ML13238A121

Comment (4) by Kenneth A. Westlake on Scoping for Shine Medical Technologies Radioisotope Production Facility

ML13238A121
Person / Time
Site:	SHINE Medical Technologies
Issue date:	08/14/2013
From:	Westlake K A Environmental Protection Agency
To:	Bladey C K Rules, Announcements, and Directives Branch
References
78FR39343 00004
Download: ML13238A121 (4)

Text

PRIUNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 577 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590 AUG 1 4 2013-7//A91 3REPLY TO THE ATTENTION OF:E-19JCindy BladeyChief, Rules, Announcements and Directives BranchOffice of Administration Mail Ston: TWB-05-B01M

0wN,-c0'-m7,'M--C/3 --U. S. Nuclear Regulatory Commission

<Washington, D.C. 20555-0001 Re: Scoping for SHINE Medical Technologies Radioisotope Production

Facility, Janesville, Wisconsin

Dear Ms. Bladey:

The U.S. Environmental Protection Agency has received the scoping request provided by theNuclear Regulatory Commission (NRC) for the proposed SHINE Medical Technologies radioisotope production facility in Janesville, Wisconsin.

Our comments are provided pursuant tothe National Environmental Policy Act (NEPA), the Council on Environmental Quality's NEPAImplementing Regulations (40 CFR 1500-1508),

and Section 309 of the Clean Air Act.SHINE Medical Technologies (SHINE) proposes to construct,

operate, and decommission aradioisotope production facility (facility) to produce molybdenum-99, iodine- 131, and xenon-133, for use in diagnostic medical isotope procedures.

The facility is proposed at a site four milessouth of Janesville, Wisconsin on U.S. Highway 51. The proposed site is 91 acres, which iscurrently used for agriculture.

NRC, as grantor of the license, will prepare an EIS analyzing potential impacts as a result of the proposed project.EPA participated in the scoping meetings held July 17, 2013 and reviewed parts of theEnvironmental Review (ER). Based on the information, we recommend the following beaddressed in the forthcoming EIS.Waste Management 0 EPA notes that both diesel and natural gas are identified as fuel sources in the ER. Thedraft EIS should include why two sources are necessary.

Further, we recommend SHINEconsider the use of renewable energy sources either in lieu of or to supplement theSUNSI Review CompleteTemplate

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proposed diesel and natural gas sources.

If SHINE or NRC dismisses the use ofalternative energy sources, the draft E.IS :should state why.* The Draft EIS should describe how the facility will comply with Underground StorageTanks (UST) regulations under the Resource Conservation and Recovery Act (RCRA)for underground storage of fuel.* The Draft EIS should include a "for official government use" document that providesdetails of proprietary information that is otherwise withheld from public disclosure, suchas the details on "Waste generated by the target vessel solution cleanup process"described in Section 19.2.5.1.1 of the ER and information on the other waste streams.* The Draft EIS should describe the disposal facility options available in the event that ananticipated disposal or storage facility is no longer available.

Waste stream and disposalfacility availability should be reviewed on an annual basis to confirm knowledge of thewaste streams relative to the disposal options available and to avoid a situation ofaccumulating waste without a disposal path. The availability of options for each solidand liquid waste stream should also be discussed.

" Section 19.2.5.3.1 (Solid Radioactive Waste Handling System) discusses the generation and management of a used resin classified as Greater than Class C (GTCC) waste thatwould be shipped to Waste Control Specialists (WCS) of Texas for long-term storage.The Draft EIS should acknowledge that currently there is not a permanent disposaloption available for commercially-generated GTCC waste, hence the need for long-term storage at WCS. The Draft EIS should evaluated whether it is possible to modify thesystem so that the used resin is generated as either Class A, B, or C low-level radioactive waste, which currently have available disposal options.* The Draft EIS should provide information on the radionuclide inventory anticipated at thesite during typical operations, with information on what would be considered processmaterial, waste material temporarily stored on site for eventual off-site transport anddisposal, or other site-specific material/product/waste designations.

Radionuclide inventory limits under the NRC license should also be described.

Air Oualitv* The draft EIS should describe how diesel emissions will be minimized throughout construction and decommissioning of the facility.

EPA suggests the following dieselemission reduction techniques be employed to further minimize impacts:o Using low-sulfur diesel fuel (15 parts per million sulfur maximum) inconstruction vehicles and equipment.

o Retrofitting engines with an exhaust filtration device to capture diesel particulate matter before it enters the construction site.o Positioning the exhaust pipe so that diesel fumes are directed away from theoperator and nearby workers, thereby reducing the fume concentration to whichpersonnel are exposed.

o Using catalytic converters to reduce carbon monoxide, aldehydes, andhydrocarbons in diesel fumes. These devices must be used with low sulfur fuels.o Ventilating wherever diesel equipment operates indoors at the Meredosia andinjection well sites. Roof vents, open doors and windows, roof fans, or othermechanical systems help move fresh air through work areas. As buildings underconstruction are gradually

enclosed, remember that fumes from diesel equipment operating indoors can build up to dangerous levels without adequate ventilation o Attaching a hose to the tailpipe of diesel vehicles running indoors and exhaust thefumes outside, where they cannot re-enter the workplace.

Inspect hoses regularly for defects and damage.o Using enclosed, climate-controlled cabs pressurized and equipped with highefficiency particulate air (HEPA) filters to reduce the operators' exposure to'diesel fumes. Pressurization ensures that air moves from inside to outside.

HEPAfilters ensure that any incoming air is filtered first.o Regularly maintaining diesel engines, which is essential to keep exhaustemissions low. Follow the manufacturer's recommended maintenance scheduleand procedures.

Smoke color can signal the need for maintenance.

For example,blue/black smoke indicates that an engine requires servicing or tuning.o Reducing exposure through work practices and training, such as turning offengines when vehicles are stopped for more than a few minutes, training diesel-equipment operators to perform routine inspection, and maintaining filtration devices.o Purchasing new vehicles that are equipped with the most advanced emissioncontrol systems available.

o Using electric starting aids such as block heaters with older vehicles to warm theengine reduces diesel emissions.

o Using respirators, which are only an interim measure to control exposure to dieselemissions.

In most cases, an N95 respirator is adequate.

Workers must be trainedand fit-tested before they wear respirators.

Depending on work being conducted, and if oil is present, concentrations of particulates present will determine theefficiency and type of mask and respirator.

Personnel familiar with the selection, care, and use of respirators must perform the fit testing.

Respirators must bear aNational Institute of Occupational Safety and Health (NIOSH) approval number.Never use paper masks or surgical masks without NIOSH approval numbers.Indirect and Cumulative ImpactsThe Draft EIS should identify any traffic management or infrastructure improvements toUS Highway 51 that will be required to handle increased capacity of truck and employeetraffic.

Any improvements and resultant impacts should be considered connected actions.

The Draft EIS should indicate whether SHINE intends to use the adjacent SouthernWisconsin Regional Airport as a means of shipping and receiving materials.

If yes, anyimprovements to the airport should be disclosed and considered connected actions.Emergency Response* The Draft EIS should discuss facility and system features to ensure safety and minimizeoff-site releases in the event of an accident or other unanticipated event.Thank you in advance for your consideration of our comments.

We appreciate early involvement in the process and look forward to reviewing the Draft EIS. Please feel free to contact me orElizabeth Poole of my staff at (312) 353-2087 or poole.elizabeth@epa.gov with any questions.

Sincerely, Kenneth A. Wes akeChief. NEPA Implementation SectionOffice of Enforcement and Compliance Assurance cc: Michelle Moser, U.S. Nuclear Regulatory Commission