NRC-2024-0078, Comment (35) of Sarah Fields on Us Sfr Owner, Llc.; Kemmerer Power Station Unit 1; Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement
| ML24226A246 | |
| Person / Time | |
|---|---|
| Site: | Kemmerer File:TerraPower icon.png |
| Issue date: | 08/12/2024 |
| From: | Fields S Uranium Watch |
| To: | Office of Administration |
| References | |
| NRC-2024-0078, 89FR4991700035 | |
| Download: ML24226A246 (1) | |
Text
8/13/24, 7:32 AM blob:https://www.fdms.gov/9e43b23a-7cb1-4eda-820a-fcf72c645b59 SUNSI Review Complete Template=ADM-013 As of: 8/13/24, 7:32 AM E-RIDS=ADM-03 ADD: Patricia Vokoun, Received: August 12, 2024 PUBLIC SUBMISSION Josh Borromeo, Deion Status: Pending_Post Atkinson, Stephanie Devlin-Gill, Mallecia Tracking No. lzr-hptp-tylf Sutton; Roel Brusselmans, Comments Due: August 12, 2024 Antoinette Walker-Smith, Submission Type: Web Mary Neely Docket: NRC-2024-0078 Comment (35)
Publication US SFR Owner, LLC; Construction Permit Application Date:6/12/2024 Citation: 89 FR 49917 Comment On: NRC-2024-0078-0006 US SFR Owner, LLC.; Kemmerer Power Station Unit 1; Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement
Document: NRC-2024-0078-DRAFT-0035 Comment on FR Doc # 2024-12810
Submitter Information
Email: sarah@uraniumwatch.org Organization: Uranium Watch
General Comment
Comments are submitted in Attached document.
Attachments
UW_DocketID_NRC-2024-0078_KemmererPSU1_Comments_081224
blob:https://www.fdms.gov/9e43b23a-7cb1-4eda-820a-fcf72c645b59 1/1 Uranium Watch
P.O. Box 1112 Moab, Utah 84532 435-26O-8384
August 12, 2023
via electronic mail https://regulations.gov Docket ID NRC-2024-0078
Of"ce of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff
RE: Public Comments: Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement. Kemmerer Power Station Unit 1.
Docket ID NRC-2024-0078. 89 Fed. Reg. 49917, 49917 - 49919; June 12, 2024.
NRC Docket No. 50-0613.
Dear Sir or Madam:
Below please "nd comments on the scope of the Environmental Impact Statement (EIS) to evaluate the environmental impacts for a Construction Permit (CP) requested by US SFR Owner, LLC, a subsidiary of TerraPower, LLC, for a proposed 840 megawatt thermal (MWt) Natrium Reactor Plant, Kemmerer Power Station Unit 1 (Kemmerer Unit 1), to be located in Lincoln County, Wyoming approximately 3 miles (4.8 km) southwest of Kemmerer, Wyoming.
Comments are submitted to the Nuclear Regulatory Commission (NRC) by Uranium Watch, a 501(c)(3) non-pro"t organization that focuses on the impacts of uranium mining and milling and other nuclear industry operations on human health and the environment.
These comments are submitted pursuant to the National Environmental Policy Act (NEPA) and NRCs conforming regulations.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 2 August 12, 2024
SCOPE OF THE EIS
- 1. Impacts The EIS should identify, describe, and evaluate the following impacts to human health and the environment from from the proposed Natrium Reactor (Reactor):
1.1. Direct impacts, indirect impacts, and cumulative impacts.
1.2. Impacts from all aspects of the proposed Natrium reactor, including construction, testing, operation, periods of non-operation, reclamation, long-term maintenance and monitoring, and decommissioning.
1.3. The EIS should describe, evaluate, and consider the impacts from the proposed Natrium reactor to land, air, water resources, wildlife, domestic animals, workers, nearby residents and communities, visual resources, economic resources, and quality of life.
1.4. The EIS must identify all adverse impacts associated with construction, testing, operation, non-operation, reclamation, long-term maintenance and monitoring, and decommissioning. The EIS must and identify, discuss, and evaluate mitigative measures for any and all adverse impacts.
1.5. The EIS should evaluate the potential impacts related to Emergency Planning or lack of Emergency Planning for the proposed Reactor. See Section 17, below.
