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Scoping Comments Received on the Waste Confidence Generic

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Scoping Comments Received on the Waste Confidence Generic Scoping Comments on the Waste Confidence Generic Environmental Impact Statement This document accompanies the Waste Confidence scoping summary report (ADAMS Accession No. ML13060A128). Comment excerpts are listed below by category. Comments are identified by the comment identification number (correspondence number-comment number) and the name of the commenter at the end of each excerpt. Comment Category Page Number 1. Land Use ........................................................................................................................... 1 2. Socioeconomics ................................................................................................................ 1 3. Environmental Justice ...................................................................................................... 3 4. Meteorology and Air Quality .............................................................................................. 5 5. Hydrology .......................................................................................................................... 8 6. Aquatic Ecology ................................................................................................................ 9 7. Transportation of Spent Nuclear Fuel ............................................................................... 9 8. Nonradiological Health .................................................................................................... 12 9. Radiological Health ......................................................................................................... 12 10. Safety .............................................................................................................................. 19 11. Accidents ......................................................................................................................... 53 12. Security and Terrorism .................................................................................................... 66 13. Cost Considerations ........................................................................................................ 70 14. Cumulative Impacts ......................................................................................................... 73 15. Alternatives ..................................................................................................................... 74 16. Evaluation Scenarios ...................................................................................................... 98 17. NEPA Process .............................................................................................................. 129 18. Rulemaking Process ..................................................................................................... 176 19. Out of Scope ................................................................................................................. 182 1. Comments Concerning Land Use Comment: The EIS must include bounding estimates for...the worst case loss of agricultural land and production...(0286-54 [Curran, Diane]) 2. Comments Concerning Socioeconomics Comment: The EIS should rigorously explore all of the potential environmental impacts associated with long-term and indefinite storage of nuclear wastes at reactor sites following reactor shutdown, including ... the social and economic impacts on the communities where these nuclear wastes will remain indefinitely at sites where there are no operating reactors. (0275-11 [Brock, Matthew] [Sipos, John] [Sorrell, William H.]) Comment: In addition, there are important, and site-specific, economic implications of the indefinite storage of spent fuel at reactor sites. Property in the vicinity of the plant will have its potential uses and value impacted by the continued presence in the neighborhood of all the downside risks of a nuclear reactor - enormous quantities of highly toxic nuclear wastes and the risks of accidental or malevolent events causing a release of that waste - without any of the -2- benefits of an operating nuclear reactor generating tax revenue, income, and jobs, all of which are frequently cited by NRC as counterbalances to the adverse impacts of nuclear plants. (0275- 3 [Brock, Matthew] [Sipos, John] [Sorrell, William H.]) Comment: The EIS should also take into account the continued, indefinite presence of the ISFSI and what that means for host communities like the City (Red Wing, Minnesota). (0291-2 [Harlan, Thomas]) Comment: Socioeconomic Factors and Impact. The EIS, consistent with NEPA principals, should address a number of different socioeconomic factors that the continued dry cask storage will have on human environment. (0291-21 [Harlan, Thomas]) Comment: With this growing number of dry casks accumulating at the PINGP (Prairie Island Nuclear Generating Plant), a significant new burden has been placed upon the City (Red Wing, Minnesota). With the current and unprecedented uncertainty regarding the final disposition of spent fuel the City is greatly concerned about the spent fuel's current and future impacts. Additionally, as a result of the stranding of the spent fuel the City will be obligated to maintain a high level of public safety services. However, the City, the Company (should it retain the land), or any other owner will not be able to recapture and develop the area to its highest and best use. This will deprive the City of its natural growth and the potential tax revenue that will come from the same. (0291-22 [Harlan, Thomas]) Comment: Finally, as roads, bridges, and other infrastructure are constructed and placed in service over the next 60, 100 and 200 years, the ISFSI [at the Prairie Island Nuclear Generating Plant] will have to be accommodated. This will require going around it and departing from normal, customary planning and development patterns. (0291-23 [Harlan, Thomas]) Comment: It should incorporate a firm economic analysis (including such factors as individual and business threshold analysis for a viable economic entities, economic activity overall), as well as income, employment, and taxes being generated. In addition, it should evaluate the social and cultural aspects of the same by valuating population and demographic changes, changes in lifestyle, stability in the community, land use patterns, and public safety and health. It should then trend this information forward and analyze it in a both positive and negative assessment, including a number of other factors including agriculture, residential, government activities and expenditures, manufacturing and industrial, financial and real estate, as well as tourism and recreation. (0291-24 [Harlan, Thomas]) Comment: The other big thing that I believe must be considered in scope is states’ rights. Since the original siting for nuclear plants was done with an understanding that the waste would be removed and handled by the federal government and not left on the site indefinitely, as -- which it now will be, at least for the long term as we foresee, and that significantly changes the states’ responsibility, and it’s a new use of the land. (0004-25-15 [Shapiro, Susan]) Comment: Therefore it may have tax implications...(talking about state's rights vs. Federal government). (0004-25-16 [Shapiro, Susan]) Comment: All States must be included as cooperating and involved agencies as a change in the Waste Confidence Rule to allow for interim or long term, 60 year storage of high level nuclear waste which was not contemplated or approved by the States in the original approvals granted by the States for use of state lands and waters. Interim or long term dry cask storage of -3- nuclear waste is essentially a new use of the State lands and creates much greater and continuing threats to the surrounding reactors communities. (0296-11 [Shapiro, Susan]) 3. Comments Concerning Environmental Justice Comment: We oppose nuclear waste dumps. A general waste confidence rule would be based on finding one or more waste dumps which would be located in economically stressed communities. Potential sites would be in the southeast, such as Savannah River or on Native American land such as Yucca Mountain. We will continue to oppose them on the basis of environmental justice. (0004-14-4 [Zeller, Lou]) Comment: Pilgrim is located close to Native American Wampanoag communities on Martha’s Vineyard and Mashpee, of whom have an interest in the environmental impacts of the long-term waste storage. (0004-23-4 [Sheehan, Margaret]) Comment: The question, how the NRC could conduct an environmental justice analysis generically and environmental justice issues and concerns are by their very nature site specific? (0004-4-4 [Johnson, Ron]) Comment: For too long the poor, rural, native and other vulnerable groups have been forced to accept or bribed into letting dangerous substances inhabit their states and neighborhoods. Please be certain this does not happen. (0041-3 [Kersting, John]) Comment: And the last thing I'll mention, we talked about environmental justice today, but I would put forward that NRC should include in its considerations the issue of generational justice. (0118-17-13 [Kamps, Kevin]) Comment: I was prompted by, I believe Lou Zeller's mention of environmental justice. That issue should certainly be within the scope of this proceeding. NRC, itself, unfortunately is guilty of environmental justice violations. And I point to the Skull Valley Goshutes Indian Reservation in Utah, where NRC granted a construction and operating license, I believe it was in 2006, to private fuel
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