ML061640114
| ML061640114 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/26/2006 |
| From: | Westlake K A Environmental Protection Agency |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 71FR9383 00014, FOIA/PA-2010-0209, NUREG-1437 | |
| Download: ML061640114 (7) | |
Text
N MaiO8?=4,1WlI UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5.77 WEST JACKSONBOULEVARD
-CHICAGO, tL 60604-3590.
a ._MAY 2`2MoBýa REPLY TO THEATTENTIONJOF-Chief, Rules Review and Directi',es Branch .U.S. Nuclear Regulatory Commission 15 Mail Stop T6-D59 %,n Washington, D.C. 20555-0001 C C-Re: Generic Environmental Impact Statement for License Renewaiia Nuclear co Plants, Supplement 27: Palisades Nuclear Plant, Van Buren County, Michiga n, Draft Report, NUREC-1437, EIS No. 20060052
Dear Sir or Madam:
In accordance with-Section
ý309 of the Clean Air Act and the National Environmental Policy Act (NEPA), the U.S. Environmental Protection Agency (EPA) has reviewed the Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 27 (SETS):, Palisades Nuclear Plant, which is a draft report. According to the SETS, the operating license for Palisades Nuclear Plant will expire on March 24, 2011. The proposed Federal action would renew the current operating license for an additional 20 years.The Nuclear Regulatory Commission (NRC) developed the Generic Environmental Impact Statement (GELS) to streamline the license renewal process on the premise that environmental impacts of most nuclear power plant license renewals are similar, in most cases. NRC develops facility-specific SEISs for individual plants as the facilities apply for license renewal. EPA provided comments on the GELS during its development process--for the draft version in 1992, and for the final version in 1996.Paltisades Nuclear Plant is locat~ed in Covert TowNvship, Van Buren County, Michigan, on the southeastern shoreline of Lake Michigan.
The plant has a single Pressurized light-water reactor.The maximum authorized power level of its reactor is 2,565 megawatts thermal. The plant's current net sumnmer capacity is 786 megawatts electric.
The plant is refueled on an 1 8-month cycle. Palisades Nuclear Plant uses a closed-loop cooling system.Based on our review of the Palisades Nuclear Plant draft SETS, we have given the project an EC-2 rating. The "EC" means that we have environmental concerns with the proposed action, and the "2" means that additional information needs to be provided in the final SEIS. Our concerns relate to: 1 .Adequacy and clarity of the information provided, , ,-'£bV*1r R ý/7 co- &F. ýa&,~ , _" ,ý6N Recycid/ecyclable
-Printed with Vegetable Oil Based Inks on 50% Recycled Paper (20% Postconsumer)
.2 2.3.4.Risk estimates,:.
.*Entrainment of fish and shellfish in. early life stages, and Threatened and endangered species.We have enclosed our comments and the U.S. EPA rating system summary.If you have any questions
'or wish to discuss. any aspect of th6 comments, please contact Newton Ellens (for NEPA-related issues) at (312) 353-5562, or. Michael Murphy (for radiation-related issues) at (312) 3 53 -6686.Sincerely, Kenneth A. Wes e, Chief NEEPA Implem nt=ation Section Office of Science, Ecosystems, and Communities Enclosures.-
U.S. Environmental Protection Agency Comments on The U.S. Nuclear Regulatory Commission's Generic Environmental Impact Statement for License Renewal of Nucleaxi Plants, Supplement 27: Palisades Nuclear.Pjt 1rf -Report,,ý.ý,ý,,.NUREGA437~-X General Comments:
.:' -.The supplement to the GenericEnvironr.'ental Jmpact Statement (GEIS) for Renewal of Nuclear Power Plant Licenses should be aý Site Specific Enironn'etntalImpact Statement instead. This would follow after forty years of operation, with a forty year data collection history, and where site specific conditions could be utilized to provide a specific response to the Environmental Impact requirements instead of a generalized one.Specific Comments: 1. Section 2.1.4.2, Gaseous Waste Processing Systems and Effluent Controls,-
Page 2-12, second paragraph.
Citations of dose values should include~the..dcse value, in addition to the citation, to make the values clearer.2. Section 2.2.7, Radiologi cal Impacts, pages 2-49, 2-50. The references to the environmental standards need to be more complete citations, including title of th 'e rule 'or regulation along with the basic standard for comparison provided consistently.
All of the environmental standards that could be used for comparison should be used, including 40 CFR 61 Radionuclide National Emission Standards for Hazardous Air Pollutants values.This will reduce the time needed to look up these citations and verifyr values that are cited in the text.3. Section 2.2.7, Radiological Impacts, page 2-49. We are concerned about the level of information provided in the draft supplemental environmental impact statement (SETS) on direct and cumulative radiological impacts. According to the draft SETS, Nuclear Management Company, LLC (NMC), the applicant for the operating license, has conducted a radiological environmental monitoring program (RENP) around the Palisades site since 1971. Through this program, NMC hass monitored and documented radiological impacts to workers, the public, and the environment.
