ML25143A233

Comment (2) E-mail Regarding Point Beach SLR 2DSEIS

ML25143A233
Person / Time
Site:	Point Beach
Issue date:	05/23/2025
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
90FR16008
Download: ML25143A233 (9)

Text

From:

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

Sent:

Friday, May 23, 2025 9:06 AM To:

Kevin Folk

Subject:

[External_Sender] USEPA's Comment Letter - DGEIS for Point Beach Re-license Attachments:

USEPA's Comment Letter - DGEIS for Point Beach License Renewal.pdf Greetings, Attached please find USEPAs comment letter regarding 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 Kathy Kowal NEPA Reviewer US EPA, Region 5 77 West Jackson Blvd.

Chicago, IL 60604 kowal.kathleen@epa.gov

Federal Register Notice:

90FR16008 Comment Number:

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Subject:

[External_Sender] USEPA's Comment Letter - DGEIS for Point Beach Re-license Sent Date:

5/23/2025 9:05:49 AM Received Date:

5/23/2025 9:06:01 AM From:

Kowal, Kathleen Created By:

kowal.kathleen@epa.gov Recipients:

"Kevin Folk" <Kevin.Folk@nrc.gov>

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May 22, 2025 VIA ELECTRONIC MAIL ONLY Kevin Folk Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 RE:

EPA Comments: Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants; Supplement 23 Second Renewal Regarding Subsequent License Renewal for Point Beach Nuclear Plant, Units 1 and 2, Draft Report for Comment (NUREG-1437); Two Creeks, Manitowoc County, Wisconsin; CEQ No. 20250043

Dear Mr. Folk:

The U.S. Environmental Protection Agency has reviewed the U.S. Nuclear Regulatory Commissions Draft Supplemental Environmental Impact Statement (Draft SEIS), dated April 11, 2025, concerning the subsequent license renewal (SLR) of Point Beach Nuclear Plant, Units 1 and 2, (PBNP) in Manitowoc County, Wisconsin. The NRC is the lead federal agency under the National Environmental Policy Act.

This letter provides EPAs comment pursuant to NEPA and Section 309 of the Clean Air Act. The CAA Section 309 role is unique to EPA. It requires EPA to review and comment publicly on any proposed federal action subject to NEPAs environmental impact statement requirements.

PBNP is a two-unit, pressurized water reactor facility that produces 1,200 Megawatts of power, located along the shores of Lake Michigan. NRC issued the original facility operating license for Unit 1 on October 5, 1970, and Unit 2 on March 8, 1973.1 NRC issued the first license renewals (LR) for Units 1 and 2 on December 12, 2005.2 On November 16, 2020, NextEra Energy Point Beach, LLC (Applicant) applied to NRC for the SLR of renewed operating facility licenses No. DPR-24 and No. DPR-27. The application for SLR seeks to extend the current facility operating license for Unit 1 through October 5, 2050, and Unit 2 through March 8, 2053.

As is procedure, NRC gathered information necessary to prepare a site-specific supplement3 to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS).4 In 1 The original licenses were set to expire October 5, 2010, and March 8, 2013, for Units 1 and 2, respectively.

2 The current facility operating license for Unit 1 will expire on October 5, 2030, and Unit 2 will expire on March 3, 2033.

3 NRC is required by 10 CFR 51.20(b)(2) and 10 CFR 51.95(c) to prepare a site-specific supplement to the LR GEIS for a license renewal and subsequent license renewal of a facilitys operating license.

2 2021, NRC published the site-specific supplement for PBNP. EPA provided technical feedback and recommendations on the proposed action via two comment letters dated March 3, 2021, and December 17, 2021. Following the 2021 Draft SEIS, NRC did not publish a Final SEIS, and PBNP did not receive a SLR for Units 1 and 2.

On February 24, 2022, the NRC Commissioners issued three orders5 and Staff Requirements Memorandum6 Rulemaking Plan for Renewing Nuclear Power Plant Operating Licenses Environmental Review that impacted the SLR of six plants across the country, including PBNP.7 In response, NRC staff issued Revision 2 to the LR GEIS to account for new information and to address the impact of initial LR, which the 2013 LR GEIS considered, as well as first SLR. NRC staff prepared the 2025 Draft SEIS as a second draft report for comment. The 2025 Draft SEIS includes the NRCs evaluation of new information obtained since the issuance of the 2021 Draft SEIS, as well as the new and revised environmental effects and impact determinations contained in the updated LR GEIS.

