NRC-2017-0141, Comment (5) of Cheryl T. Seager on Behalf of the Us Environmental Protection Agency, Region 6 on the Proposed License Renewal of River Bend Station, Unit 1
| ML18206A455 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/19/2018 |
| From: | Seager C US Environmental Protection Agency, Region 6 |
| To: | May Ma Office of Administration |
| References | |
| 83FR26310 00005, NRC-2017-0141 | |
| Download: ML18206A455 (4) | |
Text
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region6 1445 Ross Avenue, Suite 1200
. Dallas, TX 75202-2733 JUL fg 20JB.
May Ma, Director Program Management Announcements and Editing Branch Office of Administration, TWFN-7-A-60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Ms. Ma:
SUNSI Review Complete Template= ADM-013 E-RIDSc:=ADM-03 ADD= Daivd Drucker Yvonne Edmonds, Eric Oesterie COMMENT (5).
PUBLICATION DATE: 6/6/2018 CiTATION: 83 FR26310 The U.S. Environmental Protection Agency (EPA) has reviewed the draft Environmental Impact Statement (EIS) for the Generic EIS for License Reµewal of Nuclear Plants, Supplement 58, Regarding River Bend Station, Unit 1 (CEQ No. 20180122) pursuant to the National Environmental Policy Act (NEPA), Council on Environmental Quality regulations (40 C.F.R. Parts 1500-1508), and our NEPA*
review authority under Section 309 of the Clean Air Act.
The purpose of the River Bend Station license renewal is to extend nuclear power generation capabilities for an ad~itional twenty years beyond the expiration.of the cmTent license; which expires on August 29, 2025. Under the Proposed Action - license renewal, the River Bend Station would continue to operate during the license renewal tenn in the same manner as current operations; except for additional aging management programs to address structural and component aging.. The EPA has rated the draft EIS as EC-2, Environmental. Concerns - Insufficient Information'. Pleas~ r~fer to the enclosed Summary of Rating Definitions for a detailed explanation of the EPA's rating system. The EPA's.primary concern is the potential leaking of tritium.above maximum contanvnant levels (MCL) into the Uplaµd Terrace Aquifer. Further e:x;planation is provided in the enclosed detailed comments fol' your considera#on.
We appreciate the opportunity to review and comment on this document. Once completed, please send our office one copy of the Final EIS at the address above. If you have any questions, please contact Keith Hayden~ the project review lead, at 214-665-2133 or hayden.keith@epa.gov.
Enclosures:
EPA's detailed comments Summary of EPA rating definitions Sincerely, Che1yl T. Seager Director Compliance Assurance and
- Enforcement Division
DETAILED COMMENTS ONTHE PROPOSED LICENSE RENEW AL OF RIVER BEND STATION NUCLEAR PLANT The draft EIS characterizes the pote~tial effects ofradionuclides, in this case tritium, on groundwater as small to moderate. The EIS contains a good description of aquifer zones in the area, monitoring wells, the history of tiitium spills and releases at River Bend Station (RJ3S), and mitigation efforts to limit tritium releases above MCL's.
Most of the mitigation efforts listed in the EIS do not prevent tritium from being released into the groundwater but instead mitigate the releases after they have entered the Upland Terrace Aquifer (UTA). These mitigation measures include pumping tritium contaminated water and nuxing it with uncontaminated water until it falls within acceptable Nuclear Regulatory Commission (NRC) and Louisiana,Department of Environmental Quality (LDEQ) regulatory limits, and utilizing natural a:ttenuation methods such*as dilution, sorption, evaporation, and radioactive decay. In 2016, the applicant resealed the floor joints of the turbine building believed to be the sQurce of tritium leaks.
Whil~ this is a positive mitigation measlll'e that prevents tritium from entering the UT A, NRC concludes that it is too early to detennine that the applicant has identified and stopped all sources of trit~um*
contamination. EPA recommends that a more detailed description of sampling, mitigation, and response efforts be included in the final EIS that would describe ongoing efforts to deteimine all sources of
. tritimp. leaks, response_s to potential tritium leaks, and any additional mitigation efforts that would remediate harmful effects of tritium releases.
