Service (FWS) recommended that the draft SEIS address threatened species documented in and adjacent to Diablo Canyon: the Southern Sea Otter and the California Red-Legged Frog. The comment submission from the FWS included an enclosure listing measures to avoid or minimize adverse effects to these species.
The FWS recommended the incorporation of these measures into the project description in the draft SEIS. See ML24053A019 to view the full text of the submission. The FWS also requested
3 that the draft SEIS include compensatory mitigation commensurate with the Services 2023 Mitigation Policy and the Endangered Species Act (ESA) Compensatory Mitigation Policy of no net loss to appropriately offset the adverse effects to the numbers, reproduction, distribution, and recovery of listed species. The FWS also offered to provide additional guidance as needed.
The EPA provided recommendations for draft SEIS content, including identification of species and critical habitat, locations of rare or special status plants, consistency with federal or state species protections, consultations with other agencies, mitigation measures, cumulative impacts to wildlife species, and the projects consistency with existing laws and regulations.
Comments: (24-1) (47-8)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the federally protected ecological resources area and/or supplemental applicable areas.
B.1.10 Comments Concerning General Environmental Concerns
Comment Summary: Several commenters expressed general concerns about public health and safety and environment impacts from continued operation of Diablo Canyon. Other comments noted environmental benefits from continued operation of Diablo Canyon and the good condition of the surrounding environment.
Comments: (13-6) (14-10) (52-6-1) (52-11-2) (52-11-3) (52-23-4) (53-17-3) (53-19-1) (53-31-2)
(53-36-1) (53-36-13)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS.
B.1.11 Comments Concerning Geologic Environment
Comment Summary: Commenters expressed concern and requested further description of the geologic environment at Diablo Canyon. Comments noted potential for seismic activity in the area, as the plant is located near geologic faults. Commenters requested that the draft SEIS consider the findings of an updated seismic assessment available for Diablo Canyon and consider the impacts of coastal erosion and landslides.
Comments: (13-2) (14-2) (20-2) (27-4) (34-2) (36-5) (44-13) (47-18) (52-13-1) (52-41-5) (53 1) (53-40-1)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the geologic environment resource area and/or supplemental applicable areas.
4 B.1.12 Comments Concerning Greenhouse Gas Emissions and Climate Change
Comment Summary: The EPA recommended that the NRC staff do the following in the draft SEIS:
- Include an analysis of greenhouse gas emissions and climate change impacts, consistent with the Council on Environmental Quality National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change.
- Discuss how climate change could potentially influence the proposed project area, and how the proposed license renewal could worsen, lessen, or potentially mitigate for these impacts.
- Consider anticipated changes to the watershed.
- Include a robust discussion of climate change and its potential effects on the proposed 20-year continuation of plant operations and Diablo Canyons impacts.
Other commenters expressed concern that shutdown of Diablo Canyon would cause an increase in greenhouse gas emissions due to the use of alternative power sources. Several commenters stated that nuclear power was not carbon-free. Other commenters expressed concern about the effects of climate change on Diablo Canyon. One commenter expressed concern regarding fossil fuel emissions related to the nuclear fuel cycle.
Comments: (25-2) (25-8) (32-5) (40-1) (41-4) (44-14) (47-15) (52-7-4) (52-39-2) (52-40-4) (53 1) (53-3-2) (53-36-7) (53-39-2)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the greenhouse gas emissions and climate change resource area and/or supplemental applicable areas. As part of its environmental review, the NRC staff will consider the impacts of the proposed action on climate change and climate change impacts on environmental resources that are affected by the proposed action. However, the impacts of climate change on the operations and safety of the facility are outside the scope of the NRCs license renewal review.
B.1.13 Comments Concerning Historic and Cultural Resources
Comment Summary: Attorney Tori Gibbons of the law firm Shute, Mihaly & Weinberger provided comments on the proposed action on behalf of the yak titu titu yak tiłhini (YTT)
Northern Chumash Tribe. These comments reiterated concerns explained in an in-person meeting with the NRC staff in February 2024. The YTT requested that the draft SEIS include updated anthropological research identifying the YTT as lineal descendants for the project site and that an agreement document be signed with the YTT regarding the further study and treatment of cultural resources within the Diablo Canyon lands. The comments included an ethnographic study done in 2020 by John R. Johnson of the Santa Barbara Museum of Natural History that demonstrated the YTTs cultural lineage to the area.
