ML102770232

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Issuance of Environmental Scoping Summary Report Associated with the Staff'S Review of the Application by Energy Northwest for Renewal of the Operating License for Columbia Generating Station
ML102770232
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 12/29/2010
From: Pham B M
License Renewal Projects Branch 1
To: Gambhir S K
Energy Northwest
Doyle D, NRR/DLR, 415-3748
References
TAC ME3121
Download: ML102770232 (69)
v • d • e


Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 December 29,2010 Mr. S.K. Gambhir, Vice President, Technical Services Columbia Generating Station Energy Northwest MD PE04 P.O. Box 968 Richland, WA 99352 ISSUANCE OF ENVIRONMENTAL SCOPING

SUMMARY

REPORT ASSOCIATED WITH THE STAFF'S REVIEW OF THE APPLICATION BY ENERGY NORTHWEST FOR RENEWAL OF THE OPERATING LICENSE FOR COLUMBIA GENERATING STATION (TAC NO. ME3121)

Dear Mr. Gambhir:

The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted a scoping process and solicited public comments from March 11 to May 14, 2010, to determine the scope of the staff's environmental review of the application for renewal of the operating license for Columbia Generating Station (CGS). 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" (GElS), for CGS. The staff is in the process of revising the GElS. For this environmental review, the staff relied on the GElS and Addendum 1 which were issued in 1996 and 1999, respectively (ADAMS Accession Numbers ML040690705, ML040690738, and ML040690720).

As part of the scoping process, the staff held two public environmental scoping meetings in Richland, Washington on April 6, 2010, to solicit public input regarding the scope of the review. In addition to the public scoping meetings, the staff conducted an informational meeting with representatives from several affected American Indian tribes on April 27, 2010. The staff also received written comments by letter and e-mail.

At the conclusion of the scoping process, the staff prepared the enclosed environmental scoping summary report identifying comments received during the scoping period. In accordance with 10 CFR 51.29(b), the staff will send a copy of the scoping summary report to all participants in the scoping process. The transcripts of the public scoping meetings are available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.govlreading-rm/adams.html. The transcripts for the afternoon and evening meetings are listed under accession numbers ML 101241002 and ML 101241037, respectively.

Persons who encounter problems in accessing documents in ADAMS should contact the NRC's PDR reference staff by telephone at 1-800-397-4209 or 301-415-4737 or bye-mail at pdr.resource@nrc.gov.

S. Gambhir -2 The draft supplement to the GElS is scheduled to be issued in late 2011. A notice of the availability of the draft document and the procedures for providing comments will be published in the Federal Register.

If you have any questions concerning the staff's environmental review of this license renewal application, please contact Mr. Daniel Doyle, Project Manager, at 301-415-3748 or bye-mail at daniel.doyle@nrc.gov.

Sincerely, Bo M. Pham, Chief Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

As stated cc w/encl: Distribution via Listserv S. Gambhir -2 The draft supplement to the GElS is scheduled to be issued in late 2011. A notice of the availability of the draft document and the procedures for providing comments will be published in the Federal Register.

If you have any questions concerning the staff's environmental review of this license renewal application, please contact Mr. Daniel Doyle, Project Manager, at 301-415-3748 or bye-mail at daniel.doyle@nrc.gov.

Sincerely, IRA! Bo M. Pham, Chief Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION HARDCOPY:

DLR RF E-MAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource EGettys DDoyle BSingal WNalker. RIV RCohen, RIV LSubin,OGC MRyan, FSME ADAMS Accession No ML 102770232

'concurrence via e-mail OFFICE LA:DLR* PM:DLR:RPB1 OGC (NLO) BC:DLR:RPB1 D:DLR NAME IKing DDoyle LSubin BPham BHolian (MGalioway for) DATE 10/14/10 10/27/10 12/07/10 11/15/10 12/28/10 OFFICE BC:DLR:RPB1 NAME DATE I OFFICIAL RECORD COpy Environmental Impact Statement Scoping Process Summary Report Columbia Generating Station Richland, Washington December 2010 U.S. Nuclear Regulatory Commission Rockville, Maryland Introduction The U.S. Nuclear Regulatory Commission (NRC) received an application from Energy Northwest (EN), dated January 19, 2010, for renewal of the operating license for Columbia Generating Station (CGS). CGS is located in Richland, Washington. The purpose of this report is to provide a concise summary of the determinations and conclusions reached, including the significant issues identified, as a result of the scoping process in the NRC's environmental review of this license renewal application. As part of the application, EN submitted an environmental report (ER) (EN, 2010) prepared in accordance with Title 10 of the Code of Federal Regulations (CFR) Part 51 which contains the NRC requirements for implementing the National Environmental Policy Act of 1969 (NEPA).

