ML24155A084

Scoping Scoping Summary

ML24155A084
Person / Time
Site:	Browns Ferry
Issue date:	10/24/2024
From:	Sabet A, Jessica Umana NRC/NMSS/DREFS/ELRB
To:
References
Download: ML24155A084 (1)

Text

Environmental Impact Statement Scoping Process

Summary Report

Browns Ferry, Units 1, 2 and 3 Limestone County, Alabama

October 2024

U.S. Nuclear Regulatory Commission Rockville, Maryland A. Introduction

By letter dated January 19, 2024 (Agencywide Documents Access and Management System (ADAMS) Package No. ML24019A010), Tennessee Valley Authority (TVA) submitted an application for subsequent license renewal (SLR) of Renewed Facility Operating License Nos.

DPR-33, DPR-52, DPR-68 for Browns Ferry Nuclear Generating Plant, Units 1, 2 and 3 (Browns Ferry), to the U.S. Nuclear Regulatory Commission (NRC) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and Part 54 of Title 10 of the Code of Federal Regulations (10 CFR), Requirements for renewal of operating licenses for nuclear power plants.

The Browns Ferry site is located on the north shore of Wheeler Reservoir in Limestone County, Alabama, at Tennessee River Mile 294. The site is approximately 30 miles west of Huntsville, Alabama. It is 10 miles northwest of Decatur, Alabama, and 10 miles southwest of Athens, Alabama. In its application, TVA requests SLR for a period of 20 years beyond the date when the current renewed facility operating licenses expire. The SLRs would authorize TVA to operate Browns Ferry for an additional 20 years beyond the period specified in each of the current licenses. The current operating licenses for Browns Ferry expire as follows: Unit1 on December 20, 2033, Unit 2 on June 28, 2034, and Unit 3 on July 2, 2036.

The purpose of this report is to provide a concise summary of the determination of the scope of the NRC staffs environmental review of this application, incorporating stakeholder inputs. This report will briefly summarize the issues identified by the environmental scoping process associated with the NRC staffs review of TVAs SLR application.

This report is structured in four sections:

A. The Browns Ferry Public Scoping Period B. Scoping Process and Objectives C. Summary of Comments Provided D. Determinations and Conclusions

A. The Browns Ferry Public Scoping Period

Background

The TVA application and all other public documents relevant to Browns Ferry SLR are available in the NRCs Web-based ADAMS, which is accessible at http://www.nrc.gov/reading-rm/adams.html. Persons who encounter problems in accessing documents in ADAMS should contact the NRCs Public Document Room (PDR) reference staff by telephone at 1-800-397-4209 or 301-415-4737, or by e-mail at pdr.resource@nrc.gov.

For additional information, the NRC staff has made available a web site with specific information about the Browns Ferry SLR application at https://www.nrc.gov/reactors/operating/licensing/renewal/applications/browns-ferry-subsequent.html. This web site includes application information, the licensing review schedule, opportunities for public involvement, project manager information, and other relevant information. In addition, documents, including public comments, are available at the Federal rulemaking web site, https://www.regulations.gov/, under Docket ID NRC-2024-0030.As part of its application, TVA submitted an environmental report (ER) to the NRC, available at ML24023A476. TVA prepared the ER in accordance with10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions, which contains

2 NRCs requirements for implementing the National Environmental Policy Act of 1969, as amended (NEPA).

Consistent with the Commissions direction, on January 9, 2023, TVA submitted a site-specific Environmental Report. On April 3, 2024, the NRC published a notice of intent to conduct a scoping process and prepare a site-specific environmental impact statement (EIS) (89 FR 23056). Consistent with Commission Legal Issuance (CLI)-22-03, the SLR application contained an ER in which the impacts of all environmental issues were evaluated on a site-specific basis, and the NRC staff initiated a review to address the impacts for all such issues during the SLR period in a site-specific EIS. The NRC staff stated in the original notice of intent that it would first conduct a scoping process for the site-specific EIS and then prepare a draft site-specific EIS for public comment. During the 30-day scoping period, the NRC received comments through written correspondence and two public meetings.

