ML050050445
| ML050050445 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/08/2004 |
| From: | Ellens N Environmental Protection Agency |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 69FR57366 00004, NUREG-1437 S20 | |
| Download: ML050050445 (7) | |
Text
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UNITED STATES ENVIRONMENTAL PROTECtION AGENCY REGION 5
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DEC-08-2004 17:41 FROM:US EPA REGION 5 312 353 S374 TO:913014152e02 F. 2'7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD e,
z CHICAGO. IL 60604-3590 DEC U 8 2004 REPLY TO THE ATrEU7ZON OF:
B-19J Chief, Rules Review and Dircctives Branch U.S. Nuclcar Regulatory Commission Mail Stop T6-D59 Washington, D.C. 20555-0001 Re:
Generic Environmental Impact Statement for Licensc Rencwal of Nuclear Plant, Supplement 20: Donald C. Cook Nuclear Plant, Units No. I and 2, Indiana and Michigan Power Company (t&M), Draft Report, NUREG-1437, EIS No. 040452
Dear Sir or Madam:
In accordance with Section 309 of the Clean Air Act and the National Environmental Policy Act (NEPA), the U.S. Environmental Protection Agency (EPA) has reviewed the Gencric Environmental Impact Statement for Licensc Renewval of Nuclear Plant, Supplement 20 (SETS):
Donald C. Cook Nuclear Plant (Cook Nuclear Plant), Units No. 1 and 2 (Cook Units 1 and 2),
which is a draft report. According to the SEIS, the current operating licences for Cook Units I and 2 will expire on October 25, 2014 and December 23, 2017, rcspectively. The proposed Federal action would renew the currcnt operating licences for an additional 20 years.
The Nuclear Regulatory Commission (NRC) developed the Generic Environmental Impact Statement (GEIS) to streamline the license renewal process oii the premise that environmental impacts of most nuclear power plant license renewals are similar, in most cases. NRC develops facility-specific SEISs for individual plants as the facilities apply for license renewal. EPA provided comments on the GEIS during its development process-for the draft version in 1992, and for the final version in 1996.
The Cook Nuclear Plant is located in Lake Charter Township, Bcrrien County, Michigan, on the southcastern shoreline of Lake Michigan. Cook Units I and 2 are pressurized light-water reactors. Cook Unit I produces a reactor core power of 3304 megawatts-thermal, and has a design net electrical capacity of 1044 mcgawvatts. Cook Unit 2 produces a core power of 3468 megawatts-thermal, and has a design net electrical capacity of 1117 megawatts. Each unit is refueled on a 18-month cycle; this is done by refueling an altemate unit each year. The condenser cooling system for Cook Nuclear Plant is a once-through circulating water system that draws and discharges to Lakc Michigan.
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DEC-OG-2004 17:41 FROMW:US EPA REGION 5 312 533~ 5374 TO: 913014152W22 Based on our review of the Cook Nuclear Plant draft SEIS, we have given the project an EC-2 rating. The "EC" means that we have environmental concerns with the proposed action, and the "2" means that additional infornation needs to be providcd in the final SEIS. Our concerns relate to:
- 1.
Information provided on radiological impacts,
- 2.
Adequacy and clarity of the information provided,
- 3.
Risk estimates, and
- 4.
Entrainment of fish and shellfish in early life stages.
We have enclosed our comments and the U.S. EPA rating systcm summary.
Tf you have any questions or wish to discuss any aspect of the comments, please contact Newton Ellens orfmy staff at (312) 353-5562.
Sincerely, Hi Kenneth A. Westlakc, Chief NEPA Implementation Section Office of Scicnce, Ecosystems, and Communities Enclosures 2
DEC-28-2004 17:41 FROM:IJS EPA REGION 5 312 353 5374 TO: 9123814115200P P. 4/7 U.S. Environmental Protection Agency Comments on Generic Environmental Impact Statement for License Renewal of Nuclcar Plant, Supplement 20: Donald C. Cook Nuclear Plant, Units No. I and 2, Draft Rcport, NUREG-1437
- 1.
Section 2.1.3, Cooling and Auxiliary Water Systems, page 2-7. Last paragraph equates 104m' Is to 2369 million gpd. This calculation would appear to be inaccurate. The actual value would be closer to 2373 million gpd. An explanation for this amnount of variation needs to be provided.
- 2.
