ML23117A317

Comment (2) E-mail Regarding Monticello SLR EIS Scoping

ML23117A317
Person / Time
Site:	Monticello
Issue date:	04/05/2023
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
88FR15103
Download: ML23117A317 (8)

Text

From: Kowal, Kathleen <kowal.kathleen@epa.gov>

Sent: Wednesday, April 5, 2023 9:20 AM To: MonticelloEnvironmental Resource

Subject:

[External_Sender] Docket ID NRC-2023-0031 Attachments: USEPA Scoping Response - Monticello Nuclear Plant.pdf Greetings, Attached please find USEPAs comment letter re the above-mentioned project. Please do not hesitate to contact me if you have any questions or comments.

Please send an e-copy of future correspondence re the NEPA portion of this project.

Thanks, Kathy Kowal l NEPA Reviewer l Healthy Communities Team US EPA Region 5 Tribal and Multi-media Programs Office 77 West Jackson Blvd., Chicago, IL 60604 Tel: 312-353-5206 l kowal.kathleen@epa.gov A new EPA website highlights major BIL and IRA funding announcements:

EPA Funding Announcements from the Bipartisan Infrastructure Law and Inflation Reduction Act l US EPA Check out some of the great work communities have done with EJ grant funding in this interactive EJ Grants and Communities Story Map!

For Environmental Justice grant programs, funding opportunities, and assistance information, visit:

https://www.epa.gov/environmentaljustice/environmental-justice-grants-and-resources For additional information regarding work across all programs and divisions to advance and integrate environmental justice, visit:

https://www.epa.gov/environmentaljustice/environmental-justice-your-community#region5 For up-to-date information about Environmental Justice funding opportunities, events, and webinars, subscribe to EPA's Environmental Justice listserv by sending a blank email to: join-epa-ej@lists.epa.gov

Federal Register Notice: 88FR15103 Comment Number: 2 Mail Envelope Properties (SA1PR09MB8799C053C3D04E14F79243349A909)

Subject:

[External_Sender] Docket ID NRC-2023-0031 Sent Date: 4/5/2023 9:20:01 AM Received Date: 4/5/2023 9:20:16 AM From: Kowal, Kathleen Created By: kowal.kathleen@epa.gov Recipients:

"MonticelloEnvironmental Resource" <MonticelloEnvironmental.Resource@nrc.gov>

Tracking Status: None Post Office: SA1PR09MB8799.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1865 4/5/2023 9:20:16 AM USEPA Scoping Response - Monticello Nuclear Plant.pdf 238486 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 April 4, 2023 VIA ELECTRONIC MAIL ONLY Jessica Umana Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement - Monticello Nuclear Generating Plant, Unit 1, Sherburne and Wright Counties, Minnesota -- Docket ID NRC-2023-0031

Dear Ms. Umana:

The U.S. Environmental Protection Agency has reviewed the above-mentioned Notice of Intent (NOI) dated March 10, 2023 as prepared 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 found at 40 CFR 1500-1508, and Section 309 of the Clean Air Act.

During January 2023, Northern States Power Company submitted an application to the NRC for subsequent license renewal of Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant (Monticello), Unit 1, for an additional 20 years of operation. The Monticello unit is a boiling water reactor located in central Minnesota. The current facility operating license expires September 8, 2030.

The NRC is gathering information necessary to prepare a plant-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. The purpose of the Generic EIS was to streamline the license renewal process based on the premise that environmental impacts of most nuclear power plant license renewals are similar.

Following our review of the scoping materials, we have the following comments to aid in the preparation of an Environmental Impact Statement (EIS).

Air Emissions 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 and

it is reasonable to assume a 30-year old power plant will undergo refurbishment, we continue to recommend these measures to the applicant to reduce emissions from any construction activities.

We encourage the applicant to commit to incorporating applicable mitigation measures from the enclosed Construction Emission Reduction Checklist into the project, wherever possible.