NRC and the Applicant initially considered 18 alternatives, including the proposed action as well as the No Action Alternative. However, NRC eliminated 13 alternatives due to technical infeasibility, resource availability limitations, and/or commercial and regulatory limitations.8 The Draft SEIS evaluated the following four action alternatives and the No Action Alternative:

1. Subsequent License Renewal: NRC would subsequently renew PBNPs operating licenses for an additional 20 years beyond the period specified in the current licenses.

2. New Nuclear: In lieu of SLR, the Applicant would construct and operate a Small Modular Reactor (SMR)9 facility comprising of three 400 MW-electric reactor modules with total net generating capacity of approximately 1,200MWe. This alternative would require 110 acres of existing PBNP land and the installation of closed-cycle cooling system with mechanical draft cooling towers. The SMR facility would utilize the existing transmission line infrastructure.

3. Natural Gas Combined-Cycle: In lieu of SLR, the Applicant would construct and operate a natural gas facility comprising of three 460MWe natural gas units. Each unit would require the installation of two combustion turbine generators, two heat recovery steam generators, and 4 The purpose of the GEIS is to identify and evaluate environmental issues for license renewal and determine which could result in the same or similar impact to all nuclear power plants or a specific subset of plants (e.g., generic issues) and which issues could result in different levels of impacts. Per NRC regulations, a review and update of the GEIS for license renewals is conducted every ten years, if necessary. NRC published the most recent GEIS in 2024. To view NUREG-1437, see: https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/r2/index.html.

5 Commission Memorandum and Orders: CLI-22-02, CLI-22-03, CLI-22-04 6 Staff Requirements Memorandum: SECY-21-0066 7 In response to the Commissions orders, on August 6, 2024, the NRC staff amended its environmental protection regulations by updating the 2013 findings on the environmental effects of renewing the operating license of a nuclear power plant. The final rule was published on August 21, 2024, and redefined the number and scope of environmental issues that must be addressed during the review of each application for a license renewal.

8 For a full discussion on the alternatives considered, see sections 2.3 Alternatives and 2.4 Alternatives Considered but Eliminated (2021 DSEIS: pages 2-15 through 2-33; 2025 DSEIS: pages 2-6 through 2-11).

9 SMRs are advanced reactors that incorporate innovative technologies as compared to existing operating reactors. These technologies include passive safety features, alternative fuel or coolant types, and smaller reactor sizes. SMRs are a subset of light-water reactors that are designed to be more compact, scalable, and potentially safer. For more information on SMRs, view:

https://www.nrc.gov/reactors/new-reactors/advanced.html.

3 one steam turbine generator with a mechanical draft cooling tower. Construction and operations for this alternative would require 60 acres of existing PBNP land as well as an additional 120 acres for right-of-way to connect with existing natural gas supply lines. The natural gas facility would utilize the existing transmission line infrastructure.

4. Combination Alternative: In lieu of SLR, the Applicant would construct and operate: (1) an SMR facility comprising of two 800Mwe units located on existing PBNP land, requiring the installation of mechanical draft cooling towers; (2) solar photovoltaic energy facilities comprising of four 125Mwe standalone, utility-scale solar facilities, requiring the use of 3,200 acres of land; and (3) onshore wind facilities, comprising of three 120MWe farms, requiring 31,000 acres of land.

5. No Action Alternative: NRC would not subsequently renew PBNPs operating licenses, and the reactor units would shut down on or before the current license expiration date of October 5, 2030, for Unit 1, and March 8, 2033, for Unit 2.

NRC preliminarily selected Subsequent License Renewal as the Preferred Alternative. The enclosed comments focus primarily on regulatory compliance and groundwater. EPA makes these recommendations to improve the usefulness of the Draft SEIS for agency decision-making and to reduce potential environmental impacts of the proposed action. EPA recommends that NRC and the Applicant address these comments and recommendations before releasing the Final SEIS.

Thank you for the opportunity to review and provide comments on the Draft SEIS. Please send an electronic copy of future NEPA documents to R5NEPA@epa.gov. If you have any questions or would like to discuss the contents of this letter further, please contact the lead NEPA reviewer, Kathy Kowal, at kowal.kathleen@epa.gov.

Sincerely, Krystle Z. McClain, P.E.