The requirements for preparation and submittal of ERs to the NRC are outlined in 10 CFR 51.53(c)(3). The requirements in section 51.53(c)(3) were based upon the findings documented in NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GEIS) (NRC, 1996), (NRC, 1999). In the GEIS, the staff identified and evaluated the environmental impacts associated with license renewal. After issuing a draft version of the GEIS, the staff received and considered input from Federal and State agencies, public organizations, and private citizens before developing the final document. As a result of the assessments in the GEIS, a number of impacts were determined to be 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" impacts. An applicant for license renewal may adopt the conclusions contained in the GEIS for Category 1 impacts unless there is new and significant information that may cause the conclusions to differ from those of the GEIS. Other impacts that require a site-specific review were designated as "Category 2" impacts and are required to be evaluated in the applicant's ER. The Commission determined that the NRC does not have a role in energy-planning decision-making for existing 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 action. Additionally, as stated in 10 CFR 51.23(b), the Commission determined that the ER need not discuss any aspect of storage of spent fuel for the facility that is within the scope of the generic determination in 10 CFR 51.23(a). This determination was based on the Nuclear Waste Policy Act of 1982 and the NRC's Waste Confidence Rule, 10 CFR 51.23. On March 11, 2010, the NRC initiated the scoping process by issuing a Federal Register notice (75 FR 11576). This notified the public of the staff's intent to prepare a plant-specific supplement to the GEIS regarding the application for renewal of the CGS operating license.

The plant-specific supplement to the GEIS is also referred to as the Supplemental Environmental Impact Statement or SEIS. The SEIS will be prepared in accordance with 10 CFR Part 51. The scoping process provides an opportunity for public participation to identify issues to be addressed in the SEIS and to highlight public concerns and issues. The notice of intent identified the following objectives of the scoping process:

$ Define the proposed action

$ Determine the scope of the SEIS and identify significant issues to be analyzed in depth $ Identify and eliminate peripheral issues

$ Identify any environmental assessments and other environmental impact statements being prepared that are related to the SEIS

$ Identify other environmental review and consultation requirements

$ Indicate the schedule for preparation of the SEIS

$ Identify any cooperating agencies

$ Describe how the SEIS will be prepared The NRC's proposed action is whether to renew the Columbia Generating Station operating license for an additional 20 years. The scope of the SEIS includes an evaluation of the environmental impacts of CGS license renewal and reasonable alternatives to license renewal. The 'Scoping Comments and Responses' section of this report includes specific issues identified by the comments. The subsequent NRC responses explain if the issues will be addressed in the SEIS and, if so, where in the report they will likely be addressed. At the onset of the project, the NRC identified several significant issues for this license renewal, includi ng, but not limited to, the following issues that require a site-specific review: threatened or endangered species, acute effects of electromagnetic fields (electric shock), chronic effects of electromagnetic fields, housing impacts, public services (public utilities and transportation), offsite land use (during the license renewal period), historic and archaeological resources, severe accidents, and environmental justice. Among the significant issues that were identified in the scoping process are the ongoing cleanup of radioactive waste burial grounds on the Hanford Site near CGS and existing

groundwater contamination below the CGS site. Throughout the scoping process, the NRC staff identified and eliminated peripheral (i.e., out-of-scope) issues for the environmental review. This report provides responses to comments that were determined to be out of the scope of the environmental review. For in-scope comments, the staff will consider the comments in the development of the SEIS. A detailed response to in-scope comments will be provided, if necessary, in Appendix A of the SEIS.

Another environmental impact statement that is currently being prepared related to this review is the U.S. Department of Energy Tank Closure and Waste Management Environmental Impact Statement for the Hanford Site, Richland, Washington

1. Appendix G to the SEIS will include a comprehensive list of related projects considered in this review. In order to meet the requirements of the Magnuson-Stevens Fisheries Conservation and Management Act and Section 7 of the Endangered Species Act, the NRC staff is required to consult with the National Marine Fisheries Service and the U.S. Fish and Wildlife Service to evaluate the potential impacts of continued operation on bull trout, Chinook salmon, steelhead, and the essential fish habitat. In order to fulfill its obligations under the National Historic Preservation Act, the NRC additionally initiated consultation with the Advisory Council on Historic Preservation, the Washington State Historic Preservation Officer, and three 1 Draft document available at: http://www.hanford.gov/page.cfm?page=1118 Federally-recognized American Indian tribes: the Confederated Tribes of the Umatilla Indian Reservation, the Yakama Nation, and the Nez Perce Tribe. The NRC has also met with representatives of the Wanapum Band and contacted other potentially-affected American Indian communities.

The NRC staff expects to publish the draft SEIS in late 2011.

The NRC staff did not identify any cooperating agencies for this review. The NRC, as an independent regulatory agency, routinely and extensively consults with Federal, State, Tribal, and local entities during development of environmental impact statements and environmental assessments. Formal Cooperating Agency status is usually not sought or used.

