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Please specify the report number NUREG-1437, Supplement 49, in your comments, and send them by the end of the comment period specified in the Federal Register notice announcing the availability of this report. 7 8 9 10 Addresses: You may submit comments by any one of the following methods. Please include Docket ID NRC-2011-0166 in the subject line of your comments. Comments submitted in writing or in electronic form will be posted on the NRC website and on the Federal rulemaking website http://www.regulations.gov. 11 12 13 Federal Rulemaking Website: Go to http://www.regulations.gov and search for documents filed under Docket ID NRC-2011-0166. Address questions about NRC dockets to Carol Gallagher at 301-492-3668 or by e-mail at Carol.Gallagher@nrc.gov. 14 15 16 17 Mail comments to: Cindy Bladey, Chief, Rules, Announcements, and Directives Branch (RADB), Division of Administrative Services, Office of Administration, Mail Stop: TWB-05-B01M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Faxes may be sent to RADB at 301-492-3446. 18 19 For any questions about the material in this report, please contact Leslie Perkins, NRC Environmental Project Manager, at 1-800-368-5642, extension 2375, or by e-mail at leslie.perkins@nrc.gov Please be aware that any comments that you submit to the NRC will be considered a public record and entered into the Agencywide Documents Access and Management System (ADAMS). Do not provide information you would not want to be publicly available. 21 22 23 NUREG-1437, Supplement 49, has been reproduced from the best available copy. ABSTRACT 1 2 3 4 This draft supplemental environmental impact statement has been prepared in response to an application submitted by Exelon Generation Company, LLC (Exelon) to renew the operating license for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20 years. 5 6 7 8 9 This draft supplemental environmental impact statement includes the preliminary analysis that evaluates the environmental impacts of the proposed action and alternatives to the proposed action. Alternatives considered include natural gas combined-cycle (NGCC); supercritical pulverized coal; new nuclear; wind power; purchased power; and not renewing the license (the no action alternative). 10 11 12 13 The U.S. Nuclear Regulatory Commission's preliminary recommendation is that the adverse environmental impacts of license renewal for LGS are not great enough to deny the option of license renewal for energy planning decisionmakers. This recommendation is based on the following: 14 15 ? the analysis and findings in NUREG-1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants; 16 ? the environmental report submitted by Exelon; 17 ? consultation with Federal, state, and local agencies; 18 ? the NRC's environmental review; and 19 ? consideration of public comments received during the scoping process. iii 1 TABLE OF CONTENTS 2 ABSTRACT .............................................................................................................................. iii 3 TABLE OF CONTENTS ............................................................................................................ v 4 FIGURES .................................................................................................................................. xi 5 TABLES ................................................................................................................................. xiii 6 EXECUTIVE SUMMARY ......................................................................................................... xv 7 ABBREVIATIONS AND ACRONYMS .................................................................................... xxi 8 1.0 PURPOSE AND NEED FOR ACTION .............................................................................. 1-1 9 10 11 12 13 14 15 16 17 18 1.1. Proposed Federal Action............................................................................................... 1-1 1.2. Purpose and Need for the Proposed Federal Action ..................................................... 1-1 1.3. Major Environmental Review Milestones ....................................................................... 1-2 1.4. Generic Environmental Impact Statement ..................................................................... 1-3 1.5. Supplemental Environmental Impact Statement ............................................................ 1-6 1.6. Cooperating Agencies................................................................................................... 1-6 1.7. Consultations ................................................................................................................ 1-6 1.8. Correspondence ........................................................................................................... 1-7 1.9. Status of Compliance .................................................................................................... 1-7 1.10. References .................................................................................................................. 1-7 19 2.0 AFFECTED ENVIRONMENT ............................................................................................ 2-1 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 2.1. Facility Description ........................................................................................................ 2-1 2.1.1. Reactor and Containment Systems .................................................................. 2-1 2.1.2. Radioactive Waste Management ..................................................................... 2-1 2.1.3. Nonradiological Waste Management................................................................ 2-7 2.1.4. Plant Operation and Maintenance .................................................................... 2-9 Power Transmission System ............................................................................ 2-9 2.1.5. 2.1.6. Cooling and Auxiliary Water Systems ............................................................ 2-16 2.1.7. Facility Water Use and Quality ....................................................................... 2-21 2.2. Surrounding Environment ........................................................................................... 2-23 2.2.1. Land Use ....................................................................................................... 2-24 2.2.2. Air Quality and Meteorology ........................................................................... 2-25 2.2.3. Geologic Environment .................................................................................... 2-27 2.2.4. Surface Water Resources .............................................................................. 2-30 2.2.5. Groundwater Resources ................................................................................ 2-34 2.2.6. Aquatic Resources ......................................................................................... 2-37 2.2.7. Terrestrial Resources ..................................................................................... 2-47 2.2.8. Protected Species and Habitats ..................................................................... 2-50 2.2.9. Socioeconomics ............................................................................................. 2-65 2.2.10. Historic and Archaeological Resources .......................................................... 2-80 v Table of Contents 1 2 2.3. Related Federal and State Activities ........................................................................... 2-84 2.4. References ................................................................................................................. 2-84 3 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT..................................................... 3-1 4 3.1. References ................................................................................................................... 3-3 5 4.0 ENVIRONMENTAL IMPACTS OF OPERATION .............................................................. 4-1 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 4.1. Land Use ...................................................................................................................... 4-1 4.2. Air Quality ..................................................................................................................... 4-2 4.3. Geologic Environment................................................................................................... 4-2 4.3.1. Geology and Soils ............................................................................................ 4-2 4.4. Surface Water Resources ............................................................................................. 4-3 4.4.1. Generic Surface Water Issues ......................................................................... 4-3 4.4.2. Surface Water Use Conflicts ............................................................................ 4-3 4.5. Groundwater Resources ............................................................................................... 4-4 4.5.1. Generic Groundwater Issues ........................................................................... 4-5 4.5.2. Groundwater Use and Quality Conflicts ........................................................... 4-5 4.6. Aquatic Resources ........................................................................................................ 4-7 4.6.1. Exposure of Aquatic Organisms to Radionuclides ............................................ 4-8 4.7. Terrestrial Resources.................................................................................................... 4-8 4.7.1. Generic Terrestrial Resources Issues .............................................................. 4-9 4.7.2. Effects on Terrestrial Resources (Non-Cooling System Impacts) ..................... 4-9 4.8. Protected Species and Habitats .................................................................................. 4-10 4.8.1. Correspondence with Federal and State Agencies......................................... 4-10 Aquatic Species and Habitats ........................................................................ 4-11 4.8.2. 4.8.3. Terrestrial Species and Habitats .................................................................... 4-16 4.9. Human Health ............................................................................................................. 4-21 4.9.1. Generic Human Health Issues ....................................................................... 4-21 4.9.2. Radiological Impacts of Normal Operations ................................................... 4-22 4.9.3. Microbiological Organisms ............................................................................. 4-25 4.9.4. Electromagnetic Fields--Acute Effects .......................................................... 4-26 4.9.5. Electromagnetic Fields--Chronic Effects ....................................................... 4-27 4.10. Socioeconomics ........................................................................................................ 4-28 4.10.1. Generic Socioeconomic Issues ...................................................................... 4-28 4.10.2. Housing ......................................................................................................... 4-29 4.10.3. Public Services--Public Utilities ..................................................................... 4-29 4.10.4. Offsite Land Use ............................................................................................ 4-30 4.10.5. Public Services--Transportation .................................................................... 4-31 4.10.6. Historic and Archaeological Resources .......................................................... 4-31 4.10.7. Environmental Justice .................................................................................... 4-32 4.10.8. Conclusion ..................................................................................................... 4-39 4.11. Evaluation of New and Potentially Significant Information ......................................... 4-39 vi Table of Contents 1 2 3 4 5 6 7 8 9 10 4.12. Cumulative Impacts ................................................................................................... 4-41 4.12.1. Air Quality ...................................................................................................... 4-42 4.12.2. Water Resources ........................................................................................... 4-43 4.12.3. Aquatic Resources ......................................................................................... 4-46 4.12.4. Terrestrial Resources ..................................................................................... 4-48 4.12.5. Human Health ................................................................................................ 4-50 4.12.6. Socioeconomics ............................................................................................. 4-51 4.12.7. Cultural Resources ........................................................................................ 4-52 4.12.8. Summary of Cumulative Impacts ................................................................... 4-52 4.13. References ................................................................................................................ 4-54 11 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS ...................................... 5-1 12 13 14 15 5.1. 5.2. 5.3. 5.4. Design-Basis Accidents ................................................................................................ 5-1 Severe Accidents .......................................................................................................... 5-2 Severe Accident Mitigation Alternatives ........................................................................ 5-3 References ................................................................................................................. 5-14 16 17 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS ...................... 6-1 18 19 20 21 22 6.1. The Uranium Fuel Cycle ............................................................................................... 6-1 6.2. Greenhouse Gas Emissions ......................................................................................... 6-3 6.2.1. Existing Studies ............................................................................................... 6-3 6.2.2. Conclusions: Relative Greenhouse Gas Emissions......................................... 6-9 6.3. References ................................................................................................................. 6-10 23 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ................................................. 7-1 24 25 7.1. Decommissioning.......................................................................................................... 7-1 7.2. References ................................................................................................................... 7-2 26 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES ........................................................ 8-1 27 28 29 30 31 32 33 34 35 36 37 38 39 40 8.1 Natural Gas Combined-Cycle Alternative ...................................................................... 8-5 8.1.1. Air Quality ........................................................................................................ 8-7 8.1.2. Groundwater Resources .................................................................................. 8-8 8.1.3. Surface Water Resources ................................................................................ 8-9 8.1.4. Aquatic Resources ......................................................................................... 8-10 8.1.5. Terrestrial Resources ..................................................................................... 8-11 8.1.6. Human Health ................................................................................................ 8-12 8.1.7. Land Use ....................................................................................................... 8-12 8.1.8. Socioeconomics ............................................................................................. 8-13 8.1.9. Transportation................................................................................................ 8-14 8.1.10. Aesthetics ...................................................................................................... 8-14 8.1.11. Historic and Archaeological Resources .......................................................... 8-15 8.1.12. Environmental Justice .................................................................................... 8-15 8.1.13. Waste Management ....................................................................................... 8-16 vii Table of Contents 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 8.2. Supercritical Pulverized Coal-Fired Alternative ........................................................... 8-17 8.2.1. Air Quality ...................................................................................................... 8-18 8.2.2. Groundwater Resources ................................................................................ 8-20 8.2.3. Surface Water Resources .............................................................................. 8-21 8.2.4. Aquatic Resources ......................................................................................... 8-22 8.2.5. Terrestrial Resources ..................................................................................... 8-22 8.2.6. Human Health ................................................................................................ 8-23 8.2.7. Land Use ....................................................................................................... 8-24 8.2.8. Socioeconomics ............................................................................................. 8-24 8.2.9. Transportation................................................................................................ 8-25 8.2.10. Aesthetics ...................................................................................................... 8-26 8.2.11. Historic and Archaeological Resources .......................................................... 8-26 8.2.12. Environmental Justice .................................................................................... 8-26 8.2.13. Waste Management ....................................................................................... 8-27 8.3. New Nuclear ............................................................................................................... 8-28 8.3.1. Air Quality ...................................................................................................... 8-29 8.3.2. Groundwater Resources ................................................................................ 8-30 8.3.3. Surface Water Resources .............................................................................. 8-31 8.3.4. Aquatic Resources ......................................................................................... 8-31 8.3.5. Terrestrial Resources ..................................................................................... 8-32 8.3.6. Human Health ................................................................................................ 8-32 8.3.7. Land Use ....................................................................................................... 8-33 Socioeconomics ............................................................................................. 8-33 8.3.8. 8.3.9. Transportation................................................................................................ 8-34 8.3.10. Aesthetics ...................................................................................................... 8-34 8.3.11. Historic and Archaeological Resources .......................................................... 8-35 8.3.12. Environmental Justice .................................................................................... 8-35 8.3.13. Waste Management ....................................................................................... 8-36 8.4. Wind Alternative .......................................................................................................... 8-37 8.4.1. Air Quality ...................................................................................................... 8-39 8.4.2. Groundwater Resources ................................................................................ 8-39 8.4.3. Surface Water Resources .............................................................................. 8-40 8.4.4. Aquatic Resources ......................................................................................... 8-40 8.4.5. Terrestrial Resources ..................................................................................... 8-41 8.4.6. Human Health ................................................................................................ 8-41 8.4.7. Land Use ....................................................................................................... 8-42 8.4.8. Socioeconomics ............................................................................................. 8-43 8.4.9. Transportation................................................................................................ 8-44 8.4.10. Aesthetics ...................................................................................................... 8-44 8.4.11. Historic and Archaeological Resources .......................................................... 8-44 viii Table of Contents 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 8.4.12. Environmental Justice.................................................................................... 8-45 8.4.13. Waste Management ....................................................................................... 8-45 8.5. Purchased Power ....................................................................................................... 8-46 8.6. Alternatives Considered But Dismissed ...................................................................... 8-49 8.6.1. Solar Power ................................................................................................... 8-49 8.6.2. Combination Alternative: Wind, Solar, and NGCC......................................... 8-57 8.6.3. Combination Alternative: Wind and Compressed Air Energy Storage ............. 8-65 8.6.4. Wood Waste .................................................................................................. 8-74 8.6.5. Conventional Hydroelectric Power ................................................................. 8-75 8.6.6. Ocean Wave and Current Energy .................................................................. 8-75 8.6.7. Geothermal Power ......................................................................................... 8-76 8.6.8. Municipal Solid Waste .................................................................................... 8-77 8.6.9. Biomass Fuels ............................................................................................... 8-78 8.6.10. Oil-Fired Power .............................................................................................. 8-78 8.6.11. Delayed Retirement ....................................................................................... 8-78 8.6.12. Fuel Cells ....................................................................................................... 8-79 8.6.13. Coal-Fired Integrated Gasification Combined-Cycle....................................... 8-79 8.6.14. Demand-Side Management ........................................................................... 8-80 8.7. No-Action Alternative .................................................................................................. 8-81 8.7.1. Air Quality ...................................................................................................... 8-81 8.7.2. Groundwater Resources ................................................................................ 8-82 Surface Water Resources .............................................................................. 8-82 8.7.3. 8.7.4. Aquatic and Terrestrial Resources ................................................................. 8-82 8.7.5. Human Health ................................................................................................ 8-82 8.7.6. Land Use ....................................................................................................... 