ML17362A554

Issuance of Scoping Summary Report Associated with License Renewal Application Environmental Review

ML17362A554
Person / Time
Site:	River Bend
Issue date:	04/24/2018
From:	Benjamin Beasley NRC/NRR/DMLR/MENB
To:	Maguire W Entergy Operations
Drucker D, NRR-DMLR 415-6223
References
EPID L-2017-LNE-0027
Download: ML17362A554 (14)

Text

April 24, 2018

.

Mr. William F. Maguire Site Vice President, Entergy Operations, Inc.

River Bend Station, Unit 1 5485 U.S. Highway 61 N St. Francisville, LA 70775

SUBJECT:

RIVER BEND STATION, UNIT 1 - ISSUANCE OF SCOPING

SUMMARY

REPORT ASSOCIATED WITH LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW (EPID L-2017-LNE-0027)

Dear Mr. Maguire:

The U.S. Nuclear Regulatory Commission (NRC) staff conducted an environmental impact statement scoping process and solicited public comments from September 20, 2017, to October 23, 2017. This process helped determine the scope of the staffs environmental review of the application for renewal of the facility operating license for River Bend Station (RBS), Unit

1. The scoping process is the first step in the development of a plant-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS), for RBS.

As part of the scoping process, the staff held a public meeting to solicit public input regarding the scope of its environmental review in St. Francisville, Louisiana, on September 19, 2017.

The staff also received one written comment via email. The staff prepared the enclosed environmental impact statement scoping process summary report identifying comments received during the scoping period. In accordance with Section 51.29(b) of Title 10 of the Code of Federal Regulations (10 CFR), the staff will send a copy of this report to each participant in the scoping process.

The transcript of the public scoping meeting is available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or in the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. The transcript for the meeting is available under ADAMS Accession No. ML17293A547. For problems with ADAMS, please contact the NRCs PDR reference staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at pdr.resource@nrc.gov.

W. F. Maguire The draft supplement to the LR GEIS specific to RBS is scheduled to be issued in spring 2018.

A notice of the availability of this draft document and the procedures for providing comments thereon will be published in the Federal Register.

Should you have any questions concerning the staffs environmental review of the RBS license renewal application, please contact Mr. David Drucker, Project Manager, at 301-415-6223 or by e-mail at David.Drucker@nrc.gov.

Sincerely,

/RA/

Benjamin Beasley, Chief Environmental Review and NEPA Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket No. 50-458

Enclosure:

As stated cc w/encl: Distribution via Listserv

ML17362A554 OFFICE PM:MRPB:DMLR LA:MRPB:DMLR OGC BC:MENB:DMLR NAME DDrucker YEdmonds STurk BBeasley DATE 3/30/18 4/9/18 4/3/18 4/19/18 OFFICE DD:DMLR BC:MENB:DMLR NAME JDonoghue BBeasley DATE 4/24/18 4/24/18

Environmental Impact Statement Scoping Process Summary Report River Bend Station, Unit 1 St. Francisville, Louisiana April 2018 U.S. Nuclear Regulatory Commission Rockville, Maryland

Introduction The U.S. Nuclear Regulatory Commission (NRC) received an application from Entergy Operations, Inc. (Entergy) in May 2017, for renewal of the facility operating license for River Bend Station (RBS), Unit 1. RBS is located in St. Francisville, Louisiana, about 30 miles north of Baton Rouge, Louisiana. The purpose of this report is to provide a concise summary of the determinations and conclusions reached regarding the scope of the NRC staffs environmental review of that application. This report will summarize the issues identified by the environmental impact statement scoping process associated with the NRC staffs review of Entergys license renewal application.

As part of its application, Entergy submitted to the NRC an environmental report (ER) prepared in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 51, which contains the NRC requirements for implementing the National Environmental Policy Act of 1969, as amended (NEPA). The requirements for the preparation and submittal of ERs to the NRC for operating license renewal applications are outlined in 10 CFR 51.53(c)(3). The RBS ER is publicly available in the NRC's Agencywide Documents Access and Management System (ADAMS) at accession number ML17174A531. The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. Persons who encounter problems in accessing documents in ADAMS should contact the NRC's 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.

