ML092240578
| ML092240578 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 08/03/2009 |
| From: | Magerr K Environmental Protection Agency |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 74FR31772 00001 | |
| Download: ML092240578 (2) | |
Text
'HUES "L UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III ', I.
1650 Arch, Street Philadelphia, Pennsylvania 19103-2029 August 3, 2009 Chief, Rulemaking, Directives, and Editing Branch U.S. NRC Mail Stop T6-D59 Washington, D.C. 20555-0001 RE: Final Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 37 Regarding Three Mile Island Nuclear Station, Unit 1 June 2009 CEQ #20090218
Dear Sir:
The U.S. Environmental Protection Agency (EPA), Region 3, reviewed the Final, Environmental Impact Statement (FEIS) for the above-referenced document pursuant to: the, National Environmental Policy Act (NEPA), Council on Environmental Quality (CEQ) regulations (40CFR Parts 1500-1508), and Section 309 of the Clean Air Act. The FEIS was prepared in order to assess the potential impact. related to the license renewal for the Three Mile Island, Nuclear Station, Unit 1 (TMI-1) for an additional 20-year period..
'During the extended license period, the facility owners or operators may be required to undertake refurbishimienf activities,, or, for economic or safety reasons, may choose to perform such. activities. Replacement of the'pressurized-water reactor stream generators, among other thiggs,; 'is infcluded as part of the refurbishment activities. Exelon Generation Company, LLC (the facility owner/operator) plans to replace the two generators at the facility with new, once-through, enhanced stream generators. According to the Draft Generic Environmental Impact Statement, the transportation process associated with these two generators may include dredge and fill activities, temporary or permanent removal of route interferences (such as narrow tunnels, andlowmhanging overhead wires), temporary redirecting of streams, cofferdams, and weight-bearing modification to bridges, Based on the l.imited information included regarding impacts related to the generator transportation process, EPA rated the Draft Environmental Impact Statement (DEIS) as and EC-2 (Environmental Concerns, and adequacy of the impact statement as 2 - InsufficientInformation). A description of our rating system can be found at:
http ://iHwww.epa.gov/compliance/nepa/comments/ratings.html.
While the FEIS provides, among other things, additional details on bridge modifications and possible by-passes over the Pequea, Chiques, Conowingo and Conoy Creeks, it continues to be deficient in presenting the environment impacts associated with these construction activities.
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EPA recommends that the NRC continue to work with the project sponsor, as well as appropriate state and federal agencies, to identify and quantify these impacts. Every effort shall be made to avoid, minimize and mitigate these impacts.
In an effort to minimize construction emissions EPA is recommending the,following typical Best Management Practice (BMPs).
Utilize appropriate dust suppression methods during on-site construction activities.
Available methods include application of water, soil stabilizers, or vegetation; use of enclosures, covers, silt fences, or wheel 'washers;and suspension of earth-movement actiyities during high wind conditions; -_.
- Maintain a speed of less than 15 mph with construction equipment on unpaved surfaces as well as utilize fuel' with lower sulfur content;
- Employ a construction management plan in order to minimize interference with regular motor vehicle traffic;
- Use electricity from power poles instead of generators whenever possible;
- Repair and service construction equipment according to the regular maintenance schedule recommended for each individual equipment type;
- Incorporate -energy-efficient supplies whenever feasible.
Thank you for the opportunity to offer these comments. If you have any questions, please contact me at (215) 814-5724.
Sincerely, Kefn Magerr Environmental Engineer