United States Nuclear Regulatory Commission - Protecting People and the Environment

NRC: Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437 Supplement 2, Part 15)

Appendix A : Discussion of Comments on the Draft Supplement



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Section Contents

Pursuant to 10 CFR Part 51, the staff transmitted the Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Oconee Nuclear Station, Draft Report for Comment (NUREG-1437, Supplement 2, referred to as the draft SEIS) (NRC 1996) to Federal, State, and local government agencies as well as interested members of the public. As part of the process to solicit public comments on the draft SEIS, the staff

  • placed a copy of the draft SEIS into the NRC Public Document Room and the Oconee County Library, 501 West South Broad Street, in Walhalla, South Carolina
  • sent copies of the draft SEIS to the applicant and certain Federal, State, and local agencies
  • published a notice of availability of the draft SEIS in the Federal Register on May 27, 1999 (64 FR 28843)
  • issued public announcements, such as advertisements in local newspapers and postings in public places, of the availability of the draft SEIS
  • announced and held two public meetings in Clemson, South Carolina, on July 8, 1999, to describe the results of the environmental review and answer related questions
  • issued press releases announcing the issuance of the draft SEIS, the public meetings, and instructions on how to comment on the draft SEIS
  • established a website to receive comments on the draft SEIS through the Internet.

During the comment period, the staff received a total of 10 comment letters and e-mail messages in addition to the comments received during the public meetings.

The staff has reviewed the public meeting transcripts and the 10 comment letters and e-mail messages that are part of the docket file for the application, all of which are available in the NRC Public Document Room. Excerpts of the transcripts that contained comments or questions are reproduced in this appendix along with each of the 10 comment letters and e-mail messages. No written statements were provided by members of the public during the public meetings. Table A-1 lists (1) the speakers at the meetings in speaking order along with the page of the transcript excerpts in this report on which the comment appears (these comments are identified by the letter "A" followed by a number that identifies each comment in the chronological order the comments were made), and (2) the authors of the comment letters or e-mail messages. The comment letters and e-mail messages are identified by letters "B" through "K." An additional alpha-numeric identifier distinguishes among comments within a letter.(1) The staff response for each issue is provided in Section A.1 of this report. Related issues have been grouped together.

The staff addressed each comment by considering whether it was

(1) a comment about a Category 1 issue, and whether it

(a) provided significant new information that required evaluation during the review, or

(b) provided no new information

(2) a comment about a Category 2 issue, and whether it

(a) provided information that required evaluation during the review, or

(b) provided no such information

(3) a comment that raised an environmental issue not addressed in the GEIS or the draft SEIS

(4) a comment on safety issues pertaining to 10 CFR Part 54, or

(5) a comment outside the scope of license renewal (not related to 10 CFR Parts 51 or 54).

There was no significant, new information on Category 1 issues [(1)(a) above]. If the comment provided new information for a Category 2 issue [(2)(a)], then the staff evaluated the information and modified the SEIS, as appropriate. If the comment provided no new information for either Category 1 or 2 issues [(1)(b) or (2)(b)], then the GEIS and draft SEIS remained valid and bounding, and no further evaluation was performed.

Comments without a supporting technical basis or that did not provide any new information are addressed in this Appendix, providing relevant references that address the issues within the regulatory authority of the NRC, where appropriate. These references can be obtained from the NRC Public Document Room.

Subsections A.1.1 through A.1.18 correspond generally to the subject matter in the text of the supplement (purpose and scope, conclusions, site description, refurbishment, ecology, human health, socioeconomics, archaeology and historic resources, postulated accidents, uranium fuel cycle and solid waste management, decommissioning, alternatives to the proposed action, and summary and conclusions). Within each section, similar comments are grouped together for ease of reference, and a summary description of the comments is given, followed by the staff's response. Where the comment or question resulted in a change in the text of the draft report, the corresponding response refers the reader to the appropriate section of this report where the change was made. All revisions to the text, whether substantive (including those made in response to comments) or editorial, are designated by vertical lines beside the text.

Section A.2 provides relevant portions of the public meeting transcripts and the 10 letters and e-mail messages that were received in response to the draft SEIS. Each comment identified by the staff was assigned a specific alpha-numeric identifier (marker). That identifier is typed in the margin of the transcript, letter, or e-mail message at the beginning of the discussion of the comment. In addition, to assist the reader in finding the response to the comment, the section number(s) where the comment is addressed in Section A.1 of this report is also listed in the margin next to the identifier. A cross-reference of the alpha-numeric identifiers, the speaker or author of the comment, the page where the comment can be found, and the section(s) of this report in which the comment is addressed is provided in Table A-1.

