ML16007A008

Comment (12) of Kenneth A. Westlake on Behalf of Us Environmental Protection Agency on Draft Plant-Specific Supplement 55 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Fermi 2 Nuclear Power Pl

ML16007A008
Person / Time
Site:
Issue date:	12/21/2015
From:	Westlake K A Environmental Protection Agency
To:	Bladey C K Rules, Announcements, and Directives Branch
References
80FR68881 00012, E-19J, NRC-15-0100, NRC-2014-0109
Download: ML16007A008 (3)

Text

oUNITED STATEs ENVIRONMENTAL PROTECTION AGENCYoREGON5WEST JACKSON BOULEVARD 4, <R9> CHICAGO, IL 60604-3590 lii E .2 015! :2 .... .- .

TO THE ATTENTION OF:~E-19JCindy Bladey@Chief, Rules, Announcements, and Directives BranchDivision of Administrative Services.

Office of Administration Mail Stop: 16 3WFN-06-A44MiP U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Draft Plant-Specific Supplement 55 to the Generic Environmental ImpactStatement for License Renewal of Nuclear Plants Regarding Fermi 2 Nuclear PowerPlant, Monroe County, Michigan

-CEQ #20150313

Dear Ms. Bladey:

..,.., ..:. ...The U.S. Environmental Protection Agency has reviewed the Draft Supplemental Environmental Impact Statement (EIS) for the above-mentioned project prepared by the Nuclear Regulatory Commission (NRC). Our comments are provided pursuant to the National Environmental PolicyAct (NEPA), the Council on Environmental Quality's NEPA Implementing Regulations (40 CFR1500-1508),

and Section 309 of the Clean Air Act.Fermi 2 is a single-unit boiling water reactor located in Frenchtown

Township, Michigan.

Itbegan commercial operation in July 1985; the license expires in 2025. Fermi 2 sits on 1,260acres on the western shores of Lake Erie. The site also includes the permanently-shut-down Fermi 1 unit, auxiliary and support facilities, and part of the Detroit River International WildlifeRefuge. DTE Electric Company (the applicant) applied to the NRC to extend Fermi 2's operating license for an additional 20 years. No refurbishment activities associated with license renewal areproposed..NRC's preferred alternative is to grant the license renewal.The NRC-developed a Generic EIS to streamnline the license renewal process based on thepremise that environmental impacts of most nuclear power plant license renewals are similar.NRC develops facility-specific Supplemental

.EIS .documents as facilities apply for licenserenewal.

EPA ackniowledges that mi'tigation measures that are un-related to nuclear safety andsecurity cannot be included in the NRC license.

However, because we find the.se measures tofurther reduce environmental

impacts, we continue to recommend NRC share and promote such _O/Recycled/Recyclable ePrinted with Vegetable Ol ased Inkson100%

Recycled Paper(100%

Pot-Consumer) '

recommendations and measures with the applicant.

We encourage the applicant to incorporate mitigation measures into the project, wherever possible.

Based on our review of the Draft Supplemental EIS, EPA recommends a rating ofEnvironmental Concerns

-Adequate Information (EC-1). This is based, primarily, oncumulative impacts to Lake Erie water quality.

We also recommend several clarifications toimprove the quality of the document.

We have the following comments and recommendations onthe Draft Supplemental EIS.Cumulative Impacts -Aquatic Resources EPA is generally concerned about increasing intensity of algal blooms in Lake Erie. Weappreciate the disc ussion thr.oughout the docum.ent about thelinkages' among and potential

_-impacts to algal blooms, climate change, and water temperature as a result of continued discharge from Fermi 2. We acknowledge that the National Pollution Discharge Elimination System (NPDES) permit for Fermi 2's primary outfall (Outfall 001) does not include numerical temperature or nutrient limits. NRC concludes the cumulative impact to aquatic resources fromall Stressors, including Fermi 2, is LARGE. While Fermi 2 is not solely responsible for algalbloom issues in the western Lake Erie basin, EPA believes that all contributors should continueto monitor and adaptively manage their discharges in order to reduce environmental impacts,particularly as water temperature continues to' increase from climate change.Recommendation:

EPA recommends NRC and the applicant commit to ongoingmonitoring of algal blooms in the vicinity of the Fermi NPDES ouffalls.

