ML11307A387
| ML11307A387 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/25/2011 |
| From: | Stokes M Montgomery County, PA, Planning Commission |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR53498 00034, NRC-2011-0166 | |
| Download: ML11307A387 (4) | |
Text
MOI offi October 25, 2011 NTGOMERY COUNTY PLANNING COMMISSION box 311
- norristown ' pennsylvania # 19404-0311 ' 610-278-3722 ce location: suite 201
- one montgomery plaza
- swede & airy streets # norristown pa FAX 610-278-3941
- Website www.planning.montcopa.org
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.-Il co-Chief, Rules Announcements, and Directives Branch Mail Stop: TWB-05-BO1M US Nuclear Regulatory Commission Washington, DC 205550001 RE:
Environmental Scoping Comments Limerick Nuclear Generating Station Division of License Renewal NRC-2011-0166
Dear NRC Staff:
We have examined the proposed relicensing review information presented by NRC staff at the Public He'aring held in.Pottstown on September 22 and the information posted on the web site operated by the NRC. We feel that. it is vital that any decision regarding the relicensing of the Limerick Nuclear Power Station reflect careful consideration of all relevant public health and safety, security, and environmental issues that pertain to nuclear power generation in general and the unique conditions at the nuclear power generating station situated in Limerick Township. It is our understanding that an Environmental Impact Statement will be developed which addresses relevant environmental impacts pertaining to socioeconomics, environmental justice, and noise; cultural resources, archeology, and geological science; atmospheric science, air quality; hydrological sciences; transportation and land use; radiation protection; nuclear safety, fuel cycle, waste, and accident analysis; construction, operation, refurbishment,. and decommissioning; regulatory compliance; aquatic ecology; and water quality. Further it is our understanding that a detailed safety review will be conducted to review design assumptions; assess aging management of safety systems; and determine if new monitoring and inspections are needed during the expanded licensing period.
While we implore the NRC to do a full review of both environmental and public safety issues pertaining to the plant-particularly addressing radioactivity exposures during normal operation of the power station and, during various types of unusual events and disasters-we additionally feel that the impact review preceding any relicensing decision should also address specific issues.pertaining to the plant based upon it's conformity to the Montgomery County Comprehensive Plan and overall county development policies. Below we have itemized issues with respect to land use change and growth around the 'power plan t, transportation and evacuation capacity, Schuylkill River; and county trails that we feel warrant consideration in the environmental impact study.
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NRC Staff October 25, 2011 Land Use Change and Growth around the Power Plant:
Since the original plant was constructed,, the population in. the surrounding communities has grown dramatically. Limerick Township and nearby Upper Providence Township have been two of the most rapidly growing communities in the county. This growth largely fueled by access to US Route 422 Express'way and:
available land with suitable infrastructure, has dramatically changed the character of the area surrounding the Limerick Power Station. In the past few years, the : i '
Philadelphia Premium Outlet Mall, a 600,000 square foot retail facility, and the adjoining Costco shopping center opened along US Route 422 about one mile north of the.Limerick Power Stati6ii property.° -The land adjoining: thoise facilities is being, considered. for various types of retail and r6sidential uses. " Atone time, a large gambling casino had been, pioposed in this location as well. Other lands in Lower Pottsgrove Township near the Limerick Power Station* have also been proposed for similar types of uses.
While the county planning commissioni has tried to promote lower densities of growth in proximity to the Limerick Plant, the local communities and the marketplace favor this location for significant development due to its proximity to the US Route 422 interchange at Township Line/ Evergreen Road. The growth that has taken place in the area around the power plant, and in particular the growth taking.placevin the area immediately adjoining the plant and the primary access to it, as well as tlhe projected growth in the future, could complicate evacuation plans and-the movement of appropriate emergency-respo'nse personnelfto theplant in the event of a disaster.
Certainly this access could be even more crifital in the event of a natural disaster when other roads to the plant may be impassable. The environmental assessment review needs to analyze this growth in the vicinity of the power plant -to evaluate what impact it would have on plant operations and whether or not safe evacuation can take place from the newly developed areas.
Transportation and Evacuation Capacity:
The growth in the whole US Route 422 Corridor has raised numerous proposals for expanding the vehicle capacity of the 422 expressway. Current peak commuting traffic tie ups on portions of the expressway serve as evidence that it may have inadequate capacity to continue to serve as a safe evacuation corridor for the region.