1.6. The EIS must evaluate the impacts associated with the lack of public information related to the proposed Natrium Reactor. Many of the documents submitted to the NRC as part of the Application have information that has been redacted. Interested and affected member of the public cannot comment on any possible environmental impacts associated with the information that has been redacted. Therefore, public responses and public comments have been adversely impacted, because relevant information has been excluded from the public discourse. The effects of the limits placed on the public information available in the licensing processes has environmental impacts that should be identi"ed and examined as part of the NEPA process.
- 2. Climate and Air Quality
2.1. The EIS should identify, analyze, and consider the emissions from fugitive dust and combustion emissions from vehicle and diesel equipment during land disturbing and construction activities, including:
- Trucks, bulldozers, road graders, well drilling rigs, vehicles, and diesel NRC/Docket ID NRC-2024-0078/Docket No.50-0613 3 August 12, 2024
equipment,
- Conveyance systems,
- Truck size (options).
- Blasting.
- Clearing of land,
- Installation of above ground and underground structures, and
- . Other above ground and underground disturbances.
2.2. Dust suppressants need to be identi"ed. If water is to be used for dust suppression, the amount and sources of water needed to adequately reduce pollution needs to be identi"ed and disclosed. If other types of suppressants are proposed to be used, a full analysis of their impacts on adjacent natural areas needs to be identi"ed and analyzed, including chemical alterations to soils, runoff impacts etc. These analyses need to be included for each alternative.
2.3. The EIS should identify, describe, analyze, and consider impacts to air from radioactive and non-radioactive emissions during construction, testing, operation, non-operation, transportation, reclamation, long-term maintenance and monitoring (includes inde"nite long-term storage of used nuclear fuel at the reactor site), and decommissioning.
2.4. The EIS should identify, describe, analyze, and consider impacts from the processing, packaging, and storage of liquid and solid radioactive and hazardous waste and the evaporation of liquid wastes at the reactor site.
2.5. The EIS should identify, describe, analyze, and consider all the impacts associated with production of green-house gases and the short term and long-term impacts to the climate, ofter referred to as Climate Change, from all aspects of the proposed Reactor, including the production, transportation, storage (short-term and long-term), and temporary or permanent long-term care and maintenance of the nuclear fuel for the reactor.
- 3. Transportation
3.1. The EIS should identify, describe, analyze, and consider impacts to air quality, land, use, water quality, worker health and safety, road conditions and safety, and other impacts from:
- Transportation of nuclear fuel to and from the proposed reactor site,
- Transportation of liquid and solid radioactive and hazardous waste off-site,
- Transportation associated with construction, testing, operation, non-operation, reclamation, long-term maintenance and monitoring, and decommissioning.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 4 August 12, 2024
- Transportation of Reactor workers, inspectors, emergency planners, NRC staff, and others who may travel to and from the proposed Reactor site over time.
- 4. Noise Impacts
4.1. The EIS must describe and analyze the noise impacts of the proposed Reactor operations during during construction, testing, operation, non-operation, reclamation, long-term maintenance and monitoring, and decommissioning. This would include:
- Noise from construction and operating equipment, vehicles, soil disturbing activities, constriction, transportation, and other aspects of the Reactor operations,
- Impacts of noise to wildlife, domestic animals and livestock, local residents, local businesses, travelers, local workers, and on-site workers.
- 5. Historical and Cultural Resources Impacts
5.1. The EIS must identify, describe and evaluate historic, cultural, and archaeological resources. This should include consideration of local land use and other human activities, indigenous cultural resources, and cultural resources of religious signi"cance.
5.2 The EIS should describe and evaluate impacts to historical and cultural resources during during construction, testing, operation, non-operation, reclamation, long-term maintenance and monitoring, and decommissioning
- 6. Visual and Scenic Impacts
6.1. The EIS should describe, evaluate, and consider the visual and scenic impacts during construction, testing, operation, non-operation, reclamation, long-term maintenance and monitoring, and decommissioning. These include impacts to the night skies from any lights used during construction, testing, operation, non-operation, reclamation, long-term maintenance and monitoring, and decommissioning of the proposed Reactor.
6.2. The EIS must include a dark skies analysis and present alternatives that minimize impacts to dark skies. The nighttime environment is important as a natural and cultural resource, and naturally dark skies have inherent value that may have a profound effect on the quality of the many other natural and ecological resources, including wildlife, recreation, astronomy, cultural and historic resources, and overall ecosystem function.
