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Environmental Impact Statement - radioactive monticello

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Appendix A<br />

A.2.12<br />

Comments Concerning Socioeconomic Issues<br />

Comment: Page 4-32, Line 8: Add "In the bounding analysis, Monticello assumes..." This<br />

should eliminate any confusion with 4-31, line 25. (F-17)<br />

Response: The text in Section 4.4.2 of this SEIS has been changed based on the information<br />

provided in this comment.<br />

Comment: Page 4-35, Line 27: Change "procedures that will be in place" to "procedures that<br />

are in place". (F-1 8)<br />

Response: The text in Section 4.4.5 of this SEIS has been changed based on the information<br />

provided in this comment.<br />

A.2.13<br />

Comments Concerning Cumulative <strong>Impact</strong>s<br />

Comment: Page 4-48, Line 16-17: Change sentence to read: 'Three other wells have an<br />

annual usage of under 1.9 gpm and do not require appropriations permits." (See page 2-16)<br />

(F-20)<br />

Response: The text in Section 4.8.5 of this SEIS has been changed based on the information<br />

provided in this comment.<br />

Comment: We are concerned that the Draft SEIS does not discuss potential power uprates at<br />

Monticello or estimate resulting increases in radiological emissions, spent fuel, and other<br />

emissions. We recognize that NRC's regulations (10 C.F.R Section 51.53(c)(2)) state that an<br />

applicant's environmental report need not discuss the demand for power, and we are not asking<br />

for an assessment of need. Separate from purpose and need, we consider power uprates to be<br />

reasonably foreseeable actions that contribute to a cumulative radiological impact, under 40<br />

C.F.R Section 1508.7, and therefore should be discussed in NRC's final SEIS. (H-i)<br />

Response: The Commission has stated that for NEPA purposes, a possible future action<br />

"must at least constitute a proposal pending before the agency" for it to be considered along<br />

with the proposed action, which here is license renewal. The Commission's decision was set<br />

forth in the following case: Duke Energy Corp. (McGuire Nuclear Station, Units 1 and 2;<br />

Catawba Nuclear Station, Units 1 and 2) CLI-02-14, 55 NRC 278,294-297 (2002). Since NMC<br />

does not at this time have a proposal pending before the NRC that relates to a power uprate for<br />

Monticello, the SEIS does not address future power uprates in the evaluation of the impacts of<br />

license renewal on individual issues or on cumulative impacts. In addition, the Commission in<br />

the aforementioned case stated that, for the license renewal action and a separate proposal<br />

(such as a power uprate application) to be considered together, both actions must be<br />

"interdependent," such that one cannot go forward without the other. -License renewal does not<br />

depend on a power uprate, and a power uprate does not depend on license renewal; each<br />

action has separate utility. Should a power uprate amendment for Monticello be filed, the staff<br />

August 2006 A-49 NUREG-1 437, Supplement 26

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