8-82 8.7.7. Socioeconomics ............................................................................................. 8-82 8.7.8. Transportation................................................................................................ 8-83 8.7.9. Aesthetics ...................................................................................................... 8-83 8.7.10. Historic and Archaeological Resources .......................................................... 8-83 8.7.11. Environmental Justice .................................................................................... 8-83 8.7.12. Waste Management ....................................................................................... 8-83 8.8. Alternatives Summary ................................................................................................. 8-84 8.9. References ................................................................................................................. 8-86 34 9.0 CONCLUSION .................................................................................................................. 9-1 35 36 37 38 39 40 41 9.1. Environmental Impacts of License Renewal .................................................................. 9-1 9.2. Comparison of Alternatives ........................................................................................... 9-1 9.3. Resource Commitments................................................................................................ 9-2 9.3.1. Unavoidable Adverse Environmental Impacts .................................................. 9-2 9.3.2. Short-Term Versus Long-Term Productivity ..................................................... 9-2 9.3.3. Irreversible and Irretrievable Commitments of Resources ................................ 9-3 9.4. Recommendations ........................................................................................................ 9-4 ix Table of Contents 1 10.0 LIST OF PREPARERS ................................................................................................. 10-1 2 3 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS SEIS ARE SENT .................................................................................................. 11-1 4 12.0 INDEX ........................................................................................................................... 12-1 5 6 APPENDIX A COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, UNITS 1 AND 2, ENVIRONMENTAL REVIEW ................................................A-1 7 8 APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS..................................................B-1 9 APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS ........................ C-1 10 APPENDIX D CONSULTATION CORRESPONDENCE .........................................................D-1 11 APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE ....... E-1 12 13 APPENDIX F DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE IMPACT ANALYSIS......................................................................................... F-1 x Table of Contents 1 FIGURES 2 Figure 1-1. Environmental Review Process .......................................................................... 1-2 3 Figure 1-2. Environmental Issues Evaluated during License Renewal .................................. 1-5 4 Figure 2-1. Location of LGS, 6-mile (10-km) vicinity ............................................................. 2-3 5 Figure 2-2. Location of LGS, 50-mile (80-km) region ............................................................ 2-4 6 Figure 2-3. LGS site boundary and facility layout ................................................................. 2-5 7 Figure 2-4. Limerick to Cromby 230-kV Transmission Line Route ...................................... 2-11 8 Figure 2-5. Cromby to North Wales 230-kV Transmission Line Route ................................ 2-12 9 Figure 2-6. Cromby to Plymouth Meeting 230-kV Transmission Line Route ....................... 2-13 10 Figure 2-7. Limerick to Whitpain 500-kV Transmission Line Route ..................................... 2-14 11 Figure 2-8. Location of Schuylkill Pumphouse and LGS Discharge Structure ..................... 2-17 12 13 Figure 2-9. LGS Makeup Water Supply System and Alternative Water Sources within the Delaware River Basin ................................................................................. 2-19 14 Figure 4-1. 2010 Census Minority Block Groups within a 50-mi Radius of the LGS ............ 4-35 15 Figure 4-2. 2010 Census Low-Income Block Groups within a 50-mi Radius of LGS ........... 4-37 xi Table of Contents 1 TABLES 2 3 Table ES-1. Summary of NRC Conclusions Relating to Site-Specific Impacts of License Renewal .............................................................................................. xviii 4 5 Table 2-1. Annual Fuel Use and Estimated Air Emission Estimates for Significant Sources at LGS ............................................................................................... 2-27 6 Table 2-2. NOAA Trust Resources Observed in LGS-related Aquatic Studies.................. 2-46 7 Table 2-3. Federally and Pennsylvania-Listed Aquatic Species........................................ 2-52 8 Table 2-4. Federally and Pennsylvania-listed Terrestrial Species ..................................... 2-58 9 Table 2-5. Pennsylvania-listed Bird Species in the Action Area ........................................ 2-63 10 Table 2-6. Limerick Generating Station, Employee Residence by County ........................ 2-66 11 Table 2-7. Housing in Berks, Chester, and Montgomery Counties in 2010 ....................... 2-66 12 13 Table 2-8. Public Water Supply Systems in Berks, Chester, and Montgomery Counties (in million gallons per day [mgd]) ...................................................... 2-68 14 15 Table 2-9. Major Commuting Routes in the Vicinity of LGS, 2010 Average Annual Daily Traffic Count ........................................................................................... 2-69 16 17 Table 2-10. Population and Percent Growth in Berks, Chester, and Montgomery Counties from 1970 to 2000 and Projected for 2010-2050............................... 2-71 18 19 Table 2-11. Demographic Profile of the Population in the Limerick Generating Station Socioeconomic Region of Influence in 2010 .................................................... 2-72 20 21 Table 2-12. Seasonal Housing in Counties Located within 50 Miles (80 Km) of the Limerick Generating Station(a).......................................................................... 2-73 22 23 Table 2-13. Migrant Farm Workers and Temporary Farm Labor in Counties Located within 50 Miles (80 Km) of Limerick Generating Station ................................... 2-75 24 Table 2-14. Major Employers by Industry in the LGS ROI in 2010 ...................................... 2-76 25 Table 2-15. Largest Private Sector Employers - Montgomery County - 2007 .................... 2-77 26 27 Table 2-16. Estimated Income Information for the Limerick Generating Station Region of Influence in 2010 ......................................................................................... 2-77 28 Table 2-17. Limerick Generation Station Tax Distribution, 2006-2010 ............................... 2-79 29 Table 2-18. Payment as a Percentage of Taxing Authority 2010 Adopted Budget .............. 2-80 30 Table 3-1. Category 1 Issues Related to Refurbishment .................................................... 3-1 31 Table 3-2. Category 2 Issues Related to Refurbishment .................................................... 3-2 32 Table 4-1. Land Use Issues................................................................................................ 4-1 33 Table 4-2. Air Quality Issues .............................................................................................. 4-2 34 Table 4-3. Surface Water Resources Issues ...................................................................... 4-3 35 Table 4-4. Groundwater Resources Issues ........................................................................ 4-5 36 Table 4-5. Aquatic Resources Issues ................................................................................. 4-7 xiii Table of Contents 1 Table 4-6. Terrestrial Resources Issues ............................................................................. 4-8 2 Table 4-7. Protected Species and Habitats Issues ........................................................... 4-10 3 Table 4-8. Human Health Issues ...................................................................................... 4-21 4 Table 4-9. Socioeconomics Issues ................................................................................... 4-28 5 Table 4-10. Summary of Cumulative Impacts on Resource Areas ..................................... 4-53 6 Table 5-1. Issues Related to Postulated Accidents............................................................. 5-1 7 Table 6-1. Issues Related to the Uranium Fuel Cycle and Waste Management ................. 6-1 8 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal ................................... 6-6 9 Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas........................ 6-7 10 11 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources ............................................................................................................. 6-8 12 Table 7-1. Issues Related to Decommissioning .................................................................. 7-1 13 Table 8-1. Summary of Alternatives Considered In Depth .................................................. 8-5 14 15 Table 8-2. Summary of Environmental Impacts of the NGCC Alternative Compared to Continued Operation of the Existing LGS ........................................................ 8-16 16 17 Table 8-3. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative Compared to Continued Operation of LGS .................................... 8-28 18 19 Table 8-4. Summary of Environmental Impacts of the New Nuclear Alternative Compared to Continued Operation of the Existing LGS ................................... 8-37 20 21 Table 8-5. Summary of Environmental Impacts of the Wind Alternative Compared to Continued Operation of the Existing LGS ........................................................ 8-46 22 23 Table 8-6. Summary of Environmental Impacts of Purchased Power Compared to Continued Operation of the Existing LGS ........................................................ 8-49 24 25 Table 8-7. Summary of Environmental Impacts of the Solar PV Alternative Compared to Continued Operation of the Existing LGS .................................................... 8-56 26 27 Table 8-8. Summary of Environmental Impacts of the Combination Alternative Compared to Continued Operation of the Existing LGS ................................... 8-65 28 29 Table 8-9. Summary of Environmental Impacts of the Wind and CAES Alternative Compared to Continued Operation of the Existing LGS ................................... 8-74 30 Table 8-10. Environmental Impacts of No-Action Alternative .............................................. 8-84 31 Table 8-11. Summary of Environmental Impacts of Proposed Action and Alternatives ....... 8-85 32 Table 10-1. List of Preparers .............................................................................................. 10-1 33 34 Table 11-1. List of Agencies, Organizations, and Persons to Whom Copies of this SEIS Are Sent ................................................................................................. 11-1 xiv EXECUTIVE SUMMARY 1 2 BACKGROUND 3 4 5 By letter dated June 22, 2011, Exelon Generation Company, LLC (Exelon) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to issue renewed operating licenses for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20-year period. 6 7 8 9 10 Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)), the renewal of a power reactor operating license requires preparation of an environmental impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that the NRC shall prepare an EIS, which is a supplement to the Commission's NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants. 11 12 13 14 Upon acceptance of Exelon's application, the NRC staff began the environmental review process described in 10 CFR Part 51 by publishing a Notice of Intent to prepare a supplemental EIS (SEIS) and conduct scoping. In preparation of this SEIS for LGS, the NRC staff performed the following: 15 16 o conducted public scoping meetings on September 22, 2011, in Pottstown, Pennsylvania, 17 o conducted a site audit at the plant on November 7-10, 2011, 18 o reviewed Exelon's environmental report (ER) and compared it to the GEIS, 19 o consulted with other agencies, 20 21 22 o conducted a review of the issues following the guidance set forth in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal, and 23 o considered public comments received during the scoping process. 24 PROPOSED ACTION 25 26 27 28 29 Exelon initiated the proposed Federal action--issuing renewed power reactor operating licenses--by submitting an application for license renewal of LGS, for which the existing licenses (NPF-39 and NPF-85) will expire on October 26, 2024, and June 22, 2029, respectively. The NRC's Federal action is the decision whether or not to renew the license for an additional 20 years. 30 PURPOSE AND NEED FOR ACTION 31 32 33 34 35 36 37 38 The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that allows for power generation capability beyond the term of the current nuclear power plant operating license to meet future system generating needs. Such needs may be determined by other energy-planning decisionmakers, such as state, utility, and, where authorized, Federal (other than NRC). This definition of purpose and need reflects the NRC's recognition that, unless there are findings in the safety review required by the Atomic Energy Act or findings in the National Environmental Policy Act (NEPA) environmental analysis that would lead the NRC to reject a license renewal application, the NRC does not have a role in the xv Executive Summary 1 2 energy planning decisions of whether a particular nuclear power plant should continue to operate. 3 4 5 6 7 If the renewed licenses are issued, the appropriate energy-planning decisionmakers, along with Exelon, will ultimately decide if the plant will continue to operate based on factors such as the need for power. If the operating licenses are not renewed, then the facility must be shut down on or before the expiration dates of the current operating licenses, October 26, 2024, and June 22, 2029. 8 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 9 10 11 12 The SEIS evaluates the potential environmental impacts of the proposed action. The environmental impacts from the proposed action are designated as SMALL, MODERATE, or LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following criteria: 13 14 15 16 17 o The environmental impacts associated with the issue is determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other specified plant or site characteristics. 18 19 20 21 22 o A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts, except for collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal. 23 24 25 26 27 o Mitigation of adverse impacts associated with the issue is considered in the analysis, and it has been determined that additional plant-specific mitigation measures are likely not to be sufficiently beneficial to warrant implementation. SMALL: Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource. LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource. 28 29 30 31 32 33 For Category 1 issues, no additional site-specific analysis is required in this draft SEIS unless new and significant information is identified. Chapter 4 of this report presents the process for identifying new and significant information. Site-specific issues (Category 2) are those that do not meet one or more of the criteria for Category 1 issues; therefore, an additional site-specific review for these non-generic issues is required, and the results are documented in the SEIS. 34 35 36 37 38 39 40 41 42 43 44 Recently, the NRC approved a revision to its environmental protection regulation, 10 CFR Part 51, which governs environmental impact reviews of nuclear power plant operating license renewals. The NRC, through its rulemaking process, has completed an update and re-evaluation of the potential environmental impacts associated with the renewal of an operating license for a nuclear power reactor for an additional 20 years. A revised GEIS, which updates the 1996 GEIS, provides the technical basis for the revised rule. The revised GEIS specifically supports the revised list of NEPA issues and associated environmental impact findings for license renewal contained in Table B-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The revised rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues. xvi Executive Summary 1 2 3 4 5 6 7 8 The revised rule is expected to be published in 2013; it will become effective 30 days after publication in the Federal Register. Compliance by license renewal applicants will not be required until 1 year from the date of publication (i.e., license renewal environmental reports submitted later than 1 year after publication must be compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal SEISs, the potential significant impacts described by the revised rule's new Category 2 issues, and to the extent there is any new and significant information, the potential significant impacts described by the revised rule's new Category 1 issues. 9 10 11 12 13 14 15 16 17 18 The NRC staff has reviewed Exelon's established process for identifying and evaluating the significance of any new and significant information on the environmental impacts of license renewal of LGS. Neither Exelon nor the NRC identified information that is both new and significant related to Category 1 issues that would call into question the conclusions in the GEIS. This conclusion is supported by NRC's review of the applicant's ER, other documentation relevant to the applicant's activities, the public scoping process and substantive comments raised, and the findings from the environmental site audit that the NRC staff conducted. Further, the NRC staff did not identify any new issues applicable to LGS that have a significant environmental impact. The NRC staff, therefore, relies upon the conclusions of the GEIS for all Category 1 issues applicable to LGS. 19 20 21 22 Table ES-1 summarizes the Category 2 issues applicable to LGS, if any, as well as the NRC staff's findings related to those issues. If the NRC staff determined that there were no Category 2 issues applicable for a particular resource area, the findings of the GEIS, as documented in Appendix B to Subpart A of 10 CFR Part 51, stand. xvii Executive Summary 1 2 Table ES-1. Summary of NRC Conclusions Relating to Site-Specific Impacts of License Renewal Resource Area Relevant Category 2 Issues Impacts Land Use Not applicable SMALL Air Quality Not applicable SMALL Surface Water Resources Water use conflicts SMALL Groundwater Resources Groundwater use conflicts Radionuclides released to groundwater SMALL SMALL Aquatic Resources Not applicable SMALL Terrestrial Resources Not applicable SMALL Protected Species Threatened or endangered species SMALL Human Health Electromagnetic fields--acute effects (electric shock) Microbiological organisms (public health) SMALL Socioeconomics Housing impacts Public services (public utilities) Offsite land use Public services (public transportation) Historic and archaeological resources SMALL Aquatic resources SMALL to MODERATE Terrestrial resources MODERATE All other resource areas SMALL Cummulative Impacts 3 4 5 6 7 8 With respect to environmental justice, the NRC staff has determined that there would be no disproportionately high and adverse impacts to these populations from the continued operation of Exelon during the license renewal period. Additionally, the NRC staff has determined that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations in the region as a result of subsistence consumption of water, local food, fish, and wildlife. 9 SEVERE ACCIDENT MITIGATION ALTERNATIVES 10 11 12 13 14 15 16 17 18 19 20 The NRC staff previously considered Severe Accident Mitigation Alternatives (SAMAs) for the applicant's plant in the Final Environmental Statement Related to Operation of Limerick Generating Station, Units 1 and 2, in NUREG-0974, Supplement 1. The analysis was based on the licensee's analysis in the updated probabilistic risk assessment. Because the NRC staff previously considered SAMAs for LGS, NRC regulations do not require the NRC staff to reconsider SAMAs for this license renewal proceeding. Nonetheless, the NRC must consider whether new and significant information impacts this determination in the NRC regulations, as it must for all environmental issues the NRC addresses through a generic determination in its regulations. The NRC staff has not identified any new and significant information regarding the determination in the regulations to not reconsider SAMAs for facilities that have already considered them once. xviii Executive Summary 1 ALTERNATIVES 2 3 4 5 The NRC staff considered the environmental impacts associated with alternatives to license renewal. These alternatives include other methods of power generation and not renewing the LGS operating license (the no action alternative). Replacement power options considered were as follows: 6 7 8 9 10 o o o o o natural-gas-fired combined-cycle (NGCC), supercritical pulverized coal (SCPC), new nuclear, wind power, and purchased power. 11 12 13 14 15 The NRC staff initially considered a number of additional alternatives for analysis as alternatives to license renewal of LGS; these were later dismissed because of technical, resource availability, or commercial limitations that currently exist and that the NRC staff believes are likely to continue to exist when the existing LGS license expires. The no action alternative by the NRC staff, and the effects it would have, were also considered. 