ML25007A110
| ML25007A110 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/28/2025 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML25007A110 (1) | |
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Supplemental Environmental Impact Statement Scoping Process Summary Report Dresden Nuclear Power Station, Units 2 and 3 Subsequent License Renewal Application Grundy County, Illinois February 2025 U.S. Nuclear Regulatory Commission Rockville, Maryland
2 Introduction By letter dated April 17, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24108A008), Constellation Energy Generation, LLC (CEG, the applicant) submitted an application for subsequent license renewal (SLR) of Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively. CEG submitted the application to the U.S. Nuclear Regulatory Commission (NRC, the Commission) 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. DNPS is located in Grundy County, Illinois, with a small portion of its cooling lake and site boundary extending into western Will County, Illinois. It is approximately 23 miles (mi) southwest of Joliet, Illinois, and 60 mi southwest of Chicago, Illinois. In its application, CEG requested SLR for a period of 20 years beyond the date of expiration of the current renewed facility operating licenses. Therefore, the new expiration dates, if the SLR application were to be approved, would be December 22, 2049, and January 12, 2051, for DNPS, Units 2 and 3, respectively.
In accordance with 10 CFR 51.29(b), this report is 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 DNPS SLR application, incorporating stakeholder input. This report briefly summarizes the issues identified by the environmental scoping process and is structured in four sections:
A.
The DNPS Public Scoping Period B.
The Scoping Process and Objectives C.
Summary of Comments Provided D.
Determinations and Conclusions A.
The DNPS Public Scoping Period The DNPS SLR application and all other publicly available documents relevant to the DNPS SLR application 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 at 1-800-397-4209, at 301-415-4737, or by email to PDR.Resource@nrc.gov. For additional information, please see https://www.nrc.gov/reactors/operating/licensing/renewal/applications/dresden-subsequent.html.
This website includes application information, the license renewal review schedule, opportunities for public involvement, project manager information, and other relevant information. In addition, documents, including public comments, related to the DNPS SLR application are available at the Federal rulemaking website, https://www.regulations.gov/, under Docket ID NRC-2024-0080.
CEG included an environmental report (ER) as Appendix E to the DNPS SLR application (ML24108A011) in accordance with 10 CFR 54.23, Contents of applicationenvironmental information, and 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 amended (NEPA), specifically, 10 CFR 51.53(c).
The NRC staff conducted a scoping process to gather information, in addition to that in the ER,
3 necessary to prepare a supplemental environmental impact statement (SEIS) to NUREG-1437, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS) (ML24087A133), to evaluate the environmental impacts of the proposed action of DNPS SLR.
B.
The Scoping Process and Objectives On August 5, 2024, the NRC staff published in the Federal Register (FR) a notice describing the scoping process for the DNPS SLR application environmental review (89 FR 63450). This notice notified the public about the NRC staffs intent to prepare the SEIS 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 September 4, 2024. In addition to written comments, oral comments were recorded at two public meetings, which were held as online webinars on August 20, 2024. 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 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 that 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.
Indicate the relationship between the timing of the preparation of 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.
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 tableTable A-1) and a comment number. For example, Comment 6-1 refers to the first comment within the document with correspondence ID 6. This
4 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 AppendixError! Reference source not found. to this report. Comments were grouped based on being in scope or out of scope of the staffs environmental review of the DNPS SLR application, 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 In accordance with 10 CFR 51.29(b), the NRC staff has prepared a concise summary of the determinations and conclusions reached, including the significant issues identified, as detailed below.
(1) Define the proposed action The NRCs Federal action is to decide whether to subsequently renew the DNPS renewed facility operating licenses 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 of DNPS SLR include: (1) impacts associated with continued operations and refurbishment activities similar to those that have occurred during the current license terms; (2) impacts of reasonable alternatives to the proposed action; (3) impacts from the termination of nuclear power plant operations and decommissioning after the SLR 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 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 SEIS in accordance with 10 CFR 51.29, Scoping-environmental impact statement and supplement to environmental impact statement, and 10 CFR 51.70, Draft environmental impact statementgeneral. The NRC staff also follows guidance in NUREG-1555, Supplement 1, Revision 2, Standard Review Plans for Environmental Reviews for Nuclear Power Plants (ML23201A227), 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 the SLR environmental review, or within the scope of the SLR environmental review. 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 DNPS SLR on climate
5 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 discuss, in Chapters 2 and 3 of the SEIS, the following topics generally mentioned in the scoping comments:
alternatives-system design alternatives-replacement energy technologies cumulative impacts ecology-aquatic resources ecology-terrestrial resources hydrology-surface water resources meteorology and air quality process-NEPA socioeconomics general environmental concerns 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 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 of the scope of the SLR environmental review. These included comments regarding support for the licensing action, emergency preparedness, and safety. The NRC evaluates nuclear power plant operating conditions and physical infrastructure to ensure ongoing safe operations through its Reactor Oversight Process. If new information on these matters becomes available, the NRC will evaluate the new information to determine whether any safety-related changes are needed. Otherwise, any safety issues within the scope of the NRCs review of the DNPS SLR application will be addressed separately from the SEIS in a Safety Evaluation Report (SER) to be published in September 2025. 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 SLR application review. Comments that have been designated as out of scope are identified in AppendixError! Reference source not found. to this report.
