NRC-2023-0192, Comment (18) of Francisco Donez on Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2; Draft Supplement Environmental Impact Statement
| ML25058A185 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/13/2024 |
| From: | Donez F US Environmental Protection Agency, Region 9 |
| To: | Kimberly Conway Office of Nuclear Material Safety and Safeguards, Office of Administration |
| References | |
| NRC-2023-0192, 89FR87433 00018, NUREG-1437 S62 | |
| Download: ML25058A185 (1) | |
Text
PUBLIC SUBMISSION As of: 12/18/24, 1:47 PM Received: December 13, 2024 Status: Pending_Post Tracking No. m4n-9jzr-wako Comments Due: December 16, 2024 Submission Type: Web Docket: NRC-2023-0192 Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2 Comment On: NRC-2023-0192-0013 Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2; Draft Supplemental Environmental Impact Statement Document: NRC-2023-0192-DRAFT-0027 Comment on FR Doc # 2024-25444 Submitter Information Email:nelson.chloe@epa.gov Government Agency Type:Federal Government Agency:EPA General Comment Please find EPA's attached comments on the Diablo Canyon Nuclear Power Plant Draft Supplemental Environmental Impact Statement listed under Docket ID NRC-2023-0192.
Attachments 2024-12-13_EPA Comments_Diablo Canyon Draft SEIS 12/18/24, 1:47 PM blob:https://www.fdms.gov/fd380136-be50-4fb8-85be-757e70979aa4 blob:https://www.fdms.gov/fd380136-be50-4fb8-85be-757e70979aa4 1/1 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Kim Conway, Antoinette Walker-Smith, Mary Neely Comment (18)
Publication Date:
11/1/2024 Citation: 89 FR 87433
December 13, 2024 Kim Conway U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Mailstop T-4 B72 Washington, DC 20555-0001
Subject:
NUREG-1437, Supplement 62, draft, EPA Comments on the Draft Supplemental Environmental Impact Statement for the Operating License Renewal of Diablo Canyon Power Plant, Units 1 & 2, San Luis Obispo, California
Dear Kim Conway:
The U.S. Environmental Protection Agency has reviewed the above-referenced document pursuant to our NEPA review authority under 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.
The Nuclear Regulatory Commission (NRC) prepared a Draft Supplemental Environmental Impact Statement (SEIS) that evaluates the potential environmental impacts associated with the proposed operating license renewal for Diablo Canyon Power Plants (DCPP) Units 1 & 2 for an additional 20 years beyond their current license expiration dates of November 2, 2024, and August 26, 2025, respectively. The DCPP is a 2,240-megawatt nuclear-powered steam electric generating facility responsible for approximately 9% of Californias in-state electricity production. DCPP comprises 750 acres and uses a once-through cooling water system which draws water from and discharges back into the Pacific Ocean in San Luis Obispo County. The Draft SEIS evaluates the environmental impacts of the proposed action, a no-action alternative, and a replacement power alternative comprised of a purchased power and renewables combination.
The EPA did not identify significant public health, welfare, or environmental quality concerns to be addressed in the Final EIS and is providing the following recommendations to improve the assessment and/or environmental outcome of the proposed action.
2 Once-Through Cooling System Impingement & Entrainment Impact Uncertainty Page 3-82 describes the NRCs weight-of-evidence approach for analysis on the potential impacts of impingement and entrainment. This approach relies on impingement studies from 1985-1986 paired with extrapolation analysis done in 2009, and entrainment studies completed in 1996-1999 and again in 2008-2009, to conclude that insignificant changes were found during the current operating license term (p. 3-80). In the 15 years since those most recent analyses were completed for both impingement and entrainment, conditions may have changed. New studies would make the impacts analysis more robust by either confirming consistency with past trends across the entirety of the current operating license term, or by introducing new information that may alter conclusions and adjust the sum of annual interim mitigation payments. If the NRC does not plan to conduct new studies to establish current baseline data and monitor rate changes, EPA recommends that the Final SEIS clearly state the uncertainty associated with not utilizing updated environmental monitoring data for the assessed impingement-and entrainment-related impacts.
Future Reevaluation of BTA Feasibility Page 3-75 states that the Bechtel Power Corporation assessed alternative cooling technologies or modifications for Diablo Canyons existing once-through cooling system to support PG&Es compliance with Californias Once-Through Cooling (OTC) Policy, but none of the evaluated alternatives were deemed feasible. Resulting from DCPPs inability to convert to a closed-cycle system or another best technology alternative, Senate Bill 846 and the SWRCBs Resolution No. 2023-0025 to their OTC Policy established the final compliance dates for Diablo Canyon Units 1 and 2 to be October 31, 2030. Unless provisions to the contrary are made to SB-846 and SWRCBs OTC Policy, DCPP would only be able to operate for six more years regardless of whether the operating license renewal for an additional 20 years was approved. The EPA recommends that PG&E consider committing to a feasibility reevaluation of cooling modification alternatives for DCPPs once-through cooling system, should provisions be made within the next 6 years that would allow for extended plant operations past 2030. While available technology does not currently exist, future technological advancements may occur, which DCPP could adopt to obtain BTA compliance with the state OTC Policy.
We appreciate the opportunity to review the Draft SEIS. When the Final SEIS is released for public review, please send an email with a link to the document to nelson.chloe@epa.gov. If you have any questions, please contact me at (415) 972-3629, or contact Chloe Nelson, the lead reviewer for this project, at (415) 972-3502.
Sincerely, Francisco Dónez Manager Environmental Review Section 2 cc: Arwen Wyatt-Mair Senior Water Resources Control Engineer & NPDES Program Manager, Central Coast Regional Water Quality Control Board FRANCISCO DONEZ Digitally signed by FRANCISCO DONEZ Date: 2024.12.13 10:12:31 -08'00'