Table A-1. Oconee Nuclear Station SEIS Comment Log

No. Speaker or Author Source Page of Comment Section(s) Where Addressed
A1 C. Tims Afternoon Meeting Transcript (7/8/99) A-35 A.1.4
A2 C. Tims Afternoon Meeting Transcript (7/8/99) A-35 A.1.17
A3 M. Thompson Afternoon Meeting Transcript (7/8/99) A-36 A.1.17
A4 B. Williams Afternoon Meeting Transcript (7/8/99) A-37 A.1.15
A5 B. Williams Afternoon Meeting Transcript (7/8/99) A-37 A.1.15
A6 B. Williams Afternoon Meeting Transcript (7/8/99) A-37 A.1.15
A7 B. Williams Afternoon Meeting Transcript (7/8/99) A-37 A.1.14
A8 B. Williams Afternoon Meeting Transcript (7/8/99) A-37 A.1.14
A9 B. Williams Afternoon Meeting Transcript (7/8/99) A-37 A.1.4
A10 B. Williams Afternoon Meeting Transcript (7/8/99) A-38 A.1.4
A11 B. Williams Afternoon Meeting Transcript (7/8/99) A-39 A.1.4
A12 C. Tims Afternoon Meeting Transcript (7/8/99) A-39 A.1.17
A13 M. Thompson Afternoon Meeting Transcript (7/8/99) A-40 A.1.8
A14 J. Cudworth Afternoon Meeting Transcript (7/8/99) A-40 A.1.10
A15 D. Wehmire Afternoon Meeting Transcript (7/8/99) A-41 A.1.19
A16 D. Wehmire Afternoon Meeting Transcript (7/8/99) A-41 A.1.12
A17 N. Stancill Afternoon Meeting Transcript (7/8/99) A-42 A.1.14
A18 F. Plotnik Afternoon Meeting Transcript (7/8/99) A-43 A.1.4
A19 W. McCollum Afternoon Meeting Transcript (7/8/99) A-43 A.1.3
A20 D. Wehmire Afternoon Meeting Transcript (7/8/99) A-44 A.1.19
A21 D. Wehmire Afternoon Meeting Transcript (7/8/99) A-44 A.1.1
A22 D. Walters Afternoon Meeting Transcript (7/8/99) A-44 A.1.1
A23 D. Walters Afternoon Meeting Transcript (7/8/99) A-44 A.1.1
A24 T. Harper Afternoon Meeting Transcript (7/8/99) A-45 A.1.8
A25 N. Haylor Evening Meeting Transcript (7/8/99) A-47 A.1.4
A26 N. Haylor Evening Meeting Transcript (7/8/99) A-47 A.1.4
A27 N. Haylor Evening Meeting Transcript (7/8/99) A-47 A.1.4
A28 D. Sanders Evening Meeting Transcript (7/8/99) A-48 A.1.17
A29 D. Sanders Evening Meeting Transcript (7/8/99) A-48 A.1.17
A30 D. Mangrum Evening Meeting Transcript (7/8/99) A-49 A.1.4
A31 N. Haylor Evening Meeting Transcript (7/10/99) A-49 A.1.6
A32 N. Haylor Evening Meeting Transcript (7/8/99) A-49 A.1.4
A33 N. Haylor Evening Meeting Transcript (7/8/99) A-50 A.1.4
A34 N. Haylor Evening Meeting Transcript (7/8/99) A-50 A.1.15
A35 N. Haylor Evening Meeting Transcript (7/8/99) A-50 A.1.13
A36 N. Haylor Evening Meeting Transcript (7/8/99) A-50 A.1.15
A37 N. Haylor Evening Meeting Transcript (7/8/99) A-51 A.1.15
A38 N. Haylor Evening Meeting Transcript (7/8/99) A-51 A.1.15
A39 N. Haylor Evening Meeting Transcript (7/8/99) A-51 A.1.14
A40 N. Haylor Evening Meeting Transcript (7/8/99) A-51 A.1.14
A41 N. Haylor Evening Meeting Transcript (7/8/99) A-51 A.1.14
A42 N. Haylor Evening Meeting Transcript (7/8/99) A-52 A.1.14
A43 N. Haylor Evening Meeting Transcript (7/8/99) A-52 A.1.14
A44 N. Haylor Evening Meeting Transcript (78/99) A-52 A.1.13
A45 D. Sanders Evening Meeting Transcript (7/8/99) A-53 A.1.14
A46 N. Haylor Evening Meeting Transcript (7/8/99) A-55 A.1.16
A47 N. Haylor Evening Meeting Transcript (7/8/99) A-55 A.1.16
A48 N. Haylor Evening Meeting Transcript (7/8/99) A-56 A.1.9
A49 M. Thompson Evening Meeting Transcript (7/8/99) A-57 A.1.8
A50 M. Thompson Evening Meeting Transcript (7/8/99) A-57 A.1.8
A51 M. Thompson Evening Meeting Transcript (7/8/99) A-58 A.1.5
A52 N. Haylor Evening Meeting Transcript (7/8/99) A-59 A.1.4
A53 N. Haylor Evening Meeting Transcript (7/8/99) A-59 A.1.4
A54 G. Robison Evening Meeting Transcript (7/8/99) A-60 A.1.3
A55 D. Walters Evening Meeting Transcript (7/8/99) A-61 A.1.16
A56 D. Walters Evening Meeting Transcript (7/8/99) A-61 A.1.1
A57 D. Walters Evening Meeting Transcript (7/8/99) A-61 A.1.4
A58 D. Walters Evening Meeting Transcript (7/8/99) A-62 A.1.1
A59 D. Walters Evening Meeting Transcript (7/8/99) A-62 A.1.1
B N. Brock May 27, 1999 Letter A-65 A.1.11
C P.S. League August 12, 1999 Letter A-65 A.1.17
D1 H.J. Mueller August 16, 1999 Letter A-67 A.1.19
D2 H.J. Mueller August 16, 1999 Letter A-67 A.1.4
D3 H.J. Mueller August 16, 1999 Letter A-67 A.1.16
D4 H.J. Mueller August 16, 1999 Letter A-67 A.1.9
E J.H. Lee July 19, 1999 Letter A-68 A.1.17
F V. Autry, SCDHEC August 11, 1999 Letter A-68 A.1.8
G1 C.L. Gilbert, Jr. August 13, 1999 Letter A-69 A.1.2
G2 C.L. Gilbert, Jr. August 13, 1999 Letter A-69 A.1.13
G3 C.L. Gilbert, Jr. August 13, 1999 Letter A-69 A.1.17
H W.F. Squires July 9, 1999 E-mail Message A-72 A.1.1
I R. Carnes July 10, 1999 E-mail Message A-72 A.1.1
J J. Cudworth July 12, 1999 E-mail Message A-73 A.1.7
K Duke Energy August 17, 1999 Letter A-75 to A-86 A.1.3., A.1.7, A.1.8, A.1.18, A.1.19, Table A.2

A.1 Comments and Responses

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A.1.1 General Comments in Support of Nuclear Energy and License Renewal

The record of the public meetings and comment letters contains eight comments that express general support for license renewal (A21, A22, A23, A56, A58, A59, H, and I). Four of the comments express support in general (A22, A23, A56, and A59), and four specifically mention Oconee Nuclear Station (A21, A58, H and I). Reasons for supporting license renewal included

  • nuclear power is an environmentally sound way to produce electricity and meet energy needs - A21, A22, A23, A56, A58, A59, H, I
  • nuclear power is less expensive than building new electric generation capacity - A23, A59
  • there will be economic benefits to the community as a result of renewing the licenses and hardship if ONS is shut down - A23, A59.

These comments are general in nature and do not provide new information. Therefore, no further evaluation was required, and no changes to the SEIS were made as a result of these comments.

A.1.2 General Comments in Opposition to License Renewal

The record contains one comment that expressed general opposition to nuclear power and license renewal (G1). Reasons for opposing license renewal include

  • economic concerns
  • concerns regarding nuclear waste.

This comment is general in nature and does not provide new information. Therefore, no further evaluation was required, and no changes to the SEIS were made as a result of this comment.

A.1.3 General Comments on Adequacy of the Review and Analysis

The record contains three comments that expressed general opinions related to the staff's environmental review that was summarized in the draft SEIS, NUREG-1437, Supplement 2, Draft for Comment (A19, A54, and Ka). Two of the comments (A19 and A54) reflected positively on the draft SEIS. One comment (Ka) agreed with the conclusions stated in the draft SEIS that "Current measures to mitigate environmental impacts of plant operation were found to be adequate, and that no additional mitigation measures were deemed sufficiently beneficial to be warranted," and that "...the adverse impacts of likely alternatives will not be smaller than those associated with continued operation of ONS."

These comments are general in nature, and do not provide new information. Therefore, no further evaluation was required, and no changes to the SEIS were made as a result of these comments.

A.1.4 License Renewal Review Process

The record contains 15 comments and questions related to the license renewal process (A1, A9, A10, A11, A18, A25, A26, A27, A30, A32, A33, A52, A53, A57, and D2). One comment (A57) described the open nature of the review process. Two questions are related to the process that would occur after a determination is made about whether or not to renew the licenses (A1 and A18). Four questions are related to the schedule for the final inspection and the Commission's decision on license renewal (A25, A26, A27, and A30). Four comments were also made regarding the standing of the public and the Chattooga Watershed Coalition (A10, A11, A32, and A53). One comment related to the status and timing of the National Pollutant Discharge Elimination System (NPDES) permit renewal (A50). One comment related to the staff's consideration of public comments (A52). One question related to the involvement of the public during scoping or comment meetings (D2). Two comments stated that either issues were only partially being resolved through the relicensing process or that they were not being resolved and that it was unfair to the public and almost certainly illegal to proceed to a decision regarding license renewal in the absence of having answers to many open ended questions (A9 and A33).

The adequacy of the license renewal process is not within the scope of the environmental review related to the ONS license renewal. The license renewal process was established by rulemaking that included public notice and comment. Any new challenge to the process is outside the scope of this plant-specific environmental review.

The specific comments are addressed below.

Comment

Two of the comments were specific questions related to the license review process. One of the questions (A1) related to the process following the denial or refusal of the application (or in cases where the licensee does not apply for a license renewal). Another (A18) asked about the process that would be used if the license extension were granted, but then unanticipated problems developed at the site during the 15 years before the initial license period had expired.

Response

In the event that the license renewal application is denied, the current license will continue in effect until it expires. The Commission's regulations limit the duration of the operating license for a nuclear power facility to 40 years. Regulations require that upon the expiration of the original license, the utility has to initiate the decommissioning process. Decommissioning must be completed before the facility's license can be terminated. Decommissioning is defined as the safe removal of a facility from service and reduction of residual radioactivity to a level that permits termination of the NRC license.

The process that is being used by the NRC to monitor and oversee the current operating license will continue to be used if the license is renewed. If, at any time, a concern arises which affects the public health and safety, the NRC has the authority to issue orders which would require the licensee to take action to resolve that concern.

These comments did not result in modification of the SEIS text.

Comment

Three comments were related to the timing of the final inspection (A25, A26, and A27) in relationship to the final decision on the license renewal. One comment was related to the timing of the actual vote by the Commissioners to renew the license (A30).

