NRC-2020-0148, Comment (1) of Bari Richter on NextEra Energy Duane Arnold, LLC; Duane Arnold Energy Center; Post-Shutdown Decommissioning Activities Report; Reopening of Comment Period
| ML22005A170 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 12/20/2021 |
| From: | Richter B - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 86FR12990 00001, NRC-2020-0148 | |
| Download: ML22005A170 (31) | |
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1/5/22, 12:18 PM blob:https://www.fdms.gov/755743ed-d891-4957-80e5-a542da8158ae SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: 1/5/22 12:17 PM Received: December 20, 2021 PUBLIC SUBMISSION ADD: Marlayna Doell, Status: Pending_Post Sarah Achten, Anne Tracking No. kxe-wnws-t590 Fream, Mary Neely Comments Due: December 20, 2021 Comment (1)
Publication Date:
Submission Type: Web 3/5/2021 CITATION 86 FR 12990 Docket: NRC-2020-0148 NextEra Energy Duane Arnold, LLC; Duane Arnold Energy Center; Post- Shutdown Decommissioning Activities Report Comment On: NRC-2020-0148-0006 NextEra Energy Duane Arnold, LLC; Duane Arnold Energy Center; Post-Shutdown Decommissioning Activities Report; Reopening of Comment Period Document: NRC-2020-0148-DRAFT-0004 Comment on FR Doc # 2021-04631 Submitter Information Name: Bari Richter Address:
Jesup, IA, 50648 Email: bari.richter@gmail.com Phone: 3194294970 General Comment See attached file(s)
Attachments Informational Meeting Presentation_2077488_211123-090018 Decommision Report Comments 122021 blob:https://www.fdms.gov/755743ed-d891-4957-80e5-a542da8158ae 1/1
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar, LLC Duane Arnold Solar II, LLC Public Informational Meeting December 14, 2021
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar, LLC and Duane Arnold Solar II, LLC Duane Arnold Solar, LLC and Duane Arnold Solar II, LLC are wholly-owned indirect subsidiaries of NextEra Energy Resources, LLC (NEER)
As of December 31, 2020, NEER, through its affiliated entities, is the worlds largest generator of renewable energy from the wind and sun, generating approximately 23,370 MW of net generating capacity across 38 states and 520 MW of net generating capacity in 4 Canadian provinces 2
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Over $2.0 Billion invested in Iowa since 1999 Cerro Gordo Wind 40.5 MW Crystal Lake I 150 MW Crystal Lake II 200 MW Crystal Lake III 66 MW Endeavor I 100 MW Endeavor II 50 MW Hancock County 97.6 MW Heartland Divide I 103.5 MW Heartland Divide II* 200 MW Story County I 150 MW Story County II 150 MW Sac County Wind* 80 MW Generation Repair & Story County, IA Services Iowa Training Facility Polk County, IA 3
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Project Development and Ownership Duane Arnold Solar, LLC and Duane Arnold Solar II, LLC will develop, design, permit, and construct Phases I and II of the Project Alliant Energy, through its subsidiary Interstate Power
& Light Company (IPL), will purchase the Projects and distribute the renewable energy to its customers, including Iowa residents 4
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phases I and II: Site Selection Drivers Solar Resource Assessment Using best practices, the Project Study Area was identified as suitable for solar development Available capacity at Duane Arnold Substation Use pre-existing infrastructure Interested Participating Landowners and Proximity to Infrastructure 100% voluntary easements from participating landowners The Project will not seek the use of eminent domain Avoids Cultural and Natural Resources Project Need Agreement with IPL (Alliant Energy) o Consistent with Iowa law and policy promoting renewable generation o Cleaner energy for IPL customers 5
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phases I and II: Side by Side Map 6
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Project Phase I Overview Nameplate Capacity 50 MW AC (62.5 MW DC)
Transmission ITC MIDWEST Operator l Interconnection Line Point of Duane Arnold Substation Interconnection Estimated December 2023 Commercial Operation Date Estimated Start of Q2 2023 Field Construction Project Life (if not 30 years extended)
Site footprint (acres) ~316 acres Purchaser Interstate Power and Light Company (Alliant Energy) 7
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phase I Design Features Panel Acres ~96 acres Fenced Acres ~300 acres Impervious Surface ~6.4 acres Solar Array Blocks 2,050 single-axis, horizontal tracker mounting systems supported by over 23,500 steel piles; between 120,000 and 129,000 solar panels Setbacks Minimum 15 feet between panels and Project fence line Setbacks Minimum 6-10 feet between panels and access roads Setbacks 50-80 from non-participating property lines and at least 300 from non-participating landowner dwellings Flood Zones Avoids FEMA 100-year/500-year flood zones 8
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phase I Construction Timeline Q1 2023 Mobilization Q2 2023 Field Construction Q3 2023 Commissioning Dec.