The requirements in 10 CFR 51.53(c)(3) were based upon the findings documented in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS). In the LR GEIS, the NRC staff identified and evaluated the environmental impacts associated with license renewal of nuclear power plants. The NRC staff determined that a number of environmental issues were generic to all nuclear power plants (or, in some cases, to plants having specific characteristics such as a particular type of cooling system).

These generic issues were designated as Category 1 issues. An applicant for license renewal may adopt the conclusions contained in the LR GEIS for Category 1 issues without further evaluation, unless there is new and significant information that may cause the conclusions for its plant to differ from those of the LR GEIS. Other issues that were not determined generically and that require a site-specific review were designated as Category 2 issues and are required to be evaluated in the applicants ER. The Commission has also determined that the NRC does not have a role in energy-planning decision making for existing power plants. Therefore, an applicant for license renewal need not provide an analysis of the need for power or the economic costs and benefits of the proposed license renewal.

On September 20, 2017, the NRC described the scoping process for the RBS license renewal application environmental review in a Federal Register Notice (82 FR 44004). This notified the public of the NRC staffs intent to prepare a plant-specific supplement to the LR GEIS and provided the public with an opportunity to participate in the environmental scoping process, as defined in 10 CFR 51.29. The Notice invited members of the public to submit written comments by October 23, 2017, noting that comments received after that date will be considered if it is practical to do so, but assurance of consideration cannot be given to comments received after that date. The plant-specific supplement to the LR GEIS is referred to as a Supplemental Environmental Impact Statement or SEIS. The NRC will prepare the SEIS in accordance with 10 CFR Part 51.

The scoping process provides an opportunity for the public to propose environmental issues to be addressed in the SEIS and to highlight public concerns and issues. As stated in 10 CFR 51.29(a), the objectives of the scoping process are to:

• Define the proposed action;

• Determine the scope of the SEIS and identify the significant issues to be analyzed in depth;

• Identify and eliminate peripheral issues;

• Identify any environmental assessments (EAs) and other environmental impact statements which 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;

• Indicate the schedule for preparation of the SEIS;

• Identify any cooperating agencies; and

• Describe how the SEIS will be prepared.

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

The scope of the SEIS includes an evaluation of the environmental impacts of and reasonable alternatives to license renewal. The Scoping Comments and Responses section of this report includes specific issues identified by the scoping comments. The NRC responses explain whether the issues will be addressed in the SEIS, and if so, where in the SEIS they will be addressed.

The NRC staff did not identify any environmental assessments being or soon to be prepared, which relate to, but are not within the scope of the SEIS. The NRC staff is in the process of developing a SEIS regarding the license renewal application for Waterford Steam Electric Station (Waterford), Unit 3. Waterford is located approximately 90 miles southeast of RBS. To the extent relevant, the Waterford SEIS will be considered in the NRC staffs evaluation of the environmental impacts of RBS license renewal.

In parallel 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 (ESA) to evaluate the potential impacts of the operation of RBS 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 Louisiana State Historic Preservation Officer, and the Advisory Council on Historic Preservation, to fulfill its Section 106 obligations under the National Historic Preservation Act of 1966 (NHPA).

The NRC staff did not identify any cooperating agencies for this review. However, the NRC, as an independent regulatory agency, routinely consults with Federal, State, Tribal, and local entities during the development of environmental impact statements, and will do so regarding the RBS SEIS.

The SEIS will be prepared by the NRC staff with contract support from Pacific Northwest National Laboratory.

The scoping process included a public meeting which was held on September 19, 2017, in St. Francisville, Louisiana. The NRC issued a press release and purchased newspaper advertisements to advertise that meeting. In addition to participation from Entergy and local officials, several members of the public attended the meeting. The meeting began with NRC staff members providing a brief overview of the license renewal process and the NEPA environmental review process. Following the NRC staffs prepared statements, the meeting was opened for public comments. The official transcript for the meeting is publicly available at the NRC PDR, located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or in ADAMS under Accession No. ML17293A547. A summary of the scoping meeting (ADAMS Accession No. ML17293A615) was issued on October 19, 2017. The NRC staff invited the applicant; Federal, State, and local government agencies; Tribal governments; local organizations; and individuals to participate in the scoping process by providing oral comments at the scoping meeting and/or by submitting written comments before the end of the scoping period on October 23, 2017.