Response

The license renewal inspection program consists of three separate inspections to support the decision on an application for license renewal. At a minimum, a scoping inspection and aging management inspection are conducted. An optional third inspection will be performed, if needed, to verify items identified by the staff, Advisory Committee on Reactor Safeguards, and regional administrator that are needed to close open items from the technical review of the application or previous inspections. This final inspection would be performed prior to the staff's recommendation regarding the approval or disapproval of the application. The inspection reports will be available to the public through the NRC's Public Document Room in Washington, D.C. before the Commission makes its decision. The Commission's decision on the renewal application is scheduled to be made by August 2000. The transcript of any Commission meetings on the application will also be available.

These comments did not result in modification of the SEIS text.

Comment

Four comments (A10, A11, A32, and A53) related to the standing or participation of the Chattooga River Watershed Coalition.

Response

The Chattooga River Watershed Coalition was the only organization that petitioned to intervene in a proceeding related to the Oconee license renewal application. The Atomic Safety and Licensing Board found that the Coalition had standing to intervene in the proceeding (that is, the action of renewing the operating license for the Oconee plants). However, the issues presented by the Chattooga River Watershed Coalition were not considered by the Atomic Safety and Licensing Board to be admissible as contentions. Upon appeal, the Commission came to the same conclusion. Nonetheless, the Commission has acknowledged the concerns that were expressed by the Chattooga River Watershed Coalition, and the staff is considering them during its review.

These comments did not result in modification of the SEIS text.

Comment

One comment (A52) related to the staff's consideration of public comments.

Response

The staff has listened to and is addressing the concerns that the public brought forth as comments on the draft SEIS for license renewal just as it did for comments provided during the scoping phase. The comments that were presented during the public meetings or by e-mail or letter are addressed in this Appendix. Comments received after the comment period ended were accommodated in this Appendix as time constraints allowed. Members of the public who do not believe that their concerns have been adequately addressed are always free to communicate their concerns to the NRC.

This comment did not result in modification of the SEIS text.

Comment

One comment (D2) noted the Notice of Availability for related documents available to the public, but asked whether public meetings would be held within the affected communities.

Response

Two public scoping meetings were held in Clemson, South Carolina, on October 19, 1998. Two additional meetings presenting the draft SEIS were held in Clemson, South Carolina, on July 8, 1999. The complete transcripts for these meetings can be found in meeting summaries issued on November 5, 1998, and August 27, 1999. A partial transcript of the July 8, 1999, meetings and the response to questions and comments made at those meetings are given in this Appendix. Clemson, South Carolina was selected as the location for these meetings because of its geographical proximity to the effected communities.

All of these meetings were announced in the Federal Register, in an NRC press release, on the NRC web page, and in posters placed on community bulletin boards in commercial establishments in the vicinity of ONS.

This comment did not result in modification of the SEIS text.

Comment

One comment (A57) commended the NRC for the open and thorough public process that was used to develop the generic environmental impact statement, which helps ensure that the process that was used during license renewal did not overlook or leave unexplored important issues and also makes the process more efficient and effective.

Response

This comment did not result in modification of the SEIS text.

Comment

Two comments (A9 and A33) stated that some concerns (related to plant operation for the reactor coolant system and not specifically defined) are still unresolved at this point and that it is unfair to the public and almost certainly illegal to proceed to a decision regarding license renewal in the absence of having answers to many open-ended questions.

Response

This SEIS addresses the environmental impact of the renewal of the licenses for the ONS units. There are no open issues in the environmental area. Concerns related to the safety aspects of the license renewal process are outside the scope of the staff's review of the environmental effects; therefore, they have been referred to the NRC license renewal safety project manager for disposition. The staff's review of the safety aspects of the renewal application is ongoing, and the staff's conclusions will be documented in the staff's safety evaluation. The comments regarding current operation are also outside the scope of license renewal. However, these concerns have been referred to the NRC Project Manager for the ONS.

These comments did not result in modification of the SEIS text.

A.1.5 Refurbishment

The transcript contains one comment related to refurbishment (A51).

Comment

The comment asked for an explanation of the difference between component replacement and refurbishment and further asked if the public would get information about component replacement.

Response

For the purpose of the environmental impact review, refurbishment describes an activity or change in a facility that is needed to support operations during the renewal term, but that was not previously considered in an environmental document. Duke's evaluation of structures and components as required by 10 CFR 54.21 did not identify any major plant refurbishment activities or modifications necessary to support the continued operation of ONS beyond the end of the existing term of the operating licenses.

Refurbishment in the context of license renewal does not refer to routine activities at the component level, such as repairs, replacement, or reconditioning of individual components, pipe segments, and concrete walls. These activities will continue during the initial license period and are anticipated to occur during the 20-year license renewal period.

Information on component replacement must be made publicly available only in certain circumstances under NRC rules and regulations. To the extent licensees are required to discuss component replacement when requesting NRC approval of plant changes pursuant to 10 CFR 50.90 or 50.92, such information will be available to the public. However, there is no requirement for a licensee to routinely provide information to the public about component replacement.

This comment did not result in the modification of the SEIS text.

A.1.6 Ecology

The record contains one comment related to ecology (A31).

Comment

One comment (A31) was a statement that in the event of a major radiological accident at the ONS, the Chattooga Watershed, which lies within the 50-mile evacuation zone, would be greatly impacted.

Response

The staff recognizes that a major radiological accident at a nuclear power plant would have the potential to greatly impact the population living near and the environment surrounding the nuclear facility. For this reason, the NRC requires a number of safety systems that will either prevent or mitigate the consequences of a major accident. In addition, a 16-km (10-mile) and an 80-km (50-mile) radius surrounding each nuclear facility are designated as emergency planning zones in the event of an accident. Emergency planning zones are defined as the areas for which planning is needed to ensure that prompt and effective actions can be taken to protect the public in the event of an accident.

The consequences of design basis accidents have been evaluated in the staff's safety evaluation supporting initial licensing of ONS.

This comment did not result in modification of the SEIS text.

A.1.7 Transmission Lines

The record contains three comments related to the level of review of the impacts of the transmission lines (J, Kb, and K24).

Comment

Three comments (J, Kb, and K24) indicated that the transmission lines that should be considered within the scope of the proposed action are those that run from the Oconee Turbine Building to the 230 kV and 525 kV switchyards. One comment (J) further suggested that the section on transmission line impacts should be deleted because the proposed action has no impact on electric shock since the lines will remain energized whether or not the Oconee licenses are renewed.

Response

The staff is required under the regulations in 10 CFR 51.53(c)(3)(ii)(H) to review the environmental impacts from transmission lines for the Category 2 issue concerning electric shock. The transmission lines to be evaluated are those that were constructed for the specific purpose of connecting the plant to the transmission system. The NRC staff identified these lines by reviewing Duke Power Company's original environmental report, Environmental Quality Features of Keowee-Toxaway Project, submitted to the Atomic Energy Commission (AEC), NRC's predecessor, on July 10, 1970, and supplemented in October 1971.

The staff has documented their position related to the scope of the transmission line impact assessment in a May 10, 1999, letter to Duke Energy (Subject: Determination of the scope of transmission line impact assessment for Oconee License Renewal). The comments provide no information that was not previously considered by the NRC staff that led to the determination in the May 10, 1999, letter. Therefore, the staff's position remains unchanged.

Because the basis for determining the scope of transmission lines is defined as those lines originally constructed for the specific purpose of connecting the plant to the transmission system, the statement that the transmission lines will remain energized irrespective of Oconee operation is not germane.

These comments did not result in modification of the SEIS text.

A.1.8 Water Quality and Use

The record contains ten comments related to water quality and use (A13, A24, A49, A50, F, K3, K6, K30, K40, and K79 ). The staff's responses to these comments follow.

Comment

Nine of the comments (A13, A49, A50, F, K3, K6, K30, K40, and K79) relate to the current status of the NPDES permit.