NEPA Program Supervisor EPA Region 5 Enclosures EPAs Detailed Comments Appendix A: NEPAssist Attachments CC (with enclosures)

Rob Tawes, USFWS Minnesota-Wisconsin ESFO (robert_taws@fws.gov)

Kari Fleming, WDNR Wastewater (kari.l.fleming@wisconsin.gov)

Dan Kroll, WDNR Solid Waste (daniel.kroll@wisconsin.gov)

Gene Jablonowski, EPA Region 5 Health Physicist (jablonowski.eugene@epa.gov)

KRYSTLE MCCLAIN Digitally signed by KRYSTLE MCCLAIN Date: 2025.05.22 10:05:02 -05'00'

4 EPAs Detailed Comments Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants; Supplement 23 Second Renewal Regarding Subsequent License Renewal for Point Beach Nuclear Plant, Units 1 and 2; CEQ No. 20250043 Manitowoc County, Wisconsin May 22, 2025

1. CLEAN WATER ACT SECTION 316(b)

A. Under the Clean Water Act (CWA),10 Section 316(b) regulates the location, design, construction, and capacity of cooling water intake structures. These regulations require the best technology available (BTA) for minimizing impingement mortality and entrainment.11 EPA, authorized states, and Tribes impose BTA requirements through National Pollutant Discharge Elimination System (NPDES) permitting programs.

In its 2020 permit renewal application, the Applicant assessed three BTA methods to potentially reduce entrainment at PBNP and concluded the methods were infeasible based on certain construction and operational factors.12 In 2024, the Wisconsin Department of Natural Resources (WDNR) renewed the Applicants WPDES permit with conditional BTA determinations for both impingement mortality and entrainment.13 The permit requires the Applicant to conduct an alternatives analysis in compliance with entrainment BTA requirements. Following its review of the required alternatives analysis, WDNR will make a final entrainment BTA determination. EPA appreciates NRCs thorough discussion on impingement mortality and entrainment concerning the Applicants compliance with CWA Section 316(b).14 Given the Applicants BTA assessment was completed in 2020, technological advancements may have occurred since then. The Draft SEIS did not disclose why the Applicants assessment remains relevant and adequately represents current entrainment technologies.

Recommendations for the Final SEIS:

1. Consider discussing current coordination with WDNR regarding the required alternatives analysis.

2. If WDNR does not concur with the Applicants 2020 conclusions, consider discussing whether new technologies have been derived during the past five years to achieve the necessary entrainment standard.

10 Section 316(b) of the Clean Water Act grants EPA the authority to regulate cooling water intake structures to minimize adverse impacts on the aquatic environment.

11 Pursuant to Section 316(b), EPA promulgated regulations for existing facilities, such as PBNP, in 40 CFR Parts 122 & 125 (Subparts I, J, &

N). See the CWA Section 316(b) Final Rule at the Federal Register. For more on cooling water intake requirements, see EPAs webpage:

https://www.epa.gov/cooling-water-intakes.

12 Page 3-38 13 PBNPs previous WPDES permit (issued in 2016) represented an interim BTA determination for impingement mortality and entrainment.

The determination was made by WDNR in accordance with 2009 guidance. Because PBNPs previous WPDES permit (issued in 2004) expired before the effective date of the 2014 Final Rule establishing current Section 316(b) regulations, the 2014 requirements did not yet apply to PBNP during the 2016 renewal.

14 To view NRCs discussion, see Section 3.7 Aquatic Resources (2021 DSEIS: pages 3-62 through 3-103; 2025 DSEIS: pages 3-35 through 3-40).

5

2. GROUND WATER: TRITIUM A. Historically, PBNP observed high concentrations of tritium in groundwater originating from a leak in the spent fuel pool. After improvements were made to the spent fuel pool, groundwater tritium concentrations decreased. The Draft SEIS reported that 2019 tritium concentrations at six beach drains remained below EPAs Maximum Contaminant Level of 20,000 picoCuries per liter (pCi/L),15 observing ranges from 186 +/- 79 pCi/L to 631 +/- 103 pCi/L.16 In 2023, sampling results from the same six beach drains reported tritium concentrations with an annual average of 397 +/- 214 pCi/L and a maximum observed sample of 1,716 +/- 153 pCi/L.

