ML11301A074
| ML11301A074 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/25/2011 |
| From: | Drew T State of NH, Dept of Fish & Game |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR47612 00013, NRC-2010-0206-0013 | |
| Download: ML11301A074 (6) | |
Text
Page 1 of 1
/4 /6(
41~,/6**
/.~.,
jAs of: October 26, 2011 PUBLIC SUBMISSION Received: October 25, 2011 Status: PendingPost Tracking No. 80f5bebb Comments Due: October 26, 2011 Submission Type: Web Docket: NRC-2010-0206 Notice of Receipt and Availability of Application for Renewal of Facility Operating License Comment On: NRC-2010-0206-0013 NextEra Energy Seabrook, LLC; Notice of Availability of Draft Supplement 46 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meetings for the License Renewal of Seabrook Station, Unit 1 Document: NRC-2010-0206-DRAFT-0025 Comment on FR Doe # 2011-19875 Submitter Information General Comment See attached file(s)
Attachments SeabrookSEISCvrLtr 10-26-11 9]
~1
)
F]
(19 F'17 1
Mi
(~- ~)
httpsH//fdms.erulemaking.net/fdms-web-agency/component/contentstreamer?objectld=0900006480f5beb...
10/26/2011
Page 1 of I As of: October 26, 2011 Received: October 25, 2011 PUBLICSUBMISION Status: t'endmlgR-Fost PUBLICTracking No. 80f5beb7 Comments Due: October 26, 2011 Submission Type: Web Docket: NRC-2010-0206 Notice of Receipt and Availability of Application for Renewal of Facility Operating License Comment On: NRC-2010-0206-0013 NextEra Energy Seabrook, LLC; Notice of Availability of Draft Supplement 46 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meetings for the License Renewal of Seabrook Station, Unit I Document: NRC-2010-0206-DRAFT-0024 Comment on FR Doc # 2011-19875 Submitter Information Name: Timothy Drew Address:
NH Department of Environmental Services P.O. Box 95, 29 Hazen Drive Concord, NH, 02203-0095 Submitter's Representative: Timothy Drew Organization: NH Department of Environmental Services Government Agency Type: State Government Agency: Department of Environmental Services General Comment See attached file(s)
Attachments SeabrookSEISComments 10-26-11 https://fdms.erulemaking.net/fdms-web-agency/componentlcontentstreamer?obj ectld=0900006480f5beb...
10/26/2011
October 25, 2011 Chief, Rules, Announcements, and Directives Branch Division of Administrative Services Office of Administration Mail Stop: TWB-05-BO1M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE:
SEABROOK STATION, SEABROOK, N.H. - SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT - NH DEPARTMENT OF ENVIRONMENTAL SERVICES COMMENTS
Dear Colleague:
The New Hampshire Department of Environmental Services (NH DES) has completed its review of the Draft Supplemental Environmental Impact Statement (SEIS) for the Seabrook (NH)
Nuclear Electric Power Generation Station (Seabrook Station), located in Seabrook, New Hampshire.
NH DES is pleased to provide its technical comments to the U.S. Nuclear Regulatory Commission (see enclosure).
Areas addressed by the comments included a review of air quality, surface water quality and groundwater quality, drinking water / wells, geologic setting, wastewater discharge, coastal consistency and wetland issues related to the subject re-licensing project. Several of the above programs yielded no comments or concerns with the SEIS as written. Therefore, the focus of NH DES's comments relate to wastewater discharge, as well as a discussion of surface water and groundwater quality in the vicinity of Seabrook Station. Additional information has been requested relative the current status of tritium and its presence in the vicinity of the facility.
If there are questions, or there is need for clarification, please do not hesitate to contact me by telephone at (603) 271-3306 or by email at Timothy.Drewdes.nh.gov.
Sincerely, Timothy W. Drew Administrator Public Information and Permitting Office of the Commissioner Enc.
Cc:
Thomas S. Burack, Commissioner, DES Harry Stewart, Director, Water Division, DES Robert Scott, Director, Air Resources Division, DES Michael Wimsatt, Director, Waste Management Division, DES Carl DeLoi, EPA Region I, Boston, MA K. Allen Brooks, Esq., Chief, Environmental Protection Bureau, NH DoJ Jeffrey Meyers, Esq., Office of Governor John H. Lynch
-DEPARTMENT OF O
Environmental
_Services Seabrook Station, Seabrook, NH Supplemental Environmental Impact Statement U.S. Nuclear Regulatory Commission (Docket # NRC-2010-0206-0013)
NH DES Comments on Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 46, Regarding Seabrook Station, Draft Report for Comment, July 2011 (SEIS)
October 25, 2011 NH DES point of contact:
Timothy W. Drew Administrator Public Information and Permitting Unit Office of the Commissioner NH Department of Environmental Services P.O. Box 95 29 Hazen Drive Concord, NH 03302-00905 Tel: (603) 271-3306 Fax: (603) 271-2867 E-mail: Timothy.Drew(,des.nh.Qov Surface Water Discharge NH DES reviewed the SEIS sections related to cooling water, surface water (including the groundwater dewatering discharge to outfall 001), and aquatic resources. Its comments are as follows:
- 1. Section 2.2.6.3, Page 2-45, line 35 to 43. If any herbicides are used in the vicinity of surface waters during transmission line corridor maintenance then the owner and applicator may need to apply for coverage under the Pesticide General (NPDES) Permit soon to be issued by EPA.