16 17 18 Where possible, the NRC staff evaluated potential environmental impacts for these alternatives located both at the LGS site and at some other unspecified alternate location. Alternatives considered, but dismissed were as follows: 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 o o o o o o o o o o o o o o solar power, combination alternative of wind, solar, and NGCC, combination alternative of wind and compressed-air energy storage (CAES), wood waste, conventional hydroelectric power, ocean wave and current energy, geothermal power, municipal solid waste (MSW), biofuels, oiled-fired power, delayed retirement, fuel cells, coal-fired integrated gasification combined-cycle (IGCC), and demand-side management (DSM). The NRC staff evaluated each alternative using the same impact areas that were used in evaluating impacts from license renewal. xix Executive Summary 1 RECOMMENDATION 2 3 4 The NRC's preliminary recommendation is that the adverse environmental impacts of license renewal for LGS are not great enough to deny the option of license renewal for energy-planning decisionmakers. This recommendation is based on the following: 5 6 7 8 9 o o o o o analysis and findings in the GEIS, ER submitted by Exelon, consultation with Federal, state, and local agencies, NRC staff's own independent review, and consideration of public comments received during the scoping process. xx ABBREVIATIONS AND ACRONYMS 1 2 ?C degree(s) Celsius 3 ?F degree(s) Fahrenheit 4 AADT average annual daily traffic 5 ac acre(s) 6 AC alternating current 7 ACHP Advisory Council on Historic Preservation 8 ADAMS Agencywide Documents Access and Management System 9 AEA Atomic Energy Act of 1954 [Also: UK Atomic Energy Authority] 10 AEC U.S. Atomic Energy Commission 11 AEPS alternative energy portfolio standard 12 ALARA as low as is reasonably achievable 13 ANSI American National Standards Institute 14 APE area of potential effect 15 AQCR air quality control region 16 ATWS anticipated transient without scram 17 BHP Bureau of Historic Preservation 18 BMP best management practice 19 BOL Bureau of Laboratories 20 BTU British thermal unit(s) 21 BTU/kWh British thermal unit(s) per kilowatt-hour 22 BTU/lb British thermal unit(s) per pound 23 BWR boiling water reactor 24 CAA Clean Air Act, as amended through 1990 25 CAES compressed air energy storage 26 CCS carbon capture and storage 27 CDF core damage frequency 28 Ceq/kWh carbon equivalent per kilowatt-hour 29 CEQ Council on Environmental Quality 30 CFR Code of Federal Regulations 31 cfs cubic feet per second 32 cm centimeter(s) 33 cm/s centimeter(s) per second 34 CO carbon monoxide xxi Abbreviations and Acronyms 1 CO2 carbon dioxide 2 CPI Containment Performance Improvement 3 CRGIS Cultural Resources Geographic Information System 4 CS candidate species 5 CSAPR Cross-State Air Pollution Rule 6 CSP concentrated solar power 7 CT combustion turbine 8 CWA Clean Water Act of 1972 9 dB decibels 10 dBA decibels adjusted 11 DBA design basis accident 12 DC direct current 13 DMR Discharge Monitoring Report 14 DOE U.S. Department of Energy 15 DRBC Delaware River Basin Commission 16 DSEIS draft supplemental environmental impact statement 17 DSM demand-side management 18 DVRPC Delaware Valley Regional Planning Commission 19 DWS drinking water standard 20 EO Executive Order 21 EFH Essential Fish Habitat 22 EIA Energy Information Administration (of DOE) 23 EIS environmental impact statement 24 ELF EMF extremely low-frequency electromagnetic field 25 EMS environmental management system 26 EPA U.S. Environmental Protection Agency 27 EPCRA Emergency Planning and Community Right-to-Know Act of 1986 28 EPRI Electric Power Research Institute 29 EPT Ephemeroptera, Plecoptera, and Trichoptera 30 ER Environmental Report 31 ESA Endangered Species Act of 1973, as amended 32 Exelon Exelon Generation Company, LLC 33 FE Federally endangered 34 FENOC First Energy Nuclear Operating Company 35 FES final environmental statement xxii Abbreviations and Acronyms 1 fps feet per second 2 FR Federal Register 3 FSAR final safety analysis report 4 FT threatened 5 ft foot (feet) 3 6 ft 7 FW feedwater 8 FWCA Fish and Wildlife Coordination Act 9 FWS U.S. Fish and Wildlife Service 10 g gram(s) 11 gal gallon(s) 12 GE General Electric 13 14 GEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437 15 GHG greenhouse gas 16 GIC Green-is-Clean 17 gpd gallons per day 18 gpm gallons per minute 19 GW groundwater 20 ha hectare(s) 21 Hg mercury 22 HLSA high-level storage area 23 Hz hertz 24 IAEA International Atomic Energy Agency 25 IEEE Institute of Electrical and Electronics Engineers, Inc. 26 IGCC integrated gasification combined-cycle 27 in. inch(es) 28 IPE Individual Plant Examination 29 IPEEE Individual Plant Examination of External Events 30 ISFSI Independent Spent Fuel Storage Installation 31 ISO International Organization for Standardization 32 kg kilogram(s) 33 km 34 km 35 kV cubic foot (feet) kilometer(s) 2 square kilometer(s) kilovolt(s) xxiii Abbreviations and Acronyms 1 kW kilowatt(s) 2 kWh kilowatt-hour(s) 3 L/min liter(s) per minute 4 lb pound(s) 5 LEFM Leading Edge Flow Meter 6 LGS Limerick Generating Station, Units 1 and 2 7 LLMW low-level mixed waste 8 LLRW low-level radioactive waste 9 m meter(s) 10 m/s meter(s) per second m 2 square meter(s) 12 m 3 cubic meter(s) 13 m3/s cubic meters per second 14 mA milliampere(s) 15 MACCS2 MELCOR Accident Consequence Code System 2 16 MAIS macroinvertebrate aggregated index for streams 17 MassDEP Massachusetts Department of Environmental Protection 18 MATS Mercury and Air Toxics Standards 19 MBTA Migratory Bird Treaty Act of 1918 20 MCPC Montgomery County Planning Commission 21 MDPH Massachusetts Department of Public Health 22 MF migratory fishes 23 mg/L milligrams per liter 24 mgd million gallons per day 25 mGy million gallons per year 26 mi mile(s) 11 2 27 mi square mile(s) 28 min minute(s) 29 mm millimeter(s) 30 MMI Modified Mercalli Intensity 31 MMPA Marine Mammal Protection Act of 1972 32 mph mile(s) per hour 33 mrad milliradiation absorbed dose 34 mrem milliroentgen equivalent man xxiv Abbreviations and Acronyms 1 2 MSA Magnuson-Stevens Fishery Conservation and Management Act, as amended through 2006 3 MSL mean sea level 4 mSv millisievert 5 MSW municipal solid waste 6 MUR measurement uncertainty recapture 7 MT metric ton(s) 8 MW megawatt(s) 9 MWd megawatt-day(s) 10 MWd/MTU megawatt-day(s) per metric ton of uranium 11 MWe megawatt(s) electrical 12 MWt megawatt(s) thermal 13 NA not applicable 14 NAAQS National Ambient Air Quality Standards 15 NASS National Agricultural Statistics Service 16 NAS National Academy of Sciences 17 NEPA National Environmental Policy Act of 1969 18 NERC North American Electric Reliability Corporation 19 NESC National Electrical Safety Code 20 NETL National Energy Technology Laboratory 21 NGCC natural-gas-fired combined-cycle 22 NHPA National Historic Preservation Act of 1966, as amended 23 NIEHS National Institute of Environmental Health Sciences 24 NMFS National Marine Fisheries Service (of NOAA) 25 NOAA National Oceanic and Atmospheric Administration 26 NOx nitrogen oxide(s) 27 NPDES National Pollutant Discharge Elimination System 28 NPS National Park Service 29 NRC U.S. Nuclear Regulatory Commission 30 NRCS National Resources Conservation Service 31 NRHP National Register of Historic Places 32 NRR Office of Nuclear Reactor Regulation 33 34 NUREG NRC technical report designation (Nuclear Regulatory Commission) 35 NWS National Weather Service xxv Abbreviations and Acronyms 1 O3 ozone 2 OCA Owner-Controlled Area 3 ODCM Offsite Dose Calculation Manual 4 PADEP Pennsylvania Department of Environmental Protection 5 PAH polycyclic aromatic hydrocarbon 6 Pb lead 7 PBAPS Peach Bottom Atomic Power Station 8 PCBs polychlorinated biphenyl 9 pCi/L picocuries per liter 10 PDCNR Pennsylvania Department of Conservation and Natural Resources 11 PE Pennsylvania endangered 12 13 14 15 16 PECO PECO Energy Company, the energy delivery subsidiary of Exelon Corporation serving retail customers in southeastern Pennsylvania (also used in this report as an acronym for Philadelphia Electric Company or PECO Energy Company, predecessors of Exelon Generation) 17 PFBC Pennsylvania Fish and Boating Commission 18 PGA peak ground acceleration 19 PGC Pennsylvania Game Commission 20 PJM PJM Interconnection, LLC 21 PM particulate matter 22 PM10 particulate matter >2.5 microns and <=10 microns in diameter 23 PM2.5 particulate matter <=2.5 microns in diameter 24 PNDI Pennsylvania Natural Diversity Inventory 25 PNHP Pennsylvania Natural Heritage Program 26 PNNL Pacific Northwest National Laboratory 27 POST Parliamentary Office of Science and Technology 28 PPC Preparedness, Prevention, and Contingency 29 PR rare 30 PSD Prevention of Significant Deterioration 31 psia pounds per square inch absolute 32 PV photovoltaic 33 PWR pressurized water reactor 34 RCA radiological control area 35 RCRA Resource Conservation and Recovery Act of 1976, as amended 36 REMP radiological environmental monitoring program xxvi Abbreviations and Acronyms 1 REOP Radiological Environmental Operation 2 RERS reactor enclosure recirculation system 3 RGPP Radiological Groundwater Protection Program 4 RKm river kilometer 5 RM river mile 6 RMC RMC-Environmental Services 7 ROI region of influence 8 ROW(s) right(s)-of-way 9 RPS renewable portfolio standard 10 RSP radwaste storage pad 11 RWCU reactor water cleanup 12 SAMA Severe Accident Mitigation Alternative 13 SAMDA Severe Accident Mitigation Design Alternative 14 SAMGs Severe Accident Mitigation Guidelines 15 SAR safety analysis report 16 SCR selective catalytic reduction 17 SCPC supercritical pulverized coal 18 SE state endangered 19 SEIS supplemental environmental impact statement 20 SER safety evaluation report 21 SGTS standby gas treatment system 22 SHPO State Historic Preservation Officer 23 SIP State Implementation Plan 24 SO2 sulfur dioxide 25 SOx sulfur oxide(s) 26 SPCC Spill Prevention Control and Countermeasure 27 SR State rare 28 SSCs structures, systems, and components 29 SSC species of special concern 30 SSE safe-shutdown earthquake 31 ST state threatened 32 STG steam turbine generator 33 State Commonwealth of Pennsylvania (or other state if specified) 34 Stroud Stroud Water Research Center 35 Sv sievert xxvii Abbreviations and Acronyms 1 SW surface water 2 SWPPP Stormwater Pollution Prevention Plan 3 TLD thermoluminescent dosimeters 4 TMDL total maximum daily upload 5 TMI Three Mile Island 6 tpy ton(s) per year 7 TSF stocked trout 8 TSP total suspended particles 9 TWh terawatt-hour(s) 10 U uranium 11 U.S. United States 12 U.S.C. United States Code 13 UFSAR updated final safety analysis report 14 USACE U.S. Army Corps of Engineers 15 USCB U.S. Census Bureau 16 USDA U.S. Department of Agriculture 17 USGCRP United States Global Change Research Program [or GCRP] 18 USGS U.S. Geological Survey 19 VOC volatile organic compound 20 WEC wave energy conversion 21 WHC Wildlife Habitat Council 22 WWF warm water fishes xxviii 1 1.0 PURPOSE AND NEED FOR ACTION 2 3 4 5 Under the U.S. Nuclear Regulatory Commission's (NRC's) environmental protection regulations in Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51)--which carry out the National Environmental Policy Act (NEPA)--renewal of a new nuclear power plant operating license requires the preparation of an environmental impact statement (EIS). 6 7 8 The Atomic Energy Act of 1954 (AEA) originally specified that licenses for commercial power reactors be granted for up to 40 years. The 40-year licensing period was based on economic and antitrust considerations rather than on technical limitations of the nuclear facility. 9 10 11 12 13 14 The decision to seek a license renewal rests entirely with nuclear power facility owners and, typically, is based on the facility's economic viability and the investment necessary to continue to meet NRC safety and environmental requirements. The NRC makes the decision to grant or deny license renewal based on whether the applicant has demonstrated that the environmental and safety requirements in the agency's regulations can be met during the period of extended operation. 15 1.1. Proposed Federal Action 16 17 18 19 Exelon Generation Company, LLC (Exelon) initialized the proposed Federal action by submitting an application for license renewal of Limerick Generating Station, Units 1 and 2 (LGS), for which the existing licenses (NPF-39 and NPF-85) expire on October 26, 2024, and June 22, 2029. The NRC's Federal action is to decide whether to renew the license for an additional 20 years. 20 1.2. Purpose and Need for the Proposed Federal Action 21 22 23 24 25 26 27 28 29 The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by other energy-planning decisionmakers. This definition of purpose and need reflects the Commission's recognition that, unless there are findings in the safety review required by the Atomic Energy Act or findings in the NEPA environmental analysis that would lead the NRC to reject a license renewal application, the NRC does not have a role in the energy-planning decisions of state regulators and utility officials as to whether a particular nuclear power plant should continue to operate. 30 31 32 33 34 If the renewed license is issued, state regulatory agencies and Exelon will ultimately decide whether the plant will continue to operate based on factors such as the need for power or other matters within the state's jurisdiction or the purview of the owners. If the operating license is not renewed, then the facility must be shut down on or before the expiration date of the current operating licenses--October 26, 2024, and June 22, 2029. 1-1 Purpose and Need for Action 1 Figure 1-1. Environmental Review Process Company submits an application to the NRC NRC staff reviews application *Scoping Process Staff conducts environmental site audit The NRC issues draft SEIS *Draft SEIS Process * Opportunity for Public Involvement The NRC issues final SEIS NRC decision on whether to renew license 2 1.3. Major Environmental Review Milestones 3 4 5 6 7 8 Exelon submitted an Environmental Report (ER) (Exelon 2011b) as part of its license renewal application (Exelon 2011a) on June 22, 2011. After reviewing the application and ER for sufficiency, the staff published a Federal Register Notice of Acceptability and Opportunity for Hearing (76 FR 52992) on August 24, 2011. Then, on August 26, 2011, the NRC published another notice in the Federal Register (76 FR 53498) on the intent to conduct scoping, thereby beginning the 60-day scoping period. 1-2 Purpose and Need for Action 1 2 3 4 5 6 7 8 Two public scoping meetings were held on September 22, 2011, in Pottstown, Pennsylvania (NRC 2011). The comments received during the scoping process are presented in "Environmental Impact Statement, Scoping Process, Summary Report," published in February 2013 (NRC 2013). The scoping process summary report presents NRC responses to comments that the NRC staff considered to be out-of-scope of the environmental license renewal review. The comments considered to be within the scope of the environmental license renewal review and the NRC responses are presented in Appendix A of this supplemental environmental impact statement (SEIS). 9 10 11 12 13 14 To independently verify information provided in the ER, NRC staff conducted a site audit at LGS in November 2011. During the site audit, NRC staff met with plant personnel, reviewed specific documentation, toured the facility, and met with interested Federal, state, and local agencies. A summary of that site audit and the attendees is contained in "Summary of Site Audit in Support to the Environmental Review of the License Renewal Application for Limerick Generating Station, Units 1 and 2," published May 21, 2012 (NRC 2012a). 15 16 17 18 19 Upon completion of the scoping period and site audit, NRC staff compiled its findings in a draft SEIS (Figure 1-1). This document is made available for public comment for 75 days. During this time, NRC staff will host public meetings and collect public comments. Based on the information gathered, the NRC staff will amend the draft SEIS findings, as necessary, and publish the final SEIS. 20 21 22 23 24 25 The NRC has established a license renewal process that can be completed in a reasonable period of time with clear requirements to ensure safe plant operation for up to an additional 20 years of plant life. The safety review, which documents its finding in a safety evaluation report, is conducted simultaneously with the environmental review. The findings in both the SEIS and the safety evaluation report are factors in the Commission's decision to either grant or deny the issuance of a renewed license. 26 1.4. Generic Environmental Impact Statement 27 28 29 30 31 32 33 The NRC performed a generic assessment of the environmental impacts associated with license renewal to improve the efficiency of the license renewal process. The Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437 (GEIS) documented the results of the NRC staff's systematic approach to evaluate the environmental consequences of renewing the licenses of individual nuclear power plants and operating them for an additional 20 years. NRC staff analyzed in detail and resolved those environmental issues that could be resolved generically in the GEIS. 34 35 36 37 38 The GEIS establishes 92 separate issues for NRC staff to independently verify. Of these issues, NRC staff determined that 69 are generic to all plants (Category 1) while 21 issues do not lend themselves to generic consideration (Category 2). Two other issues remained uncategorized; environmental justice and chronic effects of electromagnetic fields, and must be evaluated on a site-specific basis. A list of all 92 issues can be found in Appendix B. 39 For each potential environmental issue, the GEIS: 40 (1) describes the activity that affects the environment, 41 (2) identifies the population or resource that is affected, 42 43 (3) assesses the nature and magnitude of the impact on the affected population or resource, 1-3 Purpose and Need for Action 1 2 (4) characterizes the significance of the effect for both beneficial and adverse effects, 3 (5) determines if the results of the analysis apply to all plants, and 4 5 (6) considers whether additional mitigation measures would be warranted for impacts that would have the same significance level for all plants. 6 7 8 The NRC's standard of significance for impacts was established using the Council on Environmental Quality (CEQ) terminology for "significant." The NRC established three levels of significance for potential impacts: SMALL, MODERATE, and LARGE, as defined below. 9 10 11 12 SMALL: Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. Significance indicates the importance of likely environmental impacts and is determined by considering two variables: context and intensity. 13 14 15 MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource. Context is the geographic, biophysical, and social context in which the effects will occur. 16 17 18 LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource. Intensity refers to the severity of the impact, in whatever context it occurs. 19 20 21 22 The GEIS includes a determination of whether the analysis of the environmental issue could be applied to all plants and whether additional mitigation measures would be warranted (Figure 1- 2). Issues are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet the following criteria: 23 24 25 (1) The environmental impacts associated with the issue have been determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other specified plant or site characteristics. 26 27 28 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts (except for collective off-site radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal). 29 30 31 32 (3) Mitigation of adverse impacts associated with the issue has been considered in the analysis, and it has been determined that additional plant-specific mitigation measures are likely not to be sufficiently beneficial to warrant implementation. 33 34 35 36 37 38 For generic issues (Category 1), no additional site-specific analysis is required in this SEIS unless new and significant information is identified. The process for identifying new and significant information is presented in Chapter 4. Site-specific issues (Category 2) are those that do not meet one or more of the criteria of Category 1 issues, and therefore, additional site-specific review for these issues is required. The results of that site-specific review are documented in the SEIS. 1-4 Purpose and Need for Action 1 Figure 1-2. Environmental Issues Evaluated during License Renewal 2 3 The NRC staff initially evaluated 92 issues in the GEIS. Based on the findings of the GEIS, a site-specific analysis is required for 23 of those 92 issues. 4 5 6 7 8 9 10 11 12 13 14 15 16 On December 6, 2012, the Commission affirmed a decision to publish in the Federal Register an amendment that would revise its environmental protection regulation, 10 CFR Part 51, which governs environmental impact reviews of nuclear power plant operating license renewals (NRC 2012b). Specifically, the revised rule will update and reevaluate the potential environmental impacts associated with the renewal of an operating license for a nuclear power reactor for an additional 20 years. A revised GEIS, which updates the 1996 GEIS, provides the technical basis for the revised rule. The revised GEIS specifically supports the revised list of NEPA issues and associated environmental impact findings for license renewal contained in Table B-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and rule reflect lessons learned and knowledge gained during previous license renewal environmental reviews. In addition, public comments received on the draft revised GEIS and rule and during previous license renewal environmental reviews were reexamined to validate existing environmental issues and identify new ones. 17 18 19 20 The revised rule identifies 78 environmental impact issues, of which, 17 will require plant-specific analysis. The revised rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues. The new 1-5 Purpose and Need for Action 1 2 3 4 5 Category 1 issues include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human health impact from chemicals, and physical occupational hazards. Radionuclides released to groundwater, effects on terrestrial resources (non-cooling system impacts), minority and low-income populations (i.e., environmental justice), and cumulative impacts were added as new Category 2 issues. 6 7 8 9 10 11 12 13 The revised rule is expected to be published in 2013, and it will become effective 30 days after publication in the Federal Register. Compliance by license renewal applicants will not be required until 1 year from the date of publication (i.e., license renewal environmental reports submitted later than 1 year after publication must be compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal SEISs, the potential significant impacts described by the revised rule's new Category 2 issues and, to the extent there is any new and significant information, the potential significant impacts described by the revised rule's new Category 1 issues. 14 1.5. Supplemental Environmental Impact Statement 15 16 17 18 19 20 21 The SEIS presents an analysis that considers the environmental effects of the continued operation of LGS, alternatives to license renewal, and mitigation measures for minimizing adverse environmental impacts. Chapter 8 contains analysis and comparison of the potential environmental impacts from alternatives while Chapter 9 presents the staff's preliminary recommendation to the Commission on whether or not the environmental impacts of license renewal are so great that preserving the option of license renewal would be unreasonable. The recommendation includes consideration of comments received during the public scoping period. 22 In the preparation of this SEIS for LGS, the staff: 23 24 25 26 ? ? ? ? reviewed the information provided in Exelon's ER, consulted with other Federal, state, and local agencies, conducted an independent review of the issues during a site audit, and considered the public comments received during the scoping process. 27 28 29 30 31 32 33 34 New information can be identified from a number of sources, including the applicant, the NRC, other agencies, or public comments. If a new issue is revealed, then it is first analyzed to determine if it is within the scope of the license renewal evaluation. If it is not addressed in the GEIS, then the NRC determines its significance and documents its analysis in the SEIS. 35 1.6. Cooperating Agencies 36 37 During the scoping process, no Federal, state, or local agencies were identified as cooperating agencies in the preparation of this SEIS. 38 1.7. Consultations 39 40 41 42 The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 require that Federal agencies consult with applicable state and Federal agencies and groups prior to taking action that may affect endangered species, fisheries, or historic and 1-6 New and significant information either: (1) identifies a significant environmental issue not covered in the GEIS, or (2) was not considered in the analysis in the GEIS and leads to an impact finding that is different from the finding presented in the GEIS. Purpose and Need for Action 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 archaeological resources, respectively. Below are the agencies and groups with whom the NRC consulted; Appendix D to this report includes copies of consultation documents. ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? Advisory Council on Historic Preservation National Marine Fisheries Service U.S. Environmental Protection Agency, Region 3 U.S. Fish and Wildlife Service, State College, Pennsylvania Absentee-Shawnee Tribe of Oklahoma Cayuga Nation Delaware Nation Delaware Tribe Eastern Shawnee Tribe of Oklahoma Oneida Indian Nation Oneida Nation of Wisconsin Onondaga Nation Seneca Nation of Indians Seneca-Cayuga Tribe of Oklahoma St. Regis Mohawk Tribe Shawnee Tribe Stockbridge-Munsee Band of the Mohican Nation of Wisconsin Tonawanda Seneca Nation Tuscarora Nation 22 1.8. Correspondence 23 24 During the course of the environmental review, the NRC staff contacted the Federal, state, regional, local, and tribal agencies listed in Section 1.7, as well as the following: 25 26 27 28 ? ? ? ? Pennsylvania Fish & Boat Commission Pennsylvania Game Commission Pennsylvania Historical and Museum Commission Pennsylvania Department of Conservation and Natural Resources 29 30 Appendix E contains a chronological list of all the documents sent and received during the environmental review. 31 A list of persons who received a copy of this SEIS is provided in Chapter 11. 32 1.9. Status of Compliance 33 34 35 36 Exelon is responsible for complying with all NRC regulations and other applicable Federal, state, and local requirements. A description of some of the major Federal statutes can be found in Appendix H of the GEIS. Appendix C to this SEIS includes a list of the permits and licenses issued by Federal, state, and local authorities for activities at LGS. 37 1.10. References 38 39 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulator Activities." 40 41 42 76 FR 52992. U.S. Nuclear Regulatory Commission, Washington, DC, "Notice of Acceptance for Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20-Year Period, Exelon 1-7 Purpose and Need for Action 1 2 Generation Company, LLC, Limerick Generating Station." Federal Register 76(164):52992-52994, August 24, 2011. 