NRC-2015-0012, Comment (001) of Jennifer Blonn on License Renewal of Nuclear Plants Regarding Braidwood Station, Units 1 and 2, Braidwood, Will County, Illinois
| ML16008A974 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/21/2015 |
| From: | Blonn J Environmental Protection Agency |
| To: | Baum R, Blady C, Lois James Rules, Announcements, and Directives Branch, License Renewal Projects Branch 2 |
| References | |
| 80FR72452 00001, NRC-2015-0012 | |
| Download: ML16008A974 (4) | |
Text
s)
Mendiola, Doris
Subject:
Attachments:
FW: EPA Comments on Braidwood Finai SEIS 2015_12_NRC_BraidwoodFSElS_USEPAComments.pdf From: Blonn, Jennifer [1]
Sent: Monday, December 21, 2015 1:35 PM To: Baum, Richard <Richard.Baum@nrc.gov>; James, Lois <Lois.James@nrc.gov>; Bladey, Cindy
<Cindy. Bladev@ nrc.gov>
Subject:
[External_Sender] EPA Comments on Braidwood Final SEIS Hi Cindy, Rick & Lois -
Attached please find U.S. EPA's comments on the Final SEIS for Liscense Renewal at Braidwood Station. I am also mailing a hard copy of our letter.
- Thanks, Jen Jennifer Blonn NEPA Implementation Section (E-19J)
U.S. Environmental Protection Agency, Region 5 77 W. Jackson Boulevard Chicago, Illinois 60604 312-886-6394 blonn.iennifer@epa.gov
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PROWCHICAGO, IL 60604-359O DEC 2 1 ZO05 REPLY TO THE ATENTION OF:
E-19J Cindy Bladey, Chief Rules, Announcements and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Mail Stop 16 3WFN-06-A44M\\P Washington, DC 20555-0001 Re:
Final Plant-Specific Supplement 55 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Braidwood Station, Units 1 and 2, Braidwood, Will County, Illinois - CEQ# 20150335
Dear Ms. Bladey:
The U.S. Environmental Protection Agency has reviewed the Final Supplemental Environmental Impact Statement (SETS) for the above mentioned project. Our comments are provided pursuant to the National Environmental Policy Act (NEPA), the Council on Environmental Quality's NEPA Implementing Regulations found at 40 CFR 1500-1508, and Section 309 of the Clean Air Act. The U.S. Nuclear Regulatory Commission is the lead federal agency under NEPA. Exelon Generation Company, LLC owns and operates Braidwood Station and is the project proponent.
Braidwood Station is a two-unit pressurized-water reactor located in Will County, Illinois. The existing power reactor began commercial operation in 1988, and the current operating licenses (NPF-72 and NPF-77) expire on October 17, 2026 and December 18, 2027, respectively. NRC assessed the impacts of renewing the licenses for an additional 20 years within this Final SETS and concluded that, "the adverse environmental impacts of license renewal for Braidwood are not so great that preseri~ng the option of license renewal for energy-planning decision makers would be unreasonable" (page 5-2).
EPA issued a May 12, 2015 comment letter in response to the Draft SETS and rated the document Environmental Concerns - Adequate Information due to potential impacts to threatened and endangered species, surface water, and air quality. We also raised concerns regarding NRC's consideration of climate change impacts on future Braidwood operations. NRC' s responses to our species and water comments clarify impacts and strengthen protective measures. We understand that consultation with U.S. Fish and Wildlife Service is ongoing, and we appreciate NRC's commitment to include consultation results in the Record of Decision.
Our only outstanding recommendations relate to our Draft SETS Comment 013-8-Greenhouse Gas Emissions and Climate Change and Comment O013-09-Air Quality. We understand that the "NRC cannot impose mitigation measures or standards on its nuclear power plant licensees that are not related to public health and safety from radiological hazards or common defense and Recycled/Recyclabie
- Printed with Vegetable Oil Based Inks on 100% Recycled Paper ('100% Post-Consumer)
security" (pages A-78 and A-80). We are not asking NRC to impose measures or standards related to air emissions. Rather, we ask that the NRC commit to share and promote the follo~wing recommendations with the applicant in order to facilitate the spread of best practices for protecting human health and the environment.
