Environmental Impact Statement - radioactive monticello

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