3 4 5 6 76 FR 53498. U.S. Nuclear Regulatory Commission, Washington, DC, "Exelon Generation Company, LLC; Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping Process for Limerick Generating Station, Units 1 and 2." Federal Register 76(166):53498-53500, August 26, 2011. 7 Atomic Energy Act of 1954. 42 U.S.C. ?2011, et seq. 8 Endangered Species Act of 1973, as amended. 16 U.S.C. ?1531, et seq. 9 10 11 [Exelon] Exelon Generation Company, LLC, 2011a. Limerick Generating Station, Units 1 and 2--License Renewal Application. June 2011. Agencywide Documents Access and Management System (ADAMS) Accession No. ML11179A101. 12 13 14 [Exelon] Exelon Generation Company, LLC, 2011b. License Renewal Application, Limerick Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. ADAMS Accession No. ML11179A104. 15 16 Magnuson-Stevens Fishery Conservation and Management Act, as amended by the Sustainable Fisheries Act of 1996. 16 U.S.C 1855, et seq. 17 National Environmental Policy Act of 1969, as amended. 42 U.S.C. ?4321, et seq. 18 National Historic Preservation Act of 1966. 16 U.S.C. ?470, et seq. 19 20 21 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2. Washington, DC. May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 22 23 24 25 26 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report, "Section 6.3-Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final Report, NUREG-1437, Volume 1, Addendum 1. Washington DC. August 1999. ADAMS Accession No. ML04069720. 27 28 29 30 [NRC] U.S. Nuclear Regulatory Commission. 2011. "Summary of Public Scoping Meetings Conducted on September 22, 2011, Related to the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application." September 2011. ADAMS Accession No. ML04069720. 31 32 33 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Summary of Site Audit Related to the Environmental Review of the License Renewal Application for Limerick Generating Station, Units 1 and 2." May 21, 2012. ADAMS Accession No. ML12124A127. 34 35 36 37 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Staff Requirements, SECY-12-0063 - Final Rule: Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating Licenses (10 CFR Part 51; RIN 3150-AI42). December 6, 2012. ADAMS Accession No. ML12341A134. 38 39 [NRC] U.S. Nuclear Regulatory Commission. 2013. "Environmental Impact Statement, Scoping Process, Summary Report," March 2013. ADAMS Accession No. ML12131A499. 1-8 1 2.0 AFFECTED ENVIRONMENT 2 3 4 5 6 7 8 9 Limerick Generating Station, Units 1 and 2 (LGS) is located in Limerick Township of Montgomery County, Pennsylvania, 1.7 miles (2.7 kilometers [km]) southeast of the Borough of Pottstown. The City of Reading is about 19 miles (30.6 km) northwest of the site and the Borough of Phoenixville is about 9.3 miles (15 km) southeast of the site. Other nearby population centers are the Municipality of Norristown, about 11 miles (17.7 km) southeast of the site, and the City of Philadelphia, the city limits of which are about 21 miles (33.8 km) southeast from the site. Figure 2-1 and Figure 2-2 present the 6-mile (10-km) and 50-mile (80-km) vicinity maps, respectively. 10 11 12 13 14 15 For the purposes of the evaluation in this supplemental environmental impact statement (SEIS), the "affected environment" is the environment that currently exists at and around LGS. Because existing conditions are at least partially the result of past construction and operation at the plant, the impacts of these past and ongoing actions and how they have shaped the environment are presented here. Section 2.1 of this SEIS describes the facility and its operation, and Section 2.2 discusses the surrounding environment. 16 2.1. Facility Description 17 18 19 20 21 LGS is a two-unit nuclear-powered steam electric generating facility that began commercial operation in February 1986 (Unit 1) and January 1990 (Unit 2). The nuclear reactor for each unit is a General Electric Mark II boiling water reactor (BWR) producing a reactor core rated thermal power of 3,515 megawatts (MWt). The nominal net electrical capacity is 1,170 megawatts electric (MWe). Figure 2-3 provides a general site layout of LGS. 22 2.1.1. Reactor and Containment Systems 23 24 25 26 27 The nuclear reactor system for each Limerick unit includes a single-cycle, forced circulation, General Electric Mark II BWR. The reactor core heats water that is dried by steam separators and dryers located in the upper portion of the reactor vessel. The steam is then directed through four main steam lines to the main turbine where it turns the turbine generator to produce electricity. 28 29 30 Fuel enrichment and average peak rod burnup conditions are no more than 5 percent uranium-235 and 62,000 megawatt-days per metric ton of uranium (MWd/MTU), respectively. LGS operates on a 24-month refueling cycle. 31 32 33 34 35 36 37 The reactor and related systems are enclosed in primary and secondary containments. The primary containment surrounds the reactor vessel and also houses the reactor coolant recirculation pumps and piping loops. The secondary containment is the structure that encloses the reactor's primary containment and spent fuel storage pool areas. The primary containment is a steel-lined reinforced concrete pressure-suppression system of the over-and-under configuration. The secondary containment system is a reinforced concrete building and is designed to minimize the release of airborne radioactive materials under accident conditions. 38 2.1.2. Radioactive Waste Management 39 40 41 42 The radioactive waste systems collect, treat, and dispose of radioactive and potentially radioactive wastes that are byproducts of LGS operations. The byproducts are activation products associated with nuclear fission, reactor coolant activation, and noncoolant material activation. Release of liquid and gaseous effluents are controlled to meet the limits specified in 2-1 Purpose and Need for Action 1 2 3 4 5 6 7 8 9 10 11 Title 10, Code of Federal Regulations (CFR) Part 20 and 10 CFR Part 50, Appendix I, through the Radioactive Effluent Controls Program defined in the LGS technical specifications (Exelon 2011a). Operation procedures for the radioactive waste system ensure that radioactive wastes are safely processed and discharged from the LGS. The systems are designed and operated to ensure that the quantities of radioactive materials released from LGS are as low as is reasonably achievable (ALARA) and within the dose standards set forth in 10 CFR Part 20, "Standards for protection against radiation," and Appendix I to 10 CFR Part 50, "Domestic licensing of production and utilization facilities." The LGS Offsite Dose Calculation Manual (ODCM) contains the methods and parameters used to calculate offsite doses resulting from radioactive effluents. These methods are used to ensure that radioactive material discharges from the LGS meet regulatory dose standards. 12 13 14 Radioactive wastes resulting from LGS operations are classified as liquid, gaseous, and solid. The design and operation objectives of the radioactive waste management systems are to limit the release of radioactive effluents from LGS during normal operation and anticipated operation. 15 16 17 18 19 20 21 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to as spent fuel. Spent fuel assemblies that are removed from the reactor core are replaced with fresh fuel assemblies during routine refueling outages. Spent nuclear fuel from the reactor is stored on site in a spent fuel pool and an independent spent fuel storage installation (ISFSI) located west of the Turbine Buildings. Under 10 CFR Part 50, LGS has a general license to store spent fuel from both units in pre-approved dry storage casks in accordance with the requirements in 10 CFR Part 72, Subpart K (Exelon 2011b). 22 2.1.2.1. Radioactive Liquid Waste 23 24 25 26 27 28 29 30 The liquid waste-management system collects, segregates, stores, and disposes of radioactive liquid waste. The system is designed to reduce radioactive materials in liquid effluents to levels that are ALARA and reduce the volume of waste through recycling. Liquid wastes that accumulate in radwaste drain tanks or in sumps at locations throughout each LGS unit are transferred to collection tanks in the common radwaste enclosure based on the classification of waste: equipment drain, floor drain, chemical drain, or laundry drain waste. The liquid wastes are processed for packaging and offsite shipment, returned to the condensate system, or mixed with cooling-tower blowdown and released from the plant. 31 32 33 34 35 Wastes from the equipment drains and floor drains are processed through separate precoat filters and mixed resin bed demineralizers. The processed waste is collected in one of two sample tanks. Usually, the water from these tanks is sent to the condensate tank for reuse, but if necessary, it will be treated or discharged into the Schuylkill River with radionuclide concentrations below 10 CFR Part 20 limits. 36 37 Laboratory wastes, decontamination solutions, and other wastes that may be corrosive are collected and chemically neutralized before being sent to the floor drain system for processing. 38 39 Waste from decontamination laundry facilities is processed through the laundry filter and then collected in a sample tank. 40 41 42 43 44 The contamination in the liquid wastes is concentrated in filters and ion exchange resins and then sent to solid waste management for processing. The waste is stored and eventually shipped to a licensed waste disposal facility. The processed liquids are either recycled or discharged from the plant in the cooling-tower blowdown into the Schuylkill River with radionuclide concentrations below 10 CFR Part 20 limits. 2-2 Purpose and Need for Action Figure 2-1. Location of LGS, 6-mile (10-km) vicinity 1 * Limerick Generating Station - - Minor Roads Agricultural Land ~ Exelon Property Boundary Pennsylvania --+--+ Railroad . . Pasture Land [ ___}~ County Boundary CJ Waterbody . . Forest Land Major Roads Developed Land 0 2-3 Purpose and Need for Action Figure 2-2. Location of LGS, 50-mile (80-km) region 1 * limerick Generating Station c:J State Boundary Pennsylvania = Limited Access - - - Highway - Na1ional Park Service .. Mih1ary Reserve Conservation Area County Boundary State Park Urban Area C ) waterbody 0 5 10 Miles 2-4 20 Purpose and Need for Action Figure 2-3. LGS site boundary and facility layout 1 ~ . .?'-..'??,../ . --,.?,?.,_ / ./ , /' . Exclusion Area Boundary (2,500 fe~t ra~:Uus) '? ,, , .; , ,' ~ "><:;<:; ~ , , '..I I / : I .....__ '; -..... __ / ./ ./ .? ./ ./ (: ./ ?,_ -~ ! ?,_ ?, ?.,_. / 500 kV Transmission Line 230 kV Transmission Line LGS Security Barrier c=J Exclusion Area Boundary (EAB) 0 550 1. 100 2,200 D Plant Roads -+--+ Railroad i.:::-_-_-.J Exelon Property Boundary D [~~=] Security Fence 0 Limerick Nuclear Plant Waterbody 220 440 Meters Feet 2-5 , 880 ,, ,- Purpose and Need for Action 1 2.1.2.2. Radioactive Gaseous Waste 2 3 4 5 Gaseous waste management systems process and control the release of gaseous radioactive effluents to the atmosphere. Sources of radioactive gases from LGS include condenser offgases, sources from the reactor enclosure, containment systems, and the "hot" maintenance shop. 6 7 8 9 10 The condenser offgases are the largest source of radioactive gaseous waste. The offgas system collects the noncondensable radioactive gases that are removed by the air ejectors from the main condensers. The release of the offgas is delayed to allow for radioactive decay. The stream is released to the turbine enclosure vent stack and diluted with air and monitored upon release through the north stack. 11 12 13 Other sources of radioactive gases are from the reactor enclosures, the turbine enclosures, and radwaste buildings. Discharge of these gases are planned, monitored, controlled, and discharged through the south stack. 14 15 The standby gas treatment system (SGTS) and the reactor enclosure recirculation system (RERS) are used to reduce radioactive levels before being discharged into the environment. 16 2.1.2.3. Radioactive Solid Waste 17 18 19 20 21 The solid waste management system collects, processes, and packages solid radioactive wastes for storage and offsite shipment and permanent disposal. To ensure compliance with applicable regulations in 10 CFR Parts 20, 61, and 71, characterization, classification, processing, waste storage, handling, and transportation are controlled by the LGS Process Control Program. 22 23 24 Dry wastes (mostly Class A low-level radioactive wastes [LLRWs]) are collected throughout the plant. Compressible and noncompressible wastes are packaged and temporarily stored until they are sent to Duratech in Tennessee for processing or final disposal. 25 26 27 28 29 30 Wet wastes, generally Class A LLRWs, are collected, dewatered, packaged, and stored prior to offsite shipment. Wastes from the reactor water cleanup (RWCU) system floor drains, equipment drains, and fuel pool system usually exceed the criteria for LLRW or low specific activity material and are packaged in containers and stored in the high level storage area (HLSA), which is located in the Radwaste Enclosure. Exelon Generation Company, LLC (Exelon) transports Class A LLRWs to EnergySolutions, LLC, in Clive, Utah, for disposal. 31 32 33 34 35 36 LGS has a "Green-is-Clean" (GIC) waste program that collects noncontaminated waste from the radiological control area (RCA) from the different controls streams. This waste is packaged separately and shipped to Duratech in Tennessee for processing and disposal. Any waste sent to Duratech that is found to be contaminated is repackaged and sent to the offsite LLRW facility in Clive, Utah. Exelon's corporate policy is to minimize the generation of radioactive wastes by following corporate waste minimization procedures. 37 38 39 40 There is an onsite radwaste storage pad (RSP) for temporary storage of radioactive waste containers. The RSP is located west of the spray pond and has a fenced-in holding area and another area surrounded by a concrete shell. Contaminated reusable equipment is stored here as well as Class A wastes. Higher activity Class B/C wastes are not stored in this area. 41 42 43 44 45 Since closure of the Barnwell Facility to LGS in 2008, there has been no licensed facility that accepts Class B/C LLRW shipments. Exelon has been temporarily storing the Class B/C wastes in the HLSA. In May 2011, the NRC approved transport and temporary storage of LGS Class B/C wastes at Exelon's Peach Bottom Atomic Power Station (PBAPS). Class B/C LLRW stored at LGS or packaged in the future will be sent to PBAPS to be stored at the LLRW storage 2-6 Purpose and Need for Action 1 2 facility at that site. The storage capacity for LGS Class B/C wastes at PBAPS is expected to be sufficient through the extended operating license for both LGS units. 3 2.1.2.4. Low-Level Mixed Wastes 4 5 6 7 8 9 10 11 12 Low-level mixed wastes (LLMW) are wastes that contain both low-level radioactive waste and RCRA hazardous waste (40 CFR 266.210). LLMW is handled in accordance with Exelon guidance and procedures. There is currently no LLMW stored at LGS. It is rare that LGS generates LLMW; however, if it were necessary to treat and dispose of LLMW during the license renewal period, Exelon would store it on site, in compliance with the 1976 Resource Conservation and Recovery Act (RCRA) storage and treatment conditional exemption. RCRA regulations are administered in the State by the Pennsylvania Department of Environmental Protection (PADEP) (25 Pa. Code 260a). Transportation and disposal of LLMW would also follow RCRA requirements. 13 14 15 16 17 When necessary, LLMW is shipped off site to Perma-Fix of Florida, which is licensed and permitted to treat a variety of mixed waste, solids, liquids, sludges, and debris. Treated wastes are then sent to EnergySolutions, LLC, disposal facility located near Clive, Utah. LLMW are generated at LGS on occasion. LLMW are wastes that contain both low-level radioactive waste and RCRA hazardous waste (40 CFR 266.210). 18 2.1.3. Nonradiological Waste Management 19 20 21 22 23 24 25 26 27 28 29 The LGS site generates nonradioactive wastes as part of routine plant maintenance, cleaning activities, and plant operations. RCRA governs the disposal of solid and hazardous waste. RCRA waste regulations are contained in 40 CFR Parts 239-299. In addition, 40 CFR Parts 239-259 contain regulations for solid (nonhazardous) waste, and 40 CFR Parts 260-279 contain regulations for hazardous waste. RCRA Subtitle C establishes a system for controlling hazardous waste from "cradle to grave," and RCRA Subtitle D encourages States to develop comprehensive plans to manage nonhazardous solid waste and mandates minimum technological standards for municipal solid waste landfills. RCRA regulations are administered in the State by the Pennsylvania Department of Environmental Protection (PADEP) (25 Pa. Code 260a). PADEP further classifies solid waste as either municipal waste (25 Pa. Code 271) or residual waste (25 Pa. Code 287). 30 2.1.3.1. Nonradioactive Waste Streams 31 32 33 34 35 LGS generates solid nonradioactive waste, defined by RCRA, as part of routine plant maintenance, cleaning activities, and plant operations. Exelon manages these wastes, including waste minimization, using corporate procedures that meet applicable regulations (Exelon 2011b). RCRA regulations are administered in the state by the PADEP (25 Pa. Code Article 260a). 36 37 38 39 40 EPA classifies certain nonradioactive wastes as hazardous based on characteristics including ignitability, corrosivity, reactivity, or toxicity (hazardous wastes are listed in 40 CFR Part 261). State-level regulators may add wastes to the EPA's list of hazardous wastes. RCRA supplies standards for the treatment, storage, and disposal of hazardous waste for hazardous waste generators (regulations are available in 40 CFR 262). 41 42 EPA recognizes the following main types of hazardous waste generators based on the quantity of the hazardous waste produced (EPA 2012d): 43 44 ? large quantity generators that generate 2,200 pounds (lb) (1,000 kg) per month or more of hazardous waste, more than 2.2 lb (1 kg) per month of 2-7 Purpose and Need for Action 1 2 acutely hazardous waste, or more than 220 lb (100 kg) per month of acute spill residue or soil, 3 4 ? small quantity generators that generate more than 220 lb (100 kg) but less than 2,200 lb (1,000 kg) of hazardous waste per month, and 5 6 7 8 ? conditionally exempt small quantity generators that generate 220 lb (100 kg) or less per month of hazardous waste, 2.2 lb (1 kg) or less per month of acutely hazardous waste, or less than 220 lb (100 kg) per month of acute spill residue or soil. 9 10 11 12 LGS, based on past and current generation of hazardous waste is classified as a small quantity generator of hazardous waste, according to 40 CFR 262 and given in Pa. Code 264a, with hazardous wastes between 220 lb (100 kg) and 2,200 lb (1,000 kg) per month. The quantities of hazardous waste and nonhazardous wastes are annually reported to PADEP (Exelon 2011b). 13 14 15 16 17 18 19 20 21 The EPA classifies several hazardous wastes as universal wastes; these include batteries, pesticides, mercury-containing items, and fluorescent lamps (25 Pa. Code 266b). Exelon has and expects to continue to generate universal waste such as discarded batteries, pesticides, thermostats, and mercury-containing devices. Other wastes that are not classified as hazardous waste but require regulation in Pennsylvania are (1) residual wastes such as discarded solid, liquid, semi-solids from industrial operations, waste treatment system sludges, and laboratory chemicals; (2) infectious waste; (3) regulated asbestos-containing material; and (4) municipal waste. LGS is considered a Large Quantity Generator of universal wastes (greater than 2,200 lb [1,000 kg] per month) (Exelon 2011b). 22 23 24 25 26 27 National Pollutant Discharge Elimination System (NPDES) permits that provide limits and conditions for wastewater discharge are held by Exelon for industrial wastewater discharges and storm water discharges from the LGS site into the Schuylkill River (No. PA0051926) and discharges to the Bradshaw Reservoir to the East Branch Perkiomen Creek (No. PA0052221) (Exelon 2011b). Radioactive liquid waste is addressed in Section 2.1.2.1 of this SEIS. Section 2.2.4.2 gives more information about the LGS NPDES permit and permitted discharges. 28 29 30 31 32 33 The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable facilities to supply information about hazardous and toxic chemicals to local emergency planning authorities and the EPA (42 USC 11001). On October 17, 2008, the EPA finalized several changes to the Emergency Planning (Section 302), Emergency Release Notification (Section 304), and Hazardous Chemical Reporting (Sections 311 and 312) regulations that were proposed on June 8, 1998 (63 FR 31268). 34 35 Exelon does not expect its generation rates of nonradiological waste to increase significantly during the extended period of operation (Exelon 2011b). 36 2.1.3.2. Pollution Prevention and Waste Minimization 37 38 39 In compliance with PADEP requirements, Exelon has implemented a Preparedness, Prevention and Contingency (PPC) Plan as well as a Spill Prevention Control and Countermeasure (SPCC) Plan compliant with 40 CFR 112, "Oil Pollution Prevention." 40 41 42 43 44 45 46 In support of nonradiological waste-minimization efforts, EPA's Office of Prevention and Toxics has established a clearinghouse that supplies information about waste management and technical and operational approaches to pollution prevention (EPA 2012a). The EPA clearinghouse can be used as a source for additional opportunities for waste minimization and pollution prevention at LGS, as appropriate. EPA also encourages the use of environmental management systems (EMSs) for organizations to assess and manage the environmental impacts associated with their activities, products, and services in an efficient and cost-effective 2-8 Purpose and Need for Action 1 2 3 4 5 6 7 manner. EPA defines an EMS as "a set of processes and practices that enable an organization to reduce its environmental impacts and increase its operating efficiency." EMSs help organizations fully integrate a wide range of environmental initiatives, establish environmental goals, and create a continuous monitoring process to help meet those goals. The EPA Office of Solid Waste especially advocates the use of EMSs at RCRA-regulated facilities to improve environmental performance, compliance, and pollution prevention (EPA 2012b). Exelon has implemented an EMS. 8 2.1.4. Plant Operation and Maintenance 9 10 11 12 13 14 15 Various types of maintenance activities are conducted at LGS, including inspection, testing, and surveillance to maintain current licensing basis of the facility and to ensure compliance with environmental and safety requirements. Various programs currently exist at LGS to maintain, inspect, test, and monitor performance of facility equipment. These maintenance activities include inspection requirements for reactor vessel materials, boiler and pressure vessel inservice inspection and testing, a maintenance structures monitoring program, and maintenance of water chemistry. 16 17 18 19 20 21 22 Additional programs include those carried out to meet technical specification surveillance requirements, those implemented in response to NRC generic communications, and various periodic maintenance, testing, and inspection procedures. Certain program activities are performed during operation of the plant, while others are carried out during scheduled refueling outages. Nuclear power plants must periodically discontinue production of electricity for refueling, periodic inservice inspection, and scheduled maintenance. LGS refuels on a 24-month interval. 23 2.1.5. Power Transmission System 24 25 26 27 28 29 30 31 Four 230-kilovolt (kV) lines were constructed specifically to connect LGS Unit 1 to the regional power grid, and one 500-kV line was constructed to connect LGS Unit 2 to the regional electric grid. Philadelphia Energy Company (PECO), an energy delivery subsidiary of Exelon Corporation, owns and operates these lines. The LGS site also includes two switchyards--one for each reactor unit. The Unit 1 switchyard is a 230-kV substation, and the Unit 2 switchyard is a 500-kV substation. Unless otherwise noted, the discussion of the power transmission system is adapted from the Environmental Report (ER) (Exelon 2011b) or information gathered at NRC's November 2011 environmental site audit (NRC 2012a). 