ML25239A035
| ML25239A035 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/25/2025 |
| From: | Mcclain K US Environmental Protection Agency, Region 5 |
| To: | Kevin Folk NRC/NMSS/DREFS/EPMB1 |
| References | |
| Download: ML25239A035 (1) | |
Text
August 25, 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: Final 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, Final Report (NUREG-1437); Two Creeks, Manitowoc County, Wisconsin; CEQ No. 20250117
Dear Mr. Folk:
The U.S. Environmental Protection Agency has reviewed the U.S. Nuclear Regulatory Commissions Final Supplemental Environmental Impact Statement (Final SEIS), dated August 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 comments pursuant to NEPA and Section 309 of the Clean Air Act. The CAA Section 309 role is unique to EPA and requires EPA to review and comment on the environmental impact of any proposed federal action subject to NEPAs environmental impact statement requirements and to make its comments public.
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 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 8, 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 (LR GEIS).4 In 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. NRC staff prepared the 2025 site-specific 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 environmental impacts of a subsequent license renewal; the no-action alternative; construction of a small modular reactor (SMR); a natural gas combined-cycle facility; and a SMR, solar photovoltaic energy facilities, and onshore wind facilities. The Final SEIS indicated NRC staff recommended renewal of the PBNP operating license for Unit 1 through October 5, 2050, and Unit 2 through March 8, 2053.
EPAs Draft SEIS comment letter focused on four topics: coordination with the Wisconsin Department of Natural Resources regarding best technology available for minimizing impingement mortality and entrainment, tritium concentrations in groundwater, the need for an exemption to the General Wisconsin Pollutant Discharge Elimination System industrial stormwater permit, and the use of measures to control leakage of sulfur hexafluoride (SF6). The Final SEIS addressed these comments.
We appreciate revisions to SEIS Section 3.15.3.1 explaining the Applicants inspection process for circuit breakers and switches, as well as condenser tube leak detection, to avoid breakdowns that could result in SF6 leaks.
4 The purpose of the GEIS is to identify and evaluate environmental issues for license renewal and determine which issues 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.
Thank you for the opportunity to provide comments on the Final SEIS. Please send an electronic copy of the Record of Decision related to this project to R5NEPA@epa.gov. If you have 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 CC 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: 2025.08.25 10:03:58 -05'00'