ML24093A007
| ML24093A007 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/02/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR10107 | |
| Download: ML24093A007 (4) | |
Text
From:
Virginia Gabrielle Javier <vgjavier@arizona.edu>
Sent:
Tuesday, April 2, 2024 12:45 AM To:
OconeeEnvironmental Resource Cc:
cyrgarretson@arizona.edu; gabriellaparra@arizona.edu; kirawright42@arizona.edu
Subject:
[External_Sender] NUREG-1437, Supplement 2, Second Renewal, draft, Docket ID NRC-2021-0146 Comments Attachments:
Comment Letter-NUREG-1437, Supplement 2, Second Renewal, draft.pdf
- Hello, We are students at the University of Arizona and would like to submit a comment letter on the EIS "NUREG-1437, Supplement 2, Second Renewal, draft," Docket ID NRC-2021-0146. I have attached our letter below. Thank you for your time.
- Best, Virginia Javier, Kira Wright, Gabriella Parra, and Cy Garretson Virginia Javier University of Arizona W.A. Franke Honors College l 2024 Natural Resources l Ecology, Management, and Restoration of Rangelands Partnerships Through Honors Program l Events & Experience Program Lead Tropical Climate and Coral Reef Lab l Lab Assistant FunEco Lab l Honors Thesis Researcher vgjavier@arizona.edu
Federal Register Notice:
89FR10107 Comment Number:
9 Mail Envelope Properties (CAMt5GY0AWPu3k24vPu0wgzfmo3c84M3vFPV7gdpYr93uPPM8Rw)
Subject:
[External_Sender] NUREG-1437, Supplement 2, Second Renewal, draft, Docket ID NRC-2021-0146 Comments Sent Date:
4/2/2024 12:44:40 AM Received Date:
4/2/2024 12:45:12 AM From:
Virginia Gabrielle Javier Created By:
vgjavier@arizona.edu Recipients:
"cyrgarretson@arizona.edu" <cyrgarretson@arizona.edu>
Tracking Status: None "gabriellaparra@arizona.edu" <gabriellaparra@arizona.edu>
Tracking Status: None "kirawright42@arizona.edu" <kirawright42@arizona.edu>
Tracking Status: None "OconeeEnvironmental Resource" <OconeeEnvironmental.Resource@nrc.gov>
Tracking Status: None Post Office:
mail.gmail.com Files Size Date & Time MESSAGE 693 4/2/2024 12:45:12 AM Comment Letter-NUREG-1437, Supplement 2, Second Renewal, draft.pdf 43943 Options Priority:
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April 1, 2024 Kira Wright, Virginia Javier, Gabriella Parra, and Cy Garretson The University of Arizona Saguaro Hall 1110 E South Campus Drive Tucson, AZ 85721 U.S. Nuclear Regulatory Commission Office of Administration Digital Communications and Administrative Services Branch Washington, DC 20555-0001 To Whom It May Concern, We are undergraduate students at the University of Arizona, currently taking a Natural Resources Policy and Law course. After reviewing the EIS, Site-Specific Environmental Impact Statement for Subsequent License Renewal of Oconee Nuclear Station, Units 1, 2, and 3 Second Renewal, Draft Report for Comment, we believe that the NEPA process has been followed properly and the EIS addressed most environmental and social concerns. However, we believe some issues, specifically involving the impacts of the nuclear station on an endangered bat species, categorical errors involving cooling system effects on surface and groundwater, and socioeconomic equity should be addressed and further evaluated.
The first potential environmental issue we noticed is with the state-endangered Rafinesques big-eared bat (Corynorhinus rafinesquii). On pages 3-67, line 6, it is stated that Duke Energy protects summer roosting habitat for the Rafinesques big-eared bat by protecting snag trees and mature hardwood communities. While this may help protect the species' habitat, it is also stated on pages 3-69, line 34, that The NRC staff, therefore, expects that wildlife in the affected habitats has long ago acclimated to the noise and human activity of Oconee Station operations and adjusted behavior patterns accordingly. We feel that instead of expecting that wildlife has moved from the area or has adapted to the noise levels, an evaluation should be made to see if/how the noise is affecting wildlife behavior, especially for bats. There have been studies that show noise levels affect the activity and feeding behaviors of bats as they rely on echolocation (Siemers & Schaub, 2011; Bunkley et al., 2015). A professional evaluation within their summer roosting habitat could clear up if the Oconee Station has any effects on them. If any effects are found, then Duke Energy could look into possible mitigation strategies. Any possible mitigation of noise within their habitat could benefit the endangered bats and assist in their recovery.
Next, it was made clear that the subsequent license renewal (SLR) EIS for the Oconee Nuclear Station would use the framework provided by the NCR License Renewal Generic Environmental Impact Statement (LR GEIS) to complete a site-specific analysis of the station to prepare this EIS. Specifically, they referred to Table B-1 in Appendix B to Subpart A of 10 CFR Part 51 (TN250), a list of generic issues that all nuclear power plants will encounter, and is categorized into 2 levels. Category 1 covers issues that are known to have no or a small impact on the specified area (as they are generic issues seen at all nuclear plants), whereas Category 2
issues could have moderate or large impacts, and need to be addressed on a site-specific basis. In this EIS, however, it was required that every issue, even stated as Category 1, had to be analyzed on-site because the LR GEIS was not able to cover any nuclear stations that are undergoing an SLR process. This is where there were some discrepancies found, as the SLR EIS did not cover 2 critical areas described in TN250. First, Oconee Nuclear Station has a once-through cooling system in place, and this EIS covers surface water use conflicts (plants with once-through cooling systems), a Category 1 issue. However, there is an emergency cooling system in place that would take over if the water pulled from Lake Howee is no longer flowing or at a high enough level.
This emergency system is an on-site cooling pool with impounded water, situated within the intake canal. This is now no longer a once-through cooling system and should be listed under surface water use conflicts (plants with cooling ponds or cooling towers using makeup water from a river), which is a Category 2 issue. In addition to this, there is another problem with this cooling pond system that holds impounded water (a closed system),
and it is another section that was not addressed, groundwater quality degradation (plants with cooling ponds at inland sites), another Category 2 issue. We implore that Duke Energy assess the discrepancies listed here, and ensure that these issues are made clear in the next draft of their SLR EIS.
In reviewing section 3.9 Historic and Cultural Resources, we believe that redefining acronyms in this section, such as NRHP and NRC, will make this section easier to understand for the common reader. On pages 3-143 line 13, it is unclear that the Old Pickens Presbyterian Church is listed under the National Register of Historic Places, we recommend clearly stating this. Lastly, our team was happy to see environmental justice and health impacts being addressed. To improve on this section, we recommend an addition of a cross analyzation of the amount of employment for people of color in this area. Section 3.10 does a good job of showing different economic opportunities provided by Oconee Station, but a further look into which groups these jobs are being provided for can provide insight into the socioeconomic equity of Oconee Station. An equitable employer will show employment roughly equal to the ratio of racial and ethnic groups of these areas, to ensure that economic opportunities are being well-spread in the community.
In conclusion, we feel that, overall, this EIS addressed major environmental and social impacts regarding renewing the Oconee Station license and evaluated all possible alternatives. However, there are still some concerns that we found after reviewing the EIS, especially regarding the impacts of the station on an endangered bat species, categorical errors involving cooling system effects on surface and groundwater, and socioeconomic equity concerns. We strongly encourage you to address and reevaluate these issues and consider both short-and long-term impacts.
Thank you, Kira Wright, Virginia Javier, Gabriella Parra, and Cy Garretson