Environmental Impact Statement - radioactive monticello

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Appendix A t1lY-17-2fG 13:11 P.02 /~~' uNITE STATEs ENVIRONMENTAL PRoTECTION AGENCY ArA REGION 5 .77 W6TJA SON BOULEVARD C"HIC..AGO, IL W439 MIAY O 3 2006 Chief& Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D$9 Washington, D.C. 20555-0001 B-191 Re: Generic £aviroumcntal Impact Statement for License Renewal of Nuclear Plant, Supplement 26: Monticello Nuclear Generating Plant ('EQ 14o. 20060034) Dear Sir or Madam: In accordance with Section 309 of the Clean Air Act and the National Environmental Policy Act (NEPA), the US. Envi'onmnentaJ Protection Agency (US. EPA) has reviewed the Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plant; Supplement 26. Monicello Nuclear Gcoceating Plant According to this Draft Supplemental Environmenual Impact Statement (SEIS), the plant's current operating license expires on September 8. 2010. The proposed Federal action would renew the current operating liHcn for an additional 20 years. F F F F Thc Monticello Nuclear Generating Plant is located in southeastern Minnesota on the bank of the Mississippi River, 30 miles northwest ofMinneapolis. Monticello is a single-unit plant that c, urrently generates approximately 1775 megawatt thernmaL as a result of an authorized power uprate in 1998. The plant uses Mississippi River watcr for condenser cooling and can operate as an open-cycle plant. returjing water to the river, or a closed-cycle plant, using two cooling towers. The cooling towers re ntomaUlyoperatod May through September, when te Mississippi River is generally above 68B F, or during periods of low flow. Tbis system is In effect to meet sirfacc water appropriations limits and thermal discharge limits. The Nuclear Regulatory Commission (NRC) developed the Generic Envimonmental Impact Statement (GELS) to streamline the license renewal process on the premise that cnvironmental impacts of most nuclear power plant license renewals arc similar. NRC develops facilityspecific supplemental environmental impact statement documents as the facilities apply (or license renewal. The U.S.EPA provided comments on the GElS during its development proces in 1992 and 1996. In several reviews of dacilityapcpcirlc documents, U.S. EPA's Region 5 orficc has commented that these documents do not provide site-spccific information o= impacT9 or use site-,pecific data for air and radiation and exposure calculations. Rcccntly, representatives of NRC and U.S. EPA's Office of Federal Activities discusse d-te NRC's GETS approach. NRC rciteratfd that it will continue to use the GEIS approach, except in cases where NRC is aware that site-specific data iTicates an impact at an individual plant site or when specific infooriadotn documenting potential impacts is provided by other Fedcral or State agencies or other revlcweun. While we rccognize tho GElS approach, we will continue to note Page I of 2 NUREG-1437, Supplement 26 A-76 August 2006 1
Appendix A MAY-17-206 13:11 P.04 U.S. Environmental Protection Agency Comments on Generic Enviroumeotal 7mpact Statement for License Renewal of Nuclear Plant, Supplement 26: Monticello Nuclear Generating Plant, Draft TReport, NUREG-1437 H-1 1. We arc concerned that the Draft SELS does not discuss potential power.uprates :u Monticello or estimate resulting Increases in radiological emissions. spent fuel. and other emissions. We recogni•z that NRC's regulations (10 C.F.R Section 51.53(c)(2)) state that an applicant's envirorunmental report need not discus tho demand for power, and we ore not asking for an assessment of need, Separate from purpose and need, we consider power uprates to be reasonably foreseeable actions that contributc to a cumulative radiological impact. under 40 C.F.R Section 1508.7. and therefore should be discussed in NRC's final SEIS. H-2 2. We awe concered about the abnormal releases mentioned in the Draft SEMS. The Draft SEIS refernces abnormal releases of fission and activation products and tritium during.the period from 2001 to 2004 (page 2-9). Thi is the only place these releases are discussed in the document, and their mention raises questions that ame not addressed. Information on the abnormal releases is unclear. For example, it is not clear whether there was one release event or rmore, ocwhere the event occurred. In addition, while the concentration of the release(s) is given, readers arc referred elsewhere in the documcnt and regulations to determine for themselvcs whether this is within effluent limits or how this irnpacts the public or the environment. This section implies that occasional abnormal releases are expected duri•g•the renewal period. The Final SEIS needs to explain the past 2nd future expected frequency of these releases. Finally, the Draft SBIS also claims that if fature abnormal releases occur, they will be below design dose objectives: It is not cler how this statement could be supported for hypothetical incidents. We also notc that abnormal releases are not discussed in sections on radiological impacts or water quality, presuming that these abnormal rele-ses were issued to a water body. With the GElS approa*h, NRC generally does not include.an analysis ofimpacts where staffroviewei; have not found new or significant informalion. We belicve thai past abnormal rolcascs, and the potential for future abnormal relea.es, qualify as new and significant information. We therefore recommend that the subsequent Final SEIS discuss the abnormal releases ully and in context to the environmcntul impacts analysis. We recommend including a discussion ofrpast or potential future releases and steps to prevent releases. Specifically, the Final SEIS needs to explain the number of releases and where releases occured (i.e., describe whether the release was effluent into the Mississippi River, an on-site spill, or some other relcasc). It should clarify how abnormal releases arc differmt from liquid effluent, if his is the case. We recommend that where concentrations are mentioned, the document plce these concentrations In cortext by giving effluent limits, dose limits, or other relevant measurements. We also recommend that abnormal releases be discussed in Chapte., 4.0 Environmental impacts of Operaion. H-3 3, We arc aware that there was a proposal before the Minnesota Environmental Quality Board for dry cask storage facility for spent nuclear fuel at Monticello. We note that the Environmental Impacts section of the Dramft SETS does not discuss the potential impacts associated with adding this type ofspent fuel storge facility to the txisuing operation. We August 2006 A-77 NUREG-1 437, Supplement 26 1
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NUREG-1437 Supplement 26 Generic En
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Generic Environmental Impact Statem
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Abstract The U.S. Nuclear Regulator
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Contents Abstract........... ......
