ML15189A069
| ML15189A069 | |
| Person / Time | |
|---|---|
| Site: | SHINE Medical Technologies |
| Issue date: | 07/02/2015 |
| From: | Bub L State of WI, Dept of Natural Resources |
| To: | Cindy Bladey Rules, Announcements, and Directives Branch |
| References | |
| 80FR27710 00005, NRC-2013-0053 | |
| Download: ML15189A069 (3) | |
Text
7/2/2015 7//25N R C-2013- 0053- DRAFT- 001 1.html As of: 7/2/15 3:27 PM Recepived:
Jlyl 09 2O1S PUBLIC SUBMISSION Status: PendingPost Tracking No. ljz-8jr6-xzv6 Comments Due: July 06, 201 Submission Type: Web Docket: NRC-2013-0053 SHINE Medical Technologies, Inc.Comment On: NRC-2013-0053-0016 Construction Permit Application for the SHINE Medical Radioisotope Production Facility; Draft Environmental Impact Statement.
.5 Douet R-01305-RF-01 377 Submitter Information Name: Laura Bub Address: 3911 Fish Hatchery Road Fitchburg, WI, 53590 Email: laura. bub@wisconsin, gov Government Agency Type: State Government Agency: Wisconsin Department of Natural Resources_-1L1 I-- J.1!(--3q General Comment See attached file(s)Attachments SHINE dEISDNRComments.doc SUNSI Review Complete Template = ADM -013 E-RIDS- ADM -03 Q~r r'Add= --m: file:l/C :/U sers/C AG/D ownl oads/N R C-2013- 0053- DRAFT- 0011I .html Il 1/1 S~tate of Wisconsin ATATA -~DEPARTMENT OF NATURAL RESOURCES Scott Walker, Governor 3911 Fish Hatchery Road Cathy Stepp, SecretaryIL U A I Fitchburg WI 53711-5397 Tlpoe682622 Toll Free 1 -888-936-7463 TTY Access via relay -711 O AUA EORE July 2, 2015 Ms. Cindy Bladey Office of Administration Mail Stop OWFN-12 H08 U.S. Nuclear Regulatory Commission Washington D.C. 20555-000 1
Subject:
Docket ID NR-20 13-0053, WDNR Comments for the draft Environmental Impact Statement for SHINE Medical Technologies Radioisotope Production Facility
Dear Ms. Bladey:
Thank you for the opportunity to provide comments related to the U.S. Nuclear Regulator Commissions' (NRC)draft Environmental Impact Statement (dEIS) regarding the construction permit submitted by SHINE Medical Technologies, Inc (SHINE) for the proposed SHINE Medical Radioisotope Production Facility in Janesville, Wisconsin.
SHINE submitted the application for a construction permit to the NRC on March 26, 2013. This facility would produce radioisotopes for use in diagnostic medical isotope procedures.
SHINE Proposes to construct and operate a radioisotope production facility to produce molybdenum-99 (Mo-99), iodine- 131 (1- 131t) and xenon- 133 (Xe- 133). The proposed facility would cover approximately 91 acres and would include open space, a production facility building, a support facility building, a waste staging and shipping building, a diesel generator building, an administration building, and a security station. The majority of the proposed site currently consists of cultivated agricultural land. Preliminary environmental investigations by SHINE have concluded that there are no wetlands, waterways, forest, grasslands or prairie habitats on the propoSed site.We have reviewed the draft Environmental Impact Statement published May 2015. Because the Wisconsin Department of Natural Resources (WDNR) may have regulatory jurisdiction over various aspects of this project, we submit several comments related to the draft EIS: Storm water Within the document, lines 40-42 of page 4-19 currently state that: "This stormw4ater system would be designed to address the 1-year, 2-year, and 24-hour storm events per State regulations and the 10O-year and 100-year events, as required by the City of Janesville (SHINE 2013a).'" The Department recommends that the storm water system design reference compliance with NR 151 and NR 216, Wis. Adm. Code instead of (or in addition to) the specific regulations.
The peak discharge requirement (from various storm events) that is referenced is only one of the storm water requirements and there are other specific regulatory obligations that would need to be met (total suspended solids reduction
& infiltration, for example).Additionally, referencing compliance with NR 151 and NR 216, Wis. Adm. Codes, incorporates both the Construction Site Storm Water Runoff permit and the Industrial Storm Water permit that are both required of this dnr.wi.gov
-wisconsin~gov Naturally WVISCONSINPPE Page 2 site. The sentence might be most simply re-worded to read, "The storm water system(s) shall be designed to comply with NR 151 and NR 216, Wis. Adm. Code and the City of Janesville's requirements." Air The dEIS states that, "As of February 2014, the WDNR was actively working with SHINE to determine which of these permits would be required (WDNR 2014a)," and "SHINE intends to submit an application for a Type A Registration Construction Permit to the Wisconsin Department of Natural Resources (WDNR) (SHINE 2013b)." It should be noted that the Department has not yet received an application for an air pollution control permit from SHINE.Section 4.2.2 discusses air emissions from operations.
The Department is unable to confirm the assumed emissions without a permit application.
Hazardous Waste There is reference in the dEIS to properly handling the low level mixed waste that is proposed to be generated.
It should be noted that in January 2014, the Department communicated with SHINE related to this topic and SHINE was informed of the Department's requirements.
Several times in the document, NR 460, Wisconsin Adminstrative Code, is referenced regarding hazardous waste and nonhazardous waste. See the following from the draft: "In the State of Wisconsin, EPA has delegated the primary responsibility for implementing RCRA regulations to the State of Wisconsin.
For example, Wisconsin Administrative Code NR 460 addresses the identification; generation; minimization, transportation, and final treatment, storage, or disposal of hazardous and nonhazardous waste. " This should be corrected to reference NR 66.___0, Wisconsin Administrative Code (not NR 460) and the reference to nonhazardous waste should be deleted or should include that the nonhazardous Solid Waste General requirements are detailed in NR 500, Wisconsin Administrative Code.Thank you for providing the opportunity to comment on the draft Environmental Impact Statement related to the construction permit for SI-INE Medical Technologies Radioisotope Production Facility.
Please contact Laura Bub at laura.bub~iwisconsin.gov or 608.275.3485 with any questions or comments regarding this letter.Sincerely, Laura Bub Environmental Analysis and Review Specialist Cc (via email): Michelle Moser, U.S. NRC Jim Martin, WDNR Dan Bekta, WDNR Brian Barbieur, WDNR Tom Roushar, WDNR Matt Hilse, WDNR Dennis Mack, WDNR Russ Anderson, WDNR Mark Aquino, WDNR