Comments: (51-1) (51-2) (51-3)
Response To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the historic and cultural resources area and/or supplemental applicable areas.
5 Comment Summary: The Santa Ynez Band of Chumash Indians provided comments on what the NRC staff should consider under the various federal laws and regulations pertaining to cultural resources and Tribal consultation. The Tribe requested an underwater archaeological survey for all areas that may have a ground disturbing component and requested to have a Tribal monitor present for all general ground-disturbing activities. The Tribe also stated that the NRC staff should consider all non-exhaustive methods of remediation prior to performing any excavation that could potentially impact cultural resources and should consider cumulative impacts at other project areas where remediation actions may take place. Lastly, the Tribe requested that all further communication be directed to Sam Cohen, Government Affairs and Legal Officer.
Comments: (50-1) (50-2) (50-3) (50-4) (50-5) (50-6)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the historic and cultural resources area and/or supplemental applicable areas.
Comment Summary: The EPA recommended that the NRC staff do the following in the draft SEIS:
- Identify and integrate Indigenous Knowledge into the draft SEIS analysis, as appropriate.
- Where available, include the collection of local and traditional knowledge concerning the affected environment, anticipated impacts from the project, and traditional hunting and land use patterns in the area.
- Possibly utilize CEQs Guidance for Federal Departments and Agencies on Indigenous Knowledge as a resource to address Indigenous Knowledge in the draft SEIS.
A commenter from the YTT Tribe stated that Diablo Canyon is sitting on one of their ancestral village sites. Another commenter stated that Diablo Canyon is located on land that was the ancestral home of the YTT Tribe.
Comments: (25-6) (47-22) (52-11-1)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the historic and cultural resources area and/or supplemental applicable areas.
B.1.14 Comments Concerning Human Health - Nonradiological
Comment Summary: One commenter stated that the temperature of the water around Diablo Canyon causes lung problems.
Comments: (52-40-5)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the
6 development of the draft SEIS within the human health-nonradiological resource area and/or supplemental applicable areas.
B.1.15 Comments Concerning Human Health - Radiological
Comment Summary: One commenter expressed concerns about the human health effects of radioactivity from Diablo Canyon. Another commenter stated that radiation doses from Diablo Canyon are less than one cross-country flight.
Comments: (52-40-3) (53-24-1)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the human health-radiological resource area and/or supplemental applicable areas.
B.1.16 Comments Concerning Hydrology - Surface Water Resources
Comment Summary: A commenter stated that the draft SEIS should include discussions on potential resource impacts and information on the Clean Water Act and associated requirements. Several commenters expressed concern about elevated temperature of water and salinity of water released into the ocean from the Diablo Canyon cooling system. Several commenters expressed concern that the State Water Resources Control Board has allowed waivers to the Clean Water Act for Diablo Canyon. One commenter expressed concern regarding contamination from radionuclides and heavy metals in the discharged cooling water.
One commenter expressed concern regarding sedimentation rates in the intake cove and the possibility of dredging operations.
Comments: (6-2) (6-4) (14-5) (14-7) (20-4) (25-4) (27-2) (37-5) (39-4) (44-2) (44-7) (47-5) (53-36-6)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the surface water resources area and/or supplemental applicable areas.
B.1.17 Comments Concerning Land Use and Visual Resources
Comment Summary: One commenter expressed concern that closing Diablo Canyon would require additional land to be used for energy production.
Comments: (25-3)
Response: To the extent that this comment falls within the scope of license renewal, this comment will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the land use and visual resources areas and/or supplemental applicable areas.
7 B.1.18 Comments Concerning Air Quality
Comment Summary: A commenter recommended that the draft SEIS address the characterization of existing air quality conditions in order to evaluate project impacts, evaluate whether proposed project activities could affect air quality, analyze mitigation measures, and address the timeframe for release of criteria pollutants during the license lifespan.