32 2.1.5.1. Description of the Lines 33 220-60 and 220-61 Lines 34 35 36 37 38 39 40 41 42 43 44 45 These lines extend southeast from the plant to the Cromby Substation in East Pikeland Township, Chester County (see Figure 2-4). The two lines run parallel to the Schuylkill River within two separate pre-existing railroad corridors on opposite sides of the river for about 12.9 km (8 miles). The 220-60 line traverses the Montgomery County side of the river, and the 220-61 line traverses the Chester County side of the river. The 220-60 line crosses the river into Chester County before terminating at the Cromby Substation in East Pikeland Township, Chester County. The 220-60 corridor is 18.3 m (60 ft) wide for the first 10.1 km (6.3 miles), at which point the line leaves the railroad corridor and joins with an existing 76.2-m (250-ft)-wide PECO corridor for 1.8 km (1.1 miles). The 220-60 line travels through the 220-61 corridor once it crosses the river. The 220-61 corridor is 18.3 m (60 ft) wide for the entire length of the corridor. The 220-61 line is within the Schuylkill River National and State Heritage Area and parallels a planned portion of the Schuylkill River Trail. 2-9 Purpose and Need for Action 1 220-62 Line 2 3 4 5 6 This line spans a total of 25.7 km (16 miles) from the Cromby Substation (the termination point of the 220-60 and 220-61 lines) to north and then east to the North Wales Substation in Upper Gwynedd Township, Montgomery County (see Figure 2-5). When constructed, the line was routed through an existing PECO transmission line corridor. The corridor varies from 45.7 m (150 ft) to 137.2 m (450 ft) wide and traverses the Evansburg State Park in Skippack Township. 7 220-63 and 220-64 Lines 8 9 10 11 12 13 14 15 16 The 220-63 and 220-64 lines span a total of 16.1 km (10 miles) and 5.6 km (3.5 miles), respectively, from the Cromby Substation southeast and then south to their respective termination points at Barbadoes Substation in West Norristown Township and Plymouth Meeting Substation in Plymouth Township, Montgomery County (see Figure 2-6). The lines cross the Schuylkill River in five locations and parallel an open portion of the Schuylkill River Trail between Phoenixville Borough and Philadelphia. The lines also traverse the Valley Forge National Park. When constructed, the lines were routed through a combination of existing PECO transmission line corridors and railroad corridors. The corridor width varies from 45.7 m (150 ft) to 137.2 m (450 ft). 17 5031 Line 18 19 20 21 22 23 24 This line spans a total of 27.4 km (17 miles) from the Limerick 500-kV substation east to the Whitpain Substation in Whitpain Township, Montgomery County (see Figure 2-7). The line crosses the Schuylkill River in Limerick Township and Evansburg State Park in Skippack Township. When constructed, the line was routed along an existing transmission line corridor associated with a 500-kV line originating from Peach Bottom Atomic Power Station in Delta, Pennsylvania. The line also merges with the 220-62 line corridor for about 4.8 km (3 miles). The corridor width varies from 91.4 m (300 ft) to 137.2 m (450 ft). 2-10 Purpose and Need for Action Figure 2-4. Limerick to Cromby 230-kV Transmission Line Route 1 Limerick 230 kV (Exelon Generation) EAST COVENTRY EAST VINCENT EAST PIKELAND 0 05 ':;..!!!!!!!!!!!!!!!!!i' i iiiiiiiiiiiii Miles c: Exelon. 1 in = 1 miles Rder.-,ce_ ESRI 2003 Streecs aod R~ ESRI 2(()8 Uket and RIVet$ NA() 1983Sta.t.e~Penn$Y~atlla ~ ,.,._., u-..Conb....,Conc Unear Unt: Foal US Leaend 230 kV Voltage (;li Municipal Boundary ,..., Umerick-Cromby 220-00 Line o Interstate Highway ~ Umerick-Cromby 220~1 Une 0 0 State Road o Substation (POWERmap 2009) u.s. Highway Source: Exelon 2011b 2-11 Purpose and Need for Action Figure 2-5. Cromby to North Wales 230-kV Transmission Line Route 1 N UMERICK LOWER PROVIDENCE 0 2 4 Exelon. '!!!!!!!!!!liiiiiiii!!!!!!!!5iiiiiiiiiiiiiiiiiiiiiiiiMiles 1 in = 2 miles NAO 1983State Pbne Pennsy~ll\11 SQAh Ptojectioo; Lambert Conformal Conic Unear Unit Foot US Legend 230 kV Voltage (;! Municipal Boundary ~ Cromby-N Wales 220-62 Line o Interstate Highway o Subslalion (POWERmap 2009) 0 U.S. Highway o State Pal1 (accessed 10 May 2012). 39 40 41 42 41 FR 41914. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants, determination of critical habitat for American crocodile, California condor, Indiana bat, and Florida manatee. Federal Register 41(187):41914-41916. September 24, 1976. Available at (accessed 8 May 2012). 2-85 Purpose and Need for Action 1 2 3 4 47 FR 39827. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants, determination of Isotria medeoloides (small-whorled pogonia) to be an endangered species. Federal Register 47(178):39827-39831. September 9, 1982. Available at (accessed 10 May 2012). 5 6 7 8 9 62 FR 59605. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; final rule to list the northern population of the bog turtle as threatened and the southern population as threatened due to similarity of appearance. Federal Register 62(213): 59605-59623. November 4, 1997. Available at (accessed 10 May 2012). 10 11 12 13 63 FR 31268. U.S. Environmental Protection Agency. Emergency planning and community right-to-know programs; amendments to hazardous chemical reporting thresholds, streamlining requirements; proposed rule. Federal Register 63(109):31268-31317. June 8, 1998. Available at (accessed April 2012). 14 15 75 FR 9282. U.S. Fish and Wildlife Service. General provisions; revised list of migratory birds. Federal Register 75(39):9282-9314. March 1, 2010. 16 17 18 19 77 FR 5880. National Oceanic and Atmospheric Administration. Endangered and threatened wildlife and plants; threatened and endangered status for distinct population segments of Atlantic Sturgeon in the Northeast region." Federal Register 77(24):5880-5912. February 6, 2012. 20 21 22 23 77 FR 17341. U.S. Environmental Protection Agency. Approval and promulgation of air quality implementation plans; Delaware, Maryland, New Jersey, and Pennsylvania; determinations of attainment of the 1997 8-hour ozone standard for the Philadelphia-Wilmington-Atlantic City moderate nonattainment area. Federal Register 77(58):17341-17344. March 26, 2012. 24 25 26 77 FR 18987. U.S. Environmental Protection Agency. Approval and promulgation of air quality implementation plans; Pennsylvania; nonattainment new source review; fine particulate matter (PM2.5). Federal Register 77(61):18987-18990. March 29, 2012. 27 28 29 17 Pa. Code 45. Pennsylvania Code, Title 17, Conservation and Natural Resources, Chapter 45, "Conservation of Native Wild Plants." January 1, 1988. Pennsylvania Department of Conservation and Natural Resources. 30 31 32 33 25 Pa. Code 92a. 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Available at (accessed 8 May 2012). 2-101 1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 2 3 4 5 6 7 8 9 10 11 12 Facility owners or operators may need to undertake or, for economic or safety reasons, may choose to perform refurbishment activities in anticipation of license renewal or during the license renewal term. The major refurbishment class of activities characterized in the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996) is intended to encompass actions which typically take place only once in the life of a nuclear plant, if at all. Examples of these activities include, but are not limited to, replacement of boiling water reactor recirculation piping and pressurized water reactor steam generators. These actions may have an impact on the environment beyond those that occur during normal operations and may require evaluation, depending on the type of action and the plant-specific design. Table 3-1 lists the environmental issues associated with refurbishment that the U.S. Nuclear Regulatory Commission (NRC) staff (the staff) determined to be Category 1 issues in the GEIS. 13 Table 3-1. Category 1 Issues Related to Refurbishment GEIS Section(s) Issue Surface water quality, hydrology, and use (for all plants) Impacts of refurbishment on surface water quality 3.4.1 Impacts of refurbishment on surface water use 3.4.1 Aquatic ecology (for all plants) Refurbishment 3.5 Groundwater use and quality Impacts of refurbishment on groundwater use and quality 3.4.2 Land use Onsite land use 3.2 Human health Radiation exposures to the public during refurbishment 3.8.1 Occupational radiation exposures during refurbishment 3.8.2 Socioeconomics Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4; 3.7.4.6 Aesthetic impacts (refurbishment) 3.7.8 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 14 15 16 Table 3-2 lists environmental issues related to refurbishment that the staff determined to be plant-specific or inconclusive in the GEIS. These issues are Category 2 issues. The definitions of Category 1 and 2 issues can be found in Section 1.4. 3-1 Environmental Impacts of Refurbishment Table 3-2. Category 2 Issues Related to Refurbishment 1 Issue GEIS Section(s) 10 CFR 51.53 (c)(3)(ii) Subparagraph Terrestrial resources Refurbishment impacts 3.6 E 3.9 E 3.3 F Housing impacts 3.7.2 I Public services: public utilities 3.7.4.5 I Public services: education (refurbishment) 3.7.4.1 I Offsite land use (refurbishment) 3.7.5 I Public services, transportation 3.7.4.2 J Historic and archaeological resources 3.7.7 K Threatened or endangered species (for all plants) Threatened or endangered species Air quality Air quality during refurbishment (nonattainment and maintenance areas) Socioeconomics Environmental justice Environmental justice (a) (a) Not addressed Not addressed Guidance related to environmental justice was not in place at the time the U.S. Nuclear Regulatory Commission (NRC) prepared the GEIS and the associated revision to 10 CFR Part 51. If an applicant plans to undertake refurbishment activities for license renewal, the applicant's environmental report (ER) and the staff's environmental impact statement must address environmental justice. Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 2 3 4 5 6 7 8 9 Table B-2 of the GEIS identifies systems, structures, and components (SSCs) that are subject to aging and might require refurbishment to support continued operation during the license renewal period of a nuclear facility. In preparation for its license renewal application, Exelon Generation Company, LLC (Exelon) performed an evaluation of these SSCs pursuant to Title 10 of the Code of Federal Regulation (10 CFR 54.21), in order to identify the need to undertake any major refurbishment activities that would be necessary to support the continued operation of Limerick Generating Station Units 1 and 2 (LGS) during the proposed 20-year period of extended operation. 10 11 12 13 In its SSC evaluation, Exelon did not identify the need to undertake any major refurbishment or replacement actions associated with license renewal to support the continued operation of LGS beyond the end of the existing operating license (Exelon 2011). Therefore, the staff will not assess refurbishment activities in this SEIS. 3-2 Environmental Impacts of Refurbishment 1 3.1. References 2 3 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." 4 5 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." 6 7 8 9 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) Accession No. ML11179A104. 10 11 12 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 13 14 15 16 17 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 - Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS Accession No. ML04069720. 3-3 1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 2 3 4 5 6 7 8 9 10 This chapter addresses potential environmental impacts related to the period of extended operation of Limerick Generating Station, Units 1 and 2 (LGS). These impacts are grouped and presented according to resource. Generic issues (Category 1) rely on the analysis presented in the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996), unless otherwise noted. Site-specific issues (Category 2) have been analyzed for LGS and assigned a significance level of SMALL, MODERATE, or LARGE, accordingly. Some issues are not applicable to LGS because of site characteristics or plant features. For an explanation of the criteria for Category 1 and Category 2 issues, as well as the definitions of SMALL, MODERATE, and LARGE, refer to Section 1.4. 11 4.1. Land Use 12 13 Section 2.2.1 of this supplemental environmental impact statement (SEIS) describes the land use around LGS. 14 15 16 17 18 Land use in the vicinity of nuclear power plants could be affected by the license renewal decision. However, as discussed in the GEIS, onsite land use and power line right of way (ROW) conditions are expected to remain unchanged during the license renewal term at all nuclear plants and any impacts would therefore be SMALL. These issues were classified as Category 1 issues in the GEIS and are listed in Table 4-1. 19 20 21 22 23 24 25 Exelon Generation Company, LLC's (Exelon) Environmental Report (ER) (Exelon 2011a), scoping comments, and other available information about land use in the vicinity of LGS, Units 1 and 2 were reviewed and evaluated for new and significant information. The review included a data gathering site visit to LGS. No new and significant information was identified during this review that would change the conclusions in the GEIS. Therefore, for these Category 1 issues, impacts during the renewal term are not expected to exceed those discussed in the GEIS. 26 27 28 29 30 31 32 Montgomery County has been working to develop an interconnected system of open space and trails along the Schuylkill River and within other natural resource areas of the county. The LGS site contains land along the Schuylkill River that has been identified as part of the Schuylkill River Greenway in the county plan. Onsite land use conditions at LGS are expected to remain unchanged during the license renewal term. Therefore, activities associated with continued reactor operations during the license renewal term are not expected to affect the use and management of LGS lands identified as part of the Schuylkill River Greenway. 33 Table 4-1. Land Use Issues Issue GEIS Section Category Onsite land use 4.5.3 1 Power line ROW 4.5.3 1 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 4-1 Environmental Impacts of Operation 1 4.2. Air Quality 2 3 4 5 6 7 8 9 Section 2.2.2 of this report describes the meteorology and air quality in the vicinity of the LGS site. One Category 1 air quality issue is applicable to LGS--air quality effects of transmission lines. No Category 2 issues apply for air quality, as there is no planned refurbishment associated with license renewal. The U.S. Nuclear Regulatory Commission (NRC) staff did not identify any new and significant information related to the Category 1 air quality issue during the review of Exelon's ER, the site audit, or during the scoping process. Therefore, there are no impacts related to this issue beyond those discussed in the GEIS. For this issue, the GEIS concluded that the impacts are SMALL. 10 Table 4-2. Air Quality Issues Issue GEIS Section 4.5.2 Air quality effects of transmission lines Category 1 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 11 4.3. Geologic Environment 12 4.3.1. Geology and Soils 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, "Environmental protection regulations for domestic licensing and related regulatory functions." With respect to the geologic environment of a plant site, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 issue, "Geology and soils." This new issue has an impact level of SMALL. This new Category 1 issue considers geology and soils from the perspective of those resource conditions or attributes that can be affected by continued operations during the renewal term. An understanding of geologic and soil conditions has been well established at all nuclear power plants and associated transmission lines during the current licensing term, and these conditions are expected to remain unchanged during the 20-year license renewal term for each plant. The impact of these conditions on plant operations and the impact of continued power plant operations and refurbishment activities on geology and soils are SMALL for all nuclear power plants and not expected to change appreciably during the license renewal term. Operating experience shows that any impacts to geologic and soil strata would be limited to soil disturbance from construction activities associated with routine infrastructure renovation and maintenance projects during continued plant operations. Implementing best management practices would reduce soil erosion and subsequent impacts on surface water quality. Information in plant-specific SEISs prepared to date and reference documents has not identified these impacts as being significant. 33 34 35 36 37 38 39 40 Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to LGS. The NRC staff did not identify any new and significant information with regard to this Category 1 (generic) issue based on review of the ER (Exelon 2011a), the public scoping process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS and as identified in the ER (Exelon 2011a), Exelon has no plans to conduct refurbishment or replacement actions associated with license renewal to support the continued operation of LGS. Further, Exelon anticipates no new construction or other ground disturbing-activities or changes in operations and that operation and maintenance activities would be confined to previously 4-2 Environmental Impacts of Operation 1 2 disturbed areas or existing ROWs. Based on this information, it is expected that any incremental impacts on geology and soils during the license renewal term would be SMALL. 3 4.4. Surface Water Resources 4 5 6 7 The Category 1 (generic) and Category 2 surface water use and quality issues applicable to LGS, Units 1 and 2 are discussed in the following sections and listed in Table 4-3. Surface water resources-related aspects and conditions relevant to the LGS site are described in Sections 2.1.7.1 and 2.2.4. Table 4-3. Surface Water Resources Issues 8 Issues GEIS Section Category Altered current patterns at intake and discharge structures 4.2.1.2.1 1 Altered salinity gradients 4.2.1.2.2 1 Temperature effects on sediment transport capacity 4.2.1.2.3 1 Scouring caused by discharged cooling water 4.2.1.2.3 1 Eutrophication 4.2.1.2.3 1 Discharge of chlorine or other biocides 4.2.1.2.4 1 Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1 Discharge of other metals in wastewater 4.2.1.2.4 1 4.3.2.1 2 Water use conflicts (plants with cooling ponds or cooling towers using makeup water from a river with low flow) Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 9 4.4.1. Generic Surface Water Issues 10 11 12 13 14 15 16 The NRC staff did not identify any new and significant information with regard to the Category 1 (generic) surface water issues based on review of the ER (Exelon 2011a), the public scoping process, or as a result of the environmental site audit. As a result, no information or impacts related to these issues were identified that would change the conclusions presented in the GEIS. Therefore, it is expected that there would be no incremental impacts related to these Category 1 issues during the renewal term beyond those discussed in the GEIS. For these surface water issues, the GEIS concludes that the impacts are SMALL. 17 4.4.2. Surface Water Use Conflicts 18 19 This section presents the NRC staff's review of plant-specific (Category 2) surface water use conflict issues as listed in Table 4-3. 20 4.4.2.1. Plants Using Makeup Water from a Small River with Low Flow 21 22 23 24 25 26 For nuclear power plants utilizing cooling towers or cooling ponds supplied with makeup water from a small river, the potential impact on the flow of the river and related impacts on instream and riparian ecological communities is considered a Category 2 issue, thus, requiring a plant-specific assessment. A small river is defined in 10 CFR 51.53(c)(3)(ii)(A) as one whose annual flow rate is less than 3.15x1012 ft3/yr (9x1010 m3/yr) or 100,000 cfs (2,820 m3/s). LGS has a closed-cycle, heat-dissipation system that uses natural draft cooling towers with makeup 4-3 Environmental Impacts of Operation 1 2 3 4 water pumped from the Schuylkill River (see Section 2.1.7). As noted in Section 2.2.4.1, the Schuylkill River near the LGS site has a mean annual flow rate of less than 6.3 x 1010 ft3/yr (2,000 cfs). Therefore, an assessment of the impact of the proposed action on the flow of the river is required. 5 6 7 8 9 10 11 12 13 14 15 16 17 Flow conditions in the Schuylkill River have required Exelon to supplement LGS's water sources. As discussed in Section 2.2.4.1, the mean annual flow and 90 percent exceedance flow for the Schuylkill River, as measured at the U.S. Geological Survey (USGS) Pottstown, Pennsylvania, gage station, total 1,935 cfs (54.8 m3/s) and 482 cfs (13.6 m3/s), respectively. Against these measures of flow, the withdrawal of water at the maximum consumptive use permitted by the Delaware River Basin Commission (DRBC) (65 cfs (1.84 m3/s)) represents a 3.4 percent and a 13 percent reduction, respectively, in the flow of the Schuylkill River downstream of LGS. In order to limit downstream, including aquatic and riparian, impacts in the Schuylkill River during low flow, the DRBC requires LGS to augment its consumptive use of water when the river flow falls to 560 cfs (15.9 m3/s), based on two-unit operation. This is accomplished either through withdrawing makeup water directly from other DRBC-approved water sources or through augmentation of the flow in the Schuylkill River through surface water diversion, as described in Sections 2.1.6 and 2.1.7.1 of this SEIS. 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 In 2003, as part of a demonstration project approved by the DRBC, Exelon included water from Wadesville Mine Pool and the Still Creek Reservoir in its portfolio of water sources for flow augmentation. Since their use presently remains a demonstration project and has not received final docket approval from the DRBC (Docket No. D-69-210, as revised), the NRC staff did not consider these alternative water sources in its impact level determination. Before 2003, the frequency of water withdrawals by LGS for consumptive use was approximately 50 percent from the Schuylkill River, 4 percent from Perkiomen Creek natural flow, and 46 percent from Perkiomen Creek supplemented by water diverted from the Delaware River. Under the demonstration project with releases from the Wadesville Mine Pool to the Schuylkill River, the frequency of withdrawals from the Schuylkill River to support LGS consumptive uses has increased (Exelon 2012a). This trend toward an increasing reliance on augmented flows in the Schuylkill River would be expected to increase during the license renewal term should the demonstration project continue or be made permanent by DRBC, as requested by Exelon. Regardless of the above considerations, the DBRC Comprehensive Plan (DRBC 2001) includes consideration of LGS operations. The DBRC's mission includes water conservation, control, use, and management, which is to be accomplished through the adoption and promotion of uniform and coordinated policies basin-wide (DRBC 1961). The DBRC requirement that LGS shift to alternative water sources when the flow of the Schuylkill River falls to 560 cfs (15.9 m3/s) ensures that LGS cooling water withdrawals and associated consumptive use will not reduce river flow by more than 12 percent during low-flow periods. During average flows, LGS operations will reduce the flow by about 3 percent. Therefore, because DRBC imposes requirements to ensure that LGS's consumptive water use from the Schuylkill River remains within acceptable limits, the NRC staff concludes that the impact on surface water resources and downstream water availability from consumptive water use by LGS, Units 1 and 2 during the license renewal term would be SMALL. 43 4.5. Groundwater Resources 44 45 46 The Category 1 (generic) and Category 2 groundwater use and quality issues applicable to LGS are discussed in the following sections and listed in Table 4-4. Groundwater resources related aspects and conditions relevant to the LGS site are described in Sections 2.1.7.2 and 2.2.5. 4-4 Environmental Impacts of Operation Table 4-4. Groundwater Resources Issues 1 Issues GEIS Section Category Groundwater use conflicts (potable and service water; plants that use less than 100 gpm) 4.8.1.1 1 Groundwater use conflicts (plants using cooling towers withdrawing makeup water from a small river) 4.8.1.3 2 Radionuclides released to groundwater To be determined Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51; 2 (a) (a) 2 NRC 2012b 4.5.1. Generic Groundwater Issues 3 4 5 6 7 8 9 10 11 12 Section 2.2.5 of this SEIS discusses groundwater use and quality at LGS. The NRC staff did not identify any new and significant information with regard to Category 1 (generic) groundwater issues based on the review of the ER (Exelon 2011a), the public scoping process, or as a result of the environmental site audit. NRC staff also reviewed other sources of information, such as various permits and data reports. As a result, no information or impacts related to these issues were identified that would change the conclusions presented in the GEIS. Therefore, for the single issue found to be directly applicable to LGS, it is expected that there would be no incremental impacts related to this Category 1 issue during the renewal term beyond those discussed in the GEIS. For this groundwater issue, the GEIS concludes that the impacts are SMALL. 