2023 Commercial Operations 9
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Project - Phase II Overview Nameplate Capacity 150 MW AC (187.5 MW DC) and 75 MW battery energy storage system (BESS)
Transmission ITC MIDWEST Operator l Interconnection Line Point of Duane Arnold Substation Interconnection Estimated December 2024 Commercial Operation Date Estimated Start of Q1 2023 Field Construction Useful Life (if not 30 years extended)
Site footprint (acres) ~815 acres Purchaser Interstate Power and Light Company (Alliant Energy) 10
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phase II Design Features Panel Area ~237 acres Fenced Area ~771 acres Impervious Surface ~17 acres Solar Array Blocks 5,200 single-axis, horizontal tracker mounting systems supported by over 60,500 steel piles; between 370,000 and 380,000 solar panels(2)
BESS 2.75 acres; 88 containers (20ft x 8ft), each with 10 racks; total of approximately 7,040 modules. Each container will be anchored to 6 concrete or steel pile foundations Setbacks Minimum 15 feet between panels and Project fence line Setbacks Minimum 6-10 feet between panels and access roads Setbacks 50-80 from non-participating property lines and at least 300 from non-participating landowner dwellings Flood Zones Avoids FEMA 100-year/500-year flood zones 11
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phase II 75 MW Battery Energy Storage System (BESS) 88 containers (20ft x 8ft), each with 10 racks, and a total of approximately 7,040 lithium-ion battery modules The batteries will be housed in specially designed containers Each container will be anchored to 6 foundations BESS footprint approximately 2.75 acres The BESS containers will connect to 22 inverters (4 containers per inverter) that will utilize a separate collection system to charge from and discharge to the Project substation 12
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phase II Construction Timeline Q1 2023 Mobilization Q1 2023 Field Construction Q3 2024 Commissioning Dec.
2024 Commercial Operations 13
Duane Arnold SolarFiledPhases with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 I and II Shared Facilities Project Collector Substation Transforms the electricity from the collection voltage to the interconnection voltage Allows the electricity collected to match that of the grid and end-users Main Step-Up Transformer Control Enclosure Circuit Breakers Disconnect Switches Relay Panels Surge Arrestors Grounding System Metering Communications Equipment Down-Shielded Lighting 14
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Phase I and II Shared Facilities An overhead transmission line is used to connect the Gen-Tie length < one mile (0.55 to 0.75 mile)
Project substation to the 161 kV local utility substation (drawing is for illustrative Typical Pole Single Circuit Steel Monopole purposes) ~120 feet above ground height Project Substation 1.3 acres Point of Duane Arnold Substation Interconnection Useful Life (if not 30 years extended)
Combination of repurposed and shared Project facilities minimize interconnection/transmission impacts and permit Phase I and II to interconnect hundreds of MWs of solar with minimal new transmission facilities - reducing cost and other impacts 15
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Project Phase I -
Economic Benefits Earnings Construction and Operations will result in between approximately $21.0 million and
$24.7 million in earnings for Linn County and for the State of Iowa Output Local output for Linn County and the State of Iowa is projected to collectively increase between $54.2 million and
$63.6 million.(1)
Tax Revenue
~$1.78 million in tax revenue(1)
Jobs Jobs during Construction: 90-100 Jobs during Operations: 1 FTE
- 1) Estimated over 30 years of the Project 16
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Project Phase II -
Economic Benefits Earnings Construction and Operations will result in between approximately
$63.9 million and $73.9 million in earnings for Linn County and for the State of Iowa.