On August 6, 2024, the NRC published a final rule (89 FR 64166) revising its environmental protection regulations in 10 CFR Part 51, "Environmental protection regulations for domestic licensing and related regulatory functions." The final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power plant for up to an additional 20 years for either an initial license renewal or one period of SLR. Revision 2 to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS) (ADAMS No. ML24087A133) provides the technical basis for the final rule. The revised LR GEIS supports the updated list of environmental issues and associated environmental impact findings contained in table B-1 in appendix B to subpart A of the revised 10 CFR Part 51 for both initial license renewals and one period of SLR. The final rule was updated with a correction to appendix B of subpart A on August 21, 2024 (89 FR 67522).

The final rule became effective 30 days after its publication in the Federal Register (FR), on September 5, 2024, and the staff must now consider the new and modified issues and environmental impact findings, as applicable, in its license renewal EISs. Accordingly, as noticed (89 FR 84401), the NRC staff intends to prepare a plant-specific supplement to the LR GEIS for the Browns Ferry SLR application. In contrast to the previously planned site-specific EIS, the SEIS will rely on the LR GEIS determinations for Category 1 (generic) issues that apply to all or a distinct subset of nuclear power plants. Site-specific information will be considered only for Category 2 (site-specific) issues and will be screened for new and significant information on Category 1 issues.

The NRC staff conducted a scoping process to gather information necessary to prepare a site-specific EIS to evaluate the environmental impacts of SLR for Browns Ferry. The subsequent renewed operating licenses would authorize the applicant to operate Browns Ferry for an additional 20 years beyond the period specified in the current licenses.

The NRC staff has determined that the original scoping period conducted for a site-specific EIS review is sufficient to include any comments that would have been submitted for a SEIS that relies on site-specific determinations for Category 2 issues and on the LR GEIS generic determinations for Category 1 issues; therefore, an additional scoping period will not be conducted. All information submitted during the 30-day scoping period that began April 3, 2024, will be considered and evaluated as appropriate during the development of the staffs SEIS for the Browns Ferry SLR. When issued, the draft SEIS will be made available for public comment in accordance with 10 CFR 51.73.

3 B. Scoping Process and Objectives

On February 8, 2024, the NRC published an FR notice describing the scoping process for the Browns Ferry SLR application environmental review (89 FR 23056). This notice notified stakeholders about the NRC staffs intent to prepare a site-specific EIS and provided the public with an opportunity to participate in the environmental scoping process. The notice invited members of the public to submit written comments by May 3, 2024. In addition to written comments, oral comments were recorded at two public meetings. The public meetings were held on April 11 and 18, 2024, and both were virtual. All comments, both written and oral, were considered in the agencys scoping process.

The scoping process provided an opportunity for members of the public to propose environmental issues to be addressed in the Browns Ferry EIS and to highlight public concerns and issues. In accordance with 10 CFR 51.29(b), this scoping summary report provides a concise summary of the determinations and conclusions reached because of the scoping process. The objectives of the scoping process were to:

• define the proposed action, which is to be the subject of the Browns Ferry EIS,

• gather data on the scope of the EIS and identify the significant issues to be analyzed in depth,

• identify and eliminate from detailed study those issues that are peripheral or are not significant or were covered by prior environmental review,

• identify any environmental assessments and other EISs that are being or will be prepared that are related to, but are not part of, the Browns Ferry EIS,

• identify other environmental review and consultation requirements related to the proposed action,

• indicate the relationship between the timing of the preparation of the environmental analyses and the Commissions tentative planning and decision-making schedule,

• identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completing the Browns Ferry EIS to the NRC and any cooperating agencies, and

• describe how the Browns Ferry EIS will be prepared, including any contractor assistance to be used.

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

C. Summary of Comments Provided Table A-1 provides a list of commenters who provided comment submissions (i.e., non-form letter submissions) identified by name, affiliation (if stated), the correspondence identification (ID) number, the comment source, and the ADAMS Accession Number of the source. The staff reviewed each comment submission, including the public scoping meeting transcripts, to identify individual comments. Each comment was marked with a unique identifier consisting of the correspondence ID (specified in Table A-1) and a comment number. For example, Comment 3-1 refers to the first comment within the document provided by correspondence ID 3. This unique identifier allows each comment to be traced back to the source where the comment was identified.

Comments were consolidated and categorized according to a resource area or topic. Table A-2 identifies the distribution of comments received by resource area or topic.

4 A summary of the comments and the NRC staffs responses are provided in appendix B to this report. Comments were grouped based on being in scope or out of scope of an environmental review for SLR, and comments with similar themes were further sub-grouped to capture the resources concerned. Each comment submittal was uniquely identified, and when a submittal addressed multiple issues, the submittal was further divided into separate comments with tracking identifiers.

