NRC-2024-0046, Comment (1) of Krystle Z. Mcclain on Constellation Energy Generation; Clinton Power Station, Unit 1; Draft Supplemental Environmental Impact Statement

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Comment (1) of Krystle Z. Mcclain on Constellation Energy Generation; Clinton Power Station, Unit 1; Draft Supplemental Environmental Impact Statement
ML25147A217
Person / Time
Site: Clinton Constellation icon.png
Issue date: 05/21/2025
From: Mcclain K
Environmental Protection Agency
To: Ashley Waldron
Office of Nuclear Material Safety and Safeguards, Office of Administration
References
NRC-2024-0046, 89FR16591 00001, NUREG-1437, CEQ 20250042
Download: ML25147A217 (1)


Text

PUBLIC SUBMISSION As of: 5/27/25, 2:53 PM Received: May 21, 2025 Status: Pending_Post Tracking No. may-amaz-4sgw Comments Due: June 01, 2025 Submission Type: Web Docket: NRC-2024-0046 Constellation Energy Generation, LLC; Clinton Power Station, Unit 1; License Renewal Application Comment On: NRC-2024-0046-0004 Constellation Energy Generation; Clinton Power Station, Unit 1; Draft Supplemental Environmental Impact Statement Document: NRC-2024-0046-DRAFT-0001 Comment on FR Doc # 2025-06439 Submitter Information Email:kowal.kathleen@epa.gov Government Agency Type:Federal Government Agency:EPA General Comment See attached file(s)

Attachments USEPA's Comments - Clinton Power Station License Renewal DGEIS 5/27/25, 2:56 PM NRC-2024-0046-DRAFT-0001.html file:///C:/Users/TAW/Downloads/NRC-2024-0046-DRAFT-0001.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Chris Tyree; Mark Yoo Comment (1)

Publication Date: 3/7/2024 Citation: 89 FR 16591

VIA ELECTRONIC MAIL ONLY Ashley Waldron REGION 5 CHICAGO, IL 60604 May 20, 2025 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 63 Regarding License Renewal for Clinton Power Station, Unit 1, Draft Report for Comment (NUREG-1437); Clinton, De Witt County, Illinois; CEQ No. 20250042

Dear Ms. Waldron:

The U.S. Environmental Protection Agency has reviewed the Draft Supplemental Environmental Impact Statement (Draft SEIS) dated April 2025, concerning the license renewal (LR) of Clinton Power Station, Unit 1 (CPS) in Clinton, Illinois. The U.S. Nuclear Regulatory Commission is the lead federal agency under the National Environmental Policy Act. This letter provides EPA's 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 NEPA's environmental impact statement requirements.

CPS is a single unit boiling water reactor facility that produces 1,080 Megawatts1 of power. NRC issued the original facility operating license in September 1986 and commercial operation began on April 17, 1987. On February 14, 2024, Constellation Energy Generation (Applicant) applied to NRC for the LR of renewed operating facility license (NPF-62) which is set to expire at midnight on April 17, 2027. The application for LR seeks to extend the current facility operating license for an additional 20 years of operation, expiring at midnight April 17, 2047. Plant operation activities during the LR term would be the same as, or similar to, those occurring during the current license term. The Applicant has not identified any LR-related refurbishment or replacement actions needed to maintain the functionality of systems, structures, and components, consistent with the current licensing basis, during the proposed LR term.

1 CPS was originally licensed with reactor core thermal power rated at 2,894 megawatts thermal (MWt). In 2002, the NRC approved an extended power update to increase the maximum reactor core power level to 3,473 MWt. The unit is designed to operate at a gross electrical power output of approximately 1,138.5 megawatts electric (MWe) with a net generation of 1,080 MWe.

The Draft SEIS evaluates the environmental impacts of the proposed action, a no-action alternative, and replacement power alternatives comprised of a natural gas alternative, 2 a renewable and natural gas combination alternative,3 and a purchased power alternative.4 NRC staff's preliminary recommendation is to renew the CPS operating license.

EPA's enclosed comments focus on regulatory compliance. EPA makes these recommendations to improve the usefulness of the Draft EIS 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.

Enclosures:

EPA's Detailed Comments CC (with enclosures; via electronic mail only)

Sincerely, KRYSTLE Digitally signed by KRYSTLE MCCLAIN Mee LAIN Date: 2025.05.20 09:49:12 -05'00' Krystle Z. McClain, P.E.

NEPA Program Supervisor EPA Region 5 Kristopher Lah, U.S. Fish and Wildlife Service (Kristopher Lah@fws.gov)

Rita Baker, Illinois State Historic Office (Rita.e.baker@illinois.gov)

Gene Jablonowski, EPA Region 5 Health Physicist (jablonowski.eugene@epa.gov) 2 Construction of a natural gas combined cycle plant 3 Construction of a natural gas combined cycle plant, wind energy and solar energy installation combination 4 Import electric energy into the CPS service area from multiple existing energy generating sources 2

EPA's Detailed Comments Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 63, Regarding Clinton Power Station, Unit 1 Clinton, De Witt County, Illinois May 20, 2025

1. THREATENED AND ENDANGERED SPECIES A. The Draft SEIS indicated NRC staff determined that four federally-listed species, two species proposed for federal listing as threatened, one species proposed for federal listing as endangered, and one experimental population non-essential species, may occur in the action area. NRC's Endangered Species Act determinations can be found in Table 3-16, Effect Determinations for Federally Listed Species under U.S. Fish and Wildlife Service Jurisdiction.

The Draft SEIS indicated NRC staff will seek USFWS's concurrence with these findings following issuance of the Draft SEIS.

Recommendations for the Final SEIS:

1. Discuss coordination regarding NRC's compliance with the Illinois Department of Natural Resources' Endangered Species Program. 5
2. Document coordination with both USFWS and IDNR in the final NEPA documents, with the goal of aligning NEPA and ESA Section 7 consultation processes. Include results of coordination, concurrences, and stipulations from USFWS and IDNR regarding federally-and state-protected species.
2. HISTORIC AND CULTURAL RESOURCES A. The Draft SEIS indicated NRC staff initiated Section 1066 consultations with the Illinois State Historic Preservation Office and five Tribes. The SHPO provided recommendations concerning what was expected in the Draft SEIS and emphasized the need for an inadvertent discovery plan outlining the process for any unanticipated discoveries that may occur during the 20-year term of the LR. NRC staff determined the proposed action will result in No Adverse Effect to historic properties. The Draft SEIS indicated NRC has elected to use the NEPA process to comply with its obligations under Section 106.

Recommendations for the Final SEIS:

1. Document coordination with SHPO in the final NEPA documents, with the goal of aligning NEPA and Section 106 consultation processes. Include results of coordination, concurrences, and stipulations, if applicable, from the SHPO and Tribes.

5 Nine species are listed as endangered or threatened. See https://dnr.illinois.gov/content/dam/soi/en/web/dnr/espb/documents/EORS%20by%20County%20Last0bs%20for%20website%20June20 24.pdf 6 Section 106 of the National Historic Preservation Act 3