Another commenter stated that nuclear energy has the lowest lifecycle emissions among all energy sources.
Comments: (32-7) (47-14)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the air quality resource area and/or supplemental applicable areas.
B.1.19 Comments Concerning Process - NEPA
Comment Summary: Commenters requested that the environmental review for the proposed action of Diablo Canyon license renewal include a risk and benefit analysis; ensure clear articulation of the purpose and need, analyses, and potential impacts; and be completed in an efficient and timely manner.
Comments: (15-8) (25-1) (32-3) (36-4) (37-8) (47-2) (48-1)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS.
B.1.20 Comments Concerning Process - Licensing Action
Comment Summary: Commenters expressed appreciation and concern for the license renewal process for Diablo Canyon and associated public comment opportunities. These included perceived deviations from the license renewal process, technical difficulties with submitting scoping comments or participating in virtual meetings, and the general openness and extent of the NRCs process. One commenter expressed appreciation for the NRC's flexibility in postponing the adjournment of a public meeting so they could make comments. One commenter expressed concern regarding the Coastal Zone Management Act and required documentation.
Comments: (14-1) (15-9) (16-1) (16-2) (32-1) (32-9) (39-8) (39-11) (39-12) (40-3) (40-8) (41-11)
(44-1) (46-2) (47-1) (47-4) (47-21) (52-2-1) (52-5-1) (52-11-4) (52-28-1) (52-32-1) (52-33-1) (52-39-1) (52-41-4) (53-6-1) (53-19-7) (53-26-1) (53-27-1) (53-30-6) (53-39-12) (53-39-14)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS. The NRC staff appreciates feedback related to the public comment opportunities for this action and continually seeks to improve opportunities for public involvement.
8 B.1.21 Comments Concerning Socioeconomics
Comment Summary: Commenters called attention to the ongoing beneficial economic impacts associated with the continued operation of Diablo Canyon. These comments suggest that the continued operation of Diablo Canyon under renewed operating licenses would result in beneficial economic impacts in the affected area from continued property tax revenues that provide financial support for schools, worker incomes, and philanthropic support to local organizations. One commenter expressed concern that Diablo Canyon may have fewer jobs than people estimate. One commenter stated that the draft SEIS should note that PG&E's 2021 transportation study of level of service for local roadways was based on the decommissioning of the plant, not license renewal and continued operations.
Comments: (5-3) (7-7) (11-6) (12-2) (15-3) (15-6) (18-2) (36-2) (40-5) (44-15) (46-4) (46-6) (52-1-1) (52-7-3) (52-18-2) (52-23-2) (52-24-2) (52-29-4) (53-3-5) (53-4-2) (53-10-1) (53-27-8) (53-36-11)
Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the socioeconomics area and/or supplemental applicable areas.
B.1.22 Comments Concerning the Uranium Fuel Cycle
Comment Summary: One commenter expressed concern about uranium mining on indigenous lands.
Comments: (52-41-3)
Response: To the extent that this comment falls within the scope of license renewal, this comment will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the uranium fuel cycle resource area and/or supplemental applicable areas.
B.1.23 Comments Concerning Waste Management - Radioactive Waste
Comment Summary: The EPA recommended that the draft SEIS address impacts of waste generation, identify waste types and volumes as well as waste management plans for the proposed license renewal term, address federal hazardous waste requirements, discuss waste minimization, discuss worker and public health hazards from waste management,, disclose emergency response procedures, and describe measures to protect the public and workers from radiological exposure during offsite transportation.
Other commenters expressed concerns regarding radioactive waste storage and disposal. One commenter suggested launching waste into space.
Comments: (8-3) (13-4) (19-3) (20-5) (27-6) (28-1) (39-6) (41-10) (43-2) (47-10) (47-12) (49-2)
(49-4) (52-41-2) (52-41-6) (53-9-3) (53-13-2) (53-19-2) (53-32-4) (53-32-6) (53-36-2) (53-36-5)
(53-39-11) (53-39-13)
9 Response: To the extent that these comments fall within the scope of license renewal, these comments will be considered as part of the NRC staffs review and analysis during the development of the draft SEIS within the waste management resource area and/or supplemental applicable areas.