D. Determinations and Conclusions (1) Define the proposed action

The NRCs proposed action in this instance is to determine whether to renew the Browns Ferry operating licenses for an additional 20 years.

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

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

The significant issues identified in this scoping report will be considered in the development of the draft Browns Ferry EIS in accordance with 10 CFR 51.29, Scoping-environmental impact statement and supplement environmental impact statement, and 10 CFR 51.70, Draft environmental impact statement-general. The NRC also follows guidance in NUREG-1555, Supplement 1, Revision 2, Standard Review Plans for Environmental Reviews for Nuclear Power Plants (ADAMS No. ML23201A227) to ensure compliance with all applicable regulations and NRC policies and procedures.

The NRC staff delineated and grouped comments according to resource area/topic (see appendix B). The comments will be addressed in the plant-specific supplement to the LR GEIS, as appropriate, as discussed in appendix B to this report.

The NRC staff reviewed all comments received and categorized each as general in nature, outside scope (beyond the scope of the SLR environmental review), or in-scope (the comment is applicable to the environmental review). The NRC staff considered all relevant in-scope comments as part of this review and has determined that the significant issues identified during the scoping period include the following areas: Greenhouse gas emissions and climate change, historic and cultural resources, and hydrology-surface water resources.

Greenhouse Gas Emissions and Climate Change

The NRC staff received comments regarding the effects of climate change, including major storm events, flooding, drought, and wildfire. It was recommended that the EIS include an

5 evaluation of climate-related impacts as well as discussion of efforts that the applicant is taking to address and adapt to potential climate impacts.

These comments will be considered as part of the NRC staffs technical review and analysis during the development of the EIS 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 safety of operations and safety of the facility are outside the scope of the environmental review.

Historic and Cultural Resources

The NRC staff received comments related to historic and cultural resources from consulting parties in response to the environmental scoping process and the NRC's letter initiating National Historic Preservation Act (NHPA) Section 106 consultation. These parties are the Advisory Council on Historic Preservation (ACHP), the Choctaw Nation of Oklahoma, and the Chickasaw Nation. The ACHP identified specific regulatory requirements for complying with NHPA Section 106 via the NEPA process and encouraged the NRC to review NEPA and NHPA: A Handbook for Integrating NEPA and Section 106. The Chickasaw Nation accepted the invitation to consult under NHPA Section 106 and expressed support for the proposed undertaking. The Choctaw Nation of Oklahoma indicated that Limestone County, Alabama is outside their area of historic interest.

The NRC staff is conducting NHPA Section 106 compliance through NEPA in accordance with 36 CFR 800.8(c). These comments will be considered as part of the NRC staffs technical review and analysis during the development of the EIS within the historic and cultural resource area and/or supplemental applicable areas.

Hydrology - Surface Water Resources

The NRC staff received comments regarding surface water resources, including flood hazard and temperature effects from upstream waste heat discharging operations, particularly in combination with observed and projected impacts from climate change. With regard to the National Pollutant Discharge Elimination System regulations, a commenter recommended that the EIS should discuss a water balance analysis and provide additional information from past studies. The commenter also recommended that information regarding Clean Water Act Section 404(b)(1), as well as a discussion regarding the potential significant impacts to state and federal resources, should be included in the EIS.

These comments will be considered as part of the NRC staffs technical review and analysis during the development of the EIS within the surface water resource area and/or supplemental applicable areas. However, consideration of potential impacts of climate change and associated events, such as storms and flooding, on structures, systems, and components of nuclear power plants is outside the scope of the NRC's environmental review and will not be discussed in the EIS. Safety concerns including storms, flooding, and other weather events that could affect day-to-day operations are addressed separately under the NRC's ongoing reactor licensing and oversight programs. The Safety Evaluation Report, a separate document prepared by the NRC staff, addresses the effects of weather on the nuclear power plant to the extent additional consideration is needed for the period of extended operation.

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

• Accidents - SAMAs

• Cumulative Impacts

• Environmental Justice

• Human Health - Radiological

• Waste Management - Radioactive Waste

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

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

The NRC staff received several comments that were either general in nature or otherwise beyond the scope of the SLR environmental review. These included comments in opposition of the licensing action of the Browns Ferry SLR, aging management, and safety. Comments related to the license renewal process that expressed concerns regarding public participation for the Browns Ferry public scoping meeting and date inconsistencies in notifications regarding the public meeting have also been identified as peripheral in nature.