(4) Identify any 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 that relate to, but are not part of the scope of, the DNPS SLR SEIS. Previously completed environmental impact statements will be used in the preparation of the DNPS SLR SEIS, as appropriate, including portions of the LR GEIS, Revision 2, and NUREG-1437, Supplement 17, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Dresden Nuclear Power Station, Units 2 and 3 (ML041890266).
6 (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 under Section 7 of the Endangered Species Act of 1973, as amended, to evaluate the potential impacts of the proposed action of operation of DNPS for an additional 20 years 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 Illinois State Historic Preservation Office, and the Advisory Council on Historic Preservation to fulfill its Section 106 obligations under the National Historic Preservation Act of 1966, as amended.
(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 June 2025. The 45-day comment period will offer an opportunity for participants, such as the applicant; interested Federal, State, and local government agencies; Tribal governments; local organizations; and members of the public to provide further input to the agencys environmental review process.
Comments on the draft SEIS will be considered in the preparation of the final SEIS, which the NRC staff anticipates issuing in October 2025. The NRC staff will document its separate safety review in an SER, which the staff anticipates issuing in September 2025. The findings in the SEIS and the SER will be considered in the NRCs decision to approve or deny the DNPS SLR application.
(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 the SEIS.
(8) Describe the means by which the SEIS 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.
APPENDIX A LIST OF COMMENTERS Table A-1 Individuals Providing Comments During the Scoping Comment Period Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Gordon, Alison U.S. Geological Survey 1
Email ML24226A483 McClain, Krystle Z.
U.S. Environmental Protection Agency 2
Email ML24248A075 Alderson, Randy Coal City Fire District 3
Email ML24248A077 Kucharz, Mary J.
Grundy County 4
Email ML24249A070 Gibson, Eric Grundy County Highway Department 5
Email ML24249A072 Schroder, Madison Generation Atomic 6-1 Meeting Transcript ML24250A065 Namuo, Clyne Joliet Junior College 6-2 Meeting Transcript ML24250A065 Spencer, Chris Coal City Community Unit School District No.
1 6-3 Meeting Transcript ML24250A065 Norton, Nancy Grundy Economic Development Council 6-4 Meeting Transcript ML24250A065 Table A-2 Distribution of Comments by Resource Area or Topic Resource Area/Topic Number of Comments Received Alternatives-System Design 2
Alternatives-Replacement Energy Technologies 1
Cumulative Impacts 1
Ecology-Aquatic Resources 1
Ecology-Terrestrial Resources 1
General Environmental Concerns 1
Greenhouse Gas Emissions and Climate Change 2
Hydrology-Surface Water Resources 3
Meteorology and Air Quality 1
Outside Scope-Emergency Preparedness 1
Resource Area/Topic Number of Comments Received Outside Scope-Miscellaneous 1
Outside Scope-Safety 2
Process-NEPA 12 Socioeconomics 6
Support-Licensing Action 11 Waste Management-Radioactive Waste 2
NEPA = National Environmental Policy Act of 1969, as amended.
9 APPENDIX B ANALYSIS OF COMMENTS RECEIVED DURING THE SCOPING PERIOD B.1 Comments on the Resource Areas B.1.1 Comments Concerning Alternatives - System Design Comment Summary: The U.S. Environmental Protection Agency (EPA) recommended that the draft supplemental environmental impact statement (SEIS) for the Dresden Nuclear Power Station (DNPS), Units 2 and 3 subsequent license renewal (SLR) application submitted by Constellation Energy Generation, LLC (CEG, the applicant) describe the context of the existing plant with specific descriptions of previous plant maintenance activities and any potential future refurbishment activities needed to continue operations. If refurbishment projects include the construction of new buildings, the EPA asked that the applicant consider committing to designing buildings to Leadership in Energy and Environmental Design standards. In addition, the EPA discouraged construction of permanent, impervious areas as part of any refurbishment projects.