13 4.5.2. Groundwater Use and Quality Conflicts 14 15 This section presents the NRC staff's review of plant-specific (Category 2) groundwater resources issues as listed in Table 4-4. 16 17 4.5.2.1. Plants Using Cooling Towers Withdrawing Makeup Water from a Small River, Alluvial Aquifers 18 19 20 21 22 23 For nuclear power plants utilizing cooling towers supplied with makeup water from a small river (as defined in Section 4.3.2.1), the potential impact on alluvial aquifers is also considered a Category 2 issue, thus, requiring a plant-specific assessment. This groundwater aspect was classified as a Category 2 issue in the GEIS because consumptive use of water withdrawn from a small river could adversely affect groundwater aquifer recharge. Low river flow conditions are of particular interest. 24 25 26 27 28 29 30 31 32 33 34 Based on the topography of the plant site and review of local groundwater elevations, NRC staff determined that groundwater flow across and in the vicinity of the plant site predominately discharges to the Schuylkill River and Possum Hollow Run. Groundwater provides baseflow to these surface waters. For groundwater use conflicts to occur due to reduced streamflow, the affected stream segments must also be a principal source of recharge to an affected aquifer, which is not the case. Recharge to the bedrock aquifer (Brunswick) in the region predominantly occurs in upgradient areas from precipitation and runoff, as described in Section 2.2.5.1 of the SEIS. In addition, the alluvial sediments and regolith overlying the area's bedrock are relatively thin and not used as a source of groundwater. A review of Pennsylvania water well records within a 1-mi (1.6-km) radius of the LGS site revealed that all recorded wells are in the Brunswick Formation rather than in surficial materials. Therefore, the NRC staff concludes that 4-5 Environmental Impacts of Operation 1 2 continued withdrawals of surface water for the operation of LGS, Units 1 and 2 during low-flow periods would have a SMALL impact on groundwater recharge during the license renewal term. 3 4.5.2.2. Radionuclides Released to Groundwater 4 5 6 7 8 In its ER (Exelon 2011a), Exelon identified the presence of tritium in groundwater as new, but not significant, information based on site groundwater monitoring. In response, the NRC staff specifically reviewed information relating to the current state of knowledge on groundwater quality beneath and downgradient of LGS, as detailed in Section 2.2.5.2 and summarized below. 9 10 11 12 13 14 15 16 17 18 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to groundwater quality, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, "Radionuclides released to groundwater," with an impact level range of SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from plant systems into groundwater. This new Category 2 issue has been added to evaluate the potential impact to groundwater quality from the discharge of radionuclides from plant systems, piping, and tanks. This issue was added because, within the past several years, there have been events at nuclear power reactor sites that involved unknown, uncontrolled, and unmonitored releases of radioactive liquids into the groundwater. 19 20 21 22 23 Exelon commissioned a hydrogeologic investigation in 2006 (CRA 2006), in part, to evaluate the potential impacts on groundwater quality of any inadvertent releases of tritium or other LGS-related radionuclides and to identify and eliminate contributing sources of radionuclides to groundwater. The investigation provided the basis for the site's current Radiological Groundwater Protection Program (RGPP). 24 25 26 27 28 29 30 31 32 33 As part of the 2006 investigation, a network of 15 onsite groundwater monitoring wells was installed in the Brunswick Formation (bedrock aquifer) at LGS. From the initial 2006 sampling, no strontium-90 or gamma-emitting radionuclides were detected in groundwater or surface water above analytical detection limits. Tritium was detected in five of the monitoring wells at relatively low wells, but one well (P12), located immediately south and downgradient of the power block, had a concentration of 4,360 ? 494 pCi/L. At the same time, a sample from the power block foundation sump had tritium at 2,020 ? 154 pCi/L. As noted in Section 2.2.5.2, well P12 was replaced with well no. MW-LR-9 in August 2006, to be more representative of water table conditions beneath the site. Sampling of this new well yielded tritium at 1,500 ? 210 pCi/L. 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Under the ongoing RGPP at LGS, groundwater and surface water samples are collected and analyzed for tritium and other radionuclides at least semi-annually. The results are reported in annual radiological environmental operating (REOP) reports (Exelon 2008a, 2009a, 2010a, 2011b, 2012b) that are submitted to the NRC. Since 2006, there have been no detections in groundwater of gamma-emitting radionuclides or strontium-90 associated with LGS operations. The peak tritium level observed in groundwater was 1,750 pCi/L in well MW-LR-9 in 2009. Exelon traced this to a condensate release in February 2009, which was corrected (see Section 2.2.5.2). Tritium in MW-LR-9 had decreased to a maximum of 1,154 pCi/L by April 2011. It is noted that tritium concentrations have exceeded 2,000 pCi/L in samples from the power block foundation sump since 2006 (Exelon 2011a). Regardless, monitoring data indicates that there is no migration of tritium in groundwater at LGS at concentrations exceeding 2,000 pCi/L, and observed tritium levels have been well within the U.S. Environmental Protection Agency (EPA) primary drinking water standard (i.e., 20,000 pCi/L) at all onsite monitoring wells. In addition, there are no potable water wells downgradient of the LGS power block and no drinking water pathway. The plant's potable water supply well (well 1) is located 4-6 Environmental Impacts of Operation 1 2 3 4 5 6 about 1,000 ft (300 m) upgradient and slightly cross-gradient (northeast) of MW-LR-9 and the power block sump pit. Based on the information presented and the NRC staff's review, NRC staff concludes that inadvertent releases of tritium have not substantially impaired site groundwater quality or affected groundwater use downgradient of the LGS site. The NRC staff further concludes that groundwater quality impacts would remain SMALL during the license renewal term. 7 4.6. Aquatic Resources 8 9 10 11 12 13 14 15 16 17 18 Section 2.1.6 of this SEIS describes the LGS cooling-water system; Section 2.2.5 describes the aquatic resources. Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, which are applicable to the operation of the LGS cooling-water systems during the renewed license term, are listed in Table 4-5. There are no Category 2 issues that apply to aquatic resources at LGS. The NRC staff did not find any new and significant information during the review of the applicant's ER (Exelon 2011a), the site audit, the scoping process, or the evaluation of other available information; therefore, the NRC staff concludes that there are no impacts related to aquatic resource issues beyond those discussed in the GEIS (NRC 1996) and the revised rule (NRC 2012b). Consistent with the GEIS, the NRC staff concludes that the impacts are SMALL, and additional site-specific mitigation measures are unlikely to be sufficiently beneficial to warrant implementation. 19 Table 4-5. Aquatic Resources Issues Issues GEIS Section Category For all plants Accumulation of contaminants in sediments or biota 4.2.1.2.4 1 Entrainment of phytoplankton and zooplankton 4.2.2.1.1 1 Cold shock 4.2.2.1.5 1 Thermal plume barrier to migrating fish 4.2.2.1.6 1 Distribution of aquatic organisms 4.2.2.1.6 1 Premature emergence of aquatic insects 4.2.2.1.7 1 Gas supersaturation (gas bubble disease) 4.2.2.1.8 1 Low dissolved oxygen in the discharge 4.2.2.1.9 1 Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses 4.2.2.1.10 1 Stimulation of nuisance organisms 4.2.2.1.11 1 To be (a) determined 1 Exposure of aquatic organisms to radionuclides For plants with cooling tower-based heat dissipation systems Entrainment of fish and shellfish in early life stages 4.3.3 1 Impingement of fish and shellfish 4.3.3 1 4.3.3 1 Heat shock Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51; 4-7 (a) NRC 2012b Environmental Impacts of Operation 1 4.6.1. Exposure of Aquatic Organisms to Radionuclides 2 3 4 5 6 7 8 9 10 11 12 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to the aquatic organisms, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 issue, "Exposure of aquatic organisms to radionuclides," among other changes. This new Category 1 issue considers the impacts to aquatic organisms from exposure to radioactive effluents discharged from a nuclear power plant during the license renewal term. An understanding of the radiological conditions in the aquatic environment from the discharge of radioactive effluents within NRC regulations has been well established at nuclear power plants during their current licensing term. Based on this information, the NRC concluded that the doses to aquatic organisms are expected to be well below exposure guidelines developed to protect these organisms and assigned an impact level of SMALL. 13 14 15 16 17 18 19 20 21 22 23 24 The NRC staff has not identified any new and significant information related to the exposure of aquatic organisms to radionuclides during its independent review of LGS's ER, the site audit, and the scoping process. Section 2.1.2 of this SEIS describes the applicant's radioactive waste management program to control radioactive effluent discharges to ensure that they comply with NRC regulations in 10 CFR Part 20, "Standards for protection against radiation." Section 4.9.3 of this SEIS contains the NRC staff's evaluation of the LGS's radioactive effluent and radiological environmental monitoring programs. LGS's radioactive effluent and radiological environmental monitoring programs provide further support for the conclusion that the impacts of aquatic organisms from radionuclices are SMALL. The NRC staff concludes that there would be no impacts to aquatic organisms from radionuclides beyond those impacts contained in Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule and, therefore, the impacts to aquatic organisms from radionuclides are SMALL. 25 4.7. Terrestrial Resources 26 27 28 The Category 1 (generic) and Category 2 (site-specific) terrestrial resources issues applicable to LGS are discussed in the following sections and listed in Table 4-6. Terrestrial resources issues that apply to LGS are described in Sections 2.2.7 and 2.2.8. 29 Table 4-6. Terrestrial Resources Issues Issue GEIS Section Cooling tower impacts on crops and ornamental vegetation Cooling tower impacts on native plants Bird collisions with cooling towers Power line right-of-way management (cutting herbicide application) Bird collisions with power lines Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, wildlife, livestock) Floodplains and wetland on power line right-of-way Exposure of terrestrial organisms to radionuclides Effects on terrestrial resources (non-cooling system impacts) Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51; 4-8 (a) Category 4.3.4 4.3.5.1 4.3.5.2 4.5.6.1 4.5.6.2 1 1 1 1 1 4.5.6.3 1 4.5.7 To be (a) determined To be (a) determined 1 NRC 2012b 1 2 Environmental Impacts of Operation 1 4.7.1. Generic Terrestrial Resources Issues 2 3 4 5 6 7 8 For the Category 1 terrestrial resources issues listed in Table 4-6, the NRC staff did not identify any new and significant information during the review of the ER (Exelon 2011a), the NRC staff's site audit, the scoping process, or the evaluation of other available information. Therefore, there are no impacts related to these issues beyond those discussed in the GEIS and the revised rule (NRC 2012b). For these issues, the GEIS and the revised rule concluded that the impacts are SMALL, and additional site-specific mitigation measures are not likely to be sufficiently beneficial to warrant implementation. 9 4.7.1.1. Exposure of Terrestrial Organisms to Radionuclides 10 11 12 13 14 15 16 17 18 19 20 21 As described in Section 1.4 of this draft SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 issue, "Exposure of terrestrial organisms to radionuclides," among other changes. This new issue has an impact level of SMALL. This new Category 1 issue considers the impacts to terrestrial organisms from exposure to radioactive effluents discharged from a nuclear power plant during the license renewal term. An understanding of the radiological conditions in the terrestrial environment from the discharge of radioactive effluents within NRC regulations has been well established at nuclear power plants during their current licensing term. Based on this information, the NRC concluded that the doses to terrestrial organisms are expected to be well below exposure guidelines developed to protect these organisms and assigned an impact level of SMALL. 22 23 24 25 26 27 28 29 The NRC staff has not identified any new and significant information related to the exposure of terrestrial organisms to radionuclides during its independent review of LGS's ER, the site audit, and the scoping process. Section 2.1.2 of this SEIS describes the applicant's radioactive waste management program to control radioactive effluent discharges to ensure that they comply with NRC regulations in 10 CFR Part 20. Section 4.9.3 of this SEIS contains the NRC staff's evaluation of LGS's radioactive effluent and radiological environmental monitoring programs, which provide further support for the conclusion that the impacts from radioactive effluents are SMALL. 30 31 32 33 Therefore, the NRC staff concludes that there would be no impact to terrestrial organisms from radionuclides beyond those impacts contained in Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51of the revised rule and, therefore, the impacts to terrestrial organisms from radionuclides are SMALL. 34 4.7.2. Effects on Terrestrial Resources (Non-Cooling System Impacts) 35 36 37 38 39 40 41 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by expanding the Category 2 issue, "Refurbishment impacts," among others, to include normal operations, refurbishment, and other supporting activities during the license renewal term. This issue remains a Category2 issue with an impact level range of SMALL to LARGE; however, the revised rule renames this issue "Effects on terrestrial resources (non-cooling system impacts)." 42 43 44 45 46 Section 2.2.7 describes the terrestrial resources on and in the vicinity of the LGS site and vicinity, and Section 2.2.8 describes protected species and habitats. During construction of LGS, approximately 42 percent of the plant site (270 ac (110 ha)) was cleared for buildings, parking lots, roads, and other infrastructure. The remaining terrestrial habitats have not changed significantly since construction. As discussed in Chapter 3 of this SEIS and according 4-9 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 10 11 12 13 to the applicant's ER (Exelon 2011a), Exelon has no plans to conduct refurbishment or replacement actions associated with license renewal to support the continued operation of LGS. Further, Exelon (2011a) anticipates no new construction or other ground-disturbing activities, changes in operations, or changes in existing land use conditions because of license renewal. Exelon (2011a) reports that operation and maintenance activities would be confined to previously disturbed areas or existing ROWs. As a result, Entergy (2011a) anticipates no new impacts on the terrestrial environment on the LGS site or along the in-scope transmission line corridors during the license renewal term. Based on the staff's independent review, the staff concurs that operation and maintenance activities that Exelon might undertake during the renewal term, such as maintenance and repair of plant infrastructure (e.g., roadways, piping installations, onsite transmission lines, fencing, and other security infrastructure), likely would be confined to previously disturbed areas of the LGS site. Therefore, the staff expects non-cooling system impacts on terrestrial resources during the license renewal term to be SMALL. 14 4.8. Protected Species and Habitats 15 16 17 18 Section 2.2.7 of this SEIS describes the action area, as defined by the ESA regulations at 50 CFR 402.02, and describes the protected species and habitats within the action area associated with the LGS license renewal. Table 4-7 lists the one Category 2 issue related to protected species and habitats that is applicable to LGS. Table 4-7. Protected Species and Habitats Issues 19 Issue GEIS Section Threatened or endangered species 4.1 Category 2 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 20 4.8.1. Correspondence with Federal and State Agencies 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 In accordance with Section 7 of the Endangered Species Act (ESA), in a letter to the U.S. Fish and Wildlife Service (FWS), dated September 8, 2011, the NRC staff requested information regarding Federally listed species in the action area (NRC 2011d). Also in accordance with Section 7 of the ESA, the NRC staff sent a similar request regarding Federally listed species to the National Marine Fisheries Service (NMFS) (NRC 2012a). The NRC staff sent further requests to the Pennsylvania Fish and Boat Commission (PFBC) (NRC 2011e), Pennsylvania Game Commission (PGC) (NRC 2011g), and Pennsylvania Department of Conservation and Natural Resources (PDCNR) (NRC 2011f) regarding the presence of Pennsylvania-listed species in the action area. The PFBC, PGC, FWS, and NMFS responded to the NRC staff in letters dated October 5, 2011 (PFBC 2011b); November 17, 2011 (PGC 2011); November 22, 2011 (FWS 2011b); and June 2, 2012 (NMFS 2012c), respectively. The PFBC noted that the eastern redbelly turtle (Pseudemys rubriventris) and globally rare amphipods and/or isopods may be in the project area (PFBC 2011b); Section 4.7.3 considers the potential effects to this species. The PGC determined that no impacts to Pennsylvania-listed threatened or endangered birds or mammals under PGC responsibility would be likely from the proposed license renewal (PGC 2011). The FWS indicated that the proposed project is within the known range of the bog turtle (Clemmys muhlenbergii) (FWS 2011b); Section 4.7.3 considers the potential effects to this species. However, because FWS concluded that the proposed action is not likely to have an adverse effect on the bog turtle, no further consultation with FWS under Section 7 of the ESA is required. NMFS stated that no species listed under the ESA occur 4-10 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 10 within the action area (NMFS 2012c). NMFS also stated that two candidate species--alewife (Alosa pseudoharengus) and blueback herring (Alosa aestivalis)--occur in the project area. However, as candidate species, NMFS is still considering whether the species should be listed and protected under ESA. Therefore, no further consultation with NMFS under Section 7 of the ESA is required. The NRC staff has not received a response from the PDCNR to date. However, in a March 9, 2011, letter to Exelon, the PDCNR identified several plant species that occur within the action area near LGS transmission line corridors (PDCNR 2011). The PDCNR indicated that because the proposed license renewal does not involve new construction, refurbishment, ground disturbance, or changes to operations or existing land-use conditions, no impact is likely to occur to species under the PDCNR's jurisdiction (PDCNR 2011). 11 4.8.2. Aquatic Species and Habitats 12 13 14 15 16 17 18 19 20 21 For purposes of its protected species and habitat discussion and analysis, the NRC staff considers the action area, as defined by 50 CFR 402.02, to include the lands and waterbodies associated with LGS, as defined in Section 2.2.7. Two fish species and one aquatic invertebrate protected under the ESA may occur in the Delaware River or in small waterbodies throughout Pennsylvania (FWS 2012, NMFS 2012a). Two fish within the action area are considered candidate species and species of concern by NMFS (NMFS 2012c). Three additional fish species, one additional aquatic invertebrate, and four aquatic plant species listed as a species of special concern, endangered, or threatened by the Commonwealth of Pennsylvania may occur in waterbodies in Bucks, Chester, or Montgomery Counties (PNHP 2012a). 22 4.8.2.1. Federally Protected Species 23 Shortnose Sturgeon (Acipenser brevirostrum) 24 25 26 27 28 29 30 31 The endangered shortnose sturgeon uses the tidal, estuarine, and lower portion of the Delaware River in Bucks County, Pennsylvania (NMFS 2012b). LGS-related studies from 1979-1985 did not observe shortnose sturgeon eggs or larvae at the Point Pleasant Pumping Station and downriver to river mi (RM) 138 (river km (RKm) 222.1) (Exelon 2011a; RMC 1984, 1985, 1986). The most recent population studies observed the farthest upriver migration up to 9 RM (15 RKm) below the Point Pleasant Pumping Station, which is located at RM 157 (RKm 253) (Hastings et al. 1987, O'Herron et al. 1993). NMFS stated that no species listed under the ESA occur within the action area (NMFS 2012c). 32 33 The NRC staff concludes that the proposed LGS license renewal would have no effect on the shortnose sturgeon because: 34 35 o NMFS (2012c) stated that no species listed under the ESA occur within the action area, 36 37 o the LGS intake at the Point Pleasant Pumping Station is approximately 9 RM (15 RKm) upriver of the farthest known upriver occurrence of this species, 38 39 o LGS-related studies from 1979-1985 did not observe Atlantic sturgeon eggs or larvae near the Point Pleasant Pumping Station, and 40 41 42 o no new construction, refurbishment, ground-disturbing activities, or changes to existing land use conditions at the Point Pleasant Pumping Station would occur. 4-11 Environmental Impacts of Operation 1 Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus) 2 3 4 5 6 7 8 9 The endangered Atlantic sturgeon uses the tidal, estuarine, and lower portion of the Delaware River in Bucks County, Pennsylvania (NMFS 2012b). LGS-related studies from 1979 to 1985 did not observe Atlantic sturgeon eggs or larvae at the Point Pleasant Pumping Station and downriver to 138 RM (222.1 RKm) (Exelon 2011a; RMC 1984, 1985, 1986). Tagging studies in 2005 and 2006 indicated that Atlantic sturgeon followed similar migration patterns as shortnose sturgeon with spawning potentially occurring in the upper tidal Delaware reaches between Philadelphia, Pennsylvania, and Trenton, New Jersey (Simpson and Fox undated). NMFS (2012c) stated that no species listed under the ESA occur within the action area. 10 11 The NRC staff concludes that the proposed LGS license renewal would have no effect on Atlantic sturgeon because: 12 13 o NMFS (2012) stated that no species listed under the ESA occur within the action area, 14 15 o LGS-related studies from 1979 to1985 did not observe Atlantic sturgeon eggs or larvae near the Point Pleasant Pumping Station, and 16 17 18 o no new construction, refurbishment, ground-disturbing activities, or changes to existing land use conditions at the Point Pleasant Pumping Station would occur. 19 Dwarf Wedgemussel (Alasmidonta heterodon) 20 21 22 23 24 25 26 27 28 29 FWS (2012b) lists the endangered dwarf wedgemussel as known to or believed to occur in Monroe, Pike, and Wayne Counties, Pennsylvania, which is not part of the action area. PNHP (2012a) lists the dwarf wedgemussel as potentially occurring in Bucks, Chester, and Montgomery Counties. The Philadelphia Electric Company (PECO 1984) observed rare, unidentified species of the genus Alasmidonta in the Schuylkill River in the 1970s and it is unknown whether the specimens were the dwarf wedgemussel (Exelon 2011a). Other than the rare Alasmidonta specimens observed in the 1970s in the Schuylkill River, LGS-related studies did not observe dwarf wedgemussels during benthic surveys in East Branch Perkiomen Creek, Perkiomen Creek, and the Schuylkill River between 1970 and 2009 (Exelon 2011a; NAI 2010c; PECO 1984; RMC 1984, 1985, 1986, 1987, 1989). 30 31 32 33 34 Both Exelon and the NRC staff contacted FWS to request information on potential impacts to Federally protected species. In a March 22, 2011, letter to Exelon, FWS (2011a) did not identify the dwarf wedgemussel as a concern in regard to LGS's proposed license renewal. In a November 22, 2011, letter to the NRC, the FWS (2011b) confirmed that the conclusions in their previous letter to Exelon were still appropriate. 