ML063620423

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Comment (1) of K. A. Westlake on Behalf of EPA Re Generic Environmental Impact Statement for License Renewal of Nuclear Plant, Supplement 27: Palisades, Final Report, NUREG-1437
ML063620423
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/12/2006
From: Westlake K
Environmental Protection Agency
To:
NRC/ADM/DAS/RDB
References
71FR61806 00001, B-19J, EIS 20060432, NUREG-1437
Download: ML063620423 (3)


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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590 C,

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B-19J Chief, Rules Review 'and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, D.C. 20555-0001 Re:

Generic Environmental Impact Statement for License Renewal of Nuclear Plant, Supplement 27: Palisades Nuclear Plant, Van Buren County, Michigan, Final Report, NUREG-1437, EIS No. 20060432

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 (U.S. EPA) has reviewed the Generic Environmental In pact Statement for License Renewal of Nuclear Plahts, Supplement 27 (SEIS):

Palisades Nuclear Plant (Palisades), which is a final report. According to the SEIS, the current operating license for Palisades will expire on March 24, 2011. The proposed Federal action would renew the current operating licenses for an additional 20 years.

The U.S. Nuclear Regulatory Commission (U.S. NRC) developed the Generic Environmental Impact Statement (GEIS) to streamline the license renewal process on the premise that environmental impacts of most nuclear power plant license renewals are similar, in most cases.

U.S. NRC develops facility-specific supplements for individual plants as the facilities apply for license renewal. U.S. EPA provided comments on the GEIS during its development process--for the draft version in 1992, and for the final version in 1996.

Palisades is located in Covert Township, Van Buren County, Michigan, on the southeastern shoreline of Lake Michigan. The plant has a single pressurized light-water reactor. The maximum authorized power level of its reactor is 2,565 megawatts thermal. The plant's current net summer capacity is 786 megawatts electric. The plant is refueled on an 18-month cycle.

Palisades uses a ciosed-cycle'cooling system.

U.S. EPA' iubmitied cornmnents on the draft SEIS on May 26, 2006.We ra'sedthe fowing concerns ir'bur comment letter:-

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1.

Adequacy and clarity of information provided, 6'

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Methods and documentation for ri*.kestimnates,6

3.

Entrainment of fish and shellfish in early life stages, and

4.

Threatened and endangered species.

The SEIS indicates that Palisades' closed-cycle cooling system has a reduced intake flow rate as opposed to once-though cooling systems; therefore Palisades has a lower entrainment rate for fish and shellfish in early life stages. Based on our review of the SEIS, we withdraw our concerns about the entrainment of fish and shellfish in early life stages.

On December 6, 2006, we held a teleconference with U.S. NRC to discuss our concerns about the SEIS. In regard to our concerns about (1) the adequacy and clarity of information provided, and (2) determination of risk estimates, we suggested the SEIS include the following enhancements:

1.

Use plain language,

2.

Include cited data, in addition to referencing other documents,

3.

Address terrorism-related issues, and

4.

Replace the generic evaluation approach with a site-specific approach.

Representatives from U.S. NRC acknowledged these concerns and stated that there may be instances in which the SEIS should be more transparent and self-contained, in order to address public concerns. However, U.S. NRC representatives also stated that the content of their public documentation is subject to upcoming court decisions, internal guidance, etc. Therefore, although we retain our concerns about (1) the adequacy and clarity of information provided, and (2) risk estimates, we acknowledge that U.S. NRC may be required to limit its public disclosure for environmental documentation in accordance with certain restrictions. We look forward to discussing this issue further with U.S. NRC. Specifically, U.S. NRC plans to contact us with regard to:

1.

The impact of a Ninth Circuit Court decision and U.S. NRC's determination on U.S.

NRC's ability to publicly disclose-sensitive information, and.

2.

Whether summary information from a nuclear plant's latest annual radiological effluent release and waste disposal report should be included in a supplemental environmental impact statement.

With regard to our concerns about state threatened and endangered (T&E) species; during our December 6, 2006 teleconference, U.S. NRC representatives stated that the level of information available on state T&E species affected by proposed projects vary, depending on the individual state. U.S. NRC stated, for future environmental documentation, it will look for ways to work with the applicable state to garner the appropriate information for state T&E species. Therefore, although we retain our concern about state T&E species, we appreciate the efforts U.S. NRC will

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make for future projects.

As agreed in the December 6, 2006 teleconference, we',&Will contiiiue to coordinate withfU.S.

NRC on future environmental documentation, in order to maintain an open line of communication for these issues.

Thank you for the opportunity to review the SEIS. If you have any questions or wish to discuss any aspect of the comments, please contact Michael Murphy (for radiation issues) at (312) 353-6686 or Newton Ellens (for NEPA-related issues) at (312) 353-5562.

Sincerely, Kenneth A. Westlake, ief NEPA Implementation Section Office of Science, Ecosystems, and Communities cc:

Sara Schaefer, Management Unit Supervisor Plainwell Operations Service Center MichiganDepartment of Natural Resources r