ML24353A119

Usepa Monticello Re-license Feis Comments (1)

ML24353A119
Person / Time
Site:	Monticello
Issue date:	12/12/2024
From:	Mcclain K US Environmental Protection Agency, Region 5
To:	Jessica Umana Office of Nuclear Material Safety and Safeguards
References
Download: ML24353A119 (1)

Text

December 12, 2024 VIA ELECTRONIC MAIL ONLY Jessica Umana Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE:

EPA Comments: Final Site-Specific Environmental Impact Statement for Subsequent License Renewal for Monticello Nuclear Generating Plant, Unit 1, Second Renewal, Sherburne and Wright Counties, MinnesotaCEQ No. 20240072

Dear Ms. Umana:

The U.S. Environmental Protection Agency has reviewed the Nuclear Regulatory Commissions Final Environmental Impact Statement (Final EIS) dated November 2024, concerning the subsequent license renewal (SLR) for Monticello Nuclear Generating Plant, Unit 1. This letter provides EPAs comments on the proposed project, pursuant to the National Environmental Policy Act, the Council on Environmental Qualitys NEPA Implementing Regulations (40 CFR Parts 1500-1508), and Section 309 of the Clean Air Act. The CAA Section 309 role is unique to EPA. It requires EPA to review and comment on the environmental impact on any proposed federal action subject to NEPAs environmental impact statement requirements and to make its comments public.

Monticello Nuclear Generating Plant, Unit 1, 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, and will expire on September 8, 2030. During January 2023, Xcel Energy (Applicant) applied to NRC for the SLR of Renewed Facility Operating License No. DPR-22 for an additional 20 years of operation.1 The Final EIS evaluated the No Action Alternative and four action alternatives. NRC selected License Renewal as the Preferred Alternative.

1. No Action Alternative: NRC would not renew Monticellos operating license, and the reactor unit would shut down on or before the current license expiration date of September 8, 2030.

After permanent reactor shutdown, plant operators would initiate decommissioning.

1 The SLR of Monticello would expire September 8, 2050.

2

2. License Renewal: Approval of SLR of Monticellos operating license for an additional 20 years beyond the period specified in the current license.

3. Natural Gas and Renewables: A combination alternative involving the offsite construction and installation of a new 750-megawatt natural gas-fired, two-unit combustion turbine power plant, offsite installation of 750 MW of 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 the Applicant.

4. 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.

5. New Nuclear Reactor (Small Modular Reactor): Construction of a new small modular reactor nuclear power plant generating approximately 880 MW.

EPA provided several recommendations to NRC in a comment letter dated June 5, 2024, regarding the Draft EIS. EPA recommended NRC and the Applicant incorporate construction emission mitigation measures, energy efficient standards, and sustainable building materials when applicable. Additionally, EPA recommended NRC and the Applicant create pollinator-friendly habitat and use native plant species, as applicable, on plant grounds. Finally, EPA recommended NRC to provide information regarding consultation and engagement with the Mille Lacs Band of Ojibwe concerning the protection of archeological, cultural, and historic resources (e.g., red cedar and wild rice). EPAs comments were adequality addressed in the Final EIS with the exception of issues related to Tribal resources and consultation.

EPA offers the following recommendations to NRC for consideration before finalizing the Record of Decision.

1. TRIBAL RESOURCES AND CONSULTATION A. The Mille Lacs Band of Ojibwe requested a wild rice survey within the Monticello site. As stated in the Final EIS, the Applicants contractor surveyed for wild rice in August of 2024, concluding no wild rice species was observedbecause the peak growth period for wild rice is between July and early October, Westwood was not able to complete a survey for wild rice during their field visit. Westwood plans to complete the survey in early summer 2024.2 NRC staff determined that natural and cultural resources may exist within the Monticello site that may be of interest to other consulting Tribes. However, the Final EIS did not discuss consultation with the other Tribes.

Recommendations before finalizing the Record of Decision:

1. Because numerous Tribes have gathering rights which include the Mississippi River, EPA recommends that NRC and the Applicant commit to consult with other Tribes with gathering rights that might be impacted by changes to the Mississippi River. Because NRC may not have the necessary background knowledge to determine which location(s) are important for wild rice harvests, NRC and the Applicant should contact the Tribal 2 Page 3-162

3 Historic Preservation Officers or Tribal environmental staff to determine where surveys should be conducted.

2. Because wild rice is an annual plant, seasonal abundance can vary dramatically. NRC should ensure the Applicant will consult with the affected Tribes to determine: (1) the appropriate time of year to conduct surveys; (2) the appropriate survey protocols to use; and (3) whether surveys should be conducted over multiple years (e.g., one to three years) to account for fluctuations in seasonal abundance.

3. NRC should include provisions in the re-license indicating the Applicant will work with affected Tribes to implement measures to protect wild rice.

4. EPA recommends NRC postpone making a final decision regarding whether to approve re-licensing until impacts to wild rice are known and measures to protect wild rice have been implemented.

Thank you for the opportunity to review and provide comments on the Final EIS. Please send a copy of the published Record of Decision to R5NEPA@epa.gov. If you have any questions or would like to discuss the contents of this letter further, please contact lead NEPA reviewer, Kathy Kowal, at kowal.kathleen@epa.gov or 312-353-5206.

Sincerely, Krystle Z. McClain, P.E.

NEPA Program Supervisor Environmental Justice, Community Health, and Environmental Review Division cc Perry Bunting, Director of Environmental Programs, Mille Lacs Band of Ojibwe (perry.bunitng@millelacsband.com)

Mike Wilson, THPO, Mille Lacs Band of Ojibwe (mike.wilson@millelacsband.com)

Deb Dirlam, Director of Environmental Programs/Office of Environment, Lower Sioux Indian Community (deb.dirlam@lowersioux.com)

Cheyanne St. John, THPO, Lower Sioux Indian Community (cheyanne.stjohn@lowersioux.com)

Scott Walz, Natural Resources Manager, Shakopee Mdewakanton Sioux Community (scott.walz@shakopeedakota.org)

Leonard Wabasha, THPO, Shakopee Mdewakanton Sioux Community (leonard.wabasha@shakopeedakota.org)

Sid Davis, USEPA (davis.sidler@epa.gov)

KRYSTLE MCCLAIN Digitally signed by KRYSTLE MCCLAIN Date: 2024.12.12 14:32:05

-06'00'