The NRC staff will not consider or evaluate any issues in the Browns Ferry EIS which do not pertain to the staffs environmental evaluation or are beyond the scope of the SLR review.

Comments that have been designated as out of scope are identified in appendix B as part of this report.

(4) Identify related environmental assessments and other environmental impact statements

The NRC staff did not identify any environmental assessments or environmental impact statements under preparation or soon to be prepared, which relate to, but are not within the scope of, the Browns Ferry EIS. Previously completed EISs will be used in the preparation of the Browns Ferry SLR EIS, as appropriate, including portions of NUREG-1437, Supplement 21, Generic Environmental Impact Statement for License Renewal of Nuclear Plants:

Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Final Report (ADAMS No.

ML051730443). In addition, the TVA Final EIS will be used to prepare the Browns Ferry SLR EIS.

(5) Other environmental review and consultation requirements

Concurrent with its NEPA review, the NRC staff is consulting with the U.S. Fish and Wildlife Service under Section 7 of the Endangered Species Act of 1973 to evaluate the potential impacts of the operation of Browns Ferry for an additional 20 years on endangered and threatened species and their critical habitat. Consistent with 36 CFR 800.8(c), the staff is also consulting with affected Indian Tribes, and the Alabama Historical Commission State Historic Preservation Office.

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

The NRC staff plans to issue a draft plant-specific supplement to the LR GEIS for public comment in April 2025. The 45-day comment period will offer an opportunity for participants,

7 such as the applicant; interested Federal, State, and local government agencies; Tribal governments; local organizations; and members of the public to provide further input to the agencys environmental review process.

Comments on the draft plant-specific supplement to the LR GEIS will be considered in the preparation of the final plant-specific supplement to the LR GEIS, which the NRC staff anticipates issuing in October 2025. The NRC staff has documented its safety review in a safety evaluation report (SER), and the SER is anticipated to be released in April 2025. The findings in the plant-specific supplement to the LR GEIS and the SER will be considered in the NRCs decision to issue or deny TVAs request for SLR of the Browns Ferry licenses.

(7) Identify Cooperating Agencies

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

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

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

The draft plant-specific supplement to the LR GEIS will be made available for public comment.

Once the public comment period is complete, the NRC staff will amend the draft EIS, as appropriate, and will prepare and publish a final EIS for Browns Ferry SLR.

The NRC staff will then prepare and provide a Record of Decision in accordance with 10 CFR 51.102 and 10 CFR 51.103.

8 Appendix A

List of Commenters

Table A-1. Individuals Providing Comments During the Scoping Comment Period Comment ADAMS Commenter Affiliation Correspondence ID Source Accession Number Kajumba, Environmental 1 Email ML24127A002 Ntale Protection Agency Paddock, 2-1 Meeting ML24123A157 Brian Transcript Safer, Don 2-2 Meeting ML24123A157 Transcript Paddock, 2-3 Meeting ML24123A157 Brian Transcript Hallman, Alabama 3-1 Meeting ML24123A162 Michael Department of Transcript Public Health Gordon, Alison U.S. Geological 4 Email ML24107B107 Survey Mangum, Advisory Council on 5 Email ML24131A029 Rachael Historic Preservation Denham Choctaw Nation of 6 Email ML24142A221 Downen, Oklahoma Karen John, Lisa The Chickasaw 7 Email ML24156A249 Nation

Table A-2. Distribution of Comments by Resource Area or Topic Resource Area/Topic Number of Comments Received Accidents - SAMAs 2 Cumulative Impacts 1 Environmental Justice 1 Greenhouse Gas Emissions and Climate Change 2 Historic and Cultural Resources 3 Human Health - Radiological 1 Hydrology - Surface Water Resources 3 Outside Scope - Opposition to the Licensing Action 1 Outside Scope - Aging Management 3 Outside Scope - Safety 5 Outside Scope - Licensing Action 3 Waste Management - Radioactive Waste 2

9 Appendix A

Analysis of Comments Received During the Scoping Period

A.1 Comments on the Resource Areas

A.1.1 Comments Concerning Accidents - Severe Accident Mitigation Alternatives (SAMA)s

Comment Summary: A commenter requested that the environmental impact statement (EIS) provide a detailed assessment of the environmental effects of serious accidents resulting in the release of radiation. The commenter questioned whether the 2013 License Renewal Generic Environmental Impact Statement (LR GEIS) and its analysis of probability weighed consequences provides an appropriate basis for analysis of severe accidents related to subsequent license renewals.