Output Local output for Linn County and the State of Iowa is projected to collectively increase between $171.2 million and $196.8 million.(1)
Tax Revenue
~$5.42 million in tax revenue(1)
Jobs Jobs during Construction: 90-100 Jobs during Operations: 1 FTE
- 1) Estimated over 30 years of the Project 17
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Duane Arnold Solar Project Phases I and II -
Environmental Benefits Carbon Emissions Reductions Phase I is estimated to reduce CO2 emissions by approximately 3.14 million metric tons compared to an equivalent coal-fired facility and 1.355 million metric tons in comparison to a natural gas facility.
Phase II is estimated to reduce CO2 emissions by approximately 9.49 million metric tons compared to an equivalent coal-fired facility and 4.1 million metric tons in comparison to a natural gas facility.
By design, storage batteries do not create any waste product during their charging and discharging cycles.
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Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Environmental studies completed within Project areas Each Project has evaluated site-specific conditions Biological and Bat Habitat Assessments Eagle and Raptor Nest Survey Cultural Surveys Wetland Delineations Noise Analysis Phase I Environment Site Assessment Hydrology Study Geotechnical Investigation Impacts to environmental resources have been avoided or minimized Tree clearing window to be followed for listed bats, if needed Sites on or potentially eligible for the National Register of Historic Places will be avoided Jurisdictional wetlands and waters will be avoided Project will create additional environmental benefits Fencing will allow for wildlife corridors through the Project Site Perennial vegetation Minimize Erosion 19
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Vegetative Management Plan Goals and Objectives:
Establish and sustain vegetation that will not require irrigation, regular fertilization, or pest management Comply with all applicable regulatory requirements, including Linn County ordinances for ground cover, erosion and sediment control, stormwater management, and weed control Construction Phase Cover Crops will be installed to:
o Maximize soil retention o Aid in weed suppression o Increase soil organic matter Operations Phase Solar Panel Array Zone:
The solar panel array zone will consist of predominantly native perennial vegetation that would:
o Establish quickly o Minimize erosion o Manage runoff o Build soil 20
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Low growing perennial vegetation under panels will provide several benefits Solar facilities planted with locally appropriate low growing grasses could result in a 124% increase in pollinator supply, 22% increase in soil carbon storage, 90% increase in sediment capture, and 9% increase in storm water retention capacity (1)
The Projects are coordinating with Linn County to design a diverse seed mix that is expected to result in a further increase in benefits Allows land to remain fallow, promotes accumulation of organic material, and improves soil and water quality Inclusion of legumes will fix nitrogen into soils Minimal maintenance for vegetation in contrast to some tillage and agricultural practices that can weaken soils Typical maintenance includes mowing Limited herbicide spot-treatments for invasive or woody species as needed Land can return to agricultural use after decommissioning of the Project
- 1. Walston, L. J., L. Yudi, H. M. Hartmann, J. Macknick, A. Hanson, C. Nootenboom, E. Lonsdorf, J. Hellmann. 2021. Modeling the ecosystem services of native vegetation management practices at solar energy facilities in the Midwestern United States. Ecosystem Services 47: 101227 21
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Vegetative Screening Duane Arnold Solar Phase I and II has discussed vegetative screening with participating and adjacent non-participating landowners These discussions will be on-going through construction and continue thereafter Screening may include the following:
o Screening planting plans o Funding the costs of native shrubs and trees selected and Installation o Installation by a qualified local landscape nursery 22
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Road Use Existing road evaluations consist of various field studies and reports Drainage Structure Inventory -
Bridges and Culverts High-Definition Video o Documents pre-construction condition Ground Penetrating Radar (GPR) o Document thickness and uniformity of pavement and base layers Falling Weight Deflectometer (FWD) o Measure road strength/stiffness Pavement Cores and Geoprobes o Determine components and Duane Arnold Solar Phase I and II will conduct pre-condition of subgrade construction road condition analysis in accordance with land materials use permitting in Linn County, Iowa 23
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Conclusion of Construction Projects located on 100% voluntary easements At the conclusion of construction, the Project owner will meet with landowners to discuss and settle any confirmed construction damages.
Such confirmed construction damages may include crop compensation and repair to drainage tiles damaged as a result of Project construction.
Landowners are free to negotiate specific terms applicable to their property.
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Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Decommissioning At the end of the Projects useful life, the Project owner will assess whether to cease operations and decommission the Project or to replace equipment and attempt to extend the life of the Project.