Response

The draft SEIS discussed the NPDES permit as "currently being renewed" by the South Carolina Department of Health and Environmental Control (SCDHEC). At the time that the draft SEIS was written and at the time of the public meetings in July, 1999, a toxicity compliance issue was outstanding and required completion before final approval and issuance of the NPDES permit. The compliance issue was resolved, and the SCDHEC issued the NPDES permit to Duke Energy on September 29, 1999. The current permit expires on September 30, 2003. A copy of the front page of the permit is contained in Appendix E of this report.

These comments did not result in modification of the SEIS text. However, the text of the SEIS has been changed to be consistent with the issuance of the current NPDES permit.

Comment

One comment (A24) requested the licensee make a strong commitment to making available a site on Lake Jocassee for a source of drinking water.

Response

The NRC's obligation under NEPA is specific to the action that is being taken and requires mitigative actions be taken only when such actions are required. In this case, there is no technical reason resulting from operation of ONS that would preclude municipalities from using water in Lake Keowee, such that they need to consider the use of an alternate location (such as Lake Jocassee) for drinking water intakes.

This comment did not result in a modification of the SEIS text.

A.1.9 Human Health

There are two comments in the record related to human health (A48 and D4). The staff's responses to these comments follow.

Comment

One comment (A48) requested information on nationwide systematic studies of the potential health effects within a specific radius around U.S. nuclear power plants. The comment specifically asked if the Centers for Disease Control (CDC) had ever done a study.

Response

The staff is not aware of any studies conducted by the CDC concerning potential health effects within a specific radius around U.S. nuclear power plants. However, the National Cancer Institute published a study, "Cancer in Populations Living Near Nuclear Facilities," in 1990, that examined cancer mortality between 1950 and 1984 at 62 nuclear facilities (Jablon 1990). The study did not find higher risks of leukemia or other cancers.

This comment did not result in a modification of the SEIS text.

Comment

The second comment (D4) specifically addressed the radiological impacts of the uranium fuel cycle on human populations and the definition of "tiny" doses referred to in Section 6.1, Page 6-3, as well as the type of impact that these doses may have on human populations. The comment suggested that the NRC provide clarification of the collective impact that these doses may have on human populations and requested a definition for "tiny."

Response

The comment discussed a section of the draft SEIS that quotes the findings in the Generic Environmental Impact Statement (GEIS) for License Renewal (NRC 1996). The statement was made that science cannot rule out the possibility that there will be no cancer fatalities from tiny doses. The same paragraph previously stated that tiny doses have some statistical adverse health effects. The quote from the GEIS indicates that "tiny" doses are "very small fractions of the regulatory limits and even smaller fractions of natural background exposure to the same populations." For the purposes of assessing radiological impacts, the Commission in the GEIS for license renewal (NRC 1996) has concluded that impacts are of small significance if doses and releases do not exceed permissible levels in the Commission's regulations. This determination of "small" applies to occupational doses as well as to doses to individual members of the public.

This comment did not result in a modification of the SEIS text.

A.1.10 Socioeconomics

The record contains one question related to the socioeconomic analysis that was conducted for the draft SEIS (A14). The comment is addressed below.

Comment

The comment asked what types of questions were asked and what kind of information was conveyed in the meetings with county, State, and Federal agencies during the staff's site visit in October 1999.

Response

The team met with the economic development departments of Seneca, Anderson, and Pickens Counties in South Carolina and asked questions regarding the transportation systems, public infrastructure concerns or problems, and the location and make-up of minority or low-income populations for Oconee County. They also discussed the tax base provided by ONS and the importance of that tax base to the Counties' finances. Finally, they discussed the likelihood of the Counties attracting new economic activity to the area.

The meetings with State and Federal agencies were specific to the issues that were under the purview of those agencies. For instance, discussions with the South Carolina State Historic Preservation Office related directly to historical and archaeological resources in and around the ONS. The discussions with the U.S. Fish and Wildlife Service addressed environmental issues and, specifically, endangered and threatened species.

This comment did not result in modification of the SEIS text.

A.1.11 Archaeology and Human Resources

The record contains one comment (B) related to archaeology and historic resources. The comment is addressed below.

Comment

The South Carolina State Historic Preservation Office states that relicenses with no new construction or land disturbance should have no effect on any properties included in or eligible for inclusion in the National Register of Historic Places. However, there might be unidentified archaeological sites within the plant area, and any future construction or land management activities could affect archaeological sites. The licensee may want to address the issue of future identification and management of cultural resources in the plant area as part of its continued operation.

Response

Duke, in their comment letter dated August 17, 1999 (Duke 1999), recommended that the following statement be added into the SEIS in Section 4.4.5:

To ensure that care is taken to protect cultural resources that may be encountered during construction or other land disturbing activities, the ONS site environmental work practices have been revised. If archaeological sites are identified during land disturbing activities, land disturbing activities will stop and the State Historic [P]reservation Office will be contacted to determine the appropriate steps to be taken prior to resuming the activities.

This statement has been added to the SEIS in Section 4.4.5.

A.1.12 Severe Accident Mitigation Alternatives

The record contains one comment related to severe accident mitigation alternatives (SAMAs) (A16). The comment is addressed below.

Comment

The comment asked whether any relative comparisons in the SAMA section were made, such as comparing the risk from ONS to driving a mile on a highway?

Response

No relative comparisons, such as relating the risk from ONS to driving on highways, were included in the draft SEIS. However, the Commission has established a policy statement ("Safety Goals for the Operation of Nuclear Power Plants; Policy Statement," 51 FR 30028) related to safety goals for the operation of nuclear power plants that provides qualitative and quantitative safety goals. As part of the policy statement, there were two quantitative objectives established to be used in determining achievement of the Commission's safety goals: (1) the risk of prompt fatality to an average individual in the vicinity of a nuclear power plant that might result from reactor accidents should not exceed 1/10 of 1% of the sum of prompt fatality risks resulting from other accidents to which members of the population are generally exposed, and (2) the risk to the population in the area near the nuclear power plant of cancer fatalities that might result should not exceed 1/10 of 1% of the sum of cancer fatality risks from all other causes. Based on the Oconee Probabilistic Risk Assessment and the Oconee Individual Plant Examination, the plant, by nature of its low estimated core damage frequency and robust containment design, meets these objectives. Thus, the risk associated with operation of the Oconee plant would represent less than 1/10th of 1percent of the risk to the public from all other causes.

This comment did not result in modification of the SEIS text.

A.1.13 Operational Safety Issues

The record contains three comments related to operational safety issues (A35, A44, and G2). The issues relate to (1) the temperature limits in the spent fuel pool and whether they minimize the probability of cracking of the spent fuel pool and subsequent leakage of the pool water into the groundwater and (2) the problems and inadequacies in the operation of the reactor cooling systems. These comments involve concerns that are relevant to current ONS operation. In accordance with 10 CFR 54.30, these issues are outside the scope of license renewal. They have been referred to the NRC operating plant project manager for disposition. These comments did not result in modification of the SEIS text.

A.1.14 Age-Related Safety Issues

The record contains eight comments associated with age-related safety issues (A7, A8, A17, A39, A40, A41, A42, and A43). A ninth comment was made that the SEIS does not appear to be the place for safety-related comments, but inquired as to where safety issues were addressed (A45). Five of the comments (A7, A39, A40, A41, and A43) specifically address embrittlement, fatigue, or toughness of key systems. One comment was related to embrittlement of the reactor vessel and internals (A17). Two comments (A8 and A42) dealt with the reactor building cooling units and their ability to remove heat due to degradation of the system from aging. These age-related safety issue comments are outside of the scope of the staff's review of the environmental effects of renewing the ONS licenses. However, they involve concerns that are relevant to the extended operation of the facility and have been referred to the NRC license renewal safety project manager for disposition. These comments did not result in modifications of the SEIS text.

A.1.15 Spent Nuclear Fuel

The record includes seven comments related to spent nuclear fuel storage or transportation (A4, A5, A6, A34, A36, A37, and A38). Five of the comments (A4, A6, A34, A37, and A38) address high-level waste (HLW) storage and disposal and the associated environmental impacts. The remaining two comments (A5 and A36) relate to the lack of a site-specific review of environmental impacts of transportation of HLW. The comments are addressed below.