At the conclusion of the scoping period, the NRC staff reviewed the comments submitted and the meeting transcript to identify individual comments. The only commenter at the public meeting was Mr. Kevin Couhig, Parish President of West Feliciana Parish. Mr. Couhigs comments are found in the meeting transcript (ADAMS Accession No. ML17293A547). Only one written comment was received. This comment (ADAMS Accession No. ML17304A065) was from an unknown individual with an unknown affiliation. The comments from Mr. Couhig and the unknown individual, and the NRC staffs responses to those comments, are provided in the Scoping Comments and Responses section of this report.

The NRC staff plans to issue a draft SEIS (DSEIS) for public comment in spring 2018. The DSEIS comment period will offer an opportunity for the applicant, interested Federal, State, and local government agencies, Tribal governments, local organizations, and members of the public to provide further input to the NRCs environmental review process. The comments received on the DSEIS will be considered in the preparation of the final SEIS (FSEIS). The FSEIS, along with the NRC staffs safety evaluation report (SER), will identify the information considered and evaluations performed by the NRC staff and will provide much of the basis for the NRCs ultimate decision on Entergys application for renewal of the RBS operating license.

Scoping Comments and Responses Comment from Kevin Couhig, Parish President of West Feliciana Parish (starts on line 24 of page 17 of the meeting transcript):

My name is Kevin Couhig. I'm the Parish President of West Feliciana Parish, the parish that the nuclear facility resides in.

I want to start out by saying I was in favor of the nuclear station here, and I am in favor of the renewal, but I do want to speak to you tonight about a couple of concerns that I have.

In my job, I'm the Chief Executive Officer of the county or parish, and as such I am also the head of Homeland Security, and that means that I have to work with our budget, our sheriff, our first responders with the Entergy facility and so forth to do regular operations of tests and exercise to be prepared in the event of nuclear emergencies.

Those don't come for free, and one of the concerns that I want to express to you and to the owners of the nuclear facility is because of their aggressive posture and abating taxes and avoiding taxes in our parish, it's become increasingly more difficult for us to afford to perform the necessary tasks that we are called upon to perform in terms of being -- providing those kinds of exercises and services.

And I would like to see something addressed during this process of renewal, which again, I'm in favor of, to address the fact that although the facility continues to operate safely, it is an aging facility. In the environment that we're in today there are two substantive differences between the environment when the facility was first permitted.

One, nuclear waste remains in our county or parish for the rest of time as far as we can tell. We'd like to know what the financial plan is for that nuclear waste. Someone is going to be in my job 400 years from now, and that nuclear waste will still be radioactive 400 years from now. I'd like to know what the plans are in terms of post decommissioning, whether the renewal goes forward or not, how and who is going to be responsible for that because the community was promised by both regulators and the company that the waste would be transmitted out of our community to a central site in Nevada, and that's not occurred. So we'd like to know what's the plan?

The second thing is as I mentioned it's becoming increasingly difficult for us to afford -- we're a small rural parish -- to afford to support the public safety needs that are generated by the nuclear facility in our community, and we would like to know what the plan is there because on the arc that we're on now, sometime during the 20 year extension that the company is asking for, they will no longer pay any property tax.

So those are the two things that we would ask that they address or that the regulators make part of the regulatory hearing. I think that's it. Thank you.

Response: This comment expresses the commenters general view on RBS license renewal and the accumulation of nuclear waste, and asks what the financial and post-decommissioning plan is for nuclear waste at RBS and about the implications of RBS license renewal for the West Feliciana Parishs tax revenue.

All U.S. nuclear power plants store spent nuclear fuel in "spent fuel pools. Spent fuel storage at power plant sites is considered temporary, with the ultimate goal being permanent disposal.

However, at this time there are no facilities for permanent disposal of high-level waste. In the Nuclear Waste Policy Act of 1982 (NWPA), amended in 1987, Congress directed the Department of Energy to design and construct an underground geologic repository at Yucca Mountain, Nevada. DOE applied to the NRC for a construction authorization in 2008; however, DOE canceled the project in 2010 before the NRC completed its review. The NRC closed out its review and the associated adjudicatory hearing in 2011. The NRC resumed its review in late 2013 to comply with an appeals court ruling. For more information on this process, see the fact

sheet on Licensing Yucca Mountain available at: https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/yucca-license-review.html.