Section 2.2.7, Radiological Impacts, pages 2-54, 2-55, last paragraph. The references to the environmental standards nced to be more complete citations including title of the rule or regulation, along with the basic standard for comparison. All of the environmental standards that could be uscd for a comparison should be used, including 40 C.F.R. 61 Radionuclide National Emission Standards for Hazardous Air Pollutants values. This will allow the reader to understand which citations are being referenced and to verify values that are cited in the text.
- 3.
Section 3.0 EnvironmzenitalImpacts ofRefurbishiment, page3-2, Table 3-1.. Under the section on Human Health, specific information supporting any assertions that this area "needs no further evaluation" needs to be presented or more completely cited and described.
- 4.
Section 4.2.2, Electromagnetic Fields - ChIronic Effects, page 4-25, should provide the reference to the National Institute of Environmcntal Health Sciences wcbsite for further information on this topic.
- 5.
$eciion 4.3, Radiological Impacts of Nornal Operations, page 4-26, 4-27, Table 4-7, and paragraph 3. The specific values for exposure need to be provided in addition to the complete citation ofthe source of this information. This will help to provide the reader with a clearer understanding of the infonnation, rather than relying on a citation only, which then must be reviewed to verify the standard being cited.
- 6.
Section 4.8.3, Cumulative Radiological mnpacts, page 4-48, Paragraph 1. Information or procedures used to generate values to support the assertions and conclusions in this section need to be provided more clearly to reduce the possibility of misunderstandings.
- 7.
Section 5.2.2, Estimate of Risk, page 5-6. The Supplemental Environmental Impact Statement (SEIS) states, 'Tne baseline core damage frequency (CDF) for D. C. Cook Nuclear Power Plant (Cook Nuclear Plant) is approximately 5.0 x 1 O-5 per year, based on internally-initiatcd events. T&M did not include the contribution to CDF from external events in these estimates even though the risk from cxtermal events is significantly higher for Cook Nuclear Plant, than risk from internal events." In order to produce an accurate
DEC-28-2004 17:41 FROMW:uS EPA REGIOtl 5 312 353 5374 TO:913014152002 P.5'7 risk calculation for this case, we believe that the final SEIS should include risk estimates from external events. If the final SEIS does not include these risk estimates, then it should explain why they were omitted from the risk calculations.
- 8.
Section 6.1, The Uranitumn Fuel Cycle, page 6-3. Under the bullet point for Of frsite radiological impacts (individual effects from other than disposal of spent fucl and high level waste disposal), no consideration appears to be given to the potential long tcrm storage of the spent fuel and high level waste materials on site until such time as a permanent facility is finally licensed and begins to accept these materials for disposal. A reference to other sections where this evaluation is included should be provided here as well as other sections. If this evaluation has not been adequately done, the issue needs to be considered, and an evaluation conducted.
- 9.
Section 6.1, The Uranium Fuel Cycle, page 6-8 Under the bullet point for On-Site Spent Fuel. A more thorough evaluation for the volume of spent fuel expected to be generated during the addition licensed time needs to bc provided, along with more specific information as to site specific circumstances that may impair or improve the risk values for potential exposures to this spent fuel.
- 10.
Section 7.1, Decommissioning, page 7-2, Under bullet point Radiation Doses. As the GETS is based on a forty-year licensing period, an extension of another twenty years would have an impact that needs to be quantified and reported. This information should bc included specifically in the SEIS as part of the risk that would be associated with the license extension. The specific methodology needs to be provided and explained.
II.
Section 8.1, No-Action Alternative, page 8-5, under the bullet point Human Health. The actual value representing the cited percent value should be specifically provided in addition to the citation. This will help the reader understand the actual valuc(s) being specified.
- 12.
Section S.2. 1. 1, Closed-Cycle Cooling Sysicmn, page 8-1 9, under the bullet Uranium and thorium. A better comparison or quantification of the relative concentrations of the uranium and thorum to the background lcvels needs to be provided. As is, this presentation can lead to misunderstanding and confusion.
- 13.
Section 8.2.1.1, Closed-Cycle Cooling System, page 8-20, Under bullet point Human Health. Any dose estimate that would have the potential to fall in the risk range of 1 a, to 10' or greater needs to be specifically evaluated for potential regulatory requirements or risk impacts to the public health. This should be estimated conservatively using the data that is currently available or that can be logically cxtrapo Waed from currently available information.
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DEC-08-2004 17:41 FROMi:US EPA REGIONI 5 312 353 537.
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- 14.
Section 8.2.3. 1, Closed -Cycle Cooling System, page 8-44, Under bullet point Waste Wastc impacts need to be specified, rather than merely referenced to provide a clearer understanding of the risk detemiination made in this section of the document.