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

Laboratories.

The NRC invited the applicant; Federal, State and local government agencies; American Indian tribal governments; local organizations; and individuals to participate in the scoping process by providing oral comments at the scheduled public meetings or by submitting written comments before the end of the scoping comment period on May 14, 2010. The scoping process included two public meetings which were held on April 6, 2010, at the Richland Public Library, 955 Northgate Drive, Richland, Washington 99352. The NRC issued press releases, purchased newspaper advertisements, and distributed flyers locally to advertise these meetings.

Approximately 40 people attended the meetings.

Each session began with NRC staff members providing a brief overview of the license renewal process and the NEPA environmental review process. Following the NRC's prepared statements, the floor was opened for public comments. Ten attendees provided oral comments that were recorded and transcribed by a certified court reporter. The transcripts of the comments from these meetings are included at the end of this report. The NRC issued a summary of the scoping meetings on May 10, 2010 (NRC, 2010a).

In addition to the April 6 public scoping meetings, the staff conducted an informational meeting with representatives from several affected American Indian tribes on April 27, 2010 (NRC, 2010b). The comments from the tribal representatives were recorded in the meeting notes which are also included in this report. All documents associated with this scoping process are available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from 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

. Persons who encounter problems in accessing documents in ADAMS should contact the NRC's PDR Reference staff by telephone at 1-800-

397-4209 or 301-415- 4737 or by e-mail at pdr.resource@nrc.gov. The ADAMS accession number for each document is listed below in Table 1. In addition to the comments received at the meetings, the NRC also received 11 letters and one e-mail with comments about the review. At the conclusion of the scoping period, the staff reviewed the transcripts, meeting notes, and all written material received in order to identify individual comments. Each comment was marked with a unique identifier including the Commenter ID (specified in Table 1) and a comment number, allowing each comment to be traced back to the transcript, letter, or e-mail in which the comment was submitted. Comments were consolidated and categorized according to the topic within the proposed SEIS or according to the general topic if outside the scope of the GEIS. Once comments were grouped according to subject area, the staff determined the appropriate action for the comment. The action or resolution for each comment is described in the staff's responses in this report. Table 1 identifies the individuals providing comments and the assigned Commenter ID. For oral comments, the individuals are listed in the order in which they spoke at the public meeting.

Accession numbers identify the source document of the comment in ADAMS.

TABLE 1. Individuals Providing Comments During The Scoping Comment Period Commenter Affiliation (If Stated)Comment SourceCommenter ID ADAMS Accession Number John Greenhill E-mail A ML100920546 Jerome Delvin Washington State Senate Letter B ML100980062 David V. Taylor, et al. Washington State Legislature Letter C ML101040675 James O. Luce State of Washington Energy Facility Site Evaluation Council Letter D ML101050307 Brad Peck, Rick Miller, and Robert Koch Franklin County Board of Commissioners Letter E ML101110052 Tim Sheldon Washington State Senate Letter F ML101110053 Russell Jim Confederated Tribes and Bands of the Yakama Nation Letter G ML101160435 Larry Haler, Brad Klippert, Maureen Walsh, and Terry Nealey State of Washington House of Representatives Letter H ML101110054 Tim Sheldon, et al. Washington State Senate Letter I ML101170056 Phil Rockefeller Washington State Senate Letter J ML101180459 Gary Robertson State of Washington Dept of Health Letter K ML101460059 Commenter Affiliation (If Stated)Comment SourceCommenter ID ADAMS Accession Number Ed Revell City of Richland Afternoon Scoping Meeting L ML101241002 Brad Peck Franklin County Afternoon Scoping Meeting M ML101241002 Steve Lee Pasco Chamber of Commerce Afternoon Scoping Meeting N ML101241002 Bob Link AREVA Afternoon Scoping Meeting O ML101241002 Lori Sanders Benton County PUD, EN Board of Directors Afternoon Scoping Meeting P ML101241002 Alvin Ankrum Pacific Northwest National Laboratory (PNNL) Evening Scoping Meeting Q ML101241037 Ed Harrington Evening Scoping Meeting R ML101241037 Dan Jordheim Evening Scoping Meeting S ML101241037 Gene Kinsey Evening Scoping Meeting T ML101241037, ML101960547 Carrie Mathews PNNL Evening Scoping Meeting U ML101241037 Barbara Harper Confederated Tribes of the Umatilla Indian Reservation (CTUIR) Tribal Outreach Meeting V ML102630228 Wade Riggsbee Confederated Tribes and Bands of the Yakama Nation Tribal Outreach Meeting W ML102630228 Dave Rowland Confederated Tribes and Bands of the Yakama Nation Tribal Outreach Meeting X ML102630228 Various Tribal Representatives See list of attendees in meeting summary Tribal Outreach Meeting Y ML102630228 Judy Ridge, et al. Washington public power utilities Letter Z ML103230048 The comments and suggestions received as part of the scoping process are documented in this section and the disposition of each comment is discussed. The formatting of the comment in the source document is not necessarily preserved. The meeting transcripts and written comments are included in their original form at the end of this report. Comments have been grouped into general categories.

