ML103200492

EPA Comments on Duane Arnold License Renewal Final SEIS

ML103200492
Person / Time
Site:	Duane Arnold
Issue date:	11/15/2010
From:	Cothern J Environmental Protection Agency
To:	Lesar M Rulemaking, Directives, and Editing Branch
References
NUREG-1437 S42
Download: ML103200492 (2)

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UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY REGION 7 901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101 Michael T. Lesar, Chief Rulemaking and Directives Branch Division of Administrative Services Office of Administration TWB-05-BO 1M U.S. NuclearRegulatory Commission Washington, D.C. 20555-0001,

Dear Mr. Lesar:

RE: Review of the Generic Environmental Impact Statement.fdr'License.'Renewal of Nuclear Plant~sNUREG-143'7, Supplement 42, Regarding Duane Arnold Energy Center, Final Report for Comment The U.S. Environmental Protection Agency has reviewed theNuclear Regulatory Commission's Generic Environmental Impact Statement, Supplement 42, for the Duane Amold Energy Center Final Report. Our review is provided pursuant to the National Environmental Policy, Act (NEPA) 42, U.S.C. 4231, Council on Environmental Quality regulations 40 C.F:R.

Parts 1500-1508,, and, Section 309 of the Clean Air Act. The GELS, Supplement 42, was assigned the CEQnumber'20100409.

The NRC'is proposing to renew ,the license of the Duane Arnold Energy Center (DAEC),

for-an additional20 yearsbeyond the expirationdate of the'facility's current 40-year license which is February 21, 2014. The ,facility is located in Linn County, Iowa, on the western bank of the Cedar River approximately 5.7 rmiles westnorthwest of the city of Cedar Rapids and just less than 50 miles :east-northeast of the Sac and Fox Tribe, Meskwaki Settlement.

EPA had issued arating of the draft Supplemental Environmental Impact Statement' for this project EC-2 (EnVironmehtal Concerns-Insufficient Information) onApril 16, 2010. This EC-2 rating was based on the uncertainty of potenitialimpacts to aquatic resourcesnear the Duane Arnold Energy Center (DAEC) and the evaluation of 'alternatives to DAEC, license renewal.

EPA Region 7 NEPA staff havereviewed your responses to our individual comments contained in Appendix A and we appreciateyour consideration of each ofthese issues. EPA has no issue-specific disagreements&with NRC responses' or your issue-specific decisions to make revisions to Supplement 42. EPA does note, however, some issues could be more thoroughly examined and disclosed, but are-truncated by~the GEIS/SEIS regulatory framework. We would like to strongly encourage the NRC to reconsider its.treatment and coverage of many of these individual issues in its Generic Environmental Impact Statemenit for License Renewal of Nuclear Plants, NUREG-1437 (GELS) and in .facilitY-.spieific 'SupplementalEnvironmenital Impact RECYCIE:*

Statements such as Supplement 42. We believe that there are many aspects to facility operation and potential impact in the context of an ofien unique, local environmental milieu which~should.

be characterized. and assessed in.detail within each SEIS that are presently and: routinely dismissed as Category I issues. In :addition, much of this local setting changes physically and biologically over a 40 and 20 year license lifetime. The brevity with which many facility-specific structuraLand operational aspects and site-specific natural features are characterized in each SEIS renders revieW of these documents by public agencies and .the general public to be largely perfinctory. Many'of the:remaining site-specific issues, which are not dismissed by the NRC as:Category I are often,condensed in coverage, within the SEIS and dismissed upon NRC staff determination as insignificant in impact~or effect. Whereas.it is clear to us that much data.is collected, particularly through each facility's Radiological Environmental Monitoring Program (REMP), there isý a.discontinuity 'inthepresentationofthosezdata and their relevance withineach SEIS..,. Finally,. EPA-reasserts the need for ecologically-based benchmarks to assessradiological risk to aquatic and terrestrial communities. at each site. The assumption that a lack of significant risk ,from radiological exposUreto the human community, can be extrapolated to serve as the basis for determining the risk to other.biological communities is~not adequately supported.

We appreciate the.opportunity to provide comments regarding this project and the NRC's process of licenserenewal. If you have any questions,, please contact me at (913) 551-7148, cother. oea epa. gov.

Sincerely, L Joseph E. Cothern NEPA Team Leader Environmental Services Division cc: Marthea Rountree, OECA/OFAINCD