35 36 37 Therefore, the NRC staff concludes that the proposed LGS license renewal would have no effect, on dwarf wedgemussel because effects to the species would be insignificant, discountable, or beneficial. 38 4.8.2.2. Pennsylvania-Protected Species, Candidate Species, and Species of Concern 39 Fish 40 41 42 43 44 The Commonwealth of Pennsylvania lists the banded sunfish (Enneacanthus obesus) and the longear sunfish (Lepomis megalotis) as endangered in Bucks County (PNHP 2012a). The Pennsylvania endangered ironcolor shiner (Notropis chalybaeus) occurs in Bucks and Montgomery Counties (PNHP 2012a). Blueback herring and alewife are considered candidate species and NMFS species of concern (NMFS 2012). 4-12 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 10 11 12 LGS-related activity in Bucks County that could affect the blueback herring, alewife, banded sunfish, longear sunfish, or ironcolor shiner and their habitat is the intermittent withdrawal of Delaware River water for the LGS cooling system. Direct impacts could include impingement or entrainment and indirect impacts could include impingement or entrainment of prey. Blueback herring and alewife eggs are demersal and adhesive, which make them less likely to be entrained. Eggs and larvae entrained in the Point Pleasant Pumping Station would be transported from the Delaware River to the East Branch Perkiomen Creek. Eggs and larvae would experience sudden pressure fluctuations, velocity shear forces, and physical abrasion in the pumps at Point Pleasant and Bradshaw Reservoir and throughout the pipeline. If any eggs or larvae survive the transport, successful development would depend on organisms finding suitable habitat. Prey species that survive the transport would no longer be available as prey for fish in the Delaware River. 13 14 15 16 17 18 19 20 LGS license renewal would include continued operation at the Point Pleasant Pumping Station. However, as described in Section 2.1.6, Exelon's withdrawal of water from the Delaware River is secondary to its withdrawal of water from the Schuylkill River, and Exelon plans to continue to rely less on the Delaware River and more on the Schuylkill River in the future (Exelon 2012a). LGS license renewal would not involve new construction, refurbishment, ground-disturbing activities, or changes to existing land use conditions at the Point Pleasant Pumping Station. Transmission lines associated with LGS do not cross any portion of the Delaware River (Exelon 2011a). 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 In addition to Bucks County, blueback herring, alewife, and the ironcolor shiner may occur in Montgomery County. Waters in Montgomery County associated with LGS include East Branch Perkiomen Creek, Perkiomen Creek, and the Schuylkill River.LGS license renewal would include continued operation at the Perkiomen Pumphouse, the Schuylkill Pumphouse, and the Schuylkill River discharge structure. Direct effects could include mortality if fish are impinged or entrained. Blueback herring and alewife eggs are demersal and adhesive, which make them less likely to be entrained. Indirect effects could include a decrease in habitat quality from thermal discharge in the Schuylkill River. However, the flow, temperature, and other conditions of the discharge are regulated by LGS's NPDES permit, which would limit changes in water quality. Indirect effects could also occur from the Delaware River intrabasin transfer of water, which involves diversion of Delaware River water to the East Branch Perkiomen Creek that discharges by gravity flow to Perkiomen Creek in order to augment the flow in Perkiomen Creek. As described in Section 2.2.6, NAI (2010a) sampled aquatic biota between 2001 and 2009 as part of an analysis to examine post-operational effects of the water diversion effort (Exelon 2011a). Species diversity remained relatively consistent and samples continued to be dominated by midges and oligochaetes. In addition, less variability existed along the stream gradient and over time; NAI noted that pollution-sensitive species increased in abundance (NAI 2010a, 2010c). 39 40 41 42 43 44 45 46 47 The LGS license renewal would include continued operation and maintenance of four transmission lines that extend from the Limerick site and travel and cross portions of the Schuylkill River and Perkiomen Creek (Section 2.1.5 describes the in-scope transmission lines in more detail). The transmission lines associated with LGS cross rivers and streams that have the potential to be blueback herring, alewife, or ironcolor shiner habitat. PECO must maintain the transmission lines and associated structures and manage vegetation along the transmission line corridors to prevent interference with the lines. Line and vegetation maintenance may result in a temporary decline in habitat quality from increased sedimentation and turbidity during maintenance activities. 48 49 If PECO needs to perform maintenance in or near waterbodies, it takes a number of precautions to avoid impacts to blueback herring, alewife, and ironcolor shiners or their habitat. First, PECO 4-13 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 10 11 12 typically performs mechanical vegetation maintenance activities on foot and does not operate heavy machinery near wetlands and water bodies. This type of maintenance avoids the potential for heavy machinery to affect fish habitat by reducing the amount of sedimentation and turbidity in the stream. Foot traffic could result in some minimal disturbance of fish habitat. However, foot traffic would create impacts that are insignificant (i.e., those impacts that would never reach the scale where fish mortality would occur) or discountable (i.e., those impacts that cannot be meaningfully measured, detected, or evaluated). In addition, PECO must obtain several permits and certifications for maintenance activities in wetlands or near waterbodies, which for a given work area may include: (1) a General Permit or Water Obstruction and Encroachment General Permit issued jointly by the USACE and PADEP, (2) a CWA 404 permit issued by the USACE, or (3) an erosion and sedimentation control plan from the appropriate county conservation district. 13 14 15 LGS license renewal would not involve new construction, refurbishment, ground-disturbing activities, or changes to existing land use conditions at LGS-associated facilities or transmission lines. 16 17 18 19 The NRC staff contacted PFBC to request information on potential impacts to Pennsylvania-protected species. In an October 5, 2011, letter to the NRC, PFBC (PFBC 2011b) did not identify the banded sunfish, longear sunfish, or the ironcolor shiner as a concern in regard to LGS's proposed license renewal. 20 Pizzini's Amphipod 21 22 23 24 25 The Pizzini's cave amphipod (Stygobromus pizzinii), previously named Stygonectes pizzinii, is a Pennsylvania species of concern and is possibly extirpated in Montgomery and Chester Counties (PNHP 2012a). Based on the Pennsylvania Natural Diversity Inventory (PNDI) database and PFBC files, PFBC (2011) stated in its letter to the NRC that globally rare amphipod and/or isopod species are known to occur within the vicinity of the LGS site. 26 27 28 29 30 31 32 33 34 35 36 37 38 39 LGS license renewal would include continued operation at the Perkiomen Pumphouse, the Schuylkill Pumphouse, and the Schuylkill River discharge structure. Direct effects could include mortality if amphipods are entrained. Indirect effects could include a decrease in habitat quality from thermal discharge in the Schuylkill River. However, the flow, temperature, and other conditions of the discharge are regulated by LGS's NPDES permit, which would limit changes in water quality. Indirect effects could also occur from the Delaware River intrabasin transfer of water, which involves diversion of Delaware River water to the East Branch Perkiomen Creek that discharges by gravity flow to Perkiomen Creek in order to augment the flow in Perkiomen Creek. As described in Section 2.2.6, NAI (2010a) sampled aquatic biota between 2001 and 2009 as part of an analysis to examine post-operational effects of the water diversion effort (Exelon 2011a). Species diversity remained relatively consistent and samples continued to be dominated by midges and oligochaetes. In addition, less variability existed along the stream gradient and over time; NAI noted that pollution-sensitive species increased in abundance (NAI 2010a, 2010c). 40 41 42 43 44 45 46 47 48 The LGS license renewal would include continued operation and maintenance of four transmission lines that extend from the Limerick site and travel and cross portions of the Schuylkill River and Perkiomen Creek (Section 2.1.5 describes the in-scope transmission lines in more detail). The transmission lines associated with LGS cross rivers and streams that have the potential to be Pizzini's cave amphipod habitat. PECO must maintain the transmission lines and associated structures and manage vegetation along the transmission line corridors to prevent interference with the lines. Line and vegetation maintenance may result in direct impacts to Pizzini's cave amphipod if instream work is required that could crush the amphipods. Potential indirect effects could include a temporary decline in habitat quality from increased 4-14 Environmental Impacts of Operation 1 2 3 4 5 6 7 sedimentation and turbidity during maintenance activities. In PFBC's (2011) letter to the NRC, PFBC noted that the Pizzini's cave amphipod is threatened by habitat destruction and poor water quality. If PECO needs to perform maintenance in or near waterbodies, it takes a number of precautions to reduce the likelihood of crushing amphipods and to reduce sedimentation and water quality impacts. These actions, such as performing mechanical vegetation maintenance activities on foot and obtaining necessary permits, are described in more detail earlier in this section. 8 9 10 LGS license renewal would not involve new construction, refurbishment, ground-disturbing activities, or changes to existing land use conditions at LGS-associated facilities or transmission lines. 11 12 13 14 15 16 The NRC staff contacted PFBC to request information on potential impacts to Pennsylvania-protected species. In an October 5, 2011, letter to the NRC, PFBC (2011) identified Pizzini's cave amphipod as potentially occurring in the vicinity of the LGS site. However, given that license renewal would not involve new construction, earth disturbances, or changes to existing land uses, PFBC did not anticipate any significant adverse impacts to this species (PFBC 2011b). 17 Aquatic Plants 18 19 20 21 22 Pennsylvania lists Farwell's water-milfoil (Myriophyllum farwellii), broad-leaved water-milfoil (Myriophyllum heterophyllum), floating-heart (Nymbphoides cordata), and spotted pondweed (Potamogeton pulcher) as either threatened or endangered as described in Section 2.2.7. All four plants have historic or current records of occurrence in coastal portions of Bucks County (PNHP 2012a). 23 24 25 26 27 28 29 30 31 32 33 34 LGS-related activity that could affect the Farwell's water-milfoil, broad-leaved water-milfoil, floating-heart, and spotted pondweed and their habitat is the intermittent withdrawal of Delaware River water for the LGS cooling system. Direct impacts could include mortality if the plants were sucked into the intake at the Point Pleasant Pumping Station. As described above, preferred habitat does not occur near the Point Pleasant Pumping Station. LGS license renewal would include continued operation at the Point Pleasant Pumping Station. However, as described in Section 2.1.6, Exelon's withdrawal of water from the Delaware River is secondary to its withdrawal of water from the Schuylkill River, and Exelon plans to continue to rely less on the Delaware River and more on the Schuylkill River in the future (Exelon 2012a). LGS license renewal would not involve new construction, refurbishment, ground-disturbing activities, or changes to existing land use conditions at the Point Pleasant Pumping Station. Transmission lines associated with LGS do not cross any portion of the Delaware River (Exelon 2011a). 35 36 37 38 The NRC staff contacted PFBC to request information on potential impacts to Pennsylvania-protected species. In an October 5, 2011, letter to the NRC, PFBC (2011b) did not identify the Farwell's water-milfoil, broad-leaved water-milfoil, floating-heart, and spotted pondweed aquatic plants as a concern in regard to LGS's proposed license renewal. 39 4.8.2.3. Conclusion for Aquatic Species 40 41 42 43 44 45 46 47 The NRC staff evaluated the three ESA-listed species, two candidate species, and eight additional Pennsylvania-protected species and species of special concern that could be present in the action area defined in Section 2.2.8. In its evaluation, NRC staff examined the known distributions and habitat ranges of those species, the ecological impacts of the operation of LGS on the species, and the LGS-related occurrence and monitoring studies described above. In addition, no critical habitat occurs within the action area. Given that LGS license renewal would not involve new construction, refurbishment, ground-disturbing activities, or changes to existing land use conditions at LGS-associated facilities or transmission lines, the continued operation of 4-15 Environmental Impacts of Operation 1 2 LGS is not likely to noticeably affect these species. Thus, the NRC staff concludes that the impact on protected aquatic species from the proposed license renewal would be SMALL. 3 4.8.3. Terrestrial Species and Habitats 4 Species and Habitats Protected Under the Endangered Species Act 5 Bog Turtle (Clemmys muhlenbergii) 6 7 8 9 The following analysis of the impacts of LGS license renewal on the bog turtle constitutes the biological assessment for that species required by the ESA. Under the ESA, an agency's requirement to prepare a biological assessment is independent of consultation and can be completed through the NEPA process. 10 11 12 Section 2.2.8 concludes that the bog turtle could occur in suitable wetland habitat on the LGS site, within palustrine emergent and forested wetlands along the Schuylkill River, or within wetland habitat along the transmission line corridors. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Small sections of the LGS site contain suitable habitat for bog turtles. According to Figure 10, "Habitat Map of Limerick Generating Station," in Exelon's Wildlife Management Plan (Exelon 2012a), palustrine emergent and forested wetlands lie along the Schuylkill River adjacent to riparian forest, old field, and agricultural land. Within the LGS site, the LGS license renewal would include maintenance and operation activities within developed or previously disturbed areas and would not involve new construction, refurbishment, ground-disturbing activities, changes to conduct of operations, or changes to existing land use conditions in either natural or developed areas. The proposed license renewal would have no direct or indirect adverse impacts to LGS site wetlands; therefore, it would have no direct or indirect adverse effects on the bog turtle. As noted in Section 2.2.7, poaching and loss of habitat are two of the primary threats to the species. Continued operation of LGS during the license renewal term would preserve the existing wetlands on the LGS site. Site security would prevent public access to the site, and thus, prevent poaching. Therefore, continued operation of the LGS could result in beneficial effects to the species. 27 28 29 30 31 32 The LGS license renewal would include Exelon's continued operation and maintenance of the Perkiomen Pumphouse, Bradshaw Reservoir and Pumphouse, and the Bedminster Water Processing Facility. Exelon would only perform maintenance and operation activities within developed or previously disturbed areas during the license renewal period. Thus, the proposed license renewal would have no direct or indirect adverse impacts to habitat at these offsite facilities and no direct or indirect adverse effects on the bog turtle. 33 34 35 36 37 38 39 40 41 42 43 44 45 46 The LGS license renewal also would include continued operation and maintenance of four transmission line corridors that extend from the Limerick site and travel through Montgomery and Chester Counties (Section 2.1.5 describes the in-scope transmission lines in more detail). Although the NRC does not license or regulate PECO, which owns and operates the transmission lines, the NRC considers all transmission lines that were constructed specifically to connect the facility to the transmission system in its NEPA analysis. The transmission lines associated with LGS cross rivers, streams, and wetlands that have the potential to be bog turtle habitat. PECO must maintain the transmission lines and associated structures and manage vegetation along the transmission line corridors to prevent interference with the lines. Line and vegetation maintenance may result in direct impacts to bog turtles, including takes of bog turtles or their eggs and disturbance or destruction of bog turtle habitat. Potential indirect effects could include prevention of natural successional changes in transmission line plant communities over time. This indirect effect could positively affect bog turtles because they prefer early successional wetlands. 4-16 Environmental Impacts of Operation 1 2 3 4 5 Generally, PECO maintains transmission line corridors to promote the growth of shrubs, grasses, and other low-growing vegetation. Because bog turtles prefer shallow, open-canopy wetlands, the need for maintenance in these areas is much lower. If PECO needs to perform maintenance in wetland areas, it takes a number of precautions to avoid impacts to the bog turtle or its habitat. 6 7 8 First, PECO trains all of its contractors to be knowledgeable about Federally protected species they may encounter while working and that they are able to identify potential wetlands and obtain the necessary permits before proceeding with work. 9 10 11 12 13 14 15 16 17 Second, PECO typically performs mechanical vegetation maintenance activities on foot and does not operate heavy machinery near wetlands and water bodies. This type of maintenance avoids the potential for heavy machinery to crush turtles or nests or to create ruts, crush wetland vegetation, or otherwise alter bog turtle habitat. PECO also makes an effort to perform work in wetland areas during the winter months when the ground is hard or frozen. Foot traffic could result in some minimal disturbance of wetland habitat. However, foot traffic would create insignificant impacts (i.e., those impacts that would never reach the scale where a take might occur) or discountable impacts (i.e., those impacts that cannot be meaningfully measured, detected, or evaluated). 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Finally, PECO must obtain several permits and certifications for maintenance activities in wetlands or near waterbodies, which for a given work area may include: (1) a General Permit or Water Obstruction and Encroachment General Permit issued jointly by the USACE and PADEP, (2) a CWA 404 permit issued by the USACE, or (3) an erosion and sedimentation control plan from the appropriate county conservation district. Within Montgomery and Chester Counties (through the in-scope transmission lines traverse), PADEP requires applicants for a General Permit or Water Obstruction and Encroachment General Permit to comply with bog turtle screening requirements, which includes a site assessment by qualified PADEP personnel (PADEP 2006c). In cases in which a site assessment identifies potential bog turtle habitat, the USACE and PADEP will not issue a permit until the FWS determines that the project will not have an impact on the species (PADEP 2006c). In cases in which PECO must obtain a CWA 404 permit, this permitting process triggers a PECO company process during which PECO personnel must review the proposed maintenance activities for potential impacts to bog turtles and coordinate with FWS to avoid such impacts. 32 33 34 35 36 37 PECO's maintenance of transmission line corridors to promote low-growing vegetation may benefit the species by preventing or stalling natural plant succession. Successional changes within wetland communities often gradually eliminate some wetland vegetation and reduce open areas that bog turtles use for nesting and basking (Morrow et al. 2001). In a study of bog turtles at two sites in Maryland, Morrow et al. (2001) found that bog turtles avoided dense and higher-growing vegetation and sought areas with low-lying cover. 38 39 40 41 42 43 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts to Federally protected species. In a March 22, 2011, letter to Exelon, FWS (2011a) indicated that the bog turtle occurs or may occur in or near the project area, but that the proposed action is not likely to have an adverse effect on the bog turtle based on the FWS's review of the project description and location. In a November 22, 2011, letter to the NRC, the FWS (2011b) confirmed that the conclusion in its previous letter to Exelon was still appropriate. 44 45 46 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely to adversely affect the bog turtle because effects to the species would be insignificant, discountable, or beneficial. 4-17 Environmental Impacts of Operation 1 Indiana Bat (Myotis sodalis) 2 3 4 5 6 7 8 9 10 Section 2.2.8 concludes that the Indiana bat could occur in suitable forest habitat within the action area. Potential types of Indiana bat habitat that occur in the action area include summer roosting habitat, foraging habitat, and commuting habitat. Summer roosting habitat includes trees with exfoliating bark, cracks, or crevices in trees or snags (dead trees) that are greater than 3-in. (8-cm) diameter-at-breast height (FWS 2012a). Foraging habitat includes forest patches, wooded riparian corridors, and natural vegetation adjacent to such habitats (FWS 2012a). Commuting habitat includes wooded tracts, tree lines, wooded hedgerows, streams, or other linear pathways within or connected to roosting or foraging habitat (FWS 2012a). 11 12 13 14 15 16 The LGS license renewal would not disturb or alter any natural habitats within the LGS site or offsite facilities associated with the LGS makeup water system. Thus, no direct or indirect adverse effects would result from continued operation and maintenance of these facilities. If the Indiana bat occurs on the LGS site, continued operation of LGS would be beneficial to the species because it would preserve forest habitat that might otherwise be developed or converted to some other land use. 17 18 19 20 21 22 23 24 25 26 27 Because the majority of LGS transmission line corridors contain low-growing plant communities dominated by grasses, herbs, and small shrubs, PECO's continued maintenance of the lines generally would not alter the existing habitat. Occasionally, PECO may need to remove trees that either grow tall enough to interfere with the lines or trees that die and could fall on the lines. In such cases, PECO could have to remove trees that provide summer roosting habitat for Indiana bats. However, PECO trains all of its contractors to be knowledgeable about Federally protected species they may encounter while working. If a tree that provided potential Indiana bat habitat required removal, PECO would typically coordinate with FWS and the appropriate state agencies. PECO could also perform such maintenance in the fall or winter months when the Indiana bat has migrated to hibernation sites. Thus, this potentially adverse impact would be insignificant because it is unlikely to result in a take. 28 29 30 31 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts to Federally protected species. The FWS did not mention that the Indiana bat was of particular concern in either its March 22, 2011, letter to Exelon (FWS 2011a) or its November 22, 2011, letter to the NRC (FWS 2011b). 32 33 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely to adversely affect the Indiana bat because effects to the species would be insignificant. 34 Small-Whorled Pogonia (Isotria medeoloides) 35 36 37 38 Section 2.2.8 indicates that three extant populations of the small-whorled pogonia occur in Pennsylvania, and at least one of these populations occurs in Chester County. Thus, Section 2.2.8 conservatively concludes that the small-whorled pogonia could occur in areas of suitable habitat along or near the transmission line corridor that runs through Chester County. 