In-scope comments: 1. General comments in support of EN, nuclear power, and license renewal for CGS (PRO) 2. Alternatives to license renewal of CGS (ALT)

3. Socioeconomic impact of CGS (SOC) 4. Greenhouse gas or carbon impact of CGS (GHG) 5. Other comments within the scope of NRC's environmental review (OTH, SAMA
2) Out-of-scope comments: 6. Long-term storage of waste (WST)
7. Other comments outside the scope of NRC's environmental review (OOS) In those cases where no new environmental information was provided by the commenter, only a brief response has been provided to the comment, and no further evaluation will be performed. The preparation of the SEIS will take into account all the in-scope issues raised during the scoping process. The SEIS will address both Category 1 and 2 issues along with any new information identified as a result of the scoping process. The SEIS will rely on conclusions supported by information in the GEIS for Category 1 issues and will include analysis of Category 2 issues and any new and significant information. The NRC will issue a draft SEIS for public comment. The comment period will offer the next opportunity for the applicant, interested Federal, State, and local government agencies, American Indian tribal governments, local organizations, and other members of the public to provide input to the NRC's environmental review process. The comments received on the draft SEIS will be considered in the preparation of the final SEIS. The final SEIS, along with the staff's safety evaluation report (SER), will provide much of the basis for the NRC's decision on the EN application to renew the license of CGS.

2 Severe Accident Mitigation Alternatives Columbia Generating Station Scoping Comments and Responses In-Scope Comments

1. General comments in support of Energy Northwest, nuclear power, and license renewal for Columbia Generating Station (PRO) The comments in this category can be found at the back of this report and are labeled with the following identifiers: B-1-PRO, C-1-PRO, C-3-PRO, D-1-PRO, D-3-PRO, E-1-PRO, H-1-PRO, I-1-PRO, J-2-PRO, K-2-PRO, L-2-PRO, L-4-PRO, L-6-PRO, O-1-PRO, O-3-PRO, O-4-PRO, O-5-PRO, P-3-PRO, Q-1-PRO, R-1-PRO, S-2-PRO, T-2-PRO, U-1-PRO, and Z-1-PRO.

Response: These comments are general in nature and express support for Energy Northwest (EN), nuclear power, or license renewal of Columbia Generating Station (CGS). The comments provide no new and significant information and will not be evaluated further in the development of the SEIS. 2. Alternatives to license renewal of CGS (ALT)

The comments in this category can be found at the back of this report and are labeled with the following identifiers: E-4-ALT, M-2-ALT, M-3-ALT, L-3-ALT, P-2-ALT, T-1-ALT.

Response: These comments refer to the alternatives to license renewal of Columbia Generating Station, including the alternative of not renewing the operating license, also known as the "no-action" alternative. The staff will evaluate all reasonable alternatives in Chapter 8 of the SEIS. Appendix A of the draft SEIS will include expanded responses to these comments as well as the other comments that are within the scope of the NRC's environmental review.

3. Socioeconomic impact of CGS (SOC) The comments in this category can be found at the back of this report and are labeled with the following identifiers: B-2-SOC, E-3-SOC, F-2-SOC, N-1-SOC, N-3-SOC.

Response: These comments address the socioeconomic impact of CGS. They are supportive of the applicant, in general, and also address the socioeconomic benefits of CGS on local/regional communities and economy, including other related issues such as employment, taxes, and education. The staff will address the socioeconomic impact of renewing the CGS operating license in Chapters 2 and 4 of the SEIS. In addition, the socioeconomic impact of not renewing the operating license will be discussed in Chapter 8. Appendix A of the draft SEIS will include expanded responses to these comments as well as the other comments that are within the scope of the NRC's environmental review. 4. Greenhouse gas or carbon impact of CGS (GHG) The comments in this category can be found at the back of this report and are labeled with the following identifiers: C-2-GHG, E-2-GHG, F-1-GHG, J-1-GHG, N-2-GHG, O-2-GHG, P-1-GHG, S-1-GHG. Response: These comments are generally supportive of license renewal and describe CGS as a source of power with low carbon emissions when compared to fossil fuel-powered sources.

Greenhouse gas emissions of the nuclear fuel cycle will be discussed in Chapter 6. Finally, the environmental impacts of reasonable alternatives will be discussed in Chapter 8 of the SEIS, including air emissions. Appendix A of the draft SEIS will include expanded responses to these comments as well as the other comments that are within the scope of the NRC's environmental

review. 5. Other comments within the scope of the NRC's environmental review (OTH, SAMA) The comments in this category can be found at the back of this report and are labeled with the following identifiers: A-1-SAMA, D-2-OTH, K-1-OTH, K-3-OTH, K-4-OTH, K-5-OTH, Y-1-OTH, V-2-OTH, V-3-OTH, V-4-OTH, V-5-OTH, V-6-OTH, V-7-OTH, V-8-OTH, V-9-OTH.

