ML15189A069
| ML15189A069 | |
| Person / Time | |
|---|---|
| Site: | SHINE Medical Technologies |
| Issue date: | 07/02/2015 |
| From: | Bub L State of WI, Dept of Natural Resources |
| To: | Cindy Bladey Rules, Announcements, and Directives Branch |
| References | |
| 80FR27710 00005, NRC-2013-0053 | |
| Download: ML15189A069 (3) | |
Text
7/2/20157//25N R C-2013- 0053- DRAFT- 001 1.htmlAs of: 7/2/15 3:27 PMRecepived:
Jlyl 09 2O1SPUBLIC SUBMISSION Status: PendingPost Tracking No. ljz-8jr6-xzv6 Comments Due: July 06, 201Submission Type: WebDocket: NRC-2013-0053 SHINE Medical Technologies, Inc.Comment On: NRC-2013-0053-0016 Construction Permit Application for the SHINE Medical Radioisotope Production Facility; DraftEnvironmental Impact Statement.
.5Douet R-01305-RF-01 377Submitter Information Name: Laura BubAddress:3911 Fish Hatchery RoadFitchburg, WI, 53590Email: laura. bub@wisconsin, govGovernment Agency Type: StateGovernment Agency: Wisconsin Department of Natural Resources
_-1L1I-- J.1!(--3qGeneral CommentSee attached file(s)Attachments SHINE dEISDNRComments.doc SUNSI Review CompleteTemplate
= ADM -013E-RIDS- ADM -03 Q~r r'Add= --m:file:l/C
- /U sers/C AG/D ownl oads/N R C-2013- 0053- DRAFT- 0011I .html Il1/1 S~tate of Wisconsin ATATA -~DEPARTMENT OF NATURAL RESOURCES Scott Walker, Governor3911 Fish Hatchery Road Cathy Stepp, SecretaryIL U A IFitchburg WI 53711-5397 Tlpoe682622 Toll Free 1 -888-936-7463 TTY Access via relay -711 O AUA EOREJuly 2, 2015Ms. Cindy BladeyOffice of Administration Mail Stop OWFN-12 H08U.S. Nuclear Regulatory Commission Washington D.C. 20555-000 1
Subject:
Docket ID NR-20 13-0053, WDNR Comments for the draft Environmental Impact Statement for SHINEMedical Technologies Radioisotope Production Facility
Dear Ms. Bladey:
Thank you for the opportunity to provide comments related to the U.S. Nuclear Regulator Commissions' (NRC)draft Environmental Impact Statement (dEIS) regarding the construction permit submitted by SHINE MedicalTechnologies, Inc (SHINE) for the proposed SHINE Medical Radioisotope Production Facility in Janesville, Wisconsin.
SHINE submitted the application for a construction permit to the NRC on March 26, 2013. Thisfacility would produce radioisotopes for use in diagnostic medical isotope procedures.
SHINE Proposes to construct and operate a radioisotope production facility to produce molybdenum-99 (Mo-99),iodine- 131 (1- 131t) and xenon- 133 (Xe- 133). The proposed facility would cover approximately 91 acres andwould include open space, a production facility
- building, a support facility
- building, a waste staging and shippingbuilding, a diesel generator
- building, an administration
- building, and a security station.
The majority of theproposed site currently consists of cultivated agricultural land. Preliminary environmental investigations bySHINE have concluded that there are no wetlands, waterways, forest, grasslands or prairie habitats on thepropoSed site.We have reviewed the draft Environmental Impact Statement published May 2015. Because the Wisconsin Department of Natural Resources (WDNR) may have regulatory jurisdiction over various aspects of this project,we submit several comments related to the draft EIS:Storm waterWithin the document, lines 40-42 of page 4-19 currently state that:"This stormw4ater system would be designed to address the 1-year, 2-year, and 24-hour storm events perState regulations and the 10O-year and 100-year events, as required by the City of Janesville (SHINE2013a).'"
The Department recommends that the storm water system design reference compliance with NR 151 and NR 216,Wis. Adm. Code instead of (or in addition to) the specific regulations.
The peak discharge requirement (fromvarious storm events) that is referenced is only one of the storm water requirements and there are other specificregulatory obligations that would need to be met (total suspended solids reduction
& infiltration, for example).
Additionally, referencing compliance with NR 151 and NR 216, Wis. Adm. Codes, incorporates both theConstruction Site Storm Water Runoff permit and the Industrial Storm Water permit that are both required of thisdnr.wi.gov
-wisconsin~gov Naturally WVISCONSINPPE Page 2site. The sentence might be most simply re-worded to read, "The storm water system(s) shall be designed tocomply with NR 151 and NR 216, Wis. Adm. Code and the City of Janesville's requirements."
AirThe dEIS states that, "As of February 2014, the WDNR was actively working with SHINE to determine which ofthese permits would be required (WDNR 2014a),"
and "SHINE intends to submit an application for a Type ARegistration Construction Permit to the Wisconsin Department of Natural Resources (WDNR) (SHINE 2013b)."It should be noted that the Department has not yet received an application for an air pollution control permit fromSHINE.Section 4.2.2 discusses air emissions from operations.
The Department is unable to confirm the assumedemissions without a permit application.
Hazardous WasteThere is reference in the dEIS to properly handling the low level mixed waste that is proposed to be generated.
Itshould be noted that in January 2014, the Department communicated with SHINE related to this topic and SHINEwas informed of the Department's requirements.
Several times in the document, NR 460, Wisconsin Adminstrative Code, is referenced regarding hazardous wasteand nonhazardous waste. See the following from the draft:"In the State of Wisconsin, EPA has delegated the primary responsibility for implementing RCRAregulations to the State of Wisconsin.
For example, Wisconsin Administrative Code NR 460 addresses theidentification; generation; minimization, transportation, and final treatment,
- storage, or disposal ofhazardous and nonhazardous waste. "This should be corrected to reference NR 66.___0, Wisconsin Administrative Code (not NR 460) and the reference tononhazardous waste should be deleted or should include that the nonhazardous Solid Waste General requirements are detailed in NR 500, Wisconsin Administrative Code.Thank you for providing the opportunity to comment on the draft Environmental Impact Statement related to theconstruction permit for SI-INE Medical Technologies Radioisotope Production Facility.
Please contact LauraBub at laura.bub~iwisconsin.gov or 608.275.3485 with any questions or comments regarding this letter.Sincerely, Laura BubEnvironmental Analysis and Review Specialist Cc (via email): Michelle Moser, U.S. NRCJim Martin, WDNRDan Bekta, WDNRBrian Barbieur, WDNRTom Roushar, WDNRMatt Hilse, WDNRDennis Mack, WDNRRuss Anderson, WDNRMark Aquino, WDNR