39 40 41 42 43 44 45 46 47 Because the small-whorled pogonia does not occur in Montgomery or Bucks Counties, continued operation and maintenance of the LGS site and offsite facilities associated with the LGS makeup water system would have no direct or indirect effects on the small-whorled pogonia. LGS license renewal would include continued operation and maintenance of four transmission line corridors that extend from the Limerick site and travel through Montgomery and Chester Counties. The corridor within Chester County is about 13 mi (21 km) long (Section 2.1.5 describes the in-scope transmission lines in more detail). The small-whorled pogonia generally grows in young and maturing stands of mixed-deciduous or mixed-deciduous/coniferous forests in areas close to logging roads, streams, or other features 4-18 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 10 11 that create long-persisting breaks in the forest canopy. Therefore, the species could occur near the transmission line corridor, but it is unlikely to occur in the corridor itself. Because the species is unlikely to occur within the corridor, it would not experience any direct adverse effects such as trampling caused by worker foot traffic, crushing caused by vehicles and equipment, or herbicide application when workers spray adjacent vegetation. Depending on the proximity of the small-whorled pogonia to the transmission line corridor, the species could experience indirect adverse effects such as taking up water containing chemicals from herbicide runoff. However, PECO maintains vegetation on a 5-year cycle and selectively sprays herbicides by hand, so the indirect effects from herbicide application would be so small as to not be able to be meaningfully measured or detected and would not reach the scale where a take would occur. Thus, such effects would be discountable and insignificant. 12 13 14 15 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts to Federally protected species. The FWS did not mention the small-whorled pogonia was of particular concern in either its March 22, 2011, letter to Exelon (FWS 2011a) or its November 22, 2011, letter to the NRC (FWS 2011b). 16 17 18 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely to adversely affect the small-whorled pogonia because effects to the species would be insignificant or discountable. 19 Designated Critical Habitat 20 21 22 23 24 The NRC staff did not identify any Federally designated critical habitat within the action area during its review (see Section 2.2.7). Additionally, in its correspondence with Exelon and the NRC, the FWS (2011a, 2011b) did not identify any designated critical habitat. Thus, the NRC staff concludes that the proposed license renewal would have no effect on designated critical habitat. 25 Proposed Species and Proposed Critical Habitat 26 27 28 29 30 The NRC staff did not identify any Federally proposed species or proposed critical habitat within the action area during its review (see Section 2.2.7). Additionally, in its correspondence with Exelon and the NRC, the FWS (2011a, 2011b) did not identify any proposed species or proposed critical habitat. Thus, the NRC staff concludes that the proposed license renewal would have no effect on Federally proposed species or proposed critical habitat. 31 Species Protected Under the Bald and Golden Eagle Protection Act 32 33 34 35 36 37 38 Though bald eagles occur throughout the action area, no known nests are in close proximity to any of the LGS site buildings, parking lots, or other structures; the LGS makeup water system offsite facilities; or along the transmission line corridors that could be disturbed by operations or maintenance activities associated with the proposed license renewal. Because the proposed license renewal does not involve construction or land disturbances, the proposed license renewal would not affect any bald eagle habitat. The NRC staff concludes that the impacts of the proposed LGS license renewal on the bald eagle would be SMALL. 39 Species Protected Under the Migratory Bird Treaty Act 40 41 42 43 As discussed in Section 2.2.7, a variety of migratory birds inhabit the LGS site and surrounding region. Because the proposed license renewal does not involve construction or land disturbances, the NRC staff concludes that the impacts of the proposed LGS license renewal on migratory birds would be SMALL. 4-19 Environmental Impacts of Operation 1 Species Protected by the Commonwealth of Pennsylvania 2 3 4 5 6 7 8 9 10 Section 2.2.8.3 discusses species protected under the Pennsylvania Endangered Species Program. Ten Pennsylvania-listed birds and two Pennsylvania-listed plants occur or have occurred on the LGS site since the plant began operating. An additional eight plant species occur near the transmission line corridors. One Pennsylvania-listed reptile, the eastern redbelly turtle (Pseudemys rubriventris), occurs in the vicinity of the LGS site. Because the proposed license renewal does not involve construction or land disturbances, the NRC staff concludes that the impacts of the proposed LGS license renewal on Pennsylvania-protected species on the LGS site or at offsite facilities associated with the LGS makeup water system would be SMALL. 11 12 13 14 15 16 17 18 19 20 21 Continued transmission line maintenance would not adversely affect any of the Pennsylvania-listed birds or the eastern redbelly turtle. As discussed in Section 2.1.5, PECO has implemented an avian management program to ensure that it does not unnecessarily disturb or harm birds or nests and to ensure compliance with applicable Federal and state bird regulations. The mitigative measures described above for the bog turtle would also be protective of the eastern redbelly turtle. Because the eastern redbelly turtle inhabits aquatic and wetland habitats, the likelihood of habitat disturbance or direct effects to this species is lower because PECO follows more stringent procedures when performing work in these areas. Additionally, in its February 11, 2011, letter to Exelon, the PFBC (2011a) noted that it does not anticipate the proposed license renewal will have any significant adverse impacts on Pennsylvania-listed species of concern under the PFBC's jurisdiction. 22 23 24 25 26 27 28 29 Some of the Pennsylvania-listed plants discussed in Section 2.2.8.3 occur in woodlands or other habitats near, but not directly within, the transmission line corridors. Continued transmission line maintenance would not affect these plant species because PECO only manages vegetation within the corridor. The other plant species occur in habitats compatible with transmission lines, such as old fields or other early successional communities, and PECO likely would not perform intensive maintenance or use herbicides in these areas because these habitats already contain low-growing vegetation. The NRC staff concludes that the impacts of the proposed license renewal on Pennsylvania-listed plants along the transmission line corridors would be SMALL. 30 Conclusion 31 32 33 The NRC staff concludes that the impacts of the proposed LGS license renewal on protected terrestrial species and habitats would be SMALL as defined by the NRC for the purposes of NEPA. 4-20 Environmental Impacts of Operation 1 4.9. Human Health 2 Table 4-8 lists the Category 1 and 2 issues related to human health that are applicable to LGS. 3 Table 4-8. Human Health Issues Issue GEIS Section Category a 1 Occupational radiation exposures during refurbishment a 3.8.2 1 Microbiological organisms (occupational health) 4.3.6 1 Radiation exposure to the public during refurbishment 3.8.1 (b) Microbiological organisms (public health) 4.3.6 2 Noise 4.3.7 1 Radiation exposures to public (license renewal term) 4.6.2 1 Occupational radiation exposures (license renewal term) 4.6.3 1 Electromagnetic fields--acute effects (electric shock) 4.5.4.1 2 Electromagnetic fields--chronic effects 4.5.4.2 Uncategorized Human health impact from chemicals To be (c) determined 1 Physical occupational hazards To be (c) determined 1 (a) Issues apply to refurbishment, an activity that LGS does not plan to undertake (b) Issue applies to plants with features such as cooling lakes or cooling towers that discharge to a small river. The issue applies to LGS. (c) NRC 2012b Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 4 4.9.1. Generic Human Health Issues 5 6 7 8 9 10 11 12 13 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, applicable to LGS in regard to human health impacts are listed in Table 4-9. Exelon stated in its ER (Exelon 2011a) that it was aware of one new radiological issue associated with the renewal of the LGS operating license, tritium in groundwater. Exelon's groundwater monitoring program for radioactive material is discussed in Sections 2.2.5, 4.5.2, and 4.11 of this document. Based on its review of LGS's groundwater monitoring data, the NRC staff concluded that the issue, while new, is not significant. The NRC staff has not identified any new and significant information during its independent review of Exelon's ER, the site visit, the scoping process, or its evaluation of other available information. 14 4.9.1.1. New Category 1 Human Health issues 15 16 17 18 19 20 As described in Section 1.4 of this draft SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to the human health, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding two new Category 1 issues, "Human health impact from chemicals" and "Physical occupational hazards." The first issue considers the impacts from chemicals to plant workers and members of the public. The second issue only considers the nonradiological occupational hazards of working at 4-21 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 a nuclear power plant. An understanding of these non-radiological hazards to nuclear power plant workers and members of the public have been well established at nuclear power plants during those plants' current licensing terms. The impacts from chemical hazards are expected to be minimized through the licensee's use of good industrial hygiene practices as required by permits and Federal and state regulations. Also, the impacts from physical hazards to plant workers will be of small significance if workers adhere to safety standards and use protective equipment as required by Federal and state regulations. The impacts to human health for each of these new issues from continued plant operations are SMALL. 9 10 11 12 13 14 The NRC staff has not identified any new and significant information related to these nonradiological issues during its independent review of LGS's ER, the site audit, and the scoping process. Therefore, the NRC staff concludes that there would be no impact to human health from chemicals or physical hazards beyond those impacts described in Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule and, therefore, the impacts are SMALL. 15 4.9.2. Radiological Impacts of Normal Operations 16 17 18 19 20 21 22 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, applicable to LGS in regard to radiological impacts to human health are listed in Table 4-8. The NRC staff has not identified any new and significant information related to radiological issues during its independent review of Exelon's ER, the site audit, the scoping process, or its evaluation of other available information. Therefore, the NRC staff concludes that there would be no impact from radiation exposures to the public or to workers during the license renewal term beyond those discussed in the GEIS. 23 The findings in the GEIS are as follows: 24 25 o Radiation exposures to the public (license renewal term). Based on information in the GEIS, the Commission found the following: 26 27 o Radiation doses to the public will continue at current levels associated with normal operations. 28 29 o Occupational exposures (license renewal term). Based on information in the GEIS, the Commission found the following: 30 31 32 o Projected maximum occupational doses during the license renewal term are within the range of doses experienced during normal operations and normal maintenance outages, and would be well below regulatory limits. 33 34 According to the GEIS, the impacts to human health are SMALL, and additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted. 35 There are no Category 2 issues related to radiological impacts of routine operations. 36 37 The information presented below is a discussion of selected radiological programs conducted at LGS. 38 Limerick Generating Station Radiological Environmental Monitoring Program 39 40 41 42 43 44 LGS conducts a Radiological Environmental Monitoring Program (REMP) to assess the radiological impact, if any, to its employees, the public, and the environment from the operations at LGS, Units 1 and 2. The REMP measures the aquatic, terrestrial, and atmospheric environment for radioactivity, as well as the ambient radiation. In addition, the REMP measures background radiation (i.e., cosmic sources, global fallout, and naturally occurring radioactive material, including radon). The REMP supplements the radioactive effluent monitoring program 4-22 Environmental Impacts of Operation 1 2 3 by verifying that any measurable concentrations of radioactive materials and levels of radiation in the environment are not higher than those calculated using the radioactive effluent release measurements and transport models. 4 5 6 7 8 An annual radiological environmental operating report (REOP) is issued, which contains a discussion of the results of the monitoring program. The report contains data on the monitoring performed for the previous year. The REMP collects samples of environmental media in order to measure the radioactivity levels that may be present. The media samples are representative of the radiation exposure pathways that may affect the public. 9 10 11 12 13 14 15 16 The LGS REMP is made up of three categories based on the exposure pathways to the public. They are as follows: atmospheric, aquatic, and ambient gamma radiation. The atmospheric samples taken around LGS are airborne particulate, airborne iodine, milk, and broad leaf vegetation. Airborne iodine and particulate samples are taken using vacuum pumps and glass fiber filters. The aquatic pathway samples are taken from surface water and drinking water sources. Also included in this pathway are sediment samples and fish samples. The ambient gamma radiation pathway measures direct exposure from environmental radiation doses using thermoluminescent dosimeters. 17 18 19 In addition to the REMP, LGS has a groundwater protection program designed to monitor the onsite plant environment for the detection of leaks from plant systems and pipes containing radioactive liquid (see Sections 2.2.5.2 and 4.5.2). 20 21 22 23 24 25 26 27 The NRC staff reviewed the LGS annual REOPs for 2007 through 2011 to look for any significant impacts to the environment or any unusual trends in the data (Exelon 2008a, 2009a, 2010a, 2011b, 2012b). A 5-year period provides a data set that covers a broad range of activities that occur at a nuclear power plant, such as refueling outages, routine operation, and years in which there may be significant maintenance activities. Based on the NRC staff's review, no adverse trends (i.e., steadily increasing buildup of radioactivity levels) were observed and the data showed that there was no measurable impact to the environment from LGS operations. 28 Groundwater Protection Program 29 30 A radioactive groundwater protection program was established at LGS in 2006 to assess potential impacts to groundwater from plant's operation. 31 32 33 34 35 36 37 In 2007, the Nuclear Energy Institute (NEI) established a standard for monitoring and reporting radioactive isotopes in groundwater: NEI 07-07, "Industry Ground Water Protection Initiative- Final Guidance Document" (NEI 2007). LGS implemented the recommendations of this industry standard. Data from the groundwater monitoring program are contained in the annual radiological environmental operating report submitted to the NRC in May of each year. These reports are available for review by the public through the Agencywide Documents Access and Management System (ADAMS) electronic reading room available through the NRC website. 38 39 Additional information on the groundwater protection program is discussed in Sections 2.2.5 and 4.5.2 of this SEIS. 40 41 Pennsylvania Department of Environmental Protection Bureau of Radiation Detection Environmental Monitoring Program 42 43 44 45 46 The Bureau of Radiation Protection (BRP) performs its own independent environmental monitoring around the LGS site and other nuclear facilities located in Pennsylvania. All analyses of environmental media (i.e., soil, air, water, and vegetation) are performed by its Bureau of Laboratories (BOL). The state's BRP performs the monitoring of direct radiation from a facility using thermoluminescent dosimeters (TLDs). 4-23 Environmental Impacts of Operation 1 2 3 4 The NRC staff reviewed the state's environmental summary reports for 2003 through 2004 (the most recent reports available at the time of the NRC's review) (PADEP undated). In each of the reports, the state concluded that the sample data indicated no release of radioactive material to the environment that exceeded the regulatory or license limits of the PADEP or the NRC. 5 Limerick Generating Station Radioactive Effluent Release Program 6 7 8 9 10 11 12 13 14 15 All nuclear plants were licensed with the expectation that they would release radioactive material to both the air and water during normal operation. However, NRC regulations require that radioactive gaseous and liquid releases from nuclear power plants must meet radiation dose-based limits specified in 10 CFR Part 20, and the as low as is reasonably achievable (ALARA) criteria in Appendix I to 10 CFR Part 50. Regulatory limits are placed on the radiation dose that members of the public can receive from radioactive effluents released by a nuclear power plant. In addition, nuclear power plants are required by 10 CFR 50.36(a) to submit an annual report to the NRC that lists the types and quantities of radioactive effluents released into the environment. The radioactive effluent release reports are available for review by the public through the ADAMS electronic reading room available through the NRC website. 16 17 18 19 20 The NRC staff reviewed the annual radioactive effluent release reports for 2007 through 2011 (Exelon 2008b, 2009b, 2010b, 2011c, 2012c). The review focused on the calculated doses to a member of the public from radioactive effluents released from LGS. The doses were compared to the radiation protection standards in 10 CFR 20.1301 and the ALARA dose design objectives in Appendix I to 10 CFR Part 50. 21 22 23 24 25 26 Dose estimates for members of the public are calculated based on radioactive gaseous and liquid effluent release data and atmospheric and aquatic transport models. The 2011 annual radioactive effluent release report (Exelon 2012d) contains a detailed presentation of the radioactive discharges and the resultant calculated doses. The following summarizes the calculated dose to a member of the public located outside the LGS site boundary from radioactive gaseous and liquid effluents released during 2011: 27 28 29 30 o The combined total-body dose to an offsite member of the public from LGS, Units 1 and 2 radioactive liquid effluents was 8.38x10-2 mrem (8.38x10-4 mSv), which is well below the combined 6 mrem (0.06 mSv) dose criterion for two reactor units in Appendix I to 10 CFR Part 50. 31 32 33 34 o The organ (liver) dose to an offsite member of the public from LGS, Units 1 and 2 radioactive liquid effluents was 8.38x10-2 mrem (8.38x10-4 mSv), which is well below the combined 20 mrem (0.20 mSv) dose criterion for two reactor units in Appendix I to 10 CFR Part 50. 35 36 37 38 o The air dose at the site boundary from gamma radiation in gaseous effluents from LGS, Units 1 and 2 was 1.46x10-2 mrad (1.46x10-4 mGy), which is well below the combined 20 mrad (0.2 mGy) dose criterion for two reactor units in Appendix I to 10 CFR Part 50. 39 40 41 42 o The air dose at the site boundary from beta radiation in gaseous effluents from LGS, Units 1 and 2 was 8.73x10-3 mrad (8.73x10-5 mGy), which is well below the combined 40 mrad (0.4 mGy) dose criterion for two reactor units in Appendix I to 10 CFR Part 50. 43 44 45 46 o The dose to an organ (bone) from radioactive iodine, radioactive particulates, and carbon-14 from LGS, Units 1 and 2 was 4.13x10-1 mrem (4.13x10-3 mSv), which is well below the combined 30 mrem (0.3 mSv) dose criterion for two reactor units in Appendix I to 10 CFR Part 50. 4-24 Environmental Impacts of Operation 1 2 3 4 5 6 7 o No radiation above background was detected at the site boundary from direct radiation, as measured by TLDs. There is no dose criterion for direct radiation in Appendix I to 10 CFR Part 50. The data is included in the summation of doses from all radioactive effluent release pathways to determine compliance with EPA's 40 CFR Part 190 dose standard of 25 mrem (0.25 mSv) for the total dose to members of the public from the reactor units at the LGS site. 8 9 10 11 12 13 14 o The NRC staff summed the applicant's data on the individual total body doses from radioactive gaseous and liquid effluents from both units and added it to the dose from direct radiation to obtain the maximum all pathways dose to an offsite member of the public from the operation of LGS, Units 1 and 2. The dose to a member of the public from all radioactive releases in 2011 was 1.30x10-1 mrem (1.30x10-3 mSv), which is well below the 25 mrem (0.25 mSv) dose standard in EPA's 40 CFR Part 190. 15 16 17 18 19 20 21 22 23 24 25 26 The NRC staff's review of the LGS radioactive effluent control program showed that radiation doses to members of the public were controlled within Federal radiation protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 40 CFR Part 190. ? The applicant has no plans to conduct refurbishment activities during the license renewal term; however, routine plant refueling and maintenance activities currently performed will continue during the license renewal term. Based on the past performance of the radioactive waste system to maintain the dose from radioactive effluents to be ALARA, similar performance is expected during the license renewal term. Continued compliance with regulatory requirements is expected during the license renewal term; therefore, the impacts from radioactive effluents to the public would be SMALL. 27 4.9.3. Microbiological Organisms 28 29 30 31 32 33 34 35 The effects of thermophilic microbiological organisms on human health (see Table 4-8), are categorized as a Category 2 issue and require a plant-specific evaluation during the license renewal process for plants using closed-cycle cooling, located on a small river. The Schuylkill River is considered a small river because its average annual flow is approximately 6.3 x 1010 cubic feet per year (ft3/yr) (1.7 x 108 cubic meters per year (m3/yr)), which is less than the threshold value of 3.15 x 1012 ft3/yr (9 x 1010 m3/yr) in 10 CFR 51.53(c)(3)(ii)(G) (Exelon 2011a). Therefore, the effects of the LGS cooling water discharge on microbiological organisms must be addressed for LGS license renewal. 36 37 38 39 40 41 42 43 44 45 The Category 2 designation is based on the magnitude of the potential public health impacts associated with thermal enhancement of enteric pathogens such as Salmonella spp. and Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living amoebae Naegleria spp., and Legionella spp. bacteria (NRC 1996). Thermophilic microorganisms generally occur at temperatures of 77 ?F to 176 ?F (25 ?C to 80 ?C) with an optimal growth temperature range of 122 ?F to 150 ?F (50 ?C to 66 ?C), and minimum and maximum temperature tolerances of 68 ?F (20 ?C) and 158 ?F (70 ?C), respectively. However, thermal preferences and tolerances vary across bacterial groups. Pathogenic thermophilic microbiological organisms of concern during nuclear reactor operation typically have optimal growing temperatures of approximately 99 ?F (37 ?C) (Joklik and Smith 1972). 46 47 Pseudomonas aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal infections in immunocompromised individuals. The organism produces toxins harmful to 4-25 Environmental Impacts of Operation 1 2 3 4 5 humans and animals. It has an optimal growth temperature of 99 ?F (37 ?C) (Todar 2012). Legionella spp. consists of at least 46 species and 70 serogroups. It is responsible for Legionnaires' disease, with the onset of pneumonia in the first 2 weeks of exposure. Risk groups for Legionella spp. include elderly, cigarette smokers, persons with chronic lung or immunocompromising disease, and persons receiving immunosuppressive drugs. 6 7 8 9 10 11 12 13 14 The LGS NPDES permit (No. PA0051926) requires the temperature in the thermal discharge to be monitored at least once weekly for compliance with an instantaneous maximum limit of 110 ?F (43.3 ?C) for the protection of human health. Although thermophilic microbiological organisms of concern during nuclear reactor operation could grow at