- 15.
Section 8.2.3.1, Closed -Cycle Coolingtysremn, page 8-44, Under bullet point Human Health. Human-health impacts nccd to be specified, rather than merely referenced to provide a clcarer understanding of the risk determination in this section of the document.
- 16.
We arc concerned about tle cntrainrnent of fish and shellfish in early life stages. Under a U.S. Environmental Protection Agency rule, codified in 40 C.F.R. § 125 (U.S. EPA ruie),
Cookl Nuclear Plant is required to reduce its entrainment of fish and shellfish in carly life stages. According to the SETS, certain measures already in place ("e.g., an offshore intake located where there are no bays or points to act as fish nurseries or other attraction features...and no substantial unique spawning grounds that occur in the plant arca") are expected to provide mitigation for impacts related to entrainment. Under the U.S. EPA rule, Cook Nuclear Plant is required to choose one of five compliance alternatives to rcduce entrainment, and the compliance alternative must meet a regulatory performance standard. However, the SETS is not clear about how the proposed mitigation measures function as a compliance alternative, nor does the SEIS indicatc a targeted perforrnance standard. The final SETS should provide this information.
3
DEC-08-2004 17:42 FROM:IUS EPA REGION 5 3712 353 5374 T0:912014152e02 P.7/,7 SUMMIARY OF RATING DEFINITIONS AND FOLLOW UP ACTION' EnIronmental Inpact or (lie Action LO-Tack of Obrecticns
'The EPA teview bas not identificd any potentiul environmental impacts requiring substantive changes to thc ptoposal. The review may have disclosed opportunities for application of mitigation measures that could be accomplishcd with no more than minor changes to the proposal.
EC-Environnicrtal Concerns The IEPA revicw has identified cnvironn'ental impacts that should be avoided in ordcr io fully protect the environmcnt. Correctivc errasures may require changes to thc preferred alternative or application of rairigation measurcs thatcan reduce tl.e environmental impacts. EPA would like to wo.lk with the lead agency to reducc these impacts.
EO-Environmental Oblectiom Thc EPA review bhs idenrified significant environmental impacts that must be avoided in order to provide bdkquaie protection for the crvironment( Corrective measures may require substantial changes to the prclerred alternative or constdcration of somc other project altesnative (including thc no action alternative or a new alternative). EPA inmends to wiorkl with the lead agency to reduce thcsc impacts.
'fLU-TFhnViTonrnentallv iJnsatisfactory The EPA review has identified adverse environmcntal impacts d.at are of sufficient magnitude tbat they are umsatisfaciozy.from the standpoint of public health or welfarc or environmental quality. EPA intends to work, with the lead agency to reduce these impacts. If the potential un."tisfacrory impacts are not corrected at the final EIS sate, this proposal will be recommended for trcfrnl to the CEQ.
Adequacy of the Impact Statement Caregon' l-Adeouate ITh-EPA belheves the draft ETS adequately scts forth the environmental impact(s) of the preferred alterative and thote of the altzrnatives reasonably available to the project or action. No further analysis or data collecting is necessary, but the Treiewer may suggest the addition of clarifying language or information.
Cteeorv 2-4nsufficien Information
'The draft EMS does not contain sufficient informartion for the FPA to fully asscss the environmental impacts that should be a voided in order to fully protect thc environment, or the EPA revicwer has identified new reasonably availablc iiternmtives that arc within tie spcctrum of alterrativcs analyzed in the draft ETS, which could rcduce the cnvironmental impacts of the action. The identified additional information, data, analyscs, or discussion should be included in the final EIS.
(, atecorv 3-4nad-cuate EPA does not believe that the draft EIS adequately assesses potentially significant environrmanetal impacts of the action, or the EPA reviewer his identified new, reasonably available alternatives that are outside of the spectiunn of alternativcs analy7ed in the ilraft LIS, which should be analy2cd in order to reduce the potentially significant cnvironmental impacts. EPA believcs that the identified additional infonrmtion, data analyses, or discuissions are of such a magnitudc thal they should have full public review at a draft stgc. EPA does not believe that th dr3fl EIS is anequate for the purposes of the NEPA and/or Section 309 review, and thus should be formally revised and rsde available for public comnmnt in a supplemental or revised draft ETS. On the basis of the potential significant impacts involved, this proposal could be a candidatc for referral to the CEQ.
'Frarn LPA M:Lniila Vi40 Policy nnJ idPrucduiv t;.r dic Review Or the Federal Actiorns Impactiing the Envimnrrent