ML24151A179

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Comment (3) E-mail Regarding Clinton Lr EIS Scoping
ML24151A179
Person / Time
Site: Clinton 
Issue date: 05/28/2024
From: Public Commenter
Public Commenter
To:
NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR33400
Download: ML24151A179 (9)
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Text

From:

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

Sent:

Tuesday, May 28, 2024 4:31 PM To:

ClintonEnvironmental Resource

Subject:

[External_Sender] USEPA's scoping response - Clinton Power Station Attachments:

USEPA's Scoping Letter-Clinton Power Station.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 Environmental Justice, Community Health, and Environmental Review Division 77 West Jackson Blvd., Chicago, IL 60604 Tel: 312-353-5206 l kowal.kathleen@epa.gov

Federal Register Notice:

89FR33400 Comment Number:

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Subject:

[External_Sender] USEPA's scoping response - Clinton Power Station Sent Date:

5/28/2024 4:31:23 PM Received Date:

5/28/2024 4:31:36 PM From:

Kowal, Kathleen Created By:

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

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May 28, 2024 VIA ELECTRONIC MAIL ONLY Ashley Waldron Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop: TWFN-7-A60M Washington, DC 20555-0001 Re: EPA Comments: Early Scoping Coordination - License Renewal for Constellation Energy Generation, LLC; Clinton Power Station, Unit 1, DeWitt County, Illinois, Docket ID NRC-2024-0046

Dear Ms. Waldron:

The U.S. Environmental Protection Agency (EPA) has reviewed the U.S. Nuclear Regulatory Commissions (NRC) Notice of Intent (NOI) dated April 29, 2024, for the Clinton Power Station, Unit 1 (Clinton Power Station). This letter provides EPAs comments pursuant to our authorities under the National Environmental Policy Act (NEPA), the Council on Environmental Qualitys (CEQ) NEPA Implementing Regulations (40 CFR 1500-1508), and Section 309 of the Clean Air Act.

The NOI informs the public of NRCs intention to conduct environmental scoping and prepare an Environmental Impact Statement (EIS) related to the license renewal application for the Clinton Power Station, and to provide the public with an opportunity to participate in the environmental scoping process. The Draft EIS will address potential environmental effects associated with the subsequent license renewal of the Clinton Power Station for an additional 20 years beyond the period specified in the current license1, as well as reasonable alternatives. NRC intends to prepare a plant-specific supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants2 (GEIS) related to the license renewal application from Constellation Energy Generation (Applicant)3.

1 The current facility operating license for Unit 1 will expire at midnight on April 17, 2027. The license renewal application seeks to extend the operating license for Unit 1 to April 17, 2047.

2 The purpose of the Generic EIS is to streamline the license renewal process based on the premise that environmental impacts of most nuclear power plant license renewals are similar; dated May 2013: https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/index.html 3 NRC is required by 10 CFR 51.95 to prepare a plant-specific supplement to the GEIS in connection with the renewal of an operating license.

2 EPAs detailed comments in response to the NOI are enclosed with this letter and focus on air impacts, aquatic resources, National Pollution Discharge Elimination System permits, climate resiliency, nuclear waste storage, refurbishment, and agency coordination. We recommend NRC address these comments and our recommendations when developing the forthcoming Draft EIS.

Thank you for the opportunity to provide input at the earliest stages of project development. Please send an electronic copy of future NEPA documents to R5NEPA@epa.gov. If you would like to discuss the contents of this letter further, please contact Kathy Kowal, the lead NEPA reviewer for this project, at kowal.kathleen@epa.gov. Ms. Kowal is also available at 312-353-5206.

Sincerely, Krystle Z. McClain, P.E.

NEPA Program Supervisor Environmental Justice, Community Health, and Environmental Review Division

Enclosures:

EPAs Detailed Comments Construction Emission Control Checklist KRYSTLE MCCLAIN Digitally signed by KRYSTLE MCCLAIN Date: 2024.05.28 12:08:44 -05'00'

3 EPA Detailed Comments Early Scoping Coordination - License Renewal for Constellation Energy Generation, LLC; Clinton Power Station, Unit 1, DeWitt County, Illinois Docket ID NRC-2024-0046 May 28, 2024 AIR IMPACTS 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 36-year-old power plant will undergo refurbishment, we continue to recommend these voluntary measures to the Applicant as a way to reduce emissions from any construction activities.