Comments: (2-2-3) (2-2-4)

Response: These comments will be considered as part of the Nuclear Regulatory Commission (NRC) staffs technical review and analysis during the development of the EIS within the SAMA resource area and/or supplemental applicable areas.

A.1.2 Comments Concerning Cumulative Impacts

Comment Summary: A commenter recommended that potential indirect and cumulative impacts of the proposed action be evaluated in the EIS. Specific types of impacts recommended for evaluation include radionuclides in surface water and groundwater, spent nuclear fuel storage, contaminant transport and deposition, stormwater, the impact of severe storm events affected by climate change, and analysis of communities with environmental justice concerns.

Comments: (1-1)

Response: To the extent that this comment falls within the scope of the environmental review for Subsequent License Renewal (SLR), it will be considered as part of the NRC staffs technical review during the development of the EIS and the cumulative effects analysis of the proposed agency action.

A.1.3 Comments Concerning Environmental Justice

Comment Summary: A commenter requested that the EIS discuss and evaluate potential impacts to environmental justice communities in accordance with executive orders (EO) 12898 and 14096. The recommended analysis would indicate whether minority, low income, tribal, and indigenous populations reside within the vicinity of the proposed project area. The commenter also recommended:

• including a current map depicting the population demographics near the facility in the EIS

• using specific guidance and resources to identify environmental justice communities and evaluate potential effects, including the report of the Federal Interagency Working Group

10 on Environmental Justice and National Environmental Policy Act (NEPA) Committee titled, "Promising Practices for EJ Methodologies in NEPA Reviews," the NEPAssist tool, and EJScreen

• that the NRC staff meaningfully involve potentially affected environmental justice communities throughout the decision-making process

Comments: (1-6)

Response: This comment will be considered as part of the NRC staffs technical review during the development of the EIS and the environmental justice impact analysis of the proposed agency action.

A.1.4 Comments Concerning Greenhouse Gas Emissions and Climate Change

Comment Summary: Commenters expressed concerns regarding effects of climate change, including major storm events, flooding, drought, and wildfire. A commenter recommended that the EIS include an evaluation of climate related impacts as well as discussion of efforts that the applicant is taking to address and adapt to potential climate impacts.

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

Response: To the extent that these comments fall within the scope of the environmental review for SLR, they will be considered as part of the NRC staffs technical review and analysis during the development of the EIS 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 safety of operations and safety of the facility are outside the scope of the environmental review.

A.1.5 Comments Concerning Historic and Cultural Resources

Comment Summary: The NRC staff received comments related to historic and cultural resources from consulting parties in response to the environmental scoping process and the NRC's letter initiating National Historic Preservation Act (NHPA) Section 106 consultation.

These parties are the Advisory Council on Historic Preservation (ACHP), the Choctaw Nation of Oklahoma, and the Chickasaw Nation. The ACHP identified specific regulatory requirements for complying with NHPA Section 106 via the NEPA process and encouraged the NRC to review NEPA and NHPA: A Handbook for Integrating NEPA and Section 106. The Chickasaw Nation accepted the invitation to consult under NHPA Section 106 and expressed support for the proposed undertaking. The Choctaw Nation of Oklahoma indicated that Limestone County, Alabama is outside their area of historic interest.

Comments: (6-1) (7-1) (5-1)

Response: The NRC is conducting NHPA Section 106 consultation through NEPA in accordance with 36 CFR 800.8(c). These comments will be considered as part of the NRC staffs technical review and analysis during the development of the EIS within the historic and cultural resource area and/or supplemental applicable areas.

11 A.1.6 Comments Concerning Human Health - Radiological

Comment Summary: A commenter explained that the environmental sampling conducted by the Alabama Department of Public Health (ADPH) at or near the Browns Ferry Nuclear Plant (Browns Ferry) has not presented any concerns regarding license renewal.

Comments: (3-1-1)

Response: This comment will be considered as part of the NRC staffs technical review and analysis during the development of the EIS within the human health resource area and/or supplemental applicable areas.

