NRC-2008-0672, Comment (21) of Judy-Ann Mitchell on Behalf of the Us Environmental Protection Agency, Region 2, on Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Supplement 38 Regarding Indian Point Nuclear Generating U: Difference between revisions

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#REDIRECT [[NRC-2008-0672, Comment (6) of Deborah Brancato on NRCs Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 38, Vol. 4, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3]]
| number = ML16082A272
| issue date = 03/04/2016
| title = Comment (21) of Judy-Ann Mitchell on Behalf of the Us Environmental Protection Agency, Region 2, on Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Supplement 38 Regarding Indian Point Nuclear Generating Unit N
| author name = Mitchell J
| author affiliation = US Environmental Protection Agency (EPA)
| addressee name = Bladey C
| addressee affiliation = NRC/ADM/DAS/RADB
| docket = 05000247, 05000286
| license number =
| contact person =
| case reference number = 80FR81377 00021, NRC-2008-0672
| document type = General FR Notice Comment Letter type:NRC
| page count = 4
| project =
| stage = Supplement
}}
 
=Text=
{{#Wiki_filter:. ' '
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEW YORK, NY 10007-1866 MAR 0 4 2016 Cindy Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration Mail Stop: OWFN-12-H08 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
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RE: Docket ID NRC-2008-0672; Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Supplement 38 Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3
-Draft Report for Comment (NUREG-1437, Supplement 38, Volume 5) - Rating EC-2
 
==Dear Ms. Bladey:==
In accordance with Section 309 of the Clean Air Act and t11:e National Environmental Policy Act (NEPA); the U.S. Environmental Pr6tectfon Agency has reviewed the Nuclear Regulatory*
Comin.issi'on's (NRC) Draft Secdnd Supplement(CEQ#20150364), to the final*supplemental * :
envitonmental impact statement (EIS) for the. proposed*rehewal of the operating licenses for.the Indian Point NuClear "Generating Units Nos: 2 and 3 (IP2 and IP3). The Indian Point "Energy
* Center (IPEC) is located in Westchester Couhty*in the* Village:of Buchanan, New York, approximately 24 miles north 'of New York City;' '* :. *. /~ :.. ~ * :.. 1 This* supple~ent includes.the NRC staffs *evaluation of revised engineering project. cost li:lfotination for several accident mitigation alternatives; ;newly available aquatic impact illformation; the.additional environmental issues associated with license renewal resulting from the June 2013 revision to Table B-1 in Appendix B to Subpart A of Title 10 of the Code of Federal Regulations Part 51 and NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants; and incorporates the impact determinations ofNUREG-2157, Generic Environmental Impact Statement of Continued Storage of Spent Nuclear Fuel, in accordance with the requirements in 10 DFR 51.23(b). Additionally, the supplement describes the re-initiation of consultatiOri under Section 7 cif'the Endangered-Species Act regarding the nbrthem long-eared bat (Myotis' septenirionalis).
* iri June 2013,*the NRC revised its regulations regarding which environmental issues associated with license renewal are comrtlon td all plants and therefore* should be* analyzed in the* Generic Eis and which should be 'analyzed in the(plant:.::specific EISs. '~Radionuclides r~leased to groUndwater" was added to the issues iderttified as "tho"se that do not lend themselves to* generic, consiCleraiion, and*therefore is-*diS'cussed*in this Draft Second *Supplement. While information is
*P:_rovided on this' issue iri the* document, EPA lias become aware* of another tritium leak in the I
~
*~
 
vicinity of the IP2 fuel handling* building through data collected froni the inonitbring wells on the Indian Point' site. As of this writing; the exact *source of this* 1e8.k has riot been* determined. The
* facts that EPA has received indicate this 'leak was *discovered pursuant to the NuClear Energy Institute's (NEI) 07-07 guidance and the licensee's reporting thereof. Since NEI-07-07 guidance is being applied to the IPEC and used to assure that any release of radiom.iclides to the *. * '*
groundwater is discovered, reported, assessed and evaluated, EPA recommends that a more comprehensive discussion ofNEI-07-07 and its application by the licensee be addressed in this second supplemental EIS to ensure the public is well informed especially given the re*cent operational difficulties at the facility.
EPA is aware that on February 29, 2016 the New York State Homeland Security and Emergency Services {{letter dated|date=February 29, 2016|text=letter dated February 29, 2016}} to the Secretary of the Federal Energy Regulatory Commission about a State investigation on the operational problems at IPEC and an independent safety risk analysis of Spectra Energy's Algonquin Incremental Market (AIM) project proximity to IPEC that the State agencies have been directed to undertake by the Governor. That information should be reviewed.
The facility's choice of a Ristroph screen and fish return was independently reviewed by federal and state agencies and determined to be a compliant intake structure pursuant to 316[b].
Regarding Section 4.0 of the Supplemental EIS that discusses new information for entrainment and impingement effects: Section 3 l 6(b) of the Clean Water Act requires that facilities with cooling water intake structures ensure that the location, design, construction, and capacity of the structures reflect the best technology available to minimize harmful impacts on the environment, specifically all stages of aquatic life, including early stages.
According to federal regulations at 40 CFR § 125.92, early stages offish species, including eggs and larvae, must be included in the analysis of any potential impacts from the cooling water intake structure or thermal discharge from units IP2 and IP3. As you know, neither the continued operation of Units IP2 and IP3, nor the NRC license renewal for these units can result in impairment of the designated use of the Hudson River due to impacts on aquatic life, particularly for threatened or endangered species.
In addition, Section 5.14.12 compares total expected greenhouse gas emissions with projected-state, U.S. and global greenhouse gas emissions. EPA does not recommend comparing project-level greenhouse gas emissions to total emissions in this way, as the comparison is not meaningful for decision makers. Climate change is a global problem resulting from the emissions of many individual sources that generate a large cumulative impact. These environmental impacts are best considered by using emissions as a proxy when comparing the proposal, alternatives and potential mitigation. EPA would also recommend adaptation and mitigation plans for any water level rise issues, particularly the storage of nuclear waste in casks on site.
 