We recommend the applicant take reasonable steps to further reduce the temperature of discharge as ameans of mitigating contributions to algal blooms in the western basin of Lake Erie.Cumulative Impacts -GeneralEPA notes the discussion of the proposed and licensed Fermi 3 on the existing Fermi sitethroughout 4.16 (Cumulative Impacts).

However, Fermi 3 was not included in Table P-i (Actionsand Projects Considered in Cumulative Analysis) found in Appendix E. Some subsections of thecumulative impacts analysis explicitly include Fermi 3, while others do not. The DraftSupplemental EIS is unclear if the cumulative impacts analysis included impacts from Fermi 3for all categories of impacts.Recommendation:

The Final Supplemental EIS should be revised to adequately accountfor Fermi 3 in the cumulative impacts analysis, as appropriate, or explain why inclusion of Fermi 3 is not warranted.

Terrestrial EcologyPortions of the Fermi site are part of the Detroit River International Wildlife Refuge, managed bythe U.S. Fish and Wildlife Service.

EPA commends the applicant's efforts to maintain itsWildlife Management Plan and Wildlife Habitat Council Certification.

As describes in Section2 4.6 (Terrestrial Resources),

these efforts includes biannual qualitative prairie vegetation surveysand periodic wildlife

surveys, and adherence to their own Environmental Monitoring ConductManual.Editorial EPA appreciates the colors maps provided in the document.

We recognize the added costs, butfind color maps, where appropriate, improve the readability of the document.

The document appears to have a printing error, in which page 4-35 is located between pages 4-39and 4-40.EPA continues to recommend clearer distinctions between NRC assigned categories of impacts(SMALL, MODERATE, andLARGE)....

.........

... We have reviewed the' discuissioni on age 1-23 and ...appli~cable sections of the Generic EIS regarding levels of significance.

However, we continue torecommend more information be provided in the site-specific analyses to describe the difference among levels, particularly when a range is provided.

For instance, EPA finds the discussion ofcumulative impacts to terrestrial ecology from climate change to have appropriate and cleardemarcations between MODERATE and LARGE; we recommend taking this approach to othercategories.'

Thank you for the opportunity to comment on this. document.

-If you have any questions or wishto discuss any aspect of this document, please contact Elizabeth Poole of my staff at 3 12-353-2087 or poole.el.izabeth~epa.gov.

Sincerely, Kenneth A.* Westlake/,

Chief, NEPA lmp lementing Sectionoffice of Enforcement and Compliance Assurance Enclosure (1): Summary of RatingsCc: Elaine Keegan, U.S. Nuclear Regulatory Commission 3

oUNITED STATEs ENVIRONMENTAL PROTECTION AGENCYoREGON5WEST JACKSON BOULEVARD 4, <R9> CHICAGO, IL 60604-3590 lii E .2 015! :2 .... .- .

TO THE ATTENTION OF:~E-19JCindy Bladey@Chief, Rules, Announcements, and Directives BranchDivision of Administrative Services.

Office of Administration Mail Stop: 16 3WFN-06-A44MiP U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Draft Plant-Specific Supplement 55 to the Generic Environmental ImpactStatement for License Renewal of Nuclear Plants Regarding Fermi 2 Nuclear PowerPlant, Monroe County, Michigan

-CEQ #20150313

Dear Ms. Bladey:

..,.., ..:. ...The U.S. Environmental Protection Agency has reviewed the Draft Supplemental Environmental Impact Statement (EIS) for the above-mentioned project prepared by the Nuclear Regulatory Commission (NRC). Our comments are provided pursuant to the National Environmental PolicyAct (NEPA), the Council on Environmental Quality's NEPA Implementing Regulations (40 CFR1500-1508),

and Section 309 of the Clean Air Act.Fermi 2 is a single-unit boiling water reactor located in Frenchtown

Township, Michigan.

Itbegan commercial operation in July 1985; the license expires in 2025. Fermi 2 sits on 1,260acres on the western shores of Lake Erie. The site also includes the permanently-shut-down Fermi 1 unit, auxiliary and support facilities, and part of the Detroit River International WildlifeRefuge. DTE Electric Company (the applicant) applied to the NRC to extend Fermi 2's operating license for an additional 20 years. No refurbishment activities associated with license renewal areproposed..NRC's preferred alternative is to grant the license renewal.The NRC-developed a Generic EIS to streamnline the license renewal process based on thepremise that environmental impacts of most nuclear power plant license renewals are similar.NRC develops facility-specific Supplemental

.EIS .documents as facilities apply for licenserenewal.