Comment

The record contains five comments (A4, A6, A34, A37, and A38) that address offsite HLW storage and disposal and the environmental impacts and cost of offsite HLW disposal.

Response

Onsite storage of spent nuclear fuel is a Category 1 issue. The comments provide no new and significant information.

The environmental effects of long-term storage of spent fuel onsite have been evaluated by the NRC. As set forth in the Waste Confidence Rule (see 10 CFR 51.23), the NRC generically determined that such storage can be accomplished without significant environmental impact. In the Waste Confidence Rule, the Commission determined that spent fuel can be stored onsite for at least 30 years beyond the licensed operating life, which may include the term of a renewed license.

Siting of a HLW repository is a separate regulatory action involving the U.S. Department of Energy (DOE). Characterization of the site under review is projected to be complete by 2002, and a geologic repository is not expected to be ready before 2010 (NRC 1996). In the interim, onsite spent fuel storage in pools and in dry cask storage facilities continues in accordance with NRC regulations. NRC has a certification process for such casks, as set forth in 10 CFR Part 72. Consequently, these comments did not result in modification of the SEIS text.

Comment

There were two comments or questions (A5 and A36) related to the review of the environmental impacts of transportation of HLW and the fact that there was no site-specific review of the environmental impacts of transportation of HLW.

Response

The NRC addressed the questions concerning the status and background behind the change in classification of HLW transportation from a Category 2 issue to a Category 1 issue at the July 8, 1999, public meeting. The staff indicated that the proposed rule was an NRC initiative. The draft SEIS addressed this issue in Section 6.1.1, "Transportation of Radiological Waste," because the rule had not been finalized. Now that the rule has been amended, as discussed in detail below, the issue is a Category 1 issue and, therefore, need not be addressed on a plant-specific basis. Section 6.1 of this report now reflects this reclassification.

The Commission previously revised its environmental protection regulations (10 CFR Part 51) for license renewal on December 18, 1996 (61 FR 66537). The amendment was based on the analyses and conclusions reported in NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (NRC 1996). In response to the comments received on a proposed version of the rule published on June 5, 1996 (61 FR 28467), the Commission made the following statement:

As part of its effort to develop regulatory guidance for this rule, the Commission will consider whether further changes to the rule are desirable to generically address: (1) the issue of cumulative transportation impacts and (2) the implications that the use of higher burnup fuel have for the conclusions in Table S-4. After consideration of these issues, the Commission will determine whether the issue of transportation impacts should be changed to Category 1.

In SECY-97-279, entitled "Generic and Cumulative Environmental Impacts of Transportation of High-Level Waste (HLW) in the Vicinity of a HLW Repository," dated December 3, 1997, the NRC staff informed the Commission that it was the staff's preliminary view that the supplemental analyses of the generic and cumulative impacts of the transportation of HLW and of the implications of higher fuel burnup for transportation impacts supports a reasonable technical and legal determination that transportation of HLW is a Category 1 issue and may be generically resolved and adopted in a license renewal application. In a Staff Requirements Memorandum (SRM) dated January 13, 1998, the Commission directed the NRC staff to proceed with rulemaking to amend 10 CFR 51.53(c)(3)(ii)(M) to categorize the impacts of transportation of HLW as a Category 1 issue. In a memorandum dated July 1, 1998, the NRC staff informed the Commission of its plans for amending 10 CFR Part 51.

The Commission published the proposed rule for a 60-day public comment period on February 26, 1999 (64 FR 9884). The Commission also published a Notice of Availability of NUREG-1437, Vol. 1, Addendum 1, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants: Main Report Section 6.3 - 'Transportation,' Table 9.1 'Summary of findings on NEPA issues for license renewal of nuclear power plants,' Draft for Comment," (February 1999) (64 FR 9889) (Addendum 1 to the GEIS). Although the public comment period for the proposed rule and the draft addendum to the GEIS ended on April 27, 1999, the staff considered comments dated as late as June 25, 1999, (and received in early July 1999) in developing the final rule and final version of Addendum 1 to the GEIS. The staff made this accommodation in response to concerns expressed by stakeholders about the length of the comment period.

In the SRM to SECY-99-202, "Final Rule - Changes to Requirements for Environmental Review for Renewal of Nuclear Power Plant Operating Licenses (10 CFR Part 51)," dated August 3, 1999, the Commission approved issuance of the final rule and release of the supporting Addendum 1 to the GEIS. The Commission revised the environmental protection regulations on September 3, 1999 (64 FR 48496), and the rule became effective on October 4, 1999. The Notice of Filing of the Final Addendum 1 to the GEIS was published on September 17, 1999 (64 FR 50507). Accordingly, the Commission has resolved these issues on a generic basis, and no site-specific analysis is necessary in the absence of new and significant information.

These comments did not result in modification of the SEIS text. However, the text of the SEIS has been changed to be consistent with the final rule.

A.1.16 Alternatives

The record contains four comments directly related to alternatives (A46, A47, A55, and D3). Two of the comments (A46 and A55) related to the consideration of combinations of alternative energy sources. One comment (A47) was a question about whether energy reduction (conservation) measures had been considered. The fourth comment (D3) indicated appreciation that all reasonable energy resource alternatives had been evaluated.

These comments are addressed below:

Comment

One comment (A46) questioned whether a combination of alternative energy sources had been considered as an alternative to ONS license renewal. A second comment (A55) responded to the first comment.

Response

A combination of alternatives had not been discussed in the draft SEIS. Even though individual alternatives to ONS might not be sufficient on their own to replace ONS due to the small size of the resource (a hydroelectric power plant) or lack of cost-effective opportunities (e.g., for conservation), it is conceivable that a mix of alternatives might be cost-effective. For example, if some additional cost-effective conservation opportunities could be found and combined with a smaller imported power or natural gas-fired power plant alternative, it might be possible to reduce some of the key environmental impacts of alternatives. However, it is unlikely that the environmental impact of such a hypothetical mix could be reduced so that they are SMALL (that is the environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resources). The impacts of renewing the ONS licenses are SMALL in all aspects. Therefore, the combination of alternatives would likely not reduce environmental impacts below those of the proposed action.

As a result of these comments, a new section (Section 8.2.4.13) was added to appropriately discuss the impacts of a combination of alternatives.

Comment

The question was asked (A47) whether energy-reduction measures and conservation measures were included in the SEIS analysis.

Response

Section 8.2.4.12 of both the draft and the final ONS SEIS discuss utility-sponsored conservation.

This comment did not result in modification of the SEIS text.

Comment

One comment (D3) expressed appreciation for the consideration of all reasonable energy resource alternatives in addition to relicensing and the no-action alternative

Response

This comment did not result in modification of the SEIS text.

A.1.17 Miscellaneous

The record contains eight comments that do not fall within any of other categories (A2, A3, A12, A28, A29, C, E, and G3). One of the comments asked about the makeup of the Commission (A2). One was related to the location of the public document rooms (A3). One requested the educational background and employment history of the NRC project manager (A12). Three were questions about MOX fuel (A28, A29, and G3). One was a request to submit comments after the date given in the Federal Register Notice (C) and one (E) was a statement that they had no comments on the draft SEIS.

These comments are addressed below:

Comment

One comment (A2) asked about the makeup of the Commission and specifically who the members were, if they were appointed by the President, if they are approved by the House or the Senate, and how long the terms of the appointments are.

Response

Commissioners are nominated by the President and confirmed by the Senate for an appointment of up to 5 years. The current Commission makeup consists of Chairman Meserve and Commissioners Dicus, Diaz, McGaffigan, and Merrifield. Additional information can be found at the NRC website.

This comment did not result in modification of the SEIS text.

Comment

Comment (A3) requested the location of the public document room in the vicinity of the ONS site.

Response

When this issue was raised at the public meeting, the staff responded that the NRC local public document room (LPDR) for the Oconee plant was the Public Library at 501 West South Broad Street, Walhalla, South Carolina. On November 1, 1999, the NRC implemented a nationwide electronic records architecture and discontinued support for LPDRs. Nevertheless, the staff understands that the Oconee-related material already in the library in Walhalla will be maintained. However, there have been no acquisitions related to Oconee after November 1, 1999. This SEIS will be forwarded to the public library to ensure that the complete environmental record is available at the former LPDR.