Refurbishment Temporary staging areas or facilities may be necessary for refurbishment and can lead to increased impervious surfaces. Urbanization can be a stressor to the health of aquatic resources; avoiding increasing the amounts of impervious surfaces can help reduce this stress. The future EIS should address siting of potential refurbishment activities, while striving to minimize impacts to resources (e.g., use of parking lots for staging or temporary facilities). Unnecessary permanent, impervious areas are discouraged. Any new buildings should be designed to Leadership in Energy and Environmental Design (LEED) standards. If LEED standards are pursued, this information should be included in the EIS.

Impact Categories EPA recommends the forthcoming NEPA analysis include robust explanations of NRC-designated impact categories of SMALL, MODERATE, and LARGE. Providing metrics or ranges used to differentiate between these designations and how impacts to resources could potentially increase from SMALL to MODERATE or from MODERATE to LARGE would help reviewers understand impacts Further, NRC and the applicant should identify mitigation measures to ensure that impacts are avoided or minimized and remain in the SMALL category. Mitigation measures should be specific; the use of best management practices is too general for reviewers to understand the potential extent of mitigation from best management practices.

Environmental Justice EPA recommends including the Federal Environmental Justice (EJ) Interagency Working Groups Promising Practices for EJ Methodologies in NEPA Reviews 1 (to which NRC contributed) to guide the EJ analysis and related elements (e.g., meaningful outreach to communities with EJ concerns).

Climate Change In addition to changes in meteorological parameters and greenhouse gas emissions, climate change analysis should consider the availability of water in sufficient quantities and temperatures. If temperature-specific water is required, we recommend discussing effects of climate change and whether too-warm waters may require an increased number of temperature variants to National Pollution Discharge Elimination System permits.

Because of the uncertainty associated with climate change, the EIS should include a robust discussion explaining the methods used to assess environmental impacts 25 years into the future.

1 https://www.epa.gov/sites/default/files/2016-08/documents/nepa_promising_practices_document_2016.pdf 2

EPA appreciates the opportunity to comment on this NOI. Please send us electronic copies of future correspondence related to this process. If you have any questions regarding the contents of this letter, please contact Kathy Kowal, the lead reviewer for this project, at kowal.kathleen@epa.gov. Ms. Kowal is also available at 312-353-5206.

Sincerely, Digitally signed by DAVID DAVID OGULEI Date: 2023.04.04 OGULEI 10:00:39 -05'00' David Ogulei, Acting NEPA Program Supervisor Tribal and Multi-media Programs Office Office of the Regional Administrator

Enclosure:

Construction Emissions Reduction Checklist 3

U.S. EPA Construction Emissions Control Checklist Diesel emissions and fugitive dust from project construction may pose environmental and human health risks and should be minimized. In 2002, EPA classified diesel emissions as a likely human carcinogen, and in 2012 the International Agency for Research on Cancer concluded that diesel exhaust is carcinogenic to humans. Acute exposures can lead to other health problems, such as eye and nose irritation, headaches, nausea, asthma, and other respiratory system issues.

Longer term exposure may worsen heart and lung disease. 2 We recommend the Nuclear Regulatory Commission and the applicant consider the following protective measures and commit to applicable measures in the Environmental Impact Statement.

Mobile and Stationary Source Diesel Controls Purchase or solicit bids that require the use of vehicles that are equipped with zero-emission technologies or the most advanced emission control systems available. Commit to the best available emissions control technologies for project equipment in order to meet the following standards.

• On-Highway Vehicles: On-highway vehicles should meet, or exceed, the EPA exhaust emissions standards for model year 2010 and newer heavy-duty, on-highway compression-ignition engines (e.g., long-haul trucks, refuse haulers, shuttle buses, etc.). 3

• Non-road Vehicles and Equipment: Non-road vehicles and equipment should meet, or exceed, the EPA Tier 4 exhaust emissions standards for heavy-duty, non-road compression-ignition engines (e.g., construction equipment, non-road trucks, etc.). 4

• Locomotives: Locomotives servicing infrastructure sites should meet, or exceed, the EPA Tier 4 exhaust emissions standards for line-haul and switch locomotive engines where possible.