Response: These comments address a variety of topics within the scope of the NRC's environmental review. They will be considered in the development of the draft SEIS.

Appendix A of the draft SEIS will include expanded responses to these comments as well as the other comments that are within the scope of the NRC's environmental review. Topics addressed by these comments include:

  • Risk from solar storms in the severe accident mitigation alternatives (SAMA) analysis
  • Wastewater discharges
  • Existing groundwater contamination
  • Additional radiation data that is available from the Washington State Dept. of Health
  • DOE 618-11 Burial Ground
  • DOE Waste Treatment Plant
  • Tribal participation in the environmental review
  • Proposed energy park near CGS
  • Tribal scenarios for dose assessment
  • Review schedule flexibility to accommodate tribal input
  • Mitigation in the original environmental analysis Out-of-Scope Comments
6. Long-term storage of waste (WST)

Comment G-1-WST: I am writing to urge the Nuclear Regulatory Commission to strengthen efforts to ensure the safe and secure storage of spent power reactor fuel at the Columbia Generating Station (CGS) located on the U.S. Department of Energy's Hanford site. In light of the decision by President Obama to cancel the Yucca Mountain nuclear waste repository, the timely disposal of spent power reactor fuel can no longer be assumed. Instead there is a growing likelihood that spent power reactor fuel will accumulate and remain at reactor sites for an indefinite period. In particular, we urge the NRC to end its policy of allowing dense compaction of spent fuel in pools and require highly radioactive fuel assemblies greater than five years old be placed into dry, hardened storage modes capable of withstanding aerial impacts, earthquakes and acts of malice. The Hanford site is located on land to which the Yakama Nation has perpetual rights under the Treaty of June 9, 1855. The Federal government maintains a special trust relationship with Indian tribes pursuant to treaties, statutes, Executive Orders, judicial decisions and other legal instruments. Inherent in this relationship is an enforceable fiduciary responsibility to the Yakama Nation to protect its lands and resources. Moreover, the Yakama Reservation is within the 50-mile Ingestion Pathway Zone if a major radiological release were to occur at the Columbia Generating Station. As you may know, the CGS is a Boiling Water Reactor Mark II that began operation in 1984. It is in the early process of extending its operating license, which expires in December 2023. This reactor has generated approximately 500 metric tons of spent fuel. Over the next several decades the radioactive inventory in spent fuel at the Columbia Generating Station is estimated to more than quadruple. The major preponderance of spent fuel at the CGS is densely compacted in an above ground pool, well above grade. On average, spent fuel ponds hold five to 10 times more long-lived radioactivity than a reactor core. Particularly worrisome is the large amount of cesium 137 in fuel ponds, which contain anywhere from 20 to 50 million curies of this dangerous isotope. For the past several years, the NRC has sponsored research which indicated that consequences from drainage of spent fuel pools from accidents and earthquakes could be considerable. For instance, a 1997 report for the NRC by Brookhaven National Laboratory found that a severe pool fire could render about 188 square miles uninhabitable, cause as many as 28,000 cancer fatalities, and cost $59 billion in damage. But, the frequency of these events was considered to be quite small. In 2002, Attorneys General from states hosting mo st of the nation's nuclear power plants called upon the U.S. Congress to pass legislation to "enhance protections for one of the most vulnerable components of a nuclear power plant-its spent fuel pools." In 2003 an independent study reported that drainage of a spent fuel pool by a terrorist attack could result in as much as 27,000 square miles of severe land contamination. This was the first study to consider potential risks of terrorist attacks on spent fuel pools. In response, the U.S. Congress requested the National Academy of Sciences to convene a special panel to address this concern. In 2005 the Academy panel warned that,"...under some conditions, a terrorist attack that partially or completely drained a spent fuel pool could lead to a propagating zirconium cladding fire and the release of large quantities of radioactive materials to the environment." The panel also noted that, "pools are potentially susceptible to attacks from above or from the sides depending on their elevation with respect to grade and the presence of surrounding shielding structures." Because of the sensitivity of the subject, the panel submitted classified findings and recommendations to the NRC. The Academy panel also visited German nuclear sites, where spent fuel pools are under heavy containment or stored in dry casks, which are placed in earthen berms or thick-wall structures.