This comment did not result in modification of the SEIS text.

Comment

A question was asked (A12) at the public meeting regarding the educational background and employment history of the NRC Project Manager for the environmental review.

Response

The Project Manager responded at the public meeting and provided a description of his 20 years involvement in environmental matters at the NRC.

This comment did not result in modification of the SEIS text.

Comment

Three comments (A28, A29, and G3) related to questions regarding mixed-oxide (MOX) fuel and expressed concerns regarding the environmental impact of reprocessing the MOX fuel or asked whether MOX fuel was a factor in the relicensing process or whether the public could give input on the process for making decisions on the MOX fuel.

Response

MOX fuel is not currently being used at ONS. Any licensee seeking to use MOX fuel, whether during the current license term or during the license renewal term, will need to seek NRC approval for such use by submitting a license amendment pursuant to 10 CFR 50.90 to 50.92. An opportunity for a hearing would be associated with any such amendment.

These comments are outside of the scope of the staff's review of the environmental effects of renewing the ONS licenses. Therefore, these comments did not result in modification of the SEIS text.

Comment

One comment (C) was a request to submit comments after the date given in the Federal Register Notice. The NRC staff informed the commenter that the NRC would consider additional comments, if it was practical to do so. No further comments were received from the commenter. A second letter (E) indicated that the author had no comments. These comments did not result in modification of the SEIS text.

A.1.18 Technical Clarifications and Corrections

The list of specific comments included with Comment Letter K includes 54 comments that are technical enhancements or correction of information such as plant dimensions, document dates, and plant-specific terminology. Of the specific comments provided, those in the following list fit this category (K1, K2, K4, K5, K13, K14, K15, K16, K17, K18, K19, K20, K21, K22, K23, K25, K26, K27, K28, K31, K32, K33, K34, K35, K39, K41, K42, K43, K44, K45, K47, K50, K53, K56, K57, K58, K59, K60, K61, K62, K63, K64, K65, K66, K67, K68, K69, K70, K71, K72, K76, K77, K78, and K80).

A separate log of Duke's specific comments and the NRC responses is attached as Table A.2.

A.1.19 Format and Presentation (Spelling, Grammar, References, Clarity, etc.)

There were 18 comments that suggested changes for clarification or accuracy and correction of typographical errors (A15, A20, D1, K7, K8, K10, K11, K12, K29, K38, K51, K52, K54, K55, K73, K74, K75, and K82). Two comments related to the format of the document (A15 and A20), specifically to the location of the conclusions. One comment (D1) related to the title of the document. The specific comments from Duke and the NRC responses are included in Table A.2. The remaining three comments are addressed as follows:

Comment

Two comments (A15 and A20) either requested clarification of the location of the conclusion in the EIS or recommended that the conclusions be placed closer to the front of the report and made clearer.

Response

While the conclusions are given in Chapter 9 of the report, they are repeated both in the Executive Summary and in the Abstract that are presented at the front of the report.

This comment did not result in modification of the SEIS text.

Comment

One comment (D1) stated that the word "Generic" in this document is misleading since the document is site-specific to the Oconee Nuclear Station relicensing application.

Response

Under the National Environmental Policy Act (NEPA), an environmental impact statement (EIS) is required for major Federal actions significantly affecting the quality of the human environment. The NRC has implemented Section 102 of NEPA in 10 CFR Part 51. In 10 CFR 51.20(b)(2), the Commission requires preparation of an EIS or a supplement to an EIS for renewal of a reactor operating license. Furthermore, 10 CFR 51.95(c) states that the EIS prepared at the operating license renewal stage will be a supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437. Moreover, the NRC staff is obliged to integrate its conclusions as amplified in the GEIS for all issues. Every supplement relies upon the conclusions in the GEIS and efficiencies are realized using this consistent regulatory framework. Therefore, the title of this document retains the original title of the GEIS, but includes the statement that it is the supplement that pertains to Oconee Nuclear Station (in this case, Supplement 2).

This comment did not result in modification of the SEIS text.