Accordingly, EIS must examine the impacts of the proposed plan of operation on the area's dark sky resources.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 5 August 12, 2024
- 7. Socio-economic Impacts
7.1. The EIS should describe, analyze, and consider construction and operational impacts on residents and businesses due to noise, dust, light pollution, land clearance, vehicle and equipment traf"c, construction, nuclear fuel shipments, chemical and other shipments associated with the proposed Reactor. The EIS must consider all impacts associated with the general disruption of the local communities and their environment.
7.2. The EIS should describe, analyze, and consider:
- Construction and operation effects on local housing availability,
- Construction and operation effects on local population and use of public, and services, such as schools and hospitals,
- Fiscal and resource impacts of the project to state and local jurisdictions.
7.3. The EIS should describe, analyze, and consider the social and economic impacts to Kemmerer and other Lincoln County residents and commercial and livelihood operations and endeavors. The EIS must evaluate the impacts and signi"cance of permitted industrial disturbances and foreseen and unforeseen impacts on recreation, scenic values, wildlife, plant and animal habitats, hunting, grazing, transportation routes, noise levels, and ground and surface waterin the short and long termthat will affect the population of Lincoln County and their enterprises.
8.1. The EIS should describe, analyze, and consider impacts to the wellbeing of nearby rural communities whose businesses and livelihoods may depend on this unique landscape, availability of clean water, open lands for grazing, scenic qualities, clear night skies that are not impacted by arti"cial light, undisturbed wildlife, minimal impacts from industrial noise and activities, and other resources that will be signi"cantly adversely impacted by the proposed Reactor.
8.2. The EIS should describe, analyze, and consider impacts to the minority, Indigenous, and low-income populations in the region.
8.3. The EIS should describe, analyze, and consider impacts to the ecology of Lincoln County, including impacts to wildlife, native vegetation, "owering native plants and their abundance, birds, water resources, air quality, and other aspects of the ecological framework of the area that will be impacted by the proposed Reactor.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 6 August 12, 2024
- 9. Vegetation and Noxious Weeds
9.1. The EIS should describe, analyze, and consider:
- Impacts related to the introduction and spread of new and previously introduced non-native vegetation, including noxious weeds, as a result of the proposed operations,
- Impacts to vegetation after reclamation, and
- Impacts to vegetation that wildlife and grazing livestock may be dependent upon.
9.2. The EIS should describe, analyze, and consider impacts to native vegetation and the propagation of non-native vegetation as a result of the withdrawal of any groundwater from the aquifer and the changes to, and contamination of, the aquifer during construction, operation, reclamation, and post reclamation of the proposed Reactor.
- 10. Soils
10.1. The EIS should describe, analyze, and consider:
- Impacts to soils via disturbance, erosion, contamination, surface water (runoff) controls, changes to groundwater availability, groundwater depletion, and changes over time, and
- Net soil impacts following reclamation activities.
- 11. Land Use
11.1. The EIS should include a description of existing land use authorizations.
11.2. The EIS should describe, analyze, and consider:
- Impacts to public access to the project during and after operations,
- Impacts from power line and natural gas line re-routes, and
- Impacts to roads and highways.
- 12. Wildlife and Special Status Species
12.1. The EIS should describe, analyze, and consider impacts on speci"c wildlife habitats.
12.2. The EIS should describe, analyze, and consider the displacement of speci"c wildlife, including prairie dogs, during and after Reactor operations.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 7 August 12, 2024
- 13. Analysis of Surface Water Resources
13.1. The EIS must provide baseline information on conditions and presence of surface water potentially affected by the proposed Reactor.
13.2. The EIS must identify, describe, evaluate, and consider:
- Impacts from water "ow in intermittent or ephemeral channels,
- Impacts from re-diversion of the drainages,
- Erosion and sediment transport in project area,
- Impacts to surface water quality and water chemistry, and
- Impacts to surface water from surface water discharges, leaks, and spills.
13.3. The EIS must identify, evaluate, and consider the potential impacts to Surface Water from un-planned events associated with the Reactor operation and the long-term monitoring of the site.