The German nuclear industry took these steps 25 years ago in response to fighter jet crashes and concerns over acts of terror. We note that the NRC is working on a new "waste confidence" policy. We urge that this new policy not be contingent on the timely opening of a high-level waste repository, but rather on the safety and security of spent fuel storage, which may unfortunately, extend into the indefinite future. Specifically, we urge that license extensions being sought, including that for the Columbia Generating Station be contingent on emplacement of spent fuel greater than five years of age, in dry, hardened storage. Future reactors should be required to have spent fuel pools under heavy containment. I look forward to your response.

Comment L-5-WST: The only concern that I have that's worth mentioning is where it involves the ultimate disposal of spent nuclear fuel. The community has got concerns on how long storage of spent nuclear fuel will be handled by the Department of Energy. I know that's outside the control of NRC and Columbia Generating Station or Energy Northwest. But it is an issue that needs to be addressed because, you know, the administration's trying to shutdown Yucca Mountain. However, this community is very used to working with nuclear materials. I know the storage containers that the fuel is in really would allow that fuel to be stored for a long time on-site but that's not really the contract so to speak, that the utilities had with the Federal Government. And I don't know if you'll be addressing that or not in your review. And I don't see it as a show stopper for us here because we are, as I said, a nuclear community. And we have the capability to do long term storage here but it's not something we're really looking forward to.

Response: These comments address concerns about the long-term onsite storage of spent nuclear fuel. NRC responded by letter directly to Mr. Russell Jim about the concerns he expressed in his letter. The ADAMS accession number for the NRC's response is ML101300463. The safety and environmental effects of long-term storage of spent fuel onsite have been assessed by the NRC, and, as set forth in its Waste Confidence Decision (codified at 10 CFR 51.23), the Commission generically determined that such storage could be accomplished without significant environmental impact. In the Waste Confidence Decision, the Commission determined that spent fuel can be stored onsite for at least 30 years beyond the license operating life, which may include the term of a renewed license. At or before the end of that period, the fuel would be removed to a permanent repository. In its Statement of Consideration for the 1990 update of the Waste Confidence Decision (55 FR 38472), the Commission addressed the impacts of both license renewal and potential new reactors. In its December 6, 1999, review of the Waste Confidence Decision (64 FR 68005), the Commission reaffirmed the findings in the rule. In addition to the conclusion regarding safe onsite storage of spent fuel, the Commission states in the rule that there is reasonable assurance that at least one geologic repository will be available within the first quarter of the 21st century, and sufficient repository capacity for the spent fuel will be available within 30 years beyond the licensed life for operation of any reactor. On October 9, 2008, the Commission issued a proposed revision of the Waste Confidence Decision in the Federal Register (73 FR 59551) for comment. This revision provided the basis for extending the time for sufficient repository capacity for spent fuel to be available from within 30 years beyond the licensed life for operation of any reactor to within 50 to 60 years. The proposed revision also provides reasonable assurance that spent fuel can be stored without significant environmental impacts for at least 60 years beyond the licensed life for reactor operation assuming storage of spent fuel in either a spent fuel storage basin or onsite or offsite independent spent fuel storage installation. On September 15, 2010, the Commission approved a final revision to the agency's "Waste Confidence" findings and regulation, expressing the Commission's confidence that the nation's spent nuclear fuel can be safely stored for at least 60 years beyond the licensed life of any reactor and that sufficient repository capacity will be available when necessary. In addition, the Commission directed the NRC staff to conduct additional analysis for longer-term storage to ensure that the NRC remains fully informed by current circumstances and scientific knowledge relating to spent fuel storage and disposal (NRC, 2010c). Accordingly, as discussed above and as specified by 10 CFR 51.23(b), no site-specific discussion of any environmental impact of spent fuel storage in reactor facility storage pools or ISFSIs is required in an environmental impact statement associated with license renewal. These comments are not within the scope of the environmental review and will not be evaluated further in development of the SEIS.

7. Other comments outside the scope of NRC's environmental review (OOS)

Comment L-1-OOS: I'm Ed Revell. Mayor Pro Tem for the City of Richland. And these are just more curiosity questions. What was the design life of the Columbia Generating Station and will you all be doing any special materials testing so you can evaluate certain kinds of equipment before you decide to go forward?

Response: These topics, design life and materials, are addressed in the NRC's safety review of the license renewal application and will be described in the staff's Safety Evaluation Report.

In the safety review, the staff examines EN's programs and processes designed to manage the effects of aging and ensure adequate protection of the public's health and safety during the 20-year license renewal period. This includes understanding component design life and may result in additional tests or inspections, as required. This is separate from the environmental review which focuses on the environmental impacts of license renewal rather than on technical issues related to reactor safety. However, safety issues become important to the environmental review when they could result in environmental impacts. For this reason, the environmental effects of postulated accidents will be considered in the SEIS. The NRC has codified regulations for conducting an environmental impact statement separate from the regulations for reviewing safety issues during its review of a license renewal application. The regulations governing the environmental review are contained in 10 CFR Part 51, and the regulations for the safety review are contained in 10 CFR Part 54.