EPA is rating this.second. supplement EC-2 (Environme.ntal Concerns Information).; Thank you for the opportunity to comment.... If you have ap.y questions,* please call.Lingard Knutson, Environmental Scientist at (412) 637-3747 or.Knutson.Jingard@epa.gov.
',' ~ I Sincerely yours, a~~-1tlizti#
~;:2n Mitchell, Chief Sustainability and Multimedia Programs Branch Enclosure
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==SUMMARY==
OF RATING DEFINITIONS AND FOLLOW-UP ACTION Environmental Impact of the Action LO-Lack of Objections The EPA review has not identified any potential environmental impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation measures that could be accomplished with no more than minor changes to the proposal.
EC-Environmental Concerns The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact. EPA would lik~ to work with the lead agency to reduce these impacts.
EO-Environmental Objections The EPA review has identified significant environmental impacts that must be avoided to provide adequate protection for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration of some other project alternative (including the no action alternative or a new alternative). EPA intends to work with the lead agency to reduce these impacts.
EU-Environmentally Unsatisfactory.
The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory from the standpoint of environmental quality, public health or welfare. EPA intends to work with the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS stage, this proposal will be recommend for referral to the Council on Environmental Quality (CEQ).
Adequacy of the Impact Statement Category I-Adequate EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition of clarifying language or information.
Category 2-Insufficient Information The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action. The identified additional information, data, analyses, or discussion should be included in the fmal EIS.
Category 3-Inadeguate EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analyzed in the draft EIS, which should be analyzed in order to reduce the potentially significant environmental impacts. EPA believes that the identified additional information, data, analysis, or discussions are of s,uch a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 309 review, and thus should be formally revised and made available for public comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal could be a candidate for referral to the CEQ.
*From: EPA Manual 1640, ttolicy and Procedures for the Review of Federal Actions Impacting the Environment.U
 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEW YORK, NY 10007-1866 MAR 0 4 2016 Cindy Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration Mail Stop: OWFN-12-H08 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
;oft,/ 6l-r P,/6~
~JJ?/0?lc3~7 C")
,.T.1 Vi
~
RE: Docket ID NRC-2008-0672; Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Supplement 38 Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3  
-Draft Report for Comment (NUREG-1437, Supplement 38, Volume 5) - Rating EC-2
 
==Dear Ms. Bladey:==
In accordance with Section 309 of the Clean Air Act and t11:e National Environmental Policy Act (NEPA); the U.S. Environmental Pr6tectfon Agency has reviewed the Nuclear Regulatory*
Comin.issi'on's (NRC) Draft Secdnd Supplement(CEQ#20150364), to the final*supplemental * :
envitonmental impact statement (EIS) for the. proposed*rehewal of the operating licenses for.the Indian Point NuClear "Generating Units Nos: 2 and 3 (IP2 and IP3). The Indian Point "Energy
* Center (IPEC) is located in Westchester Couhty*in the* Village:of Buchanan, New York, approximately 24 miles north 'of New York City;' '* :. *. /~ :.. ~ * :.. 1 This* supple~ent includes.the NRC staffs *evaluation of revised engineering project. cost li:lfotination for several accident mitigation alternatives; ;newly available aquatic impact illformation; the.additional environmental issues associated with license renewal resulting from the June 2013 revision to Table B-1 in Appendix B to Subpart A of Title 10 of the Code of Federal Regulations Part 51 and NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants; and incorporates the impact determinations ofNUREG-2157, Generic Environmental Impact Statement of Continued Storage of Spent Nuclear Fuel, in accordance with the requirements in 10 DFR 51.23(b). Additionally, the supplement describes the re-initiation of consultatiOri under Section 7 cif'the Endangered-Species Act regarding the nbrthem long-eared bat (Myotis' septenirionalis).
* iri June 2013,*the NRC revised its regulations regarding which environmental issues associated with license renewal are comrtlon td all plants and therefore* should be* analyzed in the* Generic Eis and which should be 'analyzed in the(plant:.::specific EISs. '~Radionuclides r~leased to groUndwater" was added to the issues iderttified as "tho"se that do not lend themselves to* generic, consiCleraiion, and*therefore is-*diS'cussed*in this Draft Second *Supplement. While information is
*P:_rovided on this' issue iri the* document, EPA lias become aware* of another tritium leak in the I
~
*~
 