Recommendations:
Greenhouse Gas Emissions Encourage the applicant to identify opportunities to minimize greenhouse gas emissions associated with refurbishment activities and overall facility operations and maintenance. For example, consider energy efficiency and renewable energy in the purchase of operational equipment, maintenance equipment, and vehicles. Cleaner energy options can yield cost savings for the applicant by reducing energy demands while also lowering the facility's contribution toward global climate change.
Air Quality Encourage the applicant to use the following practices for all applicable activities powered by diesel fuel. Such practices can minimize local health impacts from diesel emissions as well as the facility's greenhouse gas footprint.
- Use low-sulfur diesel fuel (15 ppm sulfur maximum) in construction vehicles and equipment.
- Retrofit engines with an exhaust filtration device to capture diesel particulate matter before it enters the construction site.
- 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 catalytic converters to reduce carbon monoxide, aldehydes, and hydrocarbons in diesel fumes. These devices must be used with low sulfur fuels.
- Use enclosed, climate-controlled cabs pressurized and equipped with high efficiency particulate air (JIEPA) 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.
- Regularly maintain diesel engines, which is essential to keep exhaust emissions low.
Follow the manufacturer's recommended maintenance schedule and procedures. Smoke color can signal the need for maintenance. For example, blue/black smoke indicates that an engine requires servicing or tuning.
- Reduce exposure through work practices and training, such as turning off engines when vehicles are stopped for more than a few minutes, training diesel-equipment operators to perform routine inspection, and maintaining filtration devices.
- Repower older vehicles and/or equipment with diesel-or alternatively-fueled engines certified to meet newer, more stringent emissions standards. Purchase new vehicles that are equipped with the most advanced emission control systems available.
o Use electric starting aids such as block heaters with older vehicles to warm the engine to reduce diesel emissions.
2
J*
d We thank the NRC project team for the detailed responses to our comments. We appreciate the opportunity to review this Final SEIS, and we appreciate our working relationship with NRC staff. If you have any questions, please feel free to contact Jen Blonn of my staff at 312-886-6394 or blonn.jennifer@epa.gov.
Sincerely, Kenneth A. Westlak6" Chief, NEPA Implementation Section Office of Enforcement and Compliance Assurance CC Via Email:
Nathan Grider, Illinois Department of Natural Resources Shawn Cirton, U.S. Fish and Wildlife Service Alan Keller, Illinois Environmental Protection Agency Lois James, U.S. Nuclear Regulatory Commission Richard Baum, U.S. Nuclear Regulatory Commission 3
s)
Mendiola, Doris
Subject:
Attachments:
FW: EPA Comments on Braidwood Finai SEIS 2015_12_NRC_BraidwoodFSElS_USEPAComments.pdf From: Blonn, Jennifer [2]
Sent: Monday, December 21, 2015 1:35 PM To: Baum, Richard <Richard.Baum@nrc.gov>; James, Lois <Lois.James@nrc.gov>; Bladey, Cindy
<Cindy. Bladev@ nrc.gov>
Subject:
[External_Sender] EPA Comments on Braidwood Final SEIS Hi Cindy, Rick & Lois -
Attached please find U.S. EPA's comments on the Final SEIS for Liscense Renewal at Braidwood Station. I am also mailing a hard copy of our letter.
- Thanks, Jen Jennifer Blonn NEPA Implementation Section (E-19J)
U.S. Environmental Protection Agency, Region 5 77 W. Jackson Boulevard Chicago, Illinois 60604 312-886-6394 blonn.iennifer@epa.gov
//i ///7 i-i k
--0
/
SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 1
e" il -5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
- ÷*4_**'*REGION5
- Ro.
_e77 WEST JACKSON BOULEVARD
~
PROWCHICAGO, IL 60604-359O DEC 2 1 ZO05 REPLY TO THE ATENTION OF:
E-19J Cindy Bladey, Chief Rules, Announcements and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Mail Stop 16 3WFN-06-A44M\\P Washington, DC 20555-0001 Re:
Final Plant-Specific Supplement 55 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Braidwood Station, Units 1 and 2, Braidwood, Will County, Illinois - CEQ# 20150335
Dear Ms. Bladey:
The U.S. Environmental Protection Agency has reviewed the Final Supplemental Environmental Impact Statement (SETS) for the above mentioned project. Our comments are provided pursuant to the National Environmental Policy Act (NEPA), the Council on Environmental Quality's NEPA Implementing Regulations found at 40 CFR 1500-1508, and Section 309 of the Clean Air Act. The U.S. Nuclear Regulatory Commission is the lead federal agency under NEPA. Exelon Generation Company, LLC owns and operates Braidwood Station and is the project proponent.