• Low Emission Equipment Exemptions: The equipment specifications outlined above should be met unless: 1) a piece of specialized equipment is not available for purchase or lease within the United States; or 2) the relevant project contractor has been awarded funds to retrofit existing equipment, or purchase/lease new equipment, but the funds are not yet available.

Consider requiring the following best practices through the construction contracting or oversight process:

• Establish and enforce a clear anti-idling policy for the construction site.

• Use onsite renewable electricity generation and/or grid-based electricity rather than diesel-powered generators or other equipment.

• Use electric starting aids such as block heaters with older vehicles to warm the engine.

• Regularly maintain diesel engines to keep exhaust emissions low. Follow the manufacturers recommended maintenance schedule and procedures. Smoke color can signal the need for maintenance (e.g., blue/black smoke indicates that an engine requires servicing or tuning).

• Where possible, retrofit older-tier or Tier 0 nonroad engines with an exhaust filtration device before it enters the construction site to capture diesel particulate matter.

2 Carcinogenicity of diesel-engine and gasoline-engine exhausts and some nitroarenes. The Lancet. June 15, 2012 3

http://www.epa.gov/otaq/standards/heavy-duty/hdci-exhaust.htm 4

https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-nonroad-engines-and-vehicles 4

• Replace the engines of older vehicles and/or equipment with diesel- or alternatively-fueled engines certified to meet newer, more stringent emissions standards (e.g., plug-in hybrid-electric vehicles, battery-electric vehicles, fuel cell electric vehicles, advanced technology locomotives, etc.), or with zero emissions electric systems. Retire older vehicles, given the significant contribution of vehicle emissions to the poor air quality conditions. Implement programs to encourage the voluntary removal from use and the marketplace of pre-2010 model year on-highway vehicles (e.g., scrappage rebates) and replace them with newer vehicles that meet or exceed the latest EPA exhaust emissions standards, or with zero emissions electric vehicles and/or equipment.

Fugitive Dust Source Controls

• Stabilize open storage piles and disturbed areas by covering and/or applying water or chemical/organic dust palliative, where appropriate. This applies to both inactive and active sites, during workdays, weekends, holidays, and windy conditions.

• Install wind fencing and phase grading operations where appropriate and operate water trucks for stabilization of surfaces under windy conditions.

• When hauling material and operating non-earthmoving equipment, prevent spillage and limit speeds to 15 miles per hour (mph). Limit speed of earth-moving equipment to 10 mph.

Occupational Health

• Reduce exposure through work practices and training, such as maintaining filtration devices and training diesel-equipment operators to perform routine inspections.

• Position the exhaust pipe so that diesel fumes are directed away from the operator and nearby workers, reducing the fume concentration to which personnel are exposed.

• Use 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.

• Use 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 the type of 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.

NEPA Documentation

• Per Executive Order 13045 on Childrens Health 5, EPA recommends the lead agency and project proponent pay particular attention to worksite proximity to places where children live, learn, and play, such as homes, schools, and playgrounds. Construction emission 5

Children may be more highly exposed to contaminants because they generally eat more food, drink more water, and have higher inhalation rates relative to their size. Also, childrens normal activities, such as putting their hands in their mouths or playing on the ground, can result in higher exposures to contaminants as compared with adults.

Children may be more vulnerable to the toxic effects of contaminants because their bodies and systems are not fully developed and their growing organs are more easily harmed.

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reduction measures should be strictly implemented near these locations in order to be protective of childrens health.

• Specify how impacts to sensitive receptors, such as children, elderly, and the infirm will be minimized. For example, locate construction equipment and staging zones away from sensitive receptors and fresh air intakes to buildings and air conditioners.

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