ML21069A228
| ML21069A228 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/08/2021 |
| From: | NRC |
| To: | NRC/NMSS/DREFS |
| References | |
| Download: ML21069A228 (5) | |
Text
From: Clark, Phyllis Sent: Monday, March 8, 2021 9:00 AM To: Imboden, Stacey; Folk, Kevin; Elliott, Robert
Subject:
FW: US EPA Scoping Comments on Point Beach Relicensing Attachments: USEPA Scoping Comments_Point Beach NPP Relicensing.pdf FYI From: Poole, Elizabeth Sent: Monday, March 08, 2021 8:45 AM To: Clark, Phyllis
Subject:
[External_Sender] US EPA Scoping Comments on Point Beach Relicensing Hi Phyllis -
Please see attached for our scoping comments.
My apologies - this was signed last week, but its been sitting in my outbox since then and I just realized it. We had a major update to Office and everything is a mess!
- Thanks, Elizabeth Elizabeth Poole Tribal and Multimedia Programs Office - NEPA Team 77 W Jackson Blvd Chicago, Illinois 60604 (312) 353-2087
Hearing Identifier: PointBeach_SLRDocs_Public Email Number: 5 Mail Envelope Properties (DM6PR09MB52386D0418053B9F1F372DB0F7939)
Subject:
FW: US EPA Scoping Comments on Point Beach Relicensing Sent Date: 3/8/2021 9:00:12 AM Received Date: 3/8/2021 9:00:15 AM From: Clark, Phyllis Created By: Phyllis.Clark@nrc.gov Recipients:
"Imboden, Stacey" <Stacey.Imboden@nrc.gov>
Tracking Status: None "Folk, Kevin" <Kevin.Folk@nrc.gov>
Tracking Status: None "Elliott, Robert" <Robert.Elliott@nrc.gov>
Tracking Status: None Post Office: DM6PR09MB5238.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 581 3/8/2021 9:00:15 AM USEPA Scoping Comments_Point Beach NPP Relicensing.pdf 284590 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590 March 3, 2021 REPLY TO THE ATTENTION OF:
Mail Code RM-19J Phyllis Clark Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-000 Re: Scoping - Point Beach Nuclear Plant, Units 1 and 2, Twin Creek, Manitowoc County, Wisconsin
Dear Ms. Clark:
The U.S. Environmental Protection Agency has reviewed the Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS) for the proposed license renewal for the Point Beach Nuclear Plant, Units 1 and 2 (Point Beach), provided by the Nuclear Regulatory Commission (NRC). Our comments are provided pursuant to the National Environmental Policy Act (NEPA),
the Council on Environmental Qualitys NEPA Implementing Regulations (40 CFR 1500-1508),
and Section 309 of the Clean Air Act.
Point Beach is a two-unit, pressure-water nuclear power plant located in Manitowoc County, Wisconsin, on the shore of Lake Michigan. The current facility operating license expires on October 5, 2030 (Unit 1) and March 8, 2033 (Unit 2). Based on the NOI, it is unclear whether refurbishment or other onsite construction activity is proposed. Point Beach is owned and operated by NextEra Energy, LLC (the applicant). The applicant applied to NRC for an extension to its operating license, extending operation for an additional 20-year period.
The NRC developed a Generic EIS to streamline the license renewal process based on the premise that environmental impacts of most nuclear power plant license renewals are similar.
NRC develops facility-specific Supplemental EIS documents as the facilities apply for license renewal. EPA acknowledges that mitigation measures that are un-related to nuclear safety and security cannot be included in the NRC license. This includes, but is not limited to, construction diesel emissions reduction measures. However, because we find these measures to be value-added, we continue to recommend them to the applicant for any construction activities, if applicable, and include them in our comment letters. We encourage the applicant to incorporate mitigation measures into the project, wherever possible.