Braidwood Station is a two-unit pressurized-water reactor located in Will County, Illinois. The existing power reactor began commercial operation in 1988, and the current operating licenses (NPF-72 and NPF-77) expire on October 17, 2026 and December 18, 2027, respectively. NRC assessed the impacts of renewing the licenses for an additional 20 years within this Final SETS and concluded that, "the adverse environmental impacts of license renewal for Braidwood are not so great that preseri~ng the option of license renewal for energy-planning decision makers would be unreasonable" (page 5-2).
EPA issued a May 12, 2015 comment letter in response to the Draft SETS and rated the document Environmental Concerns - Adequate Information due to potential impacts to threatened and endangered species, surface water, and air quality. We also raised concerns regarding NRC's consideration of climate change impacts on future Braidwood operations. NRC' s responses to our species and water comments clarify impacts and strengthen protective measures. We understand that consultation with U.S. Fish and Wildlife Service is ongoing, and we appreciate NRC's commitment to include consultation results in the Record of Decision.
Our only outstanding recommendations relate to our Draft SETS Comment 013-8-Greenhouse Gas Emissions and Climate Change and Comment O013-09-Air Quality. We understand that the "NRC cannot impose mitigation measures or standards on its nuclear power plant licensees that are not related to public health and safety from radiological hazards or common defense and Recycled/Recyclabie
- Printed with Vegetable Oil Based Inks on 100% Recycled Paper ('100% Post-Consumer)
security" (pages A-78 and A-80). We are not asking NRC to impose measures or standards related to air emissions. Rather, we ask that the NRC commit to share and promote the follo~wing recommendations with the applicant in order to facilitate the spread of best practices for protecting human health and the environment.
Recommendations:
Greenhouse Gas Emissions Encourage the applicant to identify opportunities to minimize greenhouse gas emissions associated with refurbishment activities and overall facility operations and maintenance. For example, consider energy efficiency and renewable energy in the purchase of operational equipment, maintenance equipment, and vehicles. Cleaner energy options can yield cost savings for the applicant by reducing energy demands while also lowering the facility's contribution toward global climate change.
Air Quality Encourage the applicant to use the following practices for all applicable activities powered by diesel fuel. Such practices can minimize local health impacts from diesel emissions as well as the facility's greenhouse gas footprint.
- Use low-sulfur diesel fuel (15 ppm sulfur maximum) in construction vehicles and equipment.
- Retrofit engines with an exhaust filtration device to capture diesel particulate matter before it enters the construction site.
- 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 catalytic converters to reduce carbon monoxide, aldehydes, and hydrocarbons in diesel fumes. These devices must be used with low sulfur fuels.
- Use enclosed, climate-controlled cabs pressurized and equipped with high efficiency particulate air (JIEPA) 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.
- Regularly maintain diesel engines, which is essential to keep exhaust emissions low.
Follow the manufacturer's recommended maintenance schedule and procedures. Smoke color can signal the need for maintenance. For example, blue/black smoke indicates that an engine requires servicing or tuning.
- Reduce exposure through work practices and training, such as turning off engines when vehicles are stopped for more than a few minutes, training diesel-equipment operators to perform routine inspection, and maintaining filtration devices.
- Repower older vehicles and/or equipment with diesel-or alternatively-fueled engines certified to meet newer, more stringent emissions standards. Purchase new vehicles that are equipped with the most advanced emission control systems available.
o Use electric starting aids such as block heaters with older vehicles to warm the engine to reduce diesel emissions.
2
J*
d We thank the NRC project team for the detailed responses to our comments. We appreciate the opportunity to review this Final SEIS, and we appreciate our working relationship with NRC staff. If you have any questions, please feel free to contact Jen Blonn of my staff at 312-886-6394 or blonn.jennifer@epa.gov.
Sincerely, Kenneth A. Westlak6" Chief, NEPA Implementation Section Office of Enforcement and Compliance Assurance CC Via Email:
Nathan Grider, Illinois Department of Natural Resources Shawn Cirton, U.S. Fish and Wildlife Service Alan Keller, Illinois Environmental Protection Agency Lois James, U.S. Nuclear Regulatory Commission Richard Baum, U.S. Nuclear Regulatory Commission 3