ML24169A188
| ML24169A188 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/07/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR31225 | |
| Download: ML24169A188 (8) | |
Text
From:
Kowal, Kathleen <kowal.kathleen@epa.gov>
Sent:
Friday, June 7, 2024 9:17 AM To:
MonticelloEnvironmental Resource
Subject:
[External_Sender] USEPA's comments re Monticello Nuclear Generating Plant, Unit 1 DRAFT-Relicensing Request Attachments:
USEPA's comments - Monticello Relicensing DEIS.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 electronic copies of future NEPA documents pertaining to this project to R5NEPA@epa.gov.
Thank you, 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:
89FR31225 Comment Number:
288 Mail Envelope Properties (SA1PR09MB87990AC4610E85F827D6B6BE9AFB2)
Subject:
[External_Sender] USEPA's comments re Monticello Nuclear Generating Plant, Unit 1 DRAFT-Relicensing Request Sent Date:
6/7/2024 9:17:22 AM Received Date:
6/7/2024 9:17:34 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 589 6/7/2024 9:17:34 AM USEPA's comments - Monticello Relicensing DEIS.pdf 347518 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
June 5, 2024 VIA ELECTRONIC MAIL ONLY Jessica Umana Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Draft Site-Specific Environmental Impact Statement for Subsequent License Renewal for Monticello Nuclear Generating Plant, Unit 1, Second Renewal, Sherburne and Wright Counties, Minnesota - CEQ No. 20240072
Dear Ms. Umana:
The U.S. Environmental Protection Agency has reviewed the above-mentioned Draft Environmental Impact Statement (EIS) dated April 2024, 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.
Monticello Nuclear Generating Plant, Unit 1, (Monticello) is a single-unit electric generating plant consisting of a single-cycle, forced-circulation, boiling water reactor located in central Minnesota.
The NRC issued the original operating license on January 9, 1971. The first renewed license was issued on November 8, 2006, expiring September 8, 2030. During January 2023, Xcel Energy (Applicant) submitted an application to the NRC for subsequent license renewal of Renewed Facility Operating License No. DPR-22 for an additional 20 years of operation. In its application, the Applicant requested a subsequent renewed operating license for a period of 20 years, until September 8, 2050.
The Draft EIS analyzed impacts from five alternatives:
- No Action Alternative. NRC would not renew the Monticello operating license, and the reactor unit would shut down at or before the expiration of the current renewed license on September 8, 2030.
After permanent reactor shutdown, plant operators would initiate decommissioning.
- License Renewal. Approval of the subsequent license renewal (SLR) of the Monticello operating license for an additional 20 years.
2
- Natural Gas and Renewables. A combination alternative involving the offsite construction and installation of a new 750 megawatt (MW) natural gas-fired, two-unit combustion turbine power plant, offsite installation of 750 MW wind turbines, and 200 MW of solar panels both on and offsite of Monticello. Additional power generation would be provided by existing natural gas-fired power plants operated by Applicant.
- Renewables and Storage. Offsite construction and installation of 950 MW of wind turbines, 700 MW of solar panels both on and offsite of Monticello, and 300 MW of offsite lithium-ion battery storage at existing solar facility locations. This alternative would be supplemented by purchased power as needed.
- New Nuclear Reactor (Small Modular Reactor). Construction of a new small modular reactor nuclear power plant generating approximately 880 MW.
NRC has selected License Renewal as the preferred alternative. EPAs detailed comments on the Draft EIS are enclosed with this letter and focus on air emissions, climate change, energy efficiency, pollinators, and historic and cultural resources. We recommend NRC address these comments and our recommendations when developing the Final EIS.
AIR EMISSIONS EPA recognizes that Wright County is a maintenance area with respect to carbon monoxide and in attainment for other National Ambient Air Quality Standards (NAAQS1) and Sherburne County is in attainment for NAAQS. 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 to diesel exhaust.
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 power plant operating since 1971 will undergo refurbishment, we continue to recommend these measures to the Applicant to reduce emissions from any construction activities.
Recommendations for the Final EIS:
- EPA encourages the Applicant to commit to incorporating applicable mitigation measures from the enclosed Construction Emission Reduction Checklist into the project, wherever possible.
1 EPA has set primary and secondary National Ambient Air Quality Standards (NAAQS) for six common criteria pollutants to protect sensitive populations and the environment (40CFR Part 50).