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Contents 4.8.7 Conclusions Regardin
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Figures Figure 2-1. Figure 2-2. Fig
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Contents Table 5-1. Category 1 Issu
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Executive Summary The Commission ha
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Executive Summary NMC and the staff
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0 degree pCi microcurie(s) pCi/mL m
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Abbreviations/Acronyms IPE IPEEE J
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Abbreviations/Acronyms rem REMP RHR
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Introduction and (4) present the st
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Introduction (1) The environmental
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Introduction I assessment of the re
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Introduction This definition of pur
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2.0 Description of Nuclear Power Pl
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Description of Site and Environment
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Descfiption of Site and Environment
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Table 2-10. Land Use in Sherburne C
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Environmental Impacts of Refurbishm
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Environmental Impacts of Refurbishm
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Environmental Impacts of Operation
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Environmental Impacts of Postulated
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Environmental Impacts of the Uraniu
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Environmental Impacts of Decommissi
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Environmental Impacts of Decommissi
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Environmental Impacts of Alternativ
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9.0 Summary and Conclusions By lett
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Summary and Conclusions The GElS co
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Summary and Conclusions not reached
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z a :m G) CA, Table 9-1. Summary of
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Summary and Conclusions U.S. Nuclea
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Appendix A: Comments Received on th
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Appendix A Commenter ID Commenter A
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Appendix A A.1 Comments and Respons
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Monticello Nuclear Generating Plant
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3. General Comments Regarding Licen
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Appendix A nuclear power (I) and Mo
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Appendix A scoping process. If an i
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Appendix A Comment: The NRC does no
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Appendix A Comment: The EIS needs t
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Appendix A Comment: The EIS needs t
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Appendix A cognitive impairment. We
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Appendix A Despite available eviden
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Page 273 and 274: the coal chain What about all the s
Page 275 and 276: gasification generation balanced ag
Page 277 and 278: Appendix A 14. Comments Concerning
Page 279 and 280: Appendix A Part II Comments Receive
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Page 285 and 286: Appendix A A.2.4 General Comments i
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Page 295 and 296: information in the Final SEIS as pa
Page 297 and 298: Appendix A Response: The impacts to
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Page 301 and 302: aging management aspects of the lic
Page 303 and 304: Appendix A A-2 PURVES TODD: Just ba
Page 305 and 306: Appendix A PURVES TODD: Thank you v
Page 307 and 308: Appendix A So you don't look for wh
Page 309 and 310: Appendix A Yes CHUCK HOSTOVSKY: I t
Page 311 and 312: Appendix A information a little bit
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Page 315 and 316: Appendix A tAY-W8-2006 11! 07 'ENCL
Page 317: Appendix A ta W.Y United States Dep
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Page 323: Appendix B Contributors to the Supp
Page 326 and 327: Appendix B Name Karen McWilliams Na
Page 329 and 330: Appendix C: Chronology of NRC Staff
Page 331 and 332: Appendix C May 27, 2005 May 27, 200
Page 333 and 334: Appendix C June 1,2005 June 2, 2005
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Page 337: Appendix D Organizations Contacted
Page 340 and 341: Appendix D Wright County Assessor,
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Page 347 and 348: Appendix E UNITED STATES -" NUCLEAR
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Appendix E During the June 2005 sit
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Appendix E Vegetation management ma
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Appendix E Lehman, R.N. 2001. Rapto
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Appendix E MAY-31-206 15:31 P.02 MI
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Appendix F GElS Environmental Issue
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Appendix F References 10 CFR Part 5
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Appendix G: NRC Staff Evaluation of
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Appendix G Table G-1. Monticello Co
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Appendix G * The MACCS2 analyses pe
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Appendix G relative risk significan
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" Permanently posting an operator a
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Appendix G accident sequences to em
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Appendix G The staff noted that the
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Appendix G (testing of the boron in
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somewhat higher than what would act
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C Cn N, a) % Risk Reduction Total B
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Appendix G G.6 Cost-Benefit Compari
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Appendix G monetary equivalent of u
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Appendix G * SAMA 16- provide passi
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Appendix G several other SAMAs, res
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Appendix G Generating Plant, Docket
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NRC FORM 335 U.S. NUCLEAR REGULATOR
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