Table A-2. Duke's Comments and Staff Response

No. Page Line Nos. Comment(a) Disposition
1. xvii 14 CCW should be "Condenser Circulating Water" Corrected as suggested
2. 1-8 Table 1-1 The following permit should be added (Reference ER Table 7.2-1):
Agency: SCDHECAuthority: RCRA, Section 3005
Requirement: Permit
Permit Number: SCD043979822
Permit Issued: 3/9/1998
Activity Covered: Part A Hazardous Waste Permit,
Interim Storage Facility for Mixed Wastes
Permit information added
3. 1-8 11 Current NPDES permit is being in the process of being renewed.
Line 11 should be revised to state:
"The permit is currently being renewed."(a)
This item is discussed in Section A.1.8
4. 1-8 8 "ONS has two permits for drinking water wells in protected area" is not a correct statement. ONS has one drinking water well for the restroom facilities at the Site Softball Field. The permit number for this well is 202098AI. (Note that the Duke ER had supplied the information on the wells. During the review of this draft SEIS, Duke found that the site has only one well permitted as a drinking water well). Clarified as suggested.
5. 1-8 11 Permit Number for SCDHEC FWPCA is incorrect. The correct permit number is SC0000515. Clarified as suggested
6. 1-8 40 Revise footnote (a) to state:
"A NPDES permit renewal application was submitted by Duke on March 27, 1998. The draft permit will be issued in mid-August for a 30-day public comment period. See Section 2.2.3."
This item is discussed in Section A.1.8
7. 2-1 9 Should be "Babcock & Wilcox." Corrected
8. 2-5 1 Revise sentence to state: "ONS is located on the shores of Lake Keowee. The main bodies of the lake lie to the north and to the southwest of the site." Clarified as suggested
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
9. 2-5 32 Several of the amenities at the Visitor's Center (lakeside picnic center and landscaped grounds) are mentioned, but the nice nature trail is not mentioned. This trail is used extensively by civic organizations and schools and is a great place for wildflower tours. Clarified as suggested
10. 2-6 Figure 2-4 Figure 2-4 appears to list the ONS 525 kV switchyard as the "825 kv Switchyard." Also the standard abbreviation for kilovolt is kV, not kv, as is used in this figure. Corrected
11. 2-7 12 Line 12 should be revised to state: "But because of their distance from the site, these zones …" Clarified as suggested
12. 2-7 29 Should be "Babcock & Wilcox." Corrected
13. 2-7 34 ONS can use fuel up to 5% enrichment.
Line should be revised to state: "ONS fuel is low enriched (up to 5 percent by weight)…"
Clarified as suggested
14. 2-8 23-25 Oconee License Renewal SER Section 2.2.3.6.3.2.1 (Page 2-102) Intake Structure within Scope of License Renewal and Subject to an Aging Management Review states that:
"...the licensing basis does not rely on the underwater weir nor recirculation of the intake canal water for decay heat removal after a loss of Lake Keowee event. Based on the above documentation, the staff agrees with the applicant's determination that the underwater weir is not within the scope of license renewal."
Therefore, the description of the function of this weir on Lines 23-25 is not applicable. It is appropriate to describe the weir and its location, but the description of the function should be deleted. Delete the sentence beginning: "The purpose of this dam is to retain…"
Clarified as suggested
15. 2-8 27 The sentence refers to Figure 2-4, showing the location of such intake features like the skimmer wall, intake structure, submerged dam, and the outfall. The location of the submerged dam is not shown on the figure. Clarified as suggested
16. 2-9 19 Evaporation is not a waste processing method; therefore, evaporator concentrates are not produced. Clarified as suggested
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
17. 2-10 18 - 20 The Radwaste Facility processes high-activity wastes, low-activity wastes, and miscellaneous wastes from the Auxiliary Building, not the opposite as currently stated in lines 18 through 20. Clarified as suggested
18. 2-10 26 Dilution is not considered part of processing. The waste is released prior to any dilution. However, hydro dilution flow is used in determining the release rate.
Delete statement: "(diluted to meet the permissible concentration limits for discharge)…."
Clarified as suggested
19. 2-10 35 The value "28,343 m3 (944,773 ft3) per year" is the potential waste generation rate. The liquid waste holdup capacity is approximately 80,000 gallons. Corrected
20. 2-11 10 Gases are also produced in tanks and piping other than those holding liquid wastes (e.g., Letdown Storage Tank, Core Flood Tank).
Line should be revised to state: "…by the evolution of gases in liquids contained in tanks and piping."
Clarified as suggested
21. 2-11 30 The word "limit" should be inserted after "rate." Clarified as suggested
22. 2-12 14-15 Change to "reactor coolant system make-up water, steam generator make-up water…" Clarified as suggested
23. 2-12 15 - 18 These lines should be changed to state:
"… and deborating demineralizers. Non-sanitary, nonradioactive wastes are neutralized and sent to the holding ponds, eventually being discharged to the Keowee River, downstream from the Keowee Hydroelectric Station. Sanitary wastes are routed to an aerated sewage lagoon. The effluents are treated by chlorination. Prior to discharge, the treated effluents from the sanitary waste treatment system are dechlorinated."
Clarified as suggested
24. 2-13 7-28 As stated in the Duke response to RAI 11, the lines that were constructed for the specific purpose of connecting the plant to the transmission system are those lines that run from the Oconee Turbine Building to the 230 kV and 525 kV switchyards. Discussed in Section A.1.7
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
25. 2-15 32-33 Revise line to state: "…provide once-through condenser circulating water (CCW)." Clarified as suggested
26. 2-15 35 The amount of water supplied from the Seneca water treatment plant and used for potable water is 120 m3/d [0.03 million gpd].
Revise line to state: "…treatment plant (120 m3/d [0.3 million gpd]) is used for potable water."
Corrected
27. 2-16 Figure 2-7 The average flow through Keowee Hydroelectric Station is listed as 1632 cfs. The correct value is 1032 cfs. Corrected
28. 2-16 8-12 Revise to state:
"There are a total of seven groundwater wells at the Oconee site. One of these wells is used to supply the site baseball field with drinking water and with water for a restroom facility. This well is also used for seasonal irrigation at the site baseball field and has a pumping capacity of 0.0019m3/s (30 gpm). The well at the baseball field is the only groundwater well on site permitted to supply drinking water. There are two groundwater wells used to supply seasonal irrigation for landscaping at a training building and an office complex. The other four wells are used infrequently as low volume, non-potable water sources. The estimated combined pumping rate for all groundwater wells at the Oconee site is less than 0.068 m3/s (100 gpm)."
Revised as suggested
29. 2-17 24 Insert "state" in front of agency. Clarified as suggested
30. 2-17 26 The 1998 toxicity issue has been resolved. The sentence referring to this issue should be deleted. Line 26 should be revised to state:
"The permit is currently being renewed. A NPDES permit renewal application was submitted by Duke on March 27, 1998. The draft permit will be issued in mid-August for a 30-day public comment period."
Discussed in Appendix A.1.8
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
31. 2-18 18 Add footnote stating:
"In May 1999 the Federal Court of Appeals (D.C. Circuit) remanded EPA's revisions to the ground-level ozone and particulate matter standards. The court held that there was no basis for either revision, and that the revised ozone standard was unconstitutional. Therefore, future implementation of revisions to these standards is uncertain."
Paragraph deleted. Footnote not necessary
32. 2-18 23-24 Add Ellicott Rock Wilderness Area and Middle Prong Wilderness Areas. No change. Areas not listed in 40 CFR Part 81, Subpart D
33. 2-19 16 Delete the word "aquatic." Clarified as suggested
34. 2-23 10 Insert "Hartwell Reservoir" following "Lake Keowee" in the list of aquatic environments. Clarified as suggested
35. 2-41 7 - 10 The reference to the location of these sites should be deleted to protect these areas from unauthorized excavation. It should be sufficient to mention that two sites exist, southwest of the plant and that these sites are categorized as having nondescript lithic scatter. Deleted as suggested
36. 3-3 14 This line lists "Public services: public utilities." This appears to be a single issue. 10 CFR Part 51, Subpart A, Table B-1 lists these as two separate issues. This should be corrected by listing these two issues separately. No change made
37. 3-3 20 This table lists Environmental Justice as a Category 2 issue related to refurbishment.
GEIS Table 9.1 does not list Environmental Justice as a Category 2 issue. The footnote used in GEIS Table 9.1 should be referenced to this issue in Table 3.2.
No change made
38. 4-2 12 The appropriate GEIS reference sections for the issue "Altered thermal stratification of lakes" are sections 4.2.1.2.3 and 4.4.2.2. Line 12 incorrectly lists GEIS Section 4.2.1.2.2 as a reference section. This should be corrected. Revised as suggested
39. 4-8 2 It is stated that the NPDES permit governs the release of effluents by Oconee Nuclear Station into the receiving waters of "Lake Keowee." The permit also governs discharges that go into Keowee Hydro's tailrace. Therefore it is recommended that the wording be changed to also include "and to the Keowee Hydro Station's tailrace." Clarified as suggested
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
40. 4-8 4 The 1998 toxicity issue has been resolved. The sentence referring to this issue should be deleted. Line 4 should be revised to state: "The permit is currently being renewed. The draft permit will be issued in mid-August for a 30 day public comment period." Discussed in A.1.8
41. 4-9 7 It is stated that the NPDES permit governs the release of effluents by Oconee Nuclear Station into the receiving waters of "Lake Keowee." The permit also governs discharges that go into Keowee Hydro's tailrace. Therefore it is recommended that the wording be changed to also include "and to the Keowee Hydro Station's tailrace." Clarified as suggested
42. 4-10 18 Draft states "Although the 316(b) demonstration was not formally approved…." Duke is not aware of any correspondence indicating that the 316(b) demonstration was not formally approved.