A.1.7 Comments Concerning Hydrology - Surface Water Resources

Comment Summary: A commenter expressed concerns regarding surface water resources, including flood hazard and temperature effects from upstream waste heat discharging operations, particularly in combination with observed and projected impacts from climate change. With regard to the National Pollutant Discharge Elimination System (NPDES) regulations, a commenter recommended that the EIS should discuss a water balance analysis and provide additional information from past studies. The commenter also recommended that information regarding Clean Water Act (CWA) Section 404(b)(1), as well as a discussion regarding the potential significant impacts to state and federal resources, should be included in the EIS.

Comments: (1-3) (1-4) (2-3-1)

Response: These comments will be considered as part of the NRC staffs technical review and analysis during the development of the EIS within the surface water resource area and/or supplemental applicable areas. However, consideration of potential impacts of climate change and associated events, such as storms and flooding, on structures, systems, and components of nuclear power plants are outside the scope of the NRC's environmental review and will not be discussed in the EIS. Safety concerns including storms, flooding, and weather events that could affect other day-to-day operations are addressed separately under the NRC's ongoing reactor licensing and oversight programs. The Safety Evaluation Report (SER), a separate document prepared by the NRC staff, addresses the effects of weather on the nuclear power plant to the extent additional consideration is needed for the period of extended operation.

A.1.8 Comments Concerning Waste Management - Radioactive Waste

Comment Summary: A commenter recommended that the EIS discuss and evaluate concerns regarding the effect of potential flooding and other storm events on waste storage, consider the potential for contamination of the environment as a result of flooding, and indicate whether any changes are anticipated in the generation of waste over the life of the program. The commenter also requested that the EIS indicate where the applicant will transport the spent nuclear fuel and spent fuel debris offsite for storage pending long-term disposal options.

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

Response: This comment will be considered as part of the NRC staffs technical review and analysis during the development of the EIS within the waste management and pollution prevention resource area and/or supplemental applicable areas. However, impacts of storm events and flooding on operations and safety of the facility are outside the scope of the environmental review.

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

A.2.1 Comments Outside Scope Concerning Opposition to the Licensing Action

Comment Summary: A commenter expressed general opposition to renewal of the operating licenses for Browns Ferry Nuclear Plant, citing safety and environmental risks.

Comments: (2-1-1)

Response: This comment is outside scope of the environmental review and will not be discussed in the EIS.

A.2.2 Comments Outside Scope Concerning Process - Licensing Action

Comment Summary: A commenter remarked that notifications for the scoping meetings should have been distributed earlier and requested information about how the scoping meetings were publicized. The United States Geological Survey (USGS) expressed appreciation for the opportunity to provide comments. The USGS had no comment at this time.

Comments: (1-7) (2-2-5) (4-1)

Response: These comments are outside the scope of the environmental review and will not be discussed in the EIS. The NRC staff appreciates this feedback about the timing of notifications announcing the public meetings and continually seeks to improve opportunities for public involvement.

A.2.3 Comments Outside Scope Concerning Aging Management

Comment Summary: A commenter expressed concern about aging components at the Browns Ferry Nuclear Plant and requested that the EIS characterize the current condition of the reactors and evaluate the ability to effectively manage aging during the period of extended operation.

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

Response: These comments are outside the scope of the environmental review and will not be discussed in the EIS. The NRC staff evaluates the applicant's aging management programs as part of the safety review of the subsequent license renewal application, which is separate from the environmental review. The Safety Evaluation Report, a separate document prepared by the NRC staff, will document the results of the safety review.

13 A.2.4 Comments Outside Scope Concerning Safety

Comment Summary: Commenters expressed concerns about the safety of nuclear power and the safety risks associated with climate change and onsite storage of high burnup fuel.

Commenters requested that the NRC reevaluate its approach to fully consider the effects of climate change during license renewals in light of the Governmental Accountability Office, Report to Congressional Requesters, Nuclear Power Plants, NRC Should Take Actions to Fully Consider the Potential Effects of Climate Change, report number GAO-24-106326, published in April 2024. Commenters expressed specific concerns about the potential for climate change to increase risk of flooding and failure of dams on the Tennessee River upstream of the facility.

Comments: (1-5) (2-1-3) (2-2-1) (2-2-7) (2-3-3)

Comment Response: To the extent that these comments concern safety issues, these comments are outside scope of the environmental review and will not be discussed in the EIS.

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 safety of operations and the safety of the facility are outside the scope of the environmental review. The NRC staff will evaluate the safety review of the SLR application separate from the environmental review. The Safety Evaluation Report (SER), a separate document prepared by the NRC staff, will document the results of the safety review.

14