B.2 Non-Technical and Comments Outside the Scope of the Environmental Review
B.2.1 General Comments in Opposition to the Licensing Action
Comment Summary: Commenters expressed opposition to nuclear power, PG&E, or the proposed action of Diablo Canyon license renewal. The commenters cited various safety and environmental concerns and a preference for other energy sources.
A comment submission from the San Luis Obispo Mothers for Peace included an attachment titled, The Prudent Course on Continued Operation of Diablo Canyon Nuclear Power Plant:
Take the Offramp Now, by Peter Bradford. The attachment provides a critique of the California Public Utilities Commission regarding the extension of operations at Diablo Canyon pursuant to California Senate Bill 846. See ML24038A403 to view the full text of the submission.
Comments: (1-1) (4-2) (9-3) (9-9) (13-1) (17-1) (19-1) (20-1) (20-9) (21-2) (22-1) (22-4) (26-5)
(27-1) (27-8) (28-3) (28-5) (33-1) (33-5) (34-1) (41-6) (43-6) (44-16) (52-13-5) (52-15-1) (52 1) (52-40-7) (52-41-1) (53-13-1) (53-18-2) (53-19-10) (53-20-3) (53-30-8) (53-32-8) (53-38-1)
(53-39-1) (53-39-7) (53-39-9) (53-39-17) (53-40-3)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS.
B.2.2 General Comments in Support of the Licensing Action
Comment Summary: Commenters expressed support for nuclear power, PG&E, or the proposed action of Diablo Canyon license renewal. The commenters cited the clean energy provided by nuclear power, the safe operation of Diablo Canyon, and the positive impact on the community by PG&E and its employees.
Comments: (2-1) (5-1) (7-1) (7-6) (7-8) (11-1) (11-2) (11-10) (12-1) (12-3) (12-6) (15-1) (15-2)
(15-7) (15-10) (18-1) (18-4) (25-7) (32-2) (36-3) (38-1) (46-1) (46-3) (46-8) (52-3-1) (52-4-1) (52-6-2) (52-7-1) (52-7-6) (52-8-1) (52-9-3) (52-10-1) (52-14-1) (52-16-1) (52-17-1) (52-18-1) (52-18-3) (52-19-1) (52-20-1) (52-21-1) (52-22-1) (52-24-1) (52-24-6) (52-25-1) (52-27-1) (52-27-2)
(52-27-3) (52-28-3) (52-29-1) (52-29-5) (52-30-1) (52-31-2) (52-34-1) (52-35-1) (52-36-1) (52-37-1) (52-38-4) (52-39-3) (52-42-1) (52-44-1) (53-2-1) (53-3-1) (53-3-7) (53-4-4) (53-6-2) (53 3) (53-8-1) (53-9-1) (53-9-4) (53-10-2) (53-12-1) (53-14-4) (53-15-1) (53-15-3) (53-16-1) (53 6) (53-21-1) (53-22-1) (53-23-1) (53-27-2) (53-27-4) (53-27-9) (53-28-1) (53-29-1) (53-32-1) (53-33-2) (53-34-1) (53-35-3)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS.
10 B.2.3 Comments Concerning Issues Outside the Scope of the Environmental Review -
Comment Summary: Commenters expressed concern regarding emergency preparedness, such as transportation complications in an emergency evacuation, coordination of emergency procedures and security, or the adequacy of emergency plans.
Comments: (23-2) (41-2) (47-11) (49-6)
Response: Emergency planning and preparedness are safety matters that are part of the Diablo Canyon current licensing basis. The NRCs environmental review is confined to environmental matters relevant to the proposed action of license renewal. These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS.
B.2.4 Comments Concerning Issues Outside the Scope of the Environmental Review -
Miscellaneous
Comment Summary: Commenters expressed concerns over the management of previous events associated with Diablo Canyon or PG&E.
Comments: (6-6) (11-7) (11-8) (16-6) (17-3) (20-7) (27-7) (39-2) (39-9) (45-1)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS. However, comments germane to the NRCs work will be passed along to the appropriate NRC staff.