Air Emissions: While EPA recognizes that part of Manitowoc County is in non-attainment status for 8-hour ozone (2015 standard), we expect construction equipment used during refurbishment and other onsite activities to result in an increase in emissions. The National Institute for Occupational Safety and Health (NIOSH) has determined that diesel exhaust is a potential occupational carcinogen, based on a combination of chemical, genotoxicity, and carcinogenicity data. In addition, acute exposures to diesel exhaust have been linked to health problems such as eye and nose irritation, headaches, nausea, asthma, and other respiratory system issues. Although every construction site is unique, common actions can reduce exposure Recycled/Recyclable
- Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post Consumer)
to diesel exhaust. EPA recommends that the applicant commit to the following actions during construction in the Draft Supplemental EIS:
x Using low-sulfur diesel fuel (15 parts per million sulfur maximum) in construction vehicles and equipment.
x Retrofitting engines with an exhaust filtration device to capture diesel particulate matter before it enters the construction site.
x Positioning the exhaust pipe so that diesel fumes are directed away from the operator and nearby workers, thereby reducing the fume concentration to which personnel are exposed.
x Using catalytic converters to reduce carbon monoxide, aldehydes, and hydrocarbons in diesel fumes. These devices must be used with low sulfur fuels.
x Ventilating wherever diesel equipment operates indoors. Roof vents, open doors and windows, roof fans, or other mechanical systems help move fresh air through work areas.
As buildings under construction are gradually enclosed, remember that fumes from diesel equipment operating indoors can build up to dangerous levels without adequate ventilation.
x Attaching a hose to the tailpipe of diesel vehicles running indoors and exhaust the fumes outside, where they cannot re-enter the workplace. Inspect hoses regularly for defects and damage.
x Using enclosed, climate-controlled cabs pressurized and equipped with high efficiency particulate air (HEPA) filters to reduce the operators exposure to diesel fumes.
Pressurization ensures that air moves from inside to outside. HEPA filters ensure that any incoming air is filtered first.
x Regularly maintaining diesel engines, which is essential to keep exhaust emissions low.
Follow the manufacturers recommended maintenance schedule and procedures. Smoke color can signal the need for maintenance. For example, blue/black smoke indicates that an engine requires servicing or tuning.
x Reducing exposure through work practices and training, such as turning off engines when vehicles are stopped for more than a few minutes, training diesel-equipment operators to perform routine inspection, and maintaining filtration devices.
x Purchasing new vehicles that are equipped with the most advanced emission control systems available.
x Using electric starting aids, such as block heaters with older vehicles to warm the engine, reduces diesel emissions.
x Using respirators, which are only an interim measure to control exposure to diesel emissions. In most cases, an N95 respirator is adequate. Workers must be trained and fit-tested before they wear respirators. Depending on work being conducted, and if oil is present, concentrations of particulates present will determine the efficiency and type of mask and respirator. Personnel familiar with the selection, care, and use of respirators must perform the fit testing. Respirators must bear a NIOSH approval number. Paper masks or surgical masks should never be used without NIOSH approval numbers.
Transparency: For license renewal reviews, EPA routinely recommends compliance with plain language writing requirements and additional efforts to improve transparency of documents, including references with specific locations within documents (rather than simply citing a full document) and clearly outlining methodologies. EPA also continues to recommend the 2
forthcoming Draft EIS include better explanations of the NRC-designated impact categories of SMALL, MODERATE, and LARGE, particularly where a range is the designated category.
Thank you for the opportunity to comment on this document. If you have any questions or wish to discuss any aspect of this document, please contact Elizabeth Poole of my staff at 312-353-2087 or poole.elizabeth@epa.gov.
Sincerely, KENNETH Digitally signed by KENNETH WESTLAKE WESTLAKE Date: 2021.03.03 08:24:13 -06'00' Kenneth A. Westlake Deputy Director Office of Tribal and Multimedia Programs Cc: Mark Ackerman, US Environmental Protection Agency, Water Division 3