The Federal government, by national policy set forth in the NWPA, has assumed responsibility for the permanent disposal of high-level waste and spent fuel. The NWPA specifies that the cost of both interim storage and permanent disposal is the responsibility of the generators and owners of the waste. NRC regulations contain provisions to determine and remain current on the financial qualifications of its reactor licensees and to reevaluate these qualifications within 2 years following permanent cessation of operations of the reactor or 5 years before the expiration of the reactor license. NRC regulations require licensees to submit written notification to the Commission for its review and approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Department of Energy. Therefore, the financial plan and financial burden of continuing spent fuel storage after reactor operations cease is analyzed within the NRCs regulatory framework. However, the NRC acknowledges that, because of delays in the siting and licensing of a repository, the Federal government bears an increasing financial responsibility for spent fuel storage costs, and it may become responsible for paying all reasonably incurred costs associated with spent fuel storage at some time in the future.

The Commission evaluated the environmental impacts of the continued storage of spent fuel by nuclear power plant licensees in a generic report, NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (September 2014). The findings of that report are generically applicable to all NRC-licensed nuclear power plants, including RBS. Based on the analysis and findings in that report, the Commission determined, in 10 CFR 51.23(b), that the impact determinations in NUREG-2157 regarding continued storage shall be deemed incorporated into the NRCs site-specific environmental impact statements, and that the environmental reports submitted for various NRC license applications, including applications for license renewal, need not consider the environmental impacts of continued spent fuel storage beyond the term of a reactor operating license.

Licensees of nuclear power plants pay taxes to local and State governments. After termination of reactor operations, property-tax payments would likely continue to provide revenue to State and local governments, albeit at a reduced rate. As long as a licensee continues to store spent fuel on land it owns, the licensee will likely pay some form of property taxes and associated fees to local and State governments. However, the NRC has no role in how States and local jurisdictions tax their utilities, assess power plant value, or how tax money is distributed.

Chapter 3, Section 3.10, of the RBS DSEIS will include a discussion of property tax payments and the distribution of tax revenue.

Comment from an unknown individual (identified as Anonymous): This comment raises numerous concerns which the NRC staff binned into the following categories: emergency preparedness, cultural and historic resources, tourism, radiological releases, energy alternatives, environmental justice, nuclear accidents, human health impacts, and the withholding of proprietary information. Comments not reproduced in the order received in their original form are preceded by . Each of the issues raised in this comment is reproduced separately below, followed by the NRC staffs response. This comment may be viewed in its original form in ADAMS, at Accession No. ML17304A065).

Comment (Anonymous) - Emergency Preparedness:

Need to thoroughly evaluate:

Short, medium; long, very long-term evacuation-abandonment (100 yrs plus) within 10 to 50 mile radius:

The combined environmental and socio-economic impact of a nuclear disaster impeding ops in the nearby petro-chemical corridor out to 50 miles must be evaluated. WHY IS ENTERGY USING A 6 MILE ZONE ON ITS MAPS?

If workers at petro-chemical plants must be evacuated due to nuclear disaster, the environmental impacts evaluation should include a combination of nuclear, fire and radiological and chemically toxic fumes (apart from the fact that most radionuclides are both radiologically and chemically toxic).

Impact of RB nuclear disaster on the French speaking minority of Louisiana must be considered. The 50 mi radius backs into Lafayette, cutting across native French speaking area, i.e. cultural genocide.

Cost of evacuation of populations from the 10 mile radius and from the 50 mile radius must be evaluated, along with feasibility.

What about the largest maximum-security prison in the United States with 6,300 prisoners & 1,800 staff, about 25 miles from RB, in the event of a nuclear disaster? What are the security and other consequences of either leaving them - probably without staff supervision or evacuating them and to where?