- 14. Analysis of Ground Water Resources
14.1. The EIS must provide baseline information on conditions and presence of groundwater potentially affected by proposed Reactor during during construction, testing, operation, non-operation, transportation, reclamation, long-term maintenance and monitoring, and decommissioning.
14.2. The EIS should describe, analyze, and consider:
- Impacts to water availability during during construction, testing, operation, reclamation, long-term maintenance and monitoring, and decommissioning,
- Effects on ground water levels and "ow direction,
- Impacts to ground water quality and ground water chemistry, and
- The amounts and sources of water to be used.
- 15. Public and Occupational Health and Safety Impacts
15.1. The EIS should describe, analyze, and consider impacts to human health, including Reactor workers and local residents. Human health impacts include impacts from dust and emissions from vehicles and industrial equipment used in the construction, operation, periods of standby, and decommissioning phases of the Reactor operation.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 8 August 12, 2024
15.2. Human health impacts include impacts from planned and unplanned radioactive and non-radioactive emissions to the air, land, and water from the proposed Reactor and all activities associated with its development, operation, and decommissioning over time.
15.3. The EIS should describe, analyze, and consider impacts to public and to worker occupational health from industrial accidents and vehicular and equipment accidents.
- 16. Waste Management Impacts
16.1. The EIS must describe, analyze, and consider all impacts from handling, storage, transportation, and disposal of radioactive and non-radioactive operational wastes.
- 17. Emergency Response Planning
17.1. The EIS should evaluate the potential impacts related to Emergency Planning for the proposed reactor. This would include 1) involvement of local, state, and federal agencies; 2) local, state, and federal emergency planning process; 3) local, state, and federal emergency plans; 4) adequacy and impacts related to on and off-site monitoring systems; 5) placement of sirens and other emergency warning and noti"cation systems; 6) costs to local, state, and federal agencies for emergency planning and maintaining emergency response readiness; and 7) the potential impacts due to inadequate emergency response planning and the establishment of emergency planning zones that are smaller than those currently established for commercial nuclear reactors.
- 18. Monitoring
18.1. The EIS should include information on the monitoring programs established to assess on-going impacts from Reactor operations and waste disposal practices to air, land, and water during construction, testing, operation, non-operation, reclamation, long-term maintenance and monitoring, and decommissioning. These would include planned and unplanned and radiological and non-radiological emissions and continuous monitoring systems.
- 19. Financial Assurance
19.1. The EIS should describe, analyze, and consider bonding for complete decommissioning and restoration of the site, including land, air, and water. The EIS should address the requirements to ensure that companies that operated nuclear reactors suf"cient funds to close down operations, decontaminate and decommission facilities, and reclaim lands.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 9 August 12, 2024
19.2. Financial assurance includes Licensee funding for emergency response planning, establishment and maintenance of emergency response plans, and "nancial compensation in case of "nancial and other impacts associated with an unforeseen Reactor emergency.
- 20. Mitigative Measures
20.1. As part of this environmental review, the BLM must consider whether mitigation measures can protect the plant and animal species, habitats, soils, geological, cultural, dark skies, scenic values, grazing, local communities and their well-being and economic and other enterprises, and other resources affected by the proposed Natrium Reactor.
20.2. The NRC must identify speci"c mitigation measures that address each impact and include an analysis of the effectiveness of each measure in order to meet NRCs duties under the National Environmental Policy Act.
20.3. The EIS must identify those impacts that cannot be mitigated, or cannot be mitigated without access to extensive "nancial and other resources.
- 21. Referenced Documents
21.1. Any document or information referenced in the Draft EIS must be available to the public. All referenced materials must be available electronically, and a link to the document must be provided in the draft EIS.
- 22. Other Permits and Regulations
22.1. The EIS should provide detailed information regarding all local, state, and federal regulations that apply to the proposed Reactor and detailed information regarding all local, state, and federal permits, licenses, and noti"cations required for the proposed Reactor.
- 23. Federal Regulations and Requirements
23.1. The National Environmental Policy Act requires federal agencies to take seriously the potential environmental consequences of a proposed action by taking a hard look at the direct, indirect and cumulative impacts of their proposed actions.
Thank you for providing this opportunity to comment.
NRC/Docket ID NRC-2024-0078/Docket No.50-0613 10 August 12, 2024
Sincerely,
/s/
Sarah Fields Program Director Uranium Watch