This portion of the sentence should be deleted or the sentence should be revised to state "No correspondence could be located indicating EPA's formal approval of the study. However, the EPA issued a modified NPDES permit on August 30, 1976, that deleted…"
Clarified as suggested
43. 4-11 37 It is stated that Duke submitted a reapplication in "April" 1998. This should be replaced to state "March, 1998." Revised as suggested
44. 4-12 9 10 CFR 51.53(c)(3)(ii)(G) states 9 x 1010 m3 /year, not 9 x 1012 m3 /year as stated in the document.
Revise Line 9 to state: "that is lower than the 9 x 1010m3 per year…"
Corrected
45. 4-12 8 - 12 The following revision is suggested:
"The combined flow rate for the Keowee and Little Rivers is lower than the 9 x 1010 m3/year (3.15 x 1012 ft3/year) specified in the 10 CFR 51.53 (c)(3)(ii)(G). This low flowrate raises a concern from the standpoint of the potential for enhancement of thermophylic microorganisms such as Naegleria fowleri. These type of organisms could be a potential health concern for members of the public swimming in the cooling source (Duke 1998a)."
Clarified as suggested
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
46. 4-15 41 The conclusion for GEIS Section 4.5.4.2.3 states:
"If NRC finds that a consensus has been reached by appropriate federal health agencies that there are adverse health effects, all license renewal applicants will have to address the health effects in the license renewal process."
SEIS Section 4.2.2 states that on this issue "evidence is inconclusive."
To ensure closure on this issue, Line 41 should be revised to add: "Therefore, no further review is required for this issue in this SEIS."
Revised based on a recent report by the National Institute of Environmental Health Sciences
47. 4-22 26 Lines 22 through 26 discuss the need to take additional care during normal operation and maintenance activities on site to protect cultural resources. To ensure this protection occurs, Duke has revised the ONS site work practices on land disturbing activities.
Revise Line 26 to add:
"To ensure that care is taken to protect cultural resources that may be encountered during construction or other land disturbing activities, the ONS site environmental work practices have been revised. If archeological sites are identified during land disturbing activities, land disturbing activities will stop and the State Historic preservation Office will be contacted to determine the appropriate steps to be taken prior to resuming the activities."
Clarified as suggested
48. 4-28 23-31 References to "preliminary" analysis and "preliminary" determination should be changed to final once the USFWS concurs with the NRC staff biological assessment conclusions, if that occurs prior to the issuance of the Final SEIS. Revised based on current status of consultation with FWS
49. 4-28 28 Line should be revised to state: "conducting surveys of sensitive habitats prior to initiation of construction activities for new transmission lines." Sentence in question was deleted based on current status of consultation with FWS
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
50. 4-29 22 The following statement should be added at the end of Line 22: "Therefore, no evaluation of this issue is required." Clarified as suggested
51. 4-29 35 The citation reference "(Should come with RAI)", needs to be clarified. Parenthetical statement deleted
52. 4-30 20 The correct reference is "Letter from M.S. Tuckman…" Corrected
53. 5-13 24 "component cooling water" should be changed to "condenser circulating water" Corrected as suggested
54. 6-6 18 Reference is made to the Baltimore Gas and Electric (BGE) ER. This Draft SEIS is written for Duke Energy Corporation's Oconee plant. The correct reference is "the Oconee ER." Corrected
55. 6-6 29 Reference for identification of new and significant information is made to the BGE ER. This Draft SEIS is written for Duke Energy Corporation's Oconee plant. The correct reference is "the Oconee ER." Corrected
56. 8-2 40-43 Water quality on Lake Keowee is affected by many factors other than the factors that Duke has an influence over by the operation of the Duke plants or by the operation of its subsidiaries.
Duke is proud to provide corporate and technical assistance to various entities in the region concerned with water quality issues. However, SCDHEC is the state agency responsible for water quality on South Carolina lakes, rivers, and streams.
Revise Line 40 to state:
"... exceptionally high if Oconee closes. Therefore, the corporate and technical leadership and assistance that Duke voluntarily provides in the area of water quality monitoring may be less readily available."
Delete the sentence beginning:" If water quality begins to decline,…"
Clarified as suggested
57. 8-4 22 Revise to state "sulfur dioxide emissions…" Clarified as suggested
58. 8-4 30 Line should be clarified by revising to state: "Approximately 90 percent of the 700,000 tons of ash would be flyash, and the remaining 10 percent would be bottom ash." Clarified as suggested
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
59. 8-4 36 Revise to state: "Facilities would be constructed to control and treat leachate from ash and scrubber waste disposal areas and runoff from coal storage areas." Clarified as suggested
60. 8-5 15 Revise to state: "Total waste volume would be 900,000 MT (1,000,000 tons)/yr. of ash and scrubber sludge." Clarified as suggested
61. 8-7 31 Revise line to state: "However, leachate from ash and scrubber waste disposal areas and runoff from coal storage areas would have to be controlled to avoid groundwater and surface water contamination." Clarified as suggested
62. 8-9 36 Revise to state "approximately 900,000 MT (1,000,000 tons)/yr. of this waste…" Clarified as suggested
63. 8-12 33 The Duke ER supplied information on use of forced draft cooling towers. Duke would not likely use natural draft cooling towers due to the aesthetic difference between natural draft and forced draft cooling towers. Recommend removing the first sentence. Clarified as suggested
64. 8-12 37-38 This line reads as if Catawba has a natural draft cooling tower. Catawba has forced draft cooling towers. Duke would not likely use natural draft cooling towers. Corrected as suggested
65. 8-13 1 Remove first sentence. Duke does not consider natural cooling towers as an option. Corrected as suggested
66. 8-13 29 Add "Addition of 30 M (100 ft) tall cooling towers or…." Corrected as suggested
67. 8-15 13 Duke would not likely use natural draft cooling towers due to the aesthetic difference between natural draft and forced draft cooling towers. Remove reference to natural draft cooling towers. Corrected as suggested
68. 8-17 23 Units for waste should be units of volume, not area. Duke estimates the volume for this waste would be "2500 ft3/yr of spent catalyst…." Corrected as suggested
69. 8-22 23-26 Duke would not likely use natural draft cooling towers due to the aesthetic difference between natural draft and forced draft cooling towers. Remove this sentence and reference.
Catawba uses forced draft cooling towers.
Corrected as suggested
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
70. 8-23 23 Add statement: "Addition of 30-M (100-ft) high mechanical draft cooling towers." Corrected as suggested
71. 8-29 1 The date of the reference is May 13, 1999. The letter is from M. S. Tuckman. Corrected as suggested
72. 9-3 25 Add statement: "Therefore, no further analysis of the chronic effects of electromagnetic fields is required." Clarified as suggested
73. 9-4 13 The fifth word on the line reads 'bonds.' This should be revised to "bounds." Corrected
74. 9-6 16 Wording "preliminary" should be deleted upon release of final document. Revised
75. C-2 5 The date of the reference is May 13, 1999. The letter is from M. S. Tuckman. Corrected
76. D-2 11 Should be Asheville, not Charlotte. Corrected as suggested
77. D-2 13 Should be Charleston, not Columbia. Corrected as suggested
78. E-2 Table E-1 The following permit should be added (Reference ER Table 7.2-1):
Agency: SCDHECAuthority: RCRA, Section 3005
Requirement: Permit
Permit Number: SCD043979822
Activity Covered: Part A Hazardous Waste Permit,
Interim Storage Facility for Mixed Wastes
Included as suggested
79. E-2 16 Add footnote to Line 16. Line 16 should state:
"being revised"(a)
Footnote (a) should be added to end of Table E-1 to state:
"A NPDES permit renewal application was submitted by Duke on March 27, 1998. The draft permit will be issued in mid-August for a 30 day public comment period. See Section 2.2.3."
This item is discussed in Section A.1.8
(a) The comments in this column were extracted directly from Comment Letter K from Duke.
80. E-2 30 "ONS has two permits for drinking water wells in protected area" is not a correct statement. ONS has one drinking water well for the restroom facilities at the Site Softball Field. The permit number for this well is 202098AI. (Note that the Duke ER had supplied the information on the wells. During the review of this draft SEIS, Duke found that the site has only one well permitted as a drinking water well). Clarified as suggested
81. F-1, F-2 N/A The GEIS issues related to impacts from refurbishment activities are not listed in this section. There are nine Category 1 issues and nine Category 2 issues that are related to refurbishment activities (Reference Table 3-1 and 3-2). These should be repeated in this table.
An alternative to listing these issues in Appendix F would be to change the title to "Appendix F GEIS Environmental Issues Not Applicable to the Oconee Nuclear Station Because of Plant or Site Characteristics."
No change
82. F-1 28 The appropriate GEIS reference sections for the issue listed on lines 28 - 30 is 4.8.1.3. Lines 28 - 29 incorrectly list GEIS Sections 4.3.2.1 and 4.4.2.1 as the GEIS sections for this issue. Corrected as suggested
(a) The comments in this column were extracted directly from Comment Letter K from Duke.

A.2 Public Meeting Transcript Excerpts and Comment Letters

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Letter A (Transcript)

transcript (pdf)

Letter B

B-1

Letter C

C-1

C-2

Letter D

D-1

D-2

D-3

Letter E

E-1

Letter F

F-1

F-2

Letter G

G-1

G-2

G-3

G-4

G-5

Letter H

H-1

Letter I

I-1

Letter J

J-1

J-2

J-3

J-4

Letter K

K-1

K-2

K-3

K-4

Attachment 1

Part 1

Part 2

Part 3

Part 4

Part 5

Part 6

Part 7

Part 8

Part 9

Part 10

Part 11

Part 12

Part 13

Part 14

Part 15

Part 16

Part 17

Part 18

Part 19

Part 20

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1. Comments provided by Duke in Letter K were already numbered 1 through 82; therefore, the two comments appearing in the cover letter were given the designation Ka and Kb.

Page Last Reviewed/Updated Thursday, August 27, 2015