Comments: (2-1-2) (2-1-16)
Response: The environmental report (ER) submitted by the applicant as part of its SLR application did not identify any SLR-related refurbishment or replacement actions (e.g., related construction of new buildings) needed to maintain the functionality of plant systems, structures, and components consistent with the plants current licensing basis during the proposed SLR operating term.
B.1.2 Comments Concerning Alternatives - Replacement Energy Technologies Comment Summary: Commenter requested that the draft SEIS consider and provide comparative analysis regarding potential impacts of replacement power, including carbon emissions, resource extraction, and land use.
Comment: (6-1-2)
Response: To the extent that this comment falls within the scope of the U.S. Nuclear Regulatory Commission (NRC, the Commission) staffs environmental review of the DNPS SLR application, it will be considered as part of the staffs review and analysis of replacement power alternatives in the draft SEIS in Chapter 3.
B.1.3 Comments Concerning Cumulative Impacts Comment Summary: The EPA recommended that the draft SEIS summarize existing and proposed development in the region surrounding the DNPS, as well as provide an explanation of all direct, indirect, and cumulative effects of the proposed action.
Comment: (2-1-17)
Response: Consistent with the NRCs regulations implementing the National Environmental Policy Act of 1969, as amended (NEPA), at 10 CFR Part 51, Environmental protection
10 regulations for domestic licensing and related regulatory functions, 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 the DNPS.
B.1.4 Comments Concerning Ecology - Aquatic Resources Comment Summary: The EPA recommended that the draft SEIS discuss the potential effects of higher surface water temperature on aquatic organisms.
Comment: (2-1-12)
Response: To the extent that this comment falls within the scope of the NRC staffs environmental review of the DNPS SLR application, it will be considered as part of the staffs review and analysis during the development of the draft SEIS within the aquatic resources area in Chapter 3.
B.1.5 Comments Concerning Ecology - Terrestrial Resources Comment Summary: The EPA recommended that if refurbishment or construction activities may result in potential impacts to wetlands, a wetland delineation should be submitted and coordinated with the U.S. Army Corps of Engineers for review and permitting, as well as included as an appendix to the draft SEIS.
Comment: (2-1-9)
Response: To the extent that this comment falls within the scope of the NRC staffs environmental review of the DNPS SLR application, it will be considered as part of the staffs review and analysis during the development of the draft SEIS within the terrestrial resources area in Chapter 3.
B.1.6 Comments Concerning Environmental Justice Comment Summary: The EPA recommended that the draft SEIS evaluate potential impacts to environmental justice (EJ) communities in accordance with Executive Orders 12898 and 14096, as well as the Council on Environmental Qualitys (CEQs) NEPA implementing regulations.
Specific recommendations included the following:
Evaluate EJ based on potential disproportionate and adverse effects.
Use EJScreen.
Consider any disproportionate non-project related pollution exposures and non-pollution stressors that may affect EJ communities.
Comment: (2-2-1)
Response: To the extent that this comment falls within the scope of the NRC staffs environmental review of the DNPS SLR application, it will be considered as part of the staffs review and analysis during the development of the draft SEIS. The staff is awaiting Commission direction on this scope given that, as of the date of this report: (1) Executive Orders 14096 and 12898 were revoked by the Presidential Actions Initial Recissions of Harmful Executive Orders
11 and Actions, dated January 20, 2025, and Ending Illegal Discrimination and Restoring Merit-Based Opportunity, dated January 21, 2025, respectively; (2) former NRC Chairman Ivan Selin, in a letter to the President dated March 31, 1994, committed the NRC to carrying out the measures set forth in Executive Order 12898 and the accompanying memorandum as part of the NRCs efforts to comply with the requirements of NEPA; and (3) the Commissions Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040, August 24, 2004) has not yet been rescinded.
B.1.7 Comments Concerning General Environmental Concerns Comment Summary: The EPA provided a list of specific databases recommended for use by the NRC staff in gathering relevant environmental information for preparation of the draft SEIS.
Comment: (2-2-5)
Response: The NRC staff will prepare the draft SEIS consistent with the NRCs regulations implementing NEPA at 10 CFR Part 51. As part of that process, the NRC staff solicits comments from the EPA and reviews those comments and any resources provided.
B.1.8 Comments Concerning Greenhouse Gas Emissions and Climate Change Comment Summary: The EPA recommended that the NRC staff do the following in the draft SEIS:
Apply the CEQs NEPA Guidance on Consideration of Greenhouse Gas (GHG) Emissions and Climate Change in conducting a climate change analysis. Consider the potential effects of the proposed action on climate change as well as the effects of climate change on the proposed action.