The draft SETS states: The REMP includes monitoring of the waterborne environment (ground water, surface water, and sediments), ingestion pathways (milk, fish and vegetation), direct radiation (gamma dose at thermoluminescent dosimeter
[TLD] locations), and atmospheric environment (airborne radioiodine, particulates, gross beta, and gamma). [Page 2-49]The draft SEIS cites two annual reports which summarizes information from the RENT, but the draft SETS does not contain this summary information itself. Summarized 2 quantitative information about-radiati'on 6id exp;6surd 1 pidthwAa'yg in th-d-environment is relevant in determnining ra .di6lo gkal impacts from thie 66ntirnied operation of Palisades.
We are unable to make -such a determination from the draft- SEIS as it is written. In addition, the draft SEIS lacks a coniprehen Is ive a ssessment of cumulative radiological impacts, since it does not include quantitative information about the D.C. Cook Nuclear Plant, located about 28 -miles south.4southWest of , alisides on Lake Michigan's shores.Therefore, we suiggest' thai the fiiW-6 1S'ihchde(1D'hrtbifthnntial sunmmary information from th6'REMP' ahd- 2ah~u~fiitdtiVe ctui ilatiV'injat~t asisisstrent of radiological iinpacts which accduiits'fbt
~impacts from the D.C. Cook Nuclear Plant.4. Section 2.2.7, Radiological Impacts, pages 2-49, 2-50. Providing the estimated total~effectiv6 dosdtequi'~iints' -TsTEBjs) toiýc6nmjafi-sons'elps in-providing the public with'Asare 6id§'thitdbtesi' A-fe'AM Low* *R~tnably Achievable (ALARA) principals of the U.S. Nuclear R-eguilatory Commission (NRC).5. Section 4.2.2, ElefrdMA #4htib-Fields
-'Chrb~nitEffe!ts, page 4-17.- Wecommend NRC for providing the reference to the National Institute of Environmental Health Sciences results and recomnkntdatio'ns' otn hrbiic ex-p~fe eWble'trohiagn~tic fields. 'This will provide the public';idth valuable infotniationi on the'sb tý'pes- of cxpcsures:
-6. Section 4.8.3, Cumulative Radiological Impacft, page 4-38; 4-39. ~Information or-procedures used to generate values to support the assdtions in, this'section need to be provided in a clearer manner to reduce the possibility of misunderstandings and the reasoninig on procedure's to r'e'cfrthese'eonclUigiori.s>
- 7. Section 5.2.2, Estimate of Risk, page 5-6. It is stated that "The baseline core damage frequency (CDF) for the purpose of the SAMA [Severe Accident Mitigation Alternatives]
evaluation is approximately 4.05 x I Oc per year. This CDF is based on the risk assessment for internally-initiated events. NMC did not include the contribution to risk from external events within the Palisades risk estimates; however it did account for the potential risk reduction benefits associated with external events by increasing the estimated benefits for internal events by -a factor of two." The estimates for risks from both types of events should be evaluated and presented, along with a rationale for not basing risk decisions on the external events or including them in the considerations as necessary to get an accurate portrayal of the risk of the licensing renewal.8. Section 6. 1, The Uranium Fuel Cycle, page 6-3. Under the bullet point for Off-site-radiologial
'm'acts (indivdu'al effects from cfthtii th~ih aijp~al 'of sWent -fuel and hiýh level waste disposal), no consideration appears to be giveni to ihpotential long-term storage of the spent fuel and high-level waste materials on site until such time- as a 3 permanent facility is finally licensed and begins to accept. these materials for disposal.
A reference to other sectionis.that "hs -evaluation may have been included in should be ,provided here as well as in other sections, or if this evaluation has not been adequately conducted, the issue needs to be considered and an appropriate, evaluation conducted.
- 9. Section 6. 1, The Uranium, F04el -Ccle, page 6-8, under the bullet point for On-Site Spent Fuel., A more thorough e-,aluWa,*on l: ~the volume of spent fuel expected to be generated during the additional licensed ;tinm needs to be providedacmg,,kngith more-specific information as to site specific -circumstances that. may impair or improve the risk values for pot-.ntial exposures to this spent fuel storage.10., Section 7. 1, Le.comrnursioni;gj page 7-2, under bufl~et point .Radiation.
Doses. As the GES s asdona ory-er icnsugpýi4,apexesion of this period wouke h~ave an impact that needs to be quantified and reported.
'This information should have been included specifically in the draft SETS as part of the risk that would be associated with the license extension.
The specific methodology needs to be provided and explained.
- 11. S ecti on 8. 1, No -,Actio~n A.t W" I va, pg8-5, under the bullet point Human Health. The-actual value represerting, the cited percent. value should be specifically provided in addition to the citation.
This will reduce unnecessary additional research by readers, except for value verifications, and potential misunderstandings or confusion as to the actual value(s) being secified.12. Section 8.2. 1, Coal-Fired Generation, page 8-17, under bullet point Human.Health.
