ML23340A018
| ML23340A018 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/03/2023 |
| From: | Kajumba N Environmental Protection Agency |
| To: | Stacy Schumann Office of Administration |
| References | |
| NRC-20230152, 88FR75627 00002 | |
| Download: ML23340A018 (1) | |
Text
SUNSI Review Complete Template=ADM-013 Stacy Schumann E-RIDS=ADM-03 ADD: Kim Conway, Antoinette Walker-Smith, Mary Neely Office of Administration, Mail Stop: TWFN-7-A60M, Comment (2)
U.S. Nuclear Regulatory Commission, Publication Date: 11/3/2023 Washington, DC 20555-0001, Citation 88 FR 75627 RE: Notice of Intent to Prepare an Environmental Impact Statement (EIS) for the Dominion Energy South Carolina, Inc.; Virgil C. Summer Nuclear Station, Subsequent License Renewal (SLR) Operating License No. NPF-12 for Unit 1, Docket ID NRC-2023-0152
Dear Stacy Schumann:
The U.S. Environmental Protection Agency (EPA) has reviewed the Nuclear Regulatory Commissions (NRC) Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS), in accordance with Section 309 of the Clean Air Act (CAA) and Section 102(2)(C) of the National Environmental Policy Act (NEPA). The CAA Section 309 role is unique to EPA. It requires the EPA to review and comment on any proposed federal action subject to NEPAs environmental impact statement requirement and to make its comments public.
The purpose of the EIS is to address the environmental effects associated with obtaining relicense renewals for the Dominion Energy South Carolina, Inc. Virgil C. Summer Nuclear Station located in Jenkinsville, South Carolina. According to the NOI, the SLR operating licenses would authorize the applicant to operate the Vigil C. Summer Nuclear facility for an additional 20 years beyond the period specified in each for the current licenses. The current operating license expires August 6, 2042.
Based on the EPAs review of the NOI, the EPA recommends that the EIS evaluate the potential effects of the proposed project and describe efforts to address the following potential impacts of the proposed action in the EIS.
(1) Indirect and Cumulative Impacts - Nuclear facilities generally have several potential indirect and cumulative project impacts that are of particular concern and should be discussed and appropriately addressed in the EIS. These impacts include but are not limited to; radionuclides in surface water and groundwater, spent nuclear fuel storage, contaminant transport and deposition, stormwater, the impact of severe storm events affected by climate change, and analysis of communities with Environmental Justice concerns.
(2) Nuclear Waste Storage - Liquid, gaseous, and solid radioactive waste management systems can collect and create radioactive byproducts from spent nuclear fuel if required for continued on-site storage. Due to the uncertainty regarding the future availability of a geologic repository or other away-from-reactor storage facility, on-site storage may be required for many decades, until a permanent repository is established. The EIS should discuss and evaluate safety concerns potential flooding and other storm events. As part of this process, storage plans for spent nuclear fuel should be evaluated to prevent contamination in the event of flooding at the site. The EIS should indicate if there will be any changes in the generation of waste including low-level radioactive waste, mixed low-level radioactive waste, transuranic waste, and hazardous and Toxic Substance Control Act wastes over the life of the program. The EIS should indicate where the applicant will transport the spent nuclear fuel and spent fuel debris offsite for storage pending long-term disposal options.
(3) National Pollution Discharge Elimination System - The EIS should discuss a water balance analysis and provide additional information from past studies, if any.
(4) Wetlands and Streams - To support wetland and stream mitigation decisions and to help evaluate potential stream impact requirements for the Clean Water Act (CWA) Section 401 Water Quality Certification, information regarding CWA Section 404(b)(1) should be included in the EIS. Providing adequate wetland and stream information within the NEPA process can help to streamline the final environmental review and permitting processes for these resources. The EIS should provide a detailed discussion regarding the potential significant impacts to state and federal resources, that comply with the most current Comprehensive any Restoration Plan.
(5) Climate Resilience - Climate change may impact the proposed project, posing threats to aging infrastructure, worker health and safety and the environment. We recommend that the EIS include an evaluation of climate related impacts including discussions of frequency and severity of major storm events, wildfires, or drought that could lead to power disruptions or increased cooling demands in summer months. Efforts that applicant is taking to address and adapt to potential climate impacts should also be discussed in the EIS.
(6) Hurricane and Storm Models - The EIS should explain the differences that may result from using different storm prediction models as well as the validations of these models. Sea level rise should be incorporated into a discussion with a Sea, Lakes, Overland and Surge from Hurricane (SLOSH) model, which is also used by the National Weather Service and federal agencies when determining storm surge predictions. The EPA recommends that the EIS provide a detailed description of any other models used for determining storm surge and flooding, and the rationale for using another model over the SLOSH model.
(7) Environmental Justice- Executive Order (E.O.) 12898 directs federal agencies to identify and address any disproportionately high and adverse human health or environmental effects of its programs, policies and activities on minority, low-income, tribal, and indigenous populations. The EIS should include an analysis that is consistent with E.O. 12898. The analysis should indicate whether minority, low income, tribal, and indigenous populations reside within the vicinity of the proposed project area. It would also be helpful to include a current map depicting the population demographics near the facility. The EJ analysis should also be completed in accordance with the new EO 14096, Revitalizing Our Nation's Commitment to Environmental Justice for All, published April 21, 2023.
The Environmental Justice Interagency Working Group Promising Practices for EJ Methodologies in NEPA Reviews, dated March 2016, provides guiding principles agencies can consider in identifying disproportionate impacts on minority and low-income populations and appropriately engage in meaningful, targeted community outreach, analyze and minimize community impacts and advance EJ through NEPA implementation. Assessing data using EJScreen (https://www.epa.gov/ejscreen), the EPAs nationally consistent environmental justice (EJ) screening and mapping tool, is a useful first step in understanding or highlighting geographic locations that may need further review or outreach. The tool provides information on environmental and socioeconomic indicators as well as pollution sources, health disparities, critical service gaps, and climate change data. The tool can help identify potential community vulnerabilities by calculating EJ Indexes and displaying other environmental and socioeconomic information in color-coded maps and standard data reports.
If communities with EJ concerns, among others, are located within the vicinity of the proposed project area or potentially affected by the proposed project, the EPA recommends the NRC meaningfully involve these communities throughout the decision-making process to help identify potential benefits, burdens, mitigation opportunities associated with relicensing and permitting decisions. Adaptive and innovative approaches to both public outreach and community involvement should be implemented during the project planning.
The EPA appreciates the opportunity to provide comments on the proposed project. If you have any questions regarding our comments, please contact Larry Long of the NEPA Section by phone at (404) 562-9460, or by e-mail at long.larry@epa.gov.
Ntale Kajumba Manager NEPA SectionlStrategic Programs Office U.S. EPA Region 4 Tel: 404-562-9620 Email: Kajumba.ntale@epa.gov