The county transportation plan recognizes the need for various road improvements along the US 422.Corridor to address current and future traffic demands. The first priority projects in the plan include interchange improvements at the Township Line Road/ Evergreen Road intersection which is also the primary access route to the plant; needed widening and reconstruction of the highway east of the power station between Route 29 and US Route 202 in King of Prussia, reconstruction: of US Route 422 in the vicinity of Pottstown, and the reconstruction and widening of the Route 422 Bridge across the Schuylkill River at Betzwood. A passenger train line is also proposed as a first priority in the transportation plan to provide service through the western portion of the county into Norristown. The proposed route for this train line is the existing Norfolk Southern rail line that goes through the Limerick Power Station Property. Other improvements including the widening and expansion bf US Route 422 from Pottstovwn to Route 29 and additional interchange improv;ements at Township Line/ Evergreen Road'are proposed as secondary priorities in: the county plan. In addition'to these improvements, several other 1ocalized improvements that may impact evacuation feasibility are'propos~d in the' cou'nty plan.
NRC Staff October 25, 2011 Due to funding limitations in Pennsylvania, these projects are not likely to move forward at this time., The environmental impact review should consider the capacity of the roadway facilities to service the Limerick Plant as well as provide sufficient evacuation.of the. area in the event of a disaster'. Possible mitigation strategies 'to be considered in the. environmental assessment review could include the role of Exelon in funding the important road improvements needed in this area to ensure safe evacuation and access to the,. plantin any type of disaster.
Schuylkill River;....,.
Since the last impact statement.was prepared in,' 1973, the Schuylkill River has been designated as a state scenic river and as a heritaige area for botfhi the state and federal government.
Due. to these designations and the efforts of non - profit organizations and local government, access to the river has been expanded so that the river has become a recreation and heritage tourism destination. Use of the river in the vicinity of the plant will continue to grow. With the return of American Shad made possible through down stream fish ladders, interest in the river could even grow further in the future.
The.Limerick Plant withdraws sizeable portions of river water. During low flow periods,: additional quantities of water are released into the river from the Wadesville Mine, and Still Creek Reservoir in Schuylkill County to compensate for the water withdrawn at the plant. This process was: initially approved by the Delaware River Basin.Commission (DRBC), in 2003 and: kept active. through a series of docket amendments. Future river water. use is, dependent upon the ability of this water make up system to operate within various water quality and flow, parameters set by DRBC.
It is important to :evaluate., the viability of the use of the river water and water make up system to provide needed water through the expanded plant lifetime. Analysis of this aspect of plant operation needs to account for the water quality impact from the total dissolved solids in the Wadesville water among other parameters. If resumed use of the Delaware water diversion is anticipated, an evaluation of that system is required to ensure that the capacity is available in the conveyance system and that water quality objectives can be met for discharge into the East Branch of the Perkiomen Creek.
County Trails and Open Space:.
The county has been working hard to develop an interconnected system of open space and trails along the Schuylkill River and within other natural resource areas of the county.. In doing this, the county has provided funding to local municipalities and non-profit conservation organizations to purchase open space and park land; acquired county land and agriculture easements; and developed trails. The Limerick.
Generating Station site contains significant land along the Schuylkill River that has been identified as part of the Schuylkill River Greenway in the county plan. The use and management of these lands relative to the county open space and natural areas inventory plans should be evaluated in. the relicensing process.
The. Montgomery County Open. Space Plan proposes a trail along the river through the power plant property.,This trail is proposed as the Schuylkill East Trail, which would be developed as unpaved trail between Mont Clare and Pottstown. Essentially the proposed route would fpJlow an old road wa. between the river and Norfolk Southern rail line through the Lim.erick Pow.er Station site. Though such a trail route would appear to raise significant safety concerns due its proposed 'proximity tothe power
NRC Staff October 25, 2011 station, appropriate elements could be designed into any trail system to limit its threat to plant's security. We have found that trails can enhance the overall security of an area since they concentrate users along a defined corridor. Furthermore, trails can provide emergency access routes that could be used during different disaster events to evacuate people and provide access for emergency response. This trail and the management of undeveloped portions of the Limerick Power Station site should be considered in 'the environmental assessment.
Community Outreach and Education:
As part of the environmental assessment process and the evaluation of the plant safety and long term operational capacity, we think that it is important for the NRC to maintain close communication with the community surrounding the plant. Overall education about the plant and the associated risks presented by its operation should be provided in a variety of ways so that the public is better informed about the plant and the overall evaluation taking place as part of the relicensing.
If you have any questions, please contact me. Also, we offer our assistance in providing local information that may be helpful to your review.
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Sincerely,..
Michael M. Stokes Assistant Director mstokes @montcopa.org (610) 278-3729.
- c. Thomas Sullivan, Public Safety Department