Any dose estimate that would have the potential to fall in the risk range of 10' to 10' or greater needs to be specifically evaluated for potential regulatory requirements or risk impacts to the public health. This should be estimated conservatively using the data that is currently available or that can be logically extrapolated from currently available information.
- 13. Section 8.2.3, Nuclear Power Generation, page 8-34. The changes in power production would provide a difference in potential risk to the public and needs to be specified, rather than merely referenced, to provide a clearer understanding of the risk determination in this section of the document.14. Section 8.2.3. 1, Closed -Cycle Cooling System, page 8-39, under bullet point Waste.Waste impacts need to be specified, rather than merely referenced, to provide a clearer understanding of the risk determination made in this section of the document.15. Section 8.2.3.1L.
Closed -Cycle Co9ling. System, page 8-:40, under bullet point Human Health. Human--health impaý-cts need -to-be -specified., rather than merely referienicd, to provide a clearer understanding of the risk determination in this section of the document.
4 16. Section 2.1.4. 1, Liquid Waste Processing Systems and Effluen~t'Controls, Page 2-12. The draft SEIS does not provide quantitative details about the planned modification of the liquid radioactive
'waste processing system,. The draft-SETS states thatNMC is planning to replace the current system, which: is based on evaporation, tW a system 'using- resins for ion exchange.
The draft SEIS does ri6t 'ptrvid6*
qWnttatfi~veld'iarils ab6ut the estitniaed change in col~lection efficiency between the two systems. This information should be provided in the-final -SEIS.,.*
.. ..17. Section 4. 1, Cooling- System. Oak 6 4-9. Wiý areconcerned-aboutentrainment of fish and shellfish in early life stages. Under a U.S. EPA rule, codified in 40 C.F.R. § 125 (U.S.EPA Rule), Palisades Nuclear Plant is required to reduce its entr~inment of fish and'sheilhish~in early1¶fb stagetvUi ndr thle U.S. EPARule.;
Palisades Nuclear-Plant is: required to choose one of five compliance -altemnatives-to, reduce entrainment, and, the compliancd'altemrativ'*emustfinýe~i ai regulat'b',rt
'.fornkiice standard.
We Wun derstand that Palisades will comply with the U.S. EPX 'ru1 &brugl c'onditioin"s m :a NPDES j'ermit issued by the Michigan Department of Environmental Quality., 1 ,1qowever, we b~elieve that the project proponents should have a proposedtcomplianc.-altermative and regulatory performance standard for Paligades, becailse.
the lproj'ect prolpdrientrimust.
assess. the feasibility of complying with ifie" rule. Listiri tfiis-infdrmationlwould pro'vide a'comprehensive public disclosure of plans to reduce entrainment.
Therefore, we request the project proponents to determine and disclose the proposedc.ompliance alternative.
and performance standard that would most likely be proposed in the NPDES permit application for Palisades in the final SETS.18. Section 4.6, Threatened and Endangered Species, pages 4-32 to 4-35. We are concerned because the draft SETS does not evaluate impacts on state-listed threatened and endangered species. The draft SETS includes an evaluation of federal and state-listed threatened and endangered species in the study area. However, the draft SETS only evaluates impacts to federal-listed threatened and endangered species. We believe that the final SETS should include a more comprehensive evaluation of threatened and endangered species, by including an evaluation of impacts to state-listed species.-S 4 SUMMLARY OF RATING DEFINITIONS AND FOLLOW UP ACTION*Environmental Impact of the Act!o LO-Lack of Objections
.--The EPA review has not identified any potential environmental imp4acts 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 mi~nor changes to. the p~oposal.EC-Environmenital Concen The EPA review has identified environmental impacts that should be avoided "in order :o fully protect the-environment.
Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impacts. EPA would like to work with the lead agency to reduce these impacts.EO-Envirchmentnl Obiectiont<F The EPA 'review has identifled signift--iant ehvifonxiental iinpaits thit nuist iue evoidtod ia crder.ýo,-rZ,vide'hdea~uate protection for the enviromnment Correctiv-ur-.s may require substantial changes to the preferred alternative or consideration of some other project alter- inclu'ding the no action alternative or a new alternative).
EPA intends to work with the lead agency to r hese imp'acts..
EU-Environmentally Unsatisfactcr
.The EPA review has d eutified adverzt. -x.~umi I acis that are of sufficient magnitude that they are unsatisfactory from thie tan~dpoi-:.iocpublic healthi orwelfeze or environmental quality. EPA intends to work with the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS sate, this proposal will be recommended for referral to the CEQ.Adequacy of the Impact Statement Categorv I-Adeqiuate The EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alte -rdtive and those of the alternatives reasonably available to the project or action. No further analysis or data collecting 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 the EPA to fully assess the 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 informnation, data, analyses, or discussion should be included in the final EIS.Category 3-Inadequate 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 analyses, or discussions are of such 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 Policy and Procedures for the Review of the Federal Actions Impacting the Environment