Seabrook Station - Supplemental Environmental Impact Statement NH DES Comments October 25, 2011 Page 1 of 3
- 2. In Section 2.2.4 on page 2-27 in lines 38 and 39 it is reported that the discharge of radioactive effluents is allowed in accordance with NRC regulations. Section 2.2.5, beginning on page 2-29, reports that groundwater is being dewatered and discharged to outfall 001 and that the groundwater contains tritium. NRC should ensure that the discharge of tritium meets the NH surface water quality standard for Gross Beta Radioactivity, which is 1,000 pCi/L. An assumed dilution of the effluent by the diffusers of 10 was used during the last re-issuance of the NPDES permit and would be appropriate in this case until a more detailed evaluation of an appropriate mixing zone is conducted.
- 3. In the "Summary of Combined Effects" on page 4-34 it is reported that the operation of Seabrook Station's cooling system has a large impact on winter flounder, rainbow smelt and kelp (L. digitata) but there is no discussion or recommendation on mitigation of those impacts. Due to the reporting of these large impacts, Clean Water Act in Section 316(b) could trigger the need for EPA to require best technology available for minimizing any adverse environmental impacts, which could entail the installation of closed cycle cooling. Therefore, there may be a need to compare the impacts of continued operation of once-through cooling with those for the construction and operation of an appropriately sized closed cycle cooling system. Such a comparison would be needed to determine whether the impacts of construction and operation of closed cycle cooling outweigh the impacts of continued operation of the open cycle cooling system, which could lead to a conclusion as to whether there are any "adverse environmental impacts" under CWA Section 316(b). Such a comparison could be made if the continued operation of Seabrook Station with the installation of a closed cycle cooling system were added as a new alternative in Section 8 of the SEIS.
- 4. References to "Storm Water Pollution Prevention General Permit" (Section 8.1.3), and "General Stormwater Permit" (Sections 8.2.3 and 8.3.3) should more appropriately be to "Construction General Permit and the NHDES' Alteration of Terrain Permit."
- 5. Sections 8.2.3 (line 18) and 8.2.4.1 (line 27) refer to NPDES permits issued by NHDES.
These sentences should be revised to refer to NPDES permits issued by the EPA, since NH has not taken delegation of the NPDES program, and all such permits for facilities in NH are issued by the EPA.
For more information, please contact:
Jeffrey G. Andrews, P.E.
Sanitary Engineer Wastewater Engineering Bureau NH Department of Environmental Services P.O. Box 95 29 Hazen Drive Concord, NH 03302-0095 Tel: (603) 271-2984 Fax: (603) 271-4128 E-mail: Jeffrev.Andrews(cdes.nh.gov Seabrook Station - Supplemental Environmental Impact Statement NH DES Comments October 25, 2011 Page 2 of 3
Groundwater Quality I Tritium Section 2.2.5 Groundwater Resources discusses radioactive liquid releases associated with the Unit 1 containment structure that resulted in detections of tritium in the onsite dewatering system and groundwater.
Specifically, in 1999 a leak from the cask loading area and transfer canal adjacent to the spent fuel pool was discovered.
In addition there is discussion of a dewatering system installed in 2000-2001 which consists of five dewatering points and withdraws approximately 3000 gallons per day. A groundwater monitoring network consisting of 22 wells has also been installed at the site and has been sampled for tritium. The SEIS reports that repairs were made to the stainless steel fuel pool liner and concentrations of tritium have declined over time.
NH DES requests that additional information be included in the SEIS to provide a better understanding of:
(1) the nature of the release; (2) the corrective actions taken to date; (3) the operation of the dewatering system; (4) geologic setting and proximity to bedrock; (5) the direction and rate of groundwater flow; and (6) the impact on groundwater quality. Following the review of the additional information, NH DES would be in a better position to further evaluate the conclusions outlined in the SEIS and provide recommendations for future actions, if warranted by the data.
For more information, please contact:
John Regan, P.G.
Hydrogeologist V State Sites Section Hazardous Waste Remediation Bureau Waste Management Division NH Department of Environmental Services P.O. Box 95 29 Hazen Drive Concord, NH 03302-0095 Tel: (603) 271-3744 Fax: (603) 271-2181 E-mail: John.Regan(@des.nh.qov Seabrook Station - Supplemental Environmental Impact Statement NH DES Comments October 25, 2011 Page 3 of 3