EPA ackniowledges that mi'tigation measures that are un-related to nuclear safety andsecurity cannot be included in the NRC license.

However, because we find the.se measures tofurther reduce environmental

impacts, we continue to recommend NRC share and promote such _O/Recycled/Recyclable ePrinted with Vegetable Ol ased Inkson100%

Recycled Paper(100%

Pot-Consumer) '

recommendations and measures with the applicant.

We encourage the applicant to incorporate mitigation measures into the project, wherever possible.

Based on our review of the Draft Supplemental EIS, EPA recommends a rating ofEnvironmental Concerns

-Adequate Information (EC-1). This is based, primarily, oncumulative impacts to Lake Erie water quality.

We also recommend several clarifications toimprove the quality of the document.

We have the following comments and recommendations onthe Draft Supplemental EIS.Cumulative Impacts -Aquatic Resources EPA is generally concerned about increasing intensity of algal blooms in Lake Erie. Weappreciate the disc ussion thr.oughout the docum.ent about thelinkages' among and potential

_-impacts to algal blooms, climate change, and water temperature as a result of continued discharge from Fermi 2. We acknowledge that the National Pollution Discharge Elimination System (NPDES) permit for Fermi 2's primary outfall (Outfall 001) does not include numerical temperature or nutrient limits. NRC concludes the cumulative impact to aquatic resources fromall Stressors, including Fermi 2, is LARGE. While Fermi 2 is not solely responsible for algalbloom issues in the western Lake Erie basin, EPA believes that all contributors should continueto monitor and adaptively manage their discharges in order to reduce environmental impacts,particularly as water temperature continues to' increase from climate change.Recommendation:

EPA recommends NRC and the applicant commit to ongoingmonitoring of algal blooms in the vicinity of the Fermi NPDES ouffalls.

We recommend the applicant take reasonable steps to further reduce the temperature of discharge as ameans of mitigating contributions to algal blooms in the western basin of Lake Erie.Cumulative Impacts -GeneralEPA notes the discussion of the proposed and licensed Fermi 3 on the existing Fermi sitethroughout 4.16 (Cumulative Impacts).

However, Fermi 3 was not included in Table P-i (Actionsand Projects Considered in Cumulative Analysis) found in Appendix E. Some subsections of thecumulative impacts analysis explicitly include Fermi 3, while others do not. The DraftSupplemental EIS is unclear if the cumulative impacts analysis included impacts from Fermi 3for all categories of impacts.Recommendation:

The Final Supplemental EIS should be revised to adequately accountfor Fermi 3 in the cumulative impacts analysis, as appropriate, or explain why inclusion of Fermi 3 is not warranted.

Terrestrial EcologyPortions of the Fermi site are part of the Detroit River International Wildlife Refuge, managed bythe U.S. Fish and Wildlife Service.

EPA commends the applicant's efforts to maintain itsWildlife Management Plan and Wildlife Habitat Council Certification.

As describes in Section2 4.6 (Terrestrial Resources),

these efforts includes biannual qualitative prairie vegetation surveysand periodic wildlife

surveys, and adherence to their own Environmental Monitoring ConductManual.Editorial EPA appreciates the colors maps provided in the document.

We recognize the added costs, butfind color maps, where appropriate, improve the readability of the document.

The document appears to have a printing error, in which page 4-35 is located between pages 4-39and 4-40.EPA continues to recommend clearer distinctions between NRC assigned categories of impacts(SMALL, MODERATE, andLARGE)....

.........

... We have reviewed the' discuissioni on age 1-23 and ...appli~cable sections of the Generic EIS regarding levels of significance.

However, we continue torecommend more information be provided in the site-specific analyses to describe the difference among levels, particularly when a range is provided.

For instance, EPA finds the discussion ofcumulative impacts to terrestrial ecology from climate change to have appropriate and cleardemarcations between MODERATE and LARGE; we recommend taking this approach to othercategories.'

Thank you for the opportunity to comment on this. document.

-If you have any questions or wishto discuss any aspect of this document, please contact Elizabeth Poole of my staff at 3 12-353-2087 or poole.el.izabeth~epa.gov.

Sincerely, Kenneth A.* Westlake/,

Chief, NEPA lmp lementing Sectionoffice of Enforcement and Compliance Assurance Enclosure (1): Summary of RatingsCc: Elaine Keegan, U.S. Nuclear Regulatory Commission 3