Because the two reviews are separate, operational safety issues and safety issues related to aging are considered outside the scope for the environmental review, just as the environmental issues are not considered as part of the safety review. These comments are not within the scope of the environmental review and will not be evaluated further in development of the SEIS.

Comment M-1-OOS: Will the EIS process take into consideration the negative consequences for the region's power supply if the plant is not relicensed?

Response: The need for power is outside the scope of license renewal pursuant to 10 CFR 51.95(c)(2). The regulatory authority over licensee economics (including the need for power) falls within the jurisdiction of the states and to some extent within the jurisdiction of the Federal Energy Regulatory Commission. The proposed rule for license renewal had included a cost-benefit analysis and consideration of licensee economics as part of the NEPA review. However, during the comment period, state, Federal, and licensee representatives expressed concern about the use of economic costs and cost-benefit balancing in the proposed rule and the GEIS. They noted that the President's Council on Environmental Quality (CEQ) regulations interpret NEPA to require only an assessment of the cumulative effects of a proposed Federal action on the natural and man-made environment and that the determination of the need for generating capacity has always been the states' responsibility. For this reason, the purpose and need for the proposed action (i.e., license renewal) is defined in the GEIS as follows: The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by State, licensee, and, where authorized, Federal (other than NRC) decision-makers. Section 51.95(c)(2) of 10 CFR states that: The supplemental environmental impact statement for license renewal is not required to include discussion of need for power or the economic costs and economic benefits of the proposed action-except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation. Since the need for power is outside the scope of the environmental review, this topic will not be evaluated further in development of the SEIS.

Comment V-1-OOS: Dr. Barbara Harper of the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) responded to introductory remarks by asking if she could contact the Intergovernmental Liaison Branch to find out, for example, with whom to speak regarding (DOE Order) 435.1 rulemaking efforts. She stated that NRC dose limits differ from those of the DOE and EPA. She asked which dose limits they should use as the standard.

Response: There is an existing effort at NRC and DOE to implement rules that are complementary regarding dose limits. Part 61 rulemaking at NRC regarding waste classification will seek to rectify the discrepancy. DOE and NRC are in discussions to meet in 2011 regarding the issue. This comment is not within the scope of the environmental review and will not be evaluated further in development of the SEIS.

Comment W-1-OOS: Mr. Riggsbee, Yakama Nation, asked whether [PNNL's involvement in the Energy Park proposal] poses a potential conflict of interest because the NRC is using PNNL as a contractor in the license renewal review.

Response: Both the Atomic Energy Act of 1954, as amended, and NRC's implementing regulations require NRC to avoid, eliminate, and/or mitigate organizational conflicts of interest. In its proposal to NRC, the DOE laboratory provided information regarding all ongoing or proposed work (whether by the laboratory or by any contractor or subcontractor that the laboratory intends to use) in the same or similar technical area as the project Statement of Work. This information enabled NRC to determine whether any actual or potential organizational conflict of interest would exist if the NRC were to place the work with the laboratory through DOE. This information was reviewed carefully by several NRC staff qualified and trained in regulations regarding organizational conflicts of interest, as well as by the Office of General Counsel, for any conflict of interest that could call into question the soundness of the technical work product. Additionally, the NRC reviewed this information to identify any appearance of an organizational conflict of interest that could diminish the public's confidence in the NRC. As part of its standard contract review process, the NRC did not identify any organizational conflict of interest in using PNNL personnel for the Columbia license renewal environmental review. Given the commenter's specific reference to the Energy Park proposal, the NRC requested additional disclosure by PNNL to identify any other potential conflict of interest. PNNL has indicated that none of the PNNL personnel on the Columbia license renewal review had any involvement in the Energy Park proposal. Additionally, in order to mitigate the appearance of an organizational conflict of interest, the NRC requested that the laboratory forgo any work in the areas of health physics/human health and cumulative impacts where the NRC staff felt that there could be an appearance of an organizational conflict of interest. The SEIS is NRC's product, and the NRC staff has ultimate oversight of every subject area the SEIS describes, providing the NRC's assessment of the environmental impact of license renewal. However, the areas of health physics/human health and cumulative impacts were singled out and were entirely produced by NRC staff to remove any appearance of an organizational conflict of interest. This comment is not within the scope of the environmental review and will not be evaluated further in development of the SEIS.

Comment X-1-OOS: Dave Rowland, Yakama Nation, asked about Emergency Planning and expressed dissatisfaction with the level of interaction between EN and the Yakama Nation.