B.2.5 Comments Concerning Issues Outside the Scope of the Environmental Review -
Comment Summary: Several commenters expressed concern about aging components at Diablo Canyon or the ability to effectively manage aging during the license renewal period.
Multiple commenters specifically cited Diablo Canyon Unit 1 components as a concern.
A comment submission from the San Luis Obispo Mothers for Peace included an attachment titled, Embrittlement of Reactor Pressure Vessel at Diablo Canyon Unit 1 Poses an Unacceptable Safety Risk During Current and Extended Operation, by Dr. Digby Macdonald.
The attachment conveys concerns that Diablo Canyon Unit 1 poses an unreasonable risk to public health and safety due to serious indications of an unacceptable degree of embrittlement, coupled with a lack of information to establish otherwise. See ML24038A403 to view the full text of the submission.
Comments: (1-3) (1-4) (6-1) (9-8) (10-1) (17-4) (20-3) (21-3) (23-1) (27-3) (29-1) (33-3) (34-3)
(34-5) (35-1) (35-2) (37-4) (52-12-1) (52-13-2) (52-26-2) (53-14-1) (53-20-1) (53-31-1) (53 10) (53-39-8)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS. Aging management issues will be addressed in the NRC staffs safety review of the license renewal application. Other safety issues are addressed under the current licensing basis for Diablo Canyon.
11 B.2.6 Comments Concerning Issues Outside the Scope of the Environmental Review -
Safety
Comment Summary: Commenters expressed general concerns over the safety of nuclear power and the safety risks associated with natural events such as seismicity, and safety risks associated with aging plant components, including embrittlement. Other commenters expressed that they did not have any safety concerns associated with Diablo Canyon.
A comment submission from the San Luis Obispo Mothers for Peace included an attachment titled, PG&E Significantly Underestimates Seismic Risk to [Diablo Canyon], by Dr. Peter Bird.
The attachment conveys concerns that the risk of an earthquake-caused accident at Diablo Canyon has been significantly underestimated. See ML24038A403 to view the full text of the attachment.
Comments: (1-2) (1-5) (3-1) (4-1) (6-5) (7-4) (8-1) (8-2) (8-5) (9-7) (13-3) (13-5) (13-7) (14-3)
(14-4) (17-2) (19-2) (20-6) (20-8) (21-4) (22-3) (26-2) (27-5) (28-2) (28-4) (30-1) (31-1) (33-2)
(33-4) (37-1) (37-7) (39-1) (39-3) (39-7) (39-10) (40-9) (41-1) (41-3) (41-5) (41-7) (41-8) (41-9)
(42-1) (42-3) (42-4) (43-1) (43-3) (43-4) (44-8) (44-9) (44-10) (44-11) (44-12) (46-5) (47-17) (47-
- 19) (49-1) (49-3) (49-5) (49-7) (52-5-2) (52-9-1) (52-10-3) (52-11-5) (52-13-4) (52-15-3) (52 1) (52-23-3) (52-24-4) (52-28-2) (52-29-3) (52-31-1) (52-33-3) (52-40-2) (52-40-6) (52-45-1) (53-3-6) (53-14-5) (53-19-4) (53-20-2) (53-24-2) (53-25-1) (53-26-2) (53-27-6) (53-32-5) (53-36-8)
(53-36-9) (53-36-14) (53-39-4) (53-39-6) (53-39-15)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS. Aging management issues will be addressed in the NRC staffs safety review of the license renewal application. Other safety issues are addressed under the current licensing basis for Diablo Canyon.
B.2.7 Comments Concerning Issues Outside the Scope of the Environmental Review -
Security
Comment Summary: One commenter stated that Diablo Canyon has a high level of security.
Comments: (53-7-1)
Response: Diablo Canyon is subject to existing NRC requirements related to physical security as part of its current licensing basis. The NRCs regulations in 10 CFR Part 73, Physical Protection of Plants and Materials, provide requirements related to physical security. These requirements apply to all operating licenses including renewed operating licenses. The NRC staff will not consider this comment further in the draft SEIS because it is outside the scope of the staffs environmental review.