vicinity of the IP2 fuel handling* building through data collected froni the inonitbring wells on the Indian Point' site. As of this writing; the exact *source of this* 1e8.k has riot been* determined. The
* facts that EPA has received indicate this 'leak was *discovered pursuant to the NuClear Energy Institute's (NEI) 07-07 guidance and the licensee's reporting thereof. Since NEI-07-07 guidance is being applied to the IPEC and used to assure that any release of radiom.iclides to the *. * '*
groundwater is discovered, reported, assessed and evaluated, EPA recommends that a more comprehensive discussion ofNEI-07-07 and its application by the licensee be addressed in this second supplemental EIS to ensure the public is well informed especially given the re*cent operational difficulties at the facility.
EPA is aware that on February 29, 2016 the New York State Homeland Security and Emergency Services {{letter dated|date=February 29, 2016|text=letter dated February 29, 2016}} to the Secretary of the Federal Energy Regulatory Commission about a State investigation on the operational problems at IPEC and an independent safety risk analysis of Spectra Energy's Algonquin Incremental Market (AIM) project proximity to IPEC that the State agencies have been directed to undertake by the Governor. That information should be reviewed.
The facility's choice of a Ristroph screen and fish return was independently reviewed by federal and state agencies and determined to be a compliant intake structure pursuant to 316[b].
Regarding Section 4.0 of the Supplemental EIS that discusses new information for entrainment and impingement effects: Section 3 l 6(b) of the Clean Water Act requires that facilities with cooling water intake structures ensure that the location, design, construction, and capacity of the structures reflect the best technology available to minimize harmful impacts on the environment, specifically all stages of aquatic life, including early stages.
According to federal regulations at 40 CFR § 125.92, early stages offish species, including eggs and larvae, must be included in the analysis of any potential impacts from the cooling water intake structure or thermal discharge from units IP2 and IP3. As you know, neither the continued operation of Units IP2 and IP3, nor the NRC license renewal for these units can result in impairment of the designated use of the Hudson River due to impacts on aquatic life, particularly for threatened or endangered species.
In addition, Section 5.14.12 compares total expected greenhouse gas emissions with projected-state, U.S. and global greenhouse gas emissions. EPA does not recommend comparing project-level greenhouse gas emissions to total emissions in this way, as the comparison is not meaningful for decision makers. Climate change is a global problem resulting from the emissions of many individual sources that generate a large cumulative impact. These environmental impacts are best considered by using emissions as a proxy when comparing the proposal, alternatives and potential mitigation. EPA would also recommend adaptation and mitigation plans for any water level rise issues, particularly the storage of nuclear waste in casks on site.
 
EPA is rating this.second. supplement EC-2 (Environme.ntal Concerns Information).; Thank you for the opportunity to comment.... If you have ap.y questions,* please call.Lingard Knutson, Environmental Scientist at (412) 637-3747 or.Knutson.Jingard@epa.gov.
',' ~ I Sincerely yours, a~~-1tlizti#
~;:2n Mitchell, Chief Sustainability and Multimedia Programs Branch Enclosure
: 1.
r: **'
: '.1*.
. t,
,'>.i**:,*
.. *..,)
}
..'..... -. ;. ;. ; ~ *.. :. :'
. -~'
~ -~.. *.
 
==SUMMARY==
OF RATING DEFINITIONS AND FOLLOW-UP ACTION Environmental Impact of the Action LO-Lack of Objections The EPA review has not identified any potential environmental impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation measures that could be accomplished with no more than minor changes to the proposal.
EC-Environmental Concerns The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact. EPA would lik~ to work with the lead agency to reduce these impacts.
EO-Environmental Objections The EPA review has identified significant environmental impacts that must be avoided to provide adequate protection for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration of some other project alternative (including the no action alternative or a new alternative). EPA intends to work with the lead agency to reduce these impacts.
EU-Environmentally Unsatisfactory.
The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory from the standpoint of environmental quality, public health or welfare. EPA intends to work with the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS stage, this proposal will be recommend for referral to the Council on Environmental Quality (CEQ).
Adequacy of the Impact Statement Category I-Adequate EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition of clarifying language or information.
Category 2-Insufficient Information The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action. The identified additional information, data, analyses, or discussion should be included in the fmal EIS.
Category 3-Inadeguate EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analyzed in the draft EIS, which should be analyzed in order to reduce the potentially significant environmental impacts. EPA believes that the identified additional information, data, analysis, or discussions are of s,uch a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 309 review, and thus should be formally revised and made available for public comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal could be a candidate for referral to the CEQ.
*From: EPA Manual 1640, ttolicy and Procedures for the Review of Federal Actions Impacting the Environment.U}}

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