In general, decommissioning activities would include:
Dismantling and removal of all above ground equipment (solar panels, racking, transformers, Project Substation, BESS equipment, etc.);
Removal of all above ground cabling; Removal of posts; Break-up and removal of concrete pads and foundations; Pumping and break-up of any septic tank (backfilled with clean soil) and abandonment of leach field (if applicable);
Removal and/or abandonment of underground utilities; and Scarification of compacted areas within and contiguous to the solar plant facility (including but not limited to internal and external access roadways).
For the Gen-Tie line and collector substation, dismantling would include:
Dismantling and demolishing above ground structures; Removal of concrete foundations; Excavation and removal of soils and broken concrete from the site; and Surface contouring to return the disturbed areas to near-original conditions.
25
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Proudly Supporting Communities Where We Work Phase I and II of the Project are projected to provide approximately $7.0 million in property taxes, additional revenue for all taxing districts Up to 200 construction jobs Two full-time, quality, high-paying jobs Significant landowner payments Efficient, reliable, and safe Community Relationships Kirkwood Community College HACAP Palo American Legion Cougar Electric Co.
Trees Forever Marion Heritage Museum Airport National Golf 26
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Thank You www.DuaneArnoldSolar.com and Click on Get Involved Visit Facebook.com/DuaneArnoldSolar Like our page to stay engaged 606 First Street, Palo, Iowa 52324 Tuesday 12 - 4 pm, Wednesday 8 am - 12 pm, Thursday 3 - 7 pm, Saturday 8 am - 12pm 27
Filed with the Iowa Utilities Board on November 23, 2021, GCU-2021-0002 Questions?
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December 20, 2021 Thank you for the opportunity to provide comment on the Post Shutdown Decomission Activities Report submitted by NextEra Energy on April 2 , 2020.
There are three areas that appear to be worthy of consideration by the Nuclear Regulatory Commission in light of the proposed Utility Solar development by NextEra Energy which will border Duane Arnold Energy Center (DAEC).
Tritium Under section 2.3.6 Groundwater Protection and Radiological Decommissioning Records Program it is noted In 2012, measureable amounts of tritium began to be detected in some of the groundwater monitoring wells in an area immediately adjacent to the south side of the Turbine and Reactor buildings, continuiing for a short distance to the southeast on the plant property.
The document then goes on to state, As a result of the ongoing mitigation and given a tritium half-life of 12.3 years, no tritium mitigation is expected to be required at the end of the SAFSTOR period.
The questions we would like nuclear regulators to consider.
1.) Will the driving of beams repeatidly in the soil cause disruption of underground water which could cause the previously controlled tritium plume to disperse?
2.) Will the distruption and/or damage of field drainage tile sytems near DAEC due to construction of Duane Arnold Solar (DAS) disrupt groundwater and change the containment of the tritium?
Fire Management In 2.2.1.4 Fire Protection Systems indicates the ability to protect spent fuel and other radioactive materials from potential fire induced releases.
The outstanding question we would like the Nuclear Regulatory Commission to verify is the facility ready to handle potential fire risk from a nearby utlity solar and battery installation with volunteer fire department support?
Security requirement discussed in 2.2.2 Dormancy is Security during the dormancy period will be conducted primarily to safeguard spent fuel on site and prevent unauthorized entry. The key words we observed in this paragraph are unauthorized entry.
There appears there may be two different security challenges due to construction of the Utility Solar facility.
1.) the increased amount of traffic that will be within proximity to the facilty during the period of construction and 2.) the reduced visibilty upon conclusion of the construction due to rows of solar panels that will project approximately 13 into the air at maximum height.
Will these changes need to impact operational plans during the decommisssioning period?
Fund Segregation Finally, in the letter dated February 20, 2020 regarding the Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv) submitted by Dean Curtland of NextEra Energy Duane Arnold Energy LLC indicated Section (a)(S)(i)(A) of 10 CFR 50.82, "Termination of license," states the following:
Decommissioning trust funds may be used by licensees if -- (A) The withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in § 50. 2.
Would the regulator make sure that if any issues occur at DAEC due to construction or operation from Duane Arnold Solar facilities, that those items are not paid from the DAEC decommissioning trust funds?
Included with this document is the presentation NextEra Energy submitted to the Iowa Utilites Board on November 23, 2021 to provide size, scope and placement of the project.
Again, thank you for the opportunity to provide comment and raise questions.
Sincerely, Bari Richter 915 Duroe St.
Jesup, IA 50648 Attachment