Recommendations for the Draft EIS:

  • Discuss applicability of the Construction Emission Control Checklist and indicate whether the Applicant will commit to incorporating applicable mitigation measures, wherever possible.

AQUATIC RESOURCES To support wetland and stream mitigation decisions and to help evaluate potential stream impact requirements for the Clean Water Act Section 401 Water Quality Certification, information regarding wetlands should be included in the Draft 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.

Recommendations for the Draft EIS:

  • Discuss impacts to wetlands, if any, within facility property that could be impacted by refurbishment.

NATIONAL POLLUTION DISCHARGE ELIMINATION SYSTEM (NPDES)

While the current NPDES permit requires monitoring to ensure that there are no point source discharges from the cooling structures to any adjacent surface waters, it is important for the facility to use relevant techniques to verify that all discharge structures are intact and able to retain nutrient-rich wastewater.

Recommendations for the Draft EIS:

  • Include a water balance analysis for the facility and provide additional information from past studies, if any.
  • Discuss the structural integrity of any discharge structures and include potential discharges from increased peak storm events.

4 CLIMATE RESILIENCY Executive Order 14008: Tackling the Climate Crisis at Home and Abroad states, states The United States and the world face a profound climate crisis. We have a narrow moment to pursue actionto avoid the most catastrophic impacts of that crisis and to seize the opportunity that tackling climate change presents. The U.S. Global Change Research Programs National Climate Assessment provides data and scenarios that may be helpful in assessing trends in temperature, precipitation, and frequency and severity of storm events4.

Recommendations for the Draft EIS:

  • Large storm events are occurring with increasing frequency and intensity in the Midwest due to climate change. Describe changing climate conditions (i.e., temperatures and frequency and severity of storm events) and assess how such changes could impact the proposed project.
  • Describe climate resilience and adaption considerations.

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.

Recommendations for the Draft EIS:

  • Discuss and evaluate safety concerns from 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.
  • 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.
  • Indicate if and where the Applicant intends to transport spent nuclear fuel and spent fuel debris offsite for storage pending long-term disposal options outside the facility.

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. Unnecessary permanent, impervious areas are discouraged.

4 Information on changing climate conditions is available through the National Climate Assessment at:

https://nca2023.globalchange.gov/.

5 Recommendations for the Draft EIS:

  • Address siting of potential refurbishment activities, while striving to minimize impacts to resources (e.g., use of parking lots for staging or temporary facilities).
  • Indicate whether any new buildings are needed and whether the Applicant will commit to designing buildings to Leadership in Energy and Environmental Design (LEED) standards.

AGENCY COORDINATION Recommendations for the Draft EIS:

  • Summarize coordination with relevant Federal and state agencies. EPA recommends that copies of letters to agencies, as well as responses from those agencies, are included as appendices to the Draft EIS.

ADDITIONAL INFORMATION The scoping letter requested information EPA may have regarding environmental resources in the project area.

Recommendations for the Draft EIS:

  • NRC should utilize the following databases to obtain environmental information related to the project area:
  • WATERS (Watershed Assessment, Tracking & Environmental Results System)5:

https://www.epa.gov/waterdata/waters-watershed-assessment-tracking-environmental-results-system

  • Clean Water Act Section 303(d) List of Impaired Waters:

https://www.epa.gov/tmdl/impaired-waters-and-tmdls-region-5

  • National Ambient Air Quality Standards status:

https://www3.epa.gov/airquality/greenbook/anayo_il.html 5 The Watershed Assessment, Tracking & Environmental Results System (WATERS) unites water quality information previously available only from several independent and unconnected databases 6 Includes enforcement and compliance information.

6 Construction Emission 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.1 We recommend the Applicant consider the following voluntary measures and commit to applicable protective measures in the Draft EIS.

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 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.).2
  • 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.).3
  • 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.

1 Carcinogenicity of diesel-engine and gasoline-engine exhausts and some nitroarenes. The Lancet. June 15, 2012 2 https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles 3 https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-nonroad-engines-and-vehicles

7

  • 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 National Institute for Occupational Safety and Health approval number.
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