ML072960360

Comment (17) of Grace Musumeci, on Behalf of the Environmental Protection Agency Re Indian Point Nuclear Generating Station, Units 2 & 3 License Renewal

ML072960360
Person / Time
Site:	Indian Point
Issue date:	10/10/2007
From:	Musumeci G Environmental Protection Agency
To:	Rulemaking, Directives, and Editing Branch
References
72FR45075 00017
Download: ML072960360 (2)

Text

A 0svgS 4 r' E W I =` +1q P R 0i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEW YORK, NY 10007-1866 OCT 1 0 2007 Chief, Rules and Directives Branch Division of Administrative Services Mailstop T-6D59 U.S. Nuclear Regulatory Commission Washington, D.C. 20555~k/' .7'U Ti'-S m 10-*11 RE: Indian Point Nuclear Generating Station, Unit Nos. 2 and 3 License Renewal

Dear Sir or Madam:

The Environmental Protection Agency (EPA) has reviewed the environmental report contained in the Indian Point Nuclear Generating Unit Nos. 2 and 3 -License Renewal Application, attended the afternoon environmental scoping meeting on September 19, 2007, and is providing the following scoping comments.

Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC has prepared anapplication to the U.S. NuclearPRegulatory Commission (NRC) to renew the operating licenses for Indian Point Units 2 and 3 (IP2 and IP3) for twenty years beyond the end of the current license terms.' Unit 1 is not operational, and is in a safe storage mode. The Indian Point Nuclear Generating Station is located on. the Hudson River in Buchanan, New York.EPA requests that the following issues be discussed in the environmental impact statement for these license renewals:

..-..1. A full discussion of the purpose and need to relicense Indian Point Units 2 and 3, quantifying energy demand and the need for such facilities in the region.2. A management plan for the spent fuel pools, and other means of storage of spent fuel that will span the relicensing period.3. An evaluation of the leaks from the spent fuel pools, including the possible impacts to groundwater, and future actions to ensure that the leakage is stopped.4. An analysis of the impacts of intentional destructive acts (e.g., terrorism).

The requirement to consider such acts is based on the Ninth District Court's decision in San Luis Obispo Mothers for Peace v. Nuclear Regulatory Commission (June 2006).5. The inclusion and analysis of all new seismological data on the. project area gathered.since the Indian Pointf Generating Station was constructed.-:,,.

6. Ani evaluation of the alternatives to the proposed project, including reasonable alternatives not within the jurisdiction of the lead agency. As the facility impacts aquatic* 6'- Internet Address (URL) 9 http://www.epa.gov Recycled/Recyclable

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~~~~3 (/P zc,9V / K)~cW52 /4 life by impingement and entrainment of fish and shellfish in cooling water, EPA recommends that several cooling alternatives be explored within the draft SEIS.7. A comprehensive evaluation of cumulative, indirect, and secondary impacts. The cumulative impacts analysis should consider the environmental impacts of the project as a whole, and, if any, as one of a number of the other proposed and/or approved actions in the area that would have the potential to impact the same resources.

8. In 1993, the Council of Environmental Quality guidance, Pollution Prevention and the National Environmental Policy Act, encouraged federal agencies to include the concepts of pollution prevention in EJSs during the scoping alternatives analysis, mitigation measure development, and decision-making processes.

Thank you for the opportunity to comment. If you have any questions concerning this letter, please contact Lingard Knutson of my staff at (212) 637-3747.Sincerely yours,Grace Musumeci, Chief Environmental Review Section Strategic Planning and Multi-Media Programs Branch 2