Provide analysis of GHG emissions in the context of State GHG reduction targets and policies. Include a detailed discussion of the projects GHG emissions in the context of national and international GHG emissions reduction goals.
Quantify estimates of the social cost of GHG emissions using the EPA technical document Report on the Social Cost of Greenhouse Gases: Estimates Incorporating Recent Scientific Advances and the associated Microsoft Excel workbook.
Include a complete discussion of the extent to which the estimated GHG emissions from the proposed project and alternatives may be inconsistent with the need to take actions necessary to achieve science-based GHG reduction targets.
Incorporate robust climate resilience and adaptation considerations.
Address reduction and mitigation of expected GHG emissions from the project.
Comments: (2-1-18) (2-1-19)
Response: To the extent that these comments fall within the scope of the NRC staffs environmental review of the DNPS SLR application, they will be considered as part of the staffs review and analysis during the development of the draft SEIS. 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 may be directly impacted by the
12 proposed action. However, the impacts of climate change on the operations and safety of the plant are outside the scope of the NRC staffs environmental review. Finally, the NRC staff notes that the documents and guidance related to the social cost of GHG emissions mentioned by the EPA have been rescinded by Presidential Action Unleashing American Energy, dated January 20, 2025.
B.1.9 Comments Concerning Hydrology - Surface Water Resources Comment Summary: The EPA expressed concern for the water quality of the rivers surrounding the DNPS and requested that a discussion of the proposed actions impact on surface water quality be included in the draft SEIS. The EPA recommended several items to support this analysis:
A description of measures to capture and filter storm water runoff from DNPS operations, including any refurbishment and/or maintenance activities.
Verification that all the discharge structures at the DNPS are functioning properly.
A water balance analysis of the DNPS site that evaluates both water quantity and temperature under current and future climate scenarios.
Comments: (2-1-10) (2-1-11) (2-1-13)
Response: To the extent that these comments fall within the scope of the NRC staffs environmental review of the DNPS SLR application, they will be considered as part of the staffs review and analysis during the development of the draft SEIS within the surface water resources area in Chapter 3.
B.1.10 Comments Concerning Meteorology and Air Quality Comment Summary: The EPA recommended that the applicant commit to voluntary measures to reduce emissions from any refurbishment or construction activities. The comment included an enclosure titled Construction Emission Control Checklist. The enclosure provides a list of voluntary protective measures that the EPA recommends the applicant consider and commit to, as applicable, in the draft SEIS to minimize environmental and human health risks from diesel emissions and fugitive dust from project construction. The EPA also recommended consideration of the location of homes, schools, daycares, and playgrounds when establishing material hauling routes.
Comment: (2-1-15)
Response: To the extent that this comment falls within the scope of the NRC staffs environmental review of the DNPS SLR application, it will be considered as part of the staffs review and analysis during the development of the draft SEIS within the meteorology and air quality resources area in Chapter 3.
B.1.11 Comments Concerning Process - NEPA Comment Summary: Commenters expressed appreciation for the opportunity to provide comments and recommended that the NRC staff address them when preparing the draft SEIS.
This included a specific recommendation to include an appendix containing all comments received during the scoping period in the draft SEIS. A commenter also recommended that the draft SEIS include copies of coordination letters sent to relevant Federal and state agencies, as
13 well as any responses received. The EPA recommended that the draft SEIS clearly describe the purpose and need for the project, include alternatives that discuss alternate sources of power for proposed users, demonstrate how the preferred alternative will address identified problems or deficiencies, and reflect CEQs final rule on NEPA implementing regulations. Additionally, the EPA recommended using specific resources to conduct meaningful outreach to EJ communities and Indian Tribes to enhance involvement and to reduce barriers to participation in the NEPA process. Finally, commenters recommended that the draft SEIS be written in plain language.
Comments: (1-1) (2-1-1) (2-1-3) (2-2-3) (2-1-4) (2-2-2) (2-2-4) (6-1-1) (6-1-3) (6-2-1) (6-3-1)
(6-4-1)
Response: The NRC staff will prepare the draft SEIS consistent with the NRCs regulations implementing NEPA at 10 CFR Part 51.
B.1.12 Comments Concerning Socioeconomics Comment Summary: Commenters called attention to the beneficial economic impacts associated with the operation of the DNPS. These comments suggest that the proposed continued operation of the DNPS 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, higher education, worker incomes, and philanthropic support to local organizations.