3 CLIMATE CHANGE The Draft EIS indicates that, under normal site hydraulic conditions, groundwater flow is toward the Mississippi River (River). Onsite groundwater is hydraulically connected to the River; therefore, groundwater flow reversal can occur due to changes in hydraulic gradient during periods of high River stage. Hydraulic gradient reverses onsite when the River level rises above the groundwater table and River water flows into the aquifer. A period of groundwater reversal occurred in April 2023, when the River stage rose 7.57 ft. As River levels decline, the hydraulic gradient reverses back toward the River, resuming normal groundwater flow conditions from Monticello toward the River.
Recommendations for the Final EIS:
- Analyze impacts from potential increased frequency and extent of groundwater flow reversal during periods of high River stage. Discuss whether additional sensors, pumps, new technology, etc. would be beneficial to alert operators of changing conditions.
ENERGY EFFICIENCY EPA acknowledges the Draft EIS states the Applicant has not identified any refurbishment activities during the proposed relicensing term. However, if refurbishment were to include new structures, as long as it does not conflict with site/facility security, EPA encourages the Applicant to commit to incorporating energy-efficient measures.
Recommendations for the Final EIS:
- Use of energy-efficient and/or sustainable building materials, such as south-facing skylights and windows, motion-sensored lighting, and Energy Star certified windows and doors.
- Replacing carbon-intensive Portland Cement in concrete; and
- Consider practices applicable from EPAs Sustainable Management of Construction and Demolition Materials webpage2.
POLLINATORSANDNATIVE PLANT SPECIES The Draft EIS indicates physical disturbances3 are expected to be limited to paved or disturbed areas, areas of mowed grass or early successional vegetation. EPA acknowledges information in the Draft EIS indicating proposed re-licensing would not degrade existing natural areas. Nevertheless, because the monarch butterfly4 may occur at Monticello during spring and fall migration, this presents a chance to develop pollinator habitat.
The 2014 Presidential Memorandum entitled, Creating a Federal Strategy to Promote the Health of Honeybees and Other Pollinators5 responds to evidence of steep declines in certain pollinator populations. Pollinators are responsible for one in every three bites of food we take, with honeybees 2 https://www.epa.gov/smm/sustainable-management-construction-and-demolition-materials 3 Physical disturbances may be associated with site maintenance, infrastructure repairs or site activities.
4 The monarch butterfly is a candidate for Endangered Species Act listing (https://www.fws.gov/press-release/2020-12/endangered-species-act-listing-monarch-butterfly-warranted-precluded).
4 alone increasing our nations crop values by more than 15 billion dollars each year. Recognizing the need to improve pollinator health, the 32-acre grassland/herbaceous and grassy, mowed areas between buildings and along walkways can provide much needed habitat for pollinators, providing food, shelter, and connections to other patches of habitat. Maintenance staff and landscape designers can take steps that would not only improve the quality of vegetation for pollinators but would also provide aesthetically pleasing areas for employees.
Recommendations for the Final EIS:
- EPA encourages the Applicant to create pollinator-friendly habitat, wherever possible. Refer to U.S. Fish and Wildlife Centers Center for Pollinator Conservation6 for additional information.
HISTORIC AND CULTURAL RESOURCES The Draft EIS indicates the Applicant has three procedures in place to identify, protect, and minimize potential impact to cultural resources. The Applicant is in the process of updating these procedures to incorporate the recommendations resulting from consultation with the Mille Lacs Band of Ojibwe (Mille Lacs Band) to ensure continued protection of archaeological, cultural, and historic resources.
The Draft EIS is not clear regarding when these updates are expected to be finalized.
Recommendations for the Final EIS:
- Provide a timeline when updates are expected to be finalized (e.g., by the end of 2024) and whether the Mille Lacs Band will be consulted on the final draft of the updates.
Thank you for the opportunity to provide input. 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
Enclosure:
Construction Emission Control Checklist 6 https://www.fws.gov/program/center-pollinator-conservation KRYSTLE MCCLAIN Digitally signed by KRYSTLE MCCLAIN Date: 2024.06.05 08:26:14 -05'00'
5 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.7 We recommend the Applicant consider the following voluntary measures and commit to applicable protective measures in the Final 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.).8
- 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.).9
- 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.
7 Carcinogenicity of diesel-engine and gasoline-engine exhausts and some nitroarenes. The Lancet. June 15, 2012 8 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
6
- 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.