ML091070269

EPA Comment on the Cooper Nuclear Station License Renewal Application

ML091070269
Person / Time
Site:	Cooper
Issue date:	04/16/2009
From:	- No Known Affiliation
To:	Sayoc E Division of License Renewal
References
Download: ML091070269 (2)

Text

Emmanuel Sayoc From: CooperEIS Resource Sent: Thursday, April 16, 2009 1:39 PM To: Emmanuel Sayoc

Subject:

FW: Scoping Comments for Relicensing of Cooper Nuclear Station, Brownville, NE

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Original Message -----

From: Shepard.Larry@epamail.epa.gov [1]

Sent: Friday, March 27, 2009 4:59 PM To: CooperEIS Resource Cc: Cothern.Joe@epamail.epa.gov; Hooper.CharlesA@epamail.epa.gov; Dunn.John@epamail.epa.gov; Lancaster.Kris@epamail.epa.gov

Subject:

Scoping Comments for Relicensing of Cooper Nuclear Station, Brownville, NE RE: Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process for Cooper Nuclear Station; Federal Register Volume 74, No. 15, January 26,2009, page 4476.

Thank you for the opportunity to provide scoping comments on the proposed relicensing of Cooper Nuclear Station (CNS), in support of the U.S. Nuclear Regulatory Commission's (NRC) preparation of an Environmental Impact Statement (EIS). EPA reviewed this project in accordance with the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act. We request that, in the future, the NRC provide an adequate period of time after conducting site audits for the submission of scoping comments by state or federal agencies. In this instance, scoping comments are to be submitted prior to the NRC site audit for this project.

Pleased consider the following comments during the EIS development process.

Radiation - Given the uncertainty involved with licensing the Yucca Mountain Nevada facility and the extremely long time-frames needed to secure Congressional approval and complete site preparation for any possible alternative permanent site for the disposal of spent nuclear fuel, all utilities planning on extending operation of existing nuclear units should consider contingencies for long-term storage of waste on-site.

Water Quality - The current CNS site has an existing infrastructure, which includes intake and discharge structures. The source of water for the plant is the Missouri River. Potential impacts to plant operation associated with available river flow, particularly during periods of sustained low flow, should be thoroughly described in the

.draft EIS. The draft EIS should articulate the assurance of a long-term water supply (i.e., greater than 20 years) for the operation of the reactor. This analysis should address contingencies created by changing regional climate and potential future changes in the operation of the river by the Army Corps of Engineers (i.e., flow I.

releases). The current facility is covered by a National Pollutant Discharge Elimination System (NPDES) permit issued by the Nebraska Department of Environmental Quality (NDEQ). New studies and analyses performed in support of the most recent permit application (e.g.,

thermal and chemical discharges) should be included in the draft EIS.

The draft EIS should also completely discuss issues associated with entrainment and impingement of aquatic organisms (i.e., Section 316b of the Clean Water Act) and include alternatives to the present intake design. From a review of the Environmental Report, it is apparent that there is a great deal of information available regarding the impact of plant operation on the river ecosystem.

However, we generally caution that these studies are 30 years old and the draft EIS should clearly articulate whether these data are representative of current river condition and ecological impact. We would expect the NRC to provide both its reasoning and data supporting that additional and more recent research is not required to adequately document current impacts.

The draft EIS should thoroughly characterize past contamination associated with the operation of CNS, particularly source and fate of tritium in the system, and document current condition of surface water and groundwater upstream and downstream from the site.

Environmental Management System - The Council on Environmental Quality (CEQ) published "Aligning NEPA processes with Environmental management Systems-A Guide for NEPA and EMS Practitioners" to improve NEPA implementation and environmental sustainability goals in NEPA and Executive Order 13423. The NEPA document should discuss EMS as appropriate.

Larry Shepard NEPA Team/Interstate Waters US EPA Region 7 913-551-7441 2