Response: Emergency planning is not within the scope of the license renewal as set forth in 10 CFR Parts 51 and 54, as it is addressed as a current licensing issue on an ongoing basis. The NRC has regulatory requirements in place under 10 CFR Part 50 to ensure that licensees have adequate emergency planning and evacuation programs in place in case of an accident/emergency scenario. Such plans are evaluated by the NRC and coordinated with the Federal Emergency Management Agency (FEMA) and local authorities for implementation. Drills and exercises are conducted periodically to verify the adequacy of the plans. Issues identified during such exercises are resolved within the context of the current operating license and are not reevaluated as part of license renewal. This comment is not within the scope of license renewal and will not be evaluated further in development of the SEIS.

References 10 CFR 50.

Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of Production and Utilization Facilities."

10 CFR 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." 10 CFR 54.

Code of Federal Regulations, Title 10, Energy , Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." Energy Northwest (EN). 2010. License Renewal Application, Columbia Generating Station, "Appendix E, Applicant's Environmental Report, Operating License Renewal Stage," ADAMS Accession No. ML100250666 National Environmental Policy Act of 1969 (NEPA). 42 U.S.C. 4321, et seq.

U.S. Nuclear Regulatory Commission (NRC). 1990. "Waste Confidence Decision,"

Federal Register, Vol. 55, p. 38472, September 18, 1990. U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants , NUREG-1437, Volumes 1 and 2, Washington, D.C., ADAMS Accession Nos. ML040690705 and ML040690738. U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final Report," NUREG-1437, Volume 1, Addendum 1, Washington, D.C., ADAMS Accession No.

ML040690720. U.S. Nuclear Regulatory Commission (NRC). 1999a. "Waste Confidence Decision Review:

Status," Federal Register, Vol. 64, No. 233, pp. 68005-68007, December 6, 1999. U.S. Nuclear Regulatory Commission (NRC). 2008. "Waste Confidence Decision Update,"

Federal Register, Vol. 73, No. 197, pp. 59551-59570, October 9, 2008. U.S. Nuclear Regulatory Commission (NRC). 2010. "Energy Northwest; Notice of Intent to Prepare an Environmental Impact Statement and Conduct the Scoping Process for Columbia

Generating Station," Federal Register, Vol. 75, No. 47, pp. 11576-11578, March 11, 2010. U.S. Nuclear Regulatory Commission (NRC). 2010a. "Summary of Public License Renewal Overview and Environmental Scoping Meetings Related to the Review of the Columbia Generating Station License Renewal Application (TAC Nos. ME3058 and ME3121)," ADAMS Accession No. ML101250540. U.S. Nuclear Regulatory Commission (NRC). 2010b. "Summary of Tribal Outreach Informational Meeting Concerning Columbia Generating Station License Renewal and Hanford Low-Level Waste," ADAMS Accession No. ML102630228. U.S. Nuclear Regulatory Commission (NRC). 2010c. Memorandum, "Staff Requirements - Affirmation Session, 8:45 a.m., Wednesday, September 15, 2010, Commissioners' Conference Room, One White Flint North, Rockville, Maryland (Open to Public Attendance)," ADAMS Accession No. ML102580229.

Comment Letters and Meeting Transcripts The following pages contain the comments, identified by commenter designation and comment number, from letters, public scoping meeting transcripts, and the informational meeting with tribal representatives conducted on April 27, 2010. A-1-SAM A B-1-PRO B-2-SOC C-1-PROC-2-GHG C-3-PRO D-1-PRO D-1-PRO, continued D-2-OTHD-3-PRO D-3-PRO, continued E-1-PRO E-3-SOC E-4-A LT E-2-GHG F-1-GHGF-2-SOC G-1-WST G-1-WST, continued H-1-PRO I-1-PRO I-1-PRO, continued J-1-GHG J-2-PRO K-1-OTH K-2-PRO K-2-PRO, continued K-4-OTH K-5-OTH K-3-OTH L-1-OOS M-1-OOS M-2-A LT M-2-ALT, continued M-3-ALT M-3-ALT, continued L-2-PRO L-3-A LTL-2-PRO, continued L-4-PROL-5-WST L-5-WST, continued N-1-SOC L-6-PRO O-1-PRO N-1-SOC, continued N-3-SOCN-2-GHG O-1-PRO, continued O-2-GHGO-3-PRO O-5-PRO O-3-PRO, continued O-4-PRO O-5-PRO, continued P-1-GHG P-2-A LT P-2-ALT, continued P-3-PR O Q-1-PRO R-1-PRO R-1-PRO, continued S-1-GHGS-2-PRO T-1-ALT T-2-PRO T-2-PRO, continued T-2-PRO, continued U-1-PRO U-1-PRO, continued (Please note: These written comments were also captured

orally in the evening meeting transcript with the same comment identifier codes) T-1-A LTT-2-PRO V-1-OOS Y-1-OTH Y-1-OTH, continued V-2-OTH V-3-OTH W-1-OOS X-1-OOS V-4-OTH V-6-OTH V-5-OTH V-4-OTH, continued V-7-OTH V-8-OTH V-9-OTH Z-1-PRO

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