Sampling from additional onsite locations resulted in observed tritium concentrations of 108 +/-

86 to 603 +/- 108 pCi/L in yard manholes; 462 +/- 104 to 2,339 +/- 169 pCi/L in the plant foundation sump; and non-detectable to 353 +/- 96 pCi/L in façade wells.17 EPA acknowledges that sampled tritium concentrations remain below EPAs MCL and that any potentially-impacted groundwater migrates toward Lake Michigan. However, groundwater concentrations have increased between 2019 and 2023, specifically in beach drains and the plant foundation sump. The Draft SEIS did not indicate if there would be an investigation into the source(s) of potential tritium leaks contributing to the increase in concentrations. This information may be helpful to the reviewer in understanding whether the potential source(s) of tritium leaks could be proactively investigated and addressed, even at levels below the EPAs MCL.

Recommendations for the Final SEIS:

1. Acknowledging the Applicant seeks to prevent ongoing contamination of groundwater, discuss potential investigations to identify source(s) of inadvertent tritium leaks, specifically any leaks contributing to the increased concentrations in these six beach drains and plant foundation sump.

3. WASTE STORAGE A. The Applicants Environmental Report stated PBNP has an exemption from WDNR concerning solid waste management regulations.18 The exemption allows the Applicant to maintain a spoils pile comprising of excess dirt and debris from past construction activities, including clean soil, broken pavement, and building materials.19 The pile is stabilized by vegetation and is visually inspected annually in compliance with the Stormwater Pollution Prevention Plan. The 2021 Draft SEIS included Figure 2-2, which showed the spoils pile located in the southern boundary of 15 EPAs regulatory threshold (also known as the Maximum Contaminant Level) of tritium in drinking water is 20,000 picoCuries per liter (pCi/L) under the Safe Drinking Water Act. For more information about tritium in drinking water, see https://semspub.epa.gov/work/HQ/175261.pdf.

16 Page 3-25 17 Page 3-25 18 Wisconsin Statute 289.43(8) and Wisconsin Administrative Code NR 500.08(4) 19 Applicants Environmental Report, page 2-23.

6 PBNPs site. EPAs review of the project boundary using NEPAssist20 reported the presence of an unnamed waterbody21 in the vicinity of the spoils pile.22 However, the 2021 Draft SEIS and subsequently the 2025 Draft SEIS, do not address the spoils pile, whether the Applicant contributes to the spoils pile (e.g., potential expansion during SLR), or if a WDNR exemption was needed. These clarifications could be helpful to determine if the unnamed waterbody could be impacted by expansion of the spoils pile during SLR.

Recommendations for the Final SEIS:

1. Clarify whether the spoils pile is likely to expand during the 20-year term of SLR and, if so, will an exemption be requested from WDNR.

2. Consider potential impacts to the unnamed waterbody and whether expansion will be in compliance with the Stormwater Pollution Prevention Plan.

4. AIR QUALITY: SULFUR HEXAFLUORIDE (SF6)

A. The Draft SEIS reported that SF6 is used in circuit breakers, circuit switchers, and in condenser tube leak detection at PBNP.23 SF6-containing equipment is designed to avoid emitting any of this gas into the atmosphere. However, SF6 gas can inadvertently escape as leaks develop during various stages of the equipment's lifecycle, including manufacturing, installation, maintenance and servicing, and de-commissioning. In some cases, significant leaks can occur from aging equipment.24 Recommendations for the Final SEIS:

1. EPA acknowledges that the Applicant does not record SF6 loss and/or leakage resulting in a lack of emissions reporting; however, EPA recommends considering including an expanded discussion of SF6 usage at the PBNP, including measures used to control leakage (e.g., procedures and training for performing SF6 leak testing).

20 https://www.epa.gov/nepa/nepassist 21 State ID WI10031576; for more information on the waterbody, see EPAs Hows My Waterway:

https://mywaterway.epa.gov/community/point%20beach%20nuclear/overview.

22 See Appendix A, Attachment 1 23 See Section 3.15.3 Greenhouse Gas Emissions and Climate Change (2025 DSEIS: pages 3-75 through 3-77).

24 For more information on sulfur hexafluoride, see EPAs webpage: https://www.epa.gov/eps-partnership/sulfur-hexafluoride-sf6-basics.

1 APPENDIX A NEPAssist Attachments 2025 aerial of vegetated spoils pile and unnamed waterbody, State ID WI10031576.