B.2.8 Comments Concerning Issues Outside the Scope of the Environmental Review -
Energy Costs
Comment Summary: Commenters expressed concern over the cost effectiveness and impacts on tax and ratepayers of nuclear power compared to alternative means of power generation and of repairing, replacing, or maintaining aging infrastructure in the license renewal period for Diablo Canyon. A commenter also expressed concern over the cost effectiveness of not
12 renewing the Diablo Canyon licenses. Several commenters stated that nuclear energy was more affordable than other options.
A comment submission from the San Luis Obispo Mothers for Peace included an attachment titled, Extended Operation of the Diablo Canyon Nuclear Plant: What will it cost and who will pay for it?, by Mark Cooper. The attachment communicates the authors perception that continued operations of Diablo Canyon places a large economic burden on energy consumers and impedes the growth of renewable energy alternatives. See ML24038A403 to view the full text of the submission.
Comments: (4-4) (6-8) (8-4) (9-2) (9-5) (10-2) (12-5) (14-9) (17-5) (19-5) (22-2) (26-4) (37-3)
(52-7-5) (52-13-3) (52-43-1) (53-3-4) (53-4-3) (53-17-4) (53-18-1) (53-19-3) (53-19-5) (53-27-7)
(53-32-2)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS. However, comments germane to the NRCs work will be passed along to the appropriate NRC staff.
B.2.9 Comments Concerning Issues Outside the Scope of the Environmental Review -
Need for Power
Comment Summary: Commenters questioned the need for nuclear power and whether there is sufficient electricity demand justifying the proposed action of Diablo Canyon license renewal, especially when considering other energy projects proposed in the region.
A comment submission from the San Luis Obispo Mothers for Peace included an attachment titled, California has enough power to keep the lights on without [Diablo Canyon], by Rao Konidena and Rakon Energy LLC. The attachment argues that California has enough power from other sources without the continued operation of Diablo Canyon and provides a critique of grid reliability planning data presented by the California Energy Commission. See ML24038A403 to view the full text of the submission.
Comments: (4-3) (5-2) (5-4) (6-7) (6-9) (7-2) (7-5) (9-1) (9-4) (9-6) (11-3) (11-5) (11-9) (12-4)
(14-8) (15-4) (15-5) (16-3) (16-4) (17-6) (18-3) (19-4) (21-1) (26-1) (26-3) (32-4) (36-1) (37-2)
(39-13) (40-2) (40-7) (42-2) (43-5) (52-5-4) (52-7-2) (52-10-2) (52-15-2) (52-24-3) (52-29-2) (52-33-2) (52-38-2) (53-7-2) (53-16-4) (53-17-1) (53-17-5) (53-19-8) (53-27-3) (53-33-1) (53-35-2)
(53-37-2) (53-37-4)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS. However, comments germane to the NRCs work will be passed along to the appropriate NRC staff.
B.2.10 Comments Concerning Issues Outside the Scope of the Environmental Review -
Other Non-License Renewal Actions
Comment Summary: Several comments address license renewal of, continued operations of, and construction of other nuclear power plants. Several comments pertain to events at nuclear power plants outside the United States. Some commenters expressed concern regarding State of California actions related to Diablo Canyon. Some commenters expressed concerns
13 regarding the responsibilities of the NRC outside of the proposed action of Diablo Canyon license renewal. One commenter expressed concern regarding other government agencies.
Comments: (34-4) (52-23-5) (52-23-6) (52-23-7) (52-23-8) (52-26-1) (52-33-4) (53-9-2) (53 6) (53-30-3) (53-32-3) (53-35-1) (53-37-1) (53-39-5) (53-40-2)
Response: These comments are outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS. However, comments germane to the NRCs work will be passed along to the appropriate NRC staff.
B.2.11 Comments Concerning Issues Outside the Scope of the Environmental Review -
Offsite Fuel Storage
Comment Summary: A commenter stated that the draft SEIS should analyze the risks of long-term offsite spent nuclear fuel storage.
Comments: (53-30-4)
Response: This comment is outside the scope of the NRC staffs environmental review and will not be discussed in the draft SEIS.
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