Response: These comments, in part, address emergency preparedness for responding to an accident at River Bend Station (RBS). Emergency preparedness is an on-going effort at all operating U.S. nuclear power plants, including plants that seek license renewal. The Commission considered the need for a review of emergency planning issues in the context of license renewal during its rulemaking proceedings on 10 CFR Part 54, which included public notice and comment. The Commission determined that there is no need for a special review of emergency planning issues in the context of an environmental review for license renewal since emergency planning is an on-going effort at all U.S. nuclear power plants (December 1991 Statements of Consideration at 56 FR 64943). Therefore, decisions and recommendations concerning emergency preparedness at nuclear plants are outside the regulatory scope of license renewal. More information on emergency preparedness at nuclear power plant is available at: https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/emerg-plan-prep-nuc-power.html.

A portion of this comment asks: WHY IS ENTERGY USING A 6 MILE ZONE ON ITS MAPS?

Entergy provided many maps in its Environmental Report (ER) and not all of them present a 6-mile radius. The maps included in the ER are included to describe the environment at and near RBS and to analyze environmental impacts. These maps are not included in the ER for reasons related to emergency preparedness.

Comment (Anonymous) - Cultural and Historic Resources and Tourism:

Impacts on tourism and irreplaceable cultural sites, including the historically significant ones noted on the RB site, which will be lost forever in a nuc disaster. Entergy is hiding info with a blank page on what seems to be a site of incredible significance to Native American history, likely including burial grounds; significant cultural artifacts.

Response: The commenter raises concerns regarding potential impacts to cultural resources in the vicinity of RBS and whether this information is sufficiently disclosed in the applicants Environmental Report (ER). Figures 3.7-11 and 3.7-12 of Entergys ER were withheld from public disclosure because they present the locations of archaeological resources on and in the vicinity of RBS. This information will be reviewed by the NRC staff and shared with the Louisiana State Historic Preservation Officer. This information is being treated as confidential in order to protect these resources from unlawful disturbance. Cultural and historic resources will be discussed in Chapter 3, Section 3.9 of the RBS DSEIS. The NRCs evaluation of impacts on cultural and historic resources will be discussed in Chapter 4, Section 4.9 of the RBS DSEIS.

The comment also raises concerns regarding the potential impacts on tourism due to a nuclear accident at RBS. The License Renewal GEIS considered the impacts of license renewal on tourism and the Commission found that the impacts are expected to be of small significance at all sites. The NRC staff will consider the impacts on tourism during its development of the RBS DSEIS. If the NRC staff identifies any new and significant information regarding the impacts on tourism, a discussion of that information will be provided in Sections 3.10 and 4.10 of the RBS DSEIS.

Comment (Anonymous) - Radiological Releases from Normal Operations and Accidents:

Impacts of BOTH the accumulation of ongoing nuclear discharges on the regional environment, some very long-lived, and nuclear accident upon the environment-population must be properly evaluated. These must include contamination cost and purification costs of groundwater; river-Gulf-ocean water; land; air. Your dilute to deceive scam fails over time.

Impacts upon colleges-universities: Southern in Baton Rouge, LSU, and any others; likely impacts upon UL Lafayette just outside the 50 mile zone must be reported.

Impacts of a nuclear disaster on the major US transportation routes crossing the area - interstate highways, river shipping and port facilities within the 50 mile radius and beyond must be evaluated.

Response: This comment states that the accumulation of ongoing nuclear discharges on the regional environment as well as the impact of radiological releases in a nuclear accident upon the environment and population must be properly evaluated, and that the evaluation must include contamination cost and purification costs of groundwater; river-Gulf-ocean water; land; and air. This comment also asserts that there is a dilute to deceive scam.

The mission of the U.S. Nuclear Regulatory Commission is to regulate the Nation's civilian use of radioactive materials, to provide reasonable assurance of adequate protection of public health and safety, to promote the common defense and security, and to protect the

environment. The NRC takes its responsibility to protect the environment very seriously and has established clear standards for protection against potentially harmful radiation in 10 CFR Part 20.

The NRC staff will describe the surface water at RBS in Section 3.5.1 and the impacts to surface water from the proposed action and alternatives in Section 4.5 of the SEIS. The NRC staff will describe the groundwater at RBS in Section 3.5.2 and the impacts to groundwater from the proposed action and alternatives in Section 4.5 of the SEIS. The NRC staff will describe land use in the vicinity of RBS in Section 3.2 and the impacts to land use from the proposed action and alternatives in Section 4.2 of the SEIS. The NRC staff will describe the air quality at RBS in Section 3.3.2 and the impacts to air quality from the proposed action and alternatives in Section 4.3 of the SEIS.