Comments: (3-2) (4-2) (5-3) (6-2-3) (6-3-2) (6-4-2)
Response: To the extent that these comments fall within the scope of the NRC staffs environmental review of the DNPS SLR application, they will be considered as part of the staffs review and analysis during the development of the draft SEIS within the socioeconomics resource area in Chapter 3. However, as provided by the NRCs regulations at 10 CFR 51.95(c)(2), the draft SEIS is not required to include discussion of the economic costs and economic benefits of the proposed action or of alternatives to the proposed action except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation.
B.1.13 Comments Concerning Waste Management - Radioactive Waste Comment Summary: The EPA stated that long-term onsite storage of spent nuclear fuel may be required for many decades and recommended that the draft SEIS indicate if there will be any changes in the generation of waste, including low-level radioactive waste, mixed low-level radioactive waste, transuranic waste, and hazardous and Toxic Substance Control Act wastes over the life of the program.
Comments: (2-1-5) (2-1-7)
Response: To the extent that these comments fall within the scope of the NRC staffs environmental review of the DNPS SLR application, they will be considered as part of the staffs review and analysis during the development of the draft SEIS within the waste management -
radioactive waste resource area in the Chapter 3.
14 B.2 Non-Technical and Comments Outside the Scope of the Environmental Review B.2.1 General Comments in Support of the Licensing Action Comment Summary: Commenters expressed general support for the applicant and for the NRCs proposed action of subsequently renewing the operating licenses for the DNPS. The commenters cited the clean energy provided by nuclear power as well as the positive impact on the local community by the applicant and its employees. A commenter stated that the DNPS provides Grundy County with clean, carbon-free energy.
Comments: (3-3) (4-1) (4-3) (5-1) (5-2) (5-4) (6-2-2) (6-2-4) (6-3-3) (6-4-4) (6-4-3)
Response: Comments expressing support for the proposed action are outside the scope of the NRC staffs environmental review of the DNPS SLR application and will not be discussed in the draft SEIS. The comment about clean, carbon-free energy from the DNPS meeting the Grundy County power needs is also outside the scope of the NRC staffs environmental review. The NRC has no role in the energy-planning decisions of power plant owners, State regulators, system operators, and, in some cases, other Federal agencies as to whether a particular nuclear power plant should continue to operate.
B.2.2 Comments Concerning Issues Outside Scope - Emergency Preparedness Comment Summary: A commenter expressed that past and current emergency plans made in coordination with the DNPS are effective in preparing for any potential incidents at the plant.
The commenter noted that DNPS personnel are committed to fire prevention and mitigation in addition to participating in further emergency plan development.
Comment: (3-1)
Response: This comment regarding emergency preparedness is outside the scope of the NRC staffs environmental review of the DNPS SLR application and will not be discussed in the draft SEIS. Emergency preparedness relative to emergency evacuation is regulated by Federal Emergency Management Agency and State authority. The NRC roles are to support/consult with the Federal Emergency Management Agency and the State and to provide oversight of the applicants role in emergency preparedness. Moreover, emergency planning and preparedness are safety matters that are part of the DNPS current licensing basis and not environmental matters relevant to the proposed action of subsequent license renewal.
B.2.3 Comments Concerning Issues Outside Scope - Miscellaneous Comment Summary: The EPA recommended that the draft SEIS describe plans to transport spent nuclear fuel and spent fuel debris offsite for storage pending long-term disposal options outside of the DNPS site.
Comment: (2-1-8)
Response: The NRC has determined by rule that for the high-level waste and spent-fuel disposal component of the fuel cycle, the impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of license renewal should be eliminated.
Therefore, this issue is outside the scope of the NRC staffs environmental review of the DNPS SLR application. Moreover, any interim offsite transportation and storage would be subject to
15 licensing action(s) and NEPA review(s) separate from the DNPS SLR application. Finally, the DNPS has no operating experience of severe accident that incurs fuel damage; therefore, there is no spent fuel debris.
B.2.4 Comments Concerning Issues Outside Scope - Safety Comment Summary: The EPA recommended that the draft SEIS discuss and evaluate safety concerns from potential flooding and other storm events, including those related to changing climate conditions. The EPA also recommended that the draft SEIS discuss the structural integrity of any discharge structures and whether discharge structures can handle flow from changing frequency and severity of storm events.
Comments: (2-1-6) (2-1-14)
Response: These comments are outside the scope of the NRC staffs environmental review of the DNPS SLR application and will not be discussed in the draft SEIS. Aging management issues will be addressed in the NRC staffs safety review of the application and other safety issues are addressed under the current licensing basis for the DNPS. Although the NRC staff will consider the impacts of the proposed action on climate change and climate change impacts on environmental resources that may be directly impacted by the proposed action, the impacts of climate change on the operations and safety of the plant are outside the scope of the NRC staffs environmental review.