The EIS states that thick clay beneath the UTA prevents any tadiological contamination from moving deeper into underlying aquifers. Also, no offsite private or public drinking wells exist along the direction of groundwater flow within the UT A. There are 21 welis screened into the UT A; outside of the RBS boundary, and east of the Mississippi River. The EIS concludes that no RBS or offsite groundwater should contact the tritium contaminated groundwater.*EPA recommends the final EIS discuss w~at safeguards are in place to ensure that any future drinking.water wells are not established within the groundwater flow zone of the UTA.
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SUMMARY
OF RATING DEFINITIONS AND FOLLOW-UP ACTION*
A. Rating the Environme_ntal Impact of the Action.
LO (Lack of Objections). The review has not identified any potential environmental impacts requiring substantive changes to the prefen*ed altemative. The rev1ew may have disclosed opportunities for application of mitigation measures that could be accomplished with no more than minor changes to the propose.cl action.
EC (Environmental Concerns). The review has identified environmental impa~ts that should be avoided in order to fully protect the environment. Corre*ctive measures may require changes to the prefen-ed alternative or application of mitigation measures that can reduce the environµiental impact.
EO (Environmental Objections). The review has identified significant environmental impacts that should be avoided in order to adequately protect the environment. Corrective measures may require substantial changes to the p1;eferred alternative or consideration of some othei* project alternative (including the no action alternative or a new alternative).
The basis for environmental Objections can include situations:
- 1. Where an ae:tion might violate or be* inconsistent with achievement or maintenance of a national environmental standard; **
- 2. Where the Federal agency violates its own substantive environmental requirements that relate to EPA's:areas of jurisdiction or expertise;
- 3. *Where there is a violation of an EPA policy declaration;
- 4. Where there are no applicable standards or where applicable standards will not be violated but there is potential fqr significant envirorunental degradation that could be conected by project modification or other feasible alternatives; or*
- 5. Where proceeding with the proposed action would set a precedent for future l'l,ctions that collectively could result in significant environmental impacts.
EU (EnvironmentallfUnsatisfactory). The review has identified adverse environmental impacts that are of sufficient 1nagnitude that EPA believes the proposed action must not proceed as proposed. The basis for an eilvir-0nmentally unsatisfactory detem1ination consists of identification of environmentally objectionable impacts. as defined above and one or more of the following conditions:
- 1. The potential violation of or inconsistency wit;h a national environmental standard is substantive and/or will occur on a long-term basis;
- 2. There are no applicable standards but the severity, duration, or geographical scope of the impacts associated with the proposed action wruTant special attention; or
- 3. The potential environmental impacts resulting froni the proposed action are of national importance because of the threat to national environmental resources or to environmental poliyies.
B. Adequacy of the Impact Statement.
1 (Adequate). The draft EIS adequately sets forth the environmental impact(s) of the prefened alternative and those of the altematives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition of cl~ifying lang~age or information.
2 (Insufficient Information). The draft EIS does not contain sufficient information to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the reviewer has identified new reasonably available. altematives that are within the spectrum of alternatives analyzed in.the draft EIS, which could reduce the environmental impacts of the proposaL The identified additional info1mati6n, data, analyses, or discussion should be included in the final EIS.
3 (Inadequate). The draft EIS does not adequately assess the potyntially significant environmental impacts of the proposal,. or the 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. The identified additional info1matio11, data, analyses, or discussions are of such a magnitude that they should have full public review at a draft_
stage. This rating indicates EP A's belier that the draft EIS does not meet the purposes of NEPA and/or the Section 309 review, and thus should be f01mally revised and made available for public comment in a supplemental or revised draft EIS.
- From EPA Manual 1640: Policy and Procedures for the Review of.Federal Actions Impacting the Environment