Nuclear power plants may give off a small amount of radiation while they are operating. The plants may also release small amounts of material that emit radiation. The NRC has strict rules to keep radiation levels in the environment very low and protect public health and safety. When it reviews a reactor license application, the NRC analyzes the possible impacts to people, animals, plants and sea life. In addition to the impacts of normal operation, environmental impacts of postulated accidents are evaluated as part of the license renewal review. In the LR GEIS, postulated accidents are typically characterized in two categories, (1) design basis accidents and (2) severe accidents. LR GEIS Section 4.9.1.2 identifies design basis accidents as a Category 1 issue whose impacts have been generically determined in the LR GEIS. In the LR GEIS, Category 1 issues were generally determined to have a SMALL impact. The RBS SEIS will address whether any new and significant information was identified during the staffs review that may change this result. LR GEIS Section 4.9.1.2 further determined that the probability-weighted consequences of severe accidents are SMALL for all plants, but identified severe accidents as a Category 2 issue to the extent that alternatives to mitigate severe accidents (SAMAs) must be considered for all plants that have not previously considered such alternatives. The SEIS will include an evaluation of Entergys severe accident mitigation alternatives analysis.

Comment (Anonymous) - Energy Alternatives:

Renewable Alternatives must be properly evaluated. They are not.

Renewables must be evaluated in combination, as well as with improved insulation; rather than Entergy's either-or.

Increasing CF (Capacity Factors) for PV and other renewables must be considered, and compared to the declining CF of RB nuclear - offline for months at a time due to defects-need of repair.

CF for current solar PV and PV CF in 8 years time must be the comparison. Ditto for algae fuels, wind, etc. RB may be at 0 for 5 mths plus per year like Grand Gulf has been.

Insulation-new films which keep heat out must be considered in combo with renewables-other non-nuclear alternatives.

Community; individual; utility owned rooftop solar (& PVs on parking lots) options must be considered, not only utility scale on virgin land. Even for virgin land, a 20,000 acres est. for PV solar must be compared to the 5,026,400 acres within 50 mi of RB which may be a permanent no-go zone (over 1 million acres for Chernobyl). Acres need[ed] for solar is declining, too.

Comparison must consider socio-economic and environmental costs of major nuclear disasters, especially the area being a permanent no-go exclusion zone. Both renewable and oil-gas alternatives then are best.

Response: In evaluating alternatives to license renewal, the NRC staff will consider energy technologies or options currently in commercial operation, as well as technologies not in current operation but likely to be commercially available by the time the current RBS operating license expires in 2025. Renewable energy alternatives will be considered in that evaluation, as appropriate. The NRC staff will evaluate reasonable alternatives to the proposed action in the RBS DSEIS, including combinations of alternatives. The staff anticipates that the DSEIS will include evaluation of renewable, oil, and gas technologies. Alternatives that could not provide the equivalent of RBSs current generating capacity and, in some cases, those alternatives whose costs do not justify inclusion in the range of reasonable alternatives, will be eliminated from detailed consideration. The NRC staff will explain the reasons why alternatives are eliminated from further consideration in Chapter 2, Section 2.3 of the RBS DSEIS.

Replacement power alternatives that can provide the equivalent of RBSs current generating capacity will be considered in detail. The NRC will evaluate the environmental impacts of these alternatives and the no-action alternative in Chapter 4 of the RBS DSEIS.

Comment (Anonymous) - Environmental Justice:

For environmental justice impacts on African Americans, the proper comparison is to the national avg - NOT the Louisiana or MS avg., nor the region. US avg. African American population is 13.3%; population in the 50 mile radius is 36.4%, meaning there is an environmental justice issue.

Response: Environmental justice populations including African Americans and low-income populations will be described in Chapter 3, Section 3.12, of the RBS DSEIS. The evaluation of environmental justice impacts will be discussed in Chapter 4, Section 4.12, of the RBS DSEIS.

Comment (Anonymous) - Nuclear Waste Accident on Site:

What about the consequences of a nuclear waste accident on site, either spent fuel fire or crack within the unmonitored 1/2 [-inch]

thick Holtec spent fuel canisters?

Response: This comment asks about the consequences of a nuclear waste accident on site, associated with a spent fuel fire or fuel canisters. The radiological consequences of accidents involving dry or pool storage of spent fuel were considered on a generic basis in Section 4.18 of NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (September 2014). There, the risk of severe accidents in spent fuel pools and dry cask storage systems was determined by the NRC to be SMALL for all NRC-licensed nuclear power plants. The findings of NUREG-2157 are generically applicable to all NRC-licensed nuclear power plants, including RBS. Based on the analysis and findings in that report, the Commission determined, in 10 CFR 51.23(b), that the impact determinations in NUREG-2157 regarding continued storage shall be deemed incorporated into the NRCs site-specific environmental impact statements, and that the environmental reports submitted for various NRC license applications, including applications for license renewal, need not consider the environmental impacts of continued spent fuel storage beyond the term of a reactor operating license.

Comment (Anonymous) - Proprietary Information:

Entergy and Holtec have requested that important information be withheld: See: ML052280428.

Response: The letter mentioned in this comment is a decision by the NRC staff stating that certain material marked as proprietary will be withheld from public disclosure, as requested by Entergy. The letter states:

We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of your statements, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure.

Therefore, the information contained in the reports and computer files entitled, "(1) Holtec Report HI-2022956 Revision 1; (2) Holtec Report HI-2043278 Revision 2; (3) Holtec Report HI-2043276 Revision 0; (4) Computer files associated with (2) and (3),"

marked as proprietary will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended.

Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents.

As indicated in the cited letter, the NRC may withhold from public disclosure certain information, where a request to withhold such information satisfies the requirements of 10 CFR 2.390. In accordance with 10 CFR 2.390(a)(4) information that may be withheld includes [t]rade secrets and commercial or financial information obtained from a person and privileged or confidential.

The withholding of such information is consistent with an exemption from disclosure set forth in the Administrative Procedures Act, 5 U.S.C. 552(b)(4).

Comment (Anonymous) - Human Health Impacts:

Financial and social costs should include but not be limited to health care. Impacts of life-shortening effects, including loss of family care-givers must be included. The US govt BEIR report puts increased cancer rate at 1% per 100 mSv exposure. A more recent US govt funded study suggests that it is higher-15% or greater. Using the outdated ICRP percentage is unacceptable.

What is the financial & psychological cost for fertility treatments due to radiation induced infertility? The psychological cost when they are ineffective? Not all feel that more immigration is a fair substitute for having their own children. Immigrants replacing locals is actually defined as genocide.

Response: This comment raises concerns regarding the human health impacts of radioactivity in the environment contributed by nuclear power plants, including potential cancer incidence and psychological costs resulting from nuclear power plant operation.

The NRCs regulatory limits for radiological protection are set to protect workers and the public from the harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. The limits are based on the recommendations of standards-setting organizations.

Radiation standards reflect extensive scientific study by national and international organizations.

This comment mentions the BEIR report ("Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII - Phase 2) and ICRP (International Commission on Radiological Protection).

Section 3.9, Human Health of the NRCs NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (ADAMS Accession No. ML13106A241) provides a discussion of the BEIR VII report and ICRP recommendations in relation to radiological exposure and risk to nuclear power plant workers and members of the public from operation of nuclear power plants.

Human Health impacts will be discussed in Section 4.11 of the RBS DSEIS.

Regarding psychological costs, the Commission has determined that the NRC need not consider psychological impact or mental stress to the public in exercising its regulatory responsibilities under the Atomic Energy Act. Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), CLI-82-6, 15 NRC 407 (1982). The Supreme Court further held that the NRC need not consider these factors under the National Environmental Policy Act (NEPA).

Metropolitan Edison Co. v. People Against Nuclear Energy, 460 U.S. 766 (1983). Hence, psychological cost will not be reviewed further in the SEIS for RBS license renewal.

SCOPING

SUMMARY

REPORT CONCLUSION As discussed above, the comments provided during the environmental scoping process identified many important issues that will be addressed by the NRC staff in its DSEIS for RBS license renewal. Issues which do not pertain to the staffs environmental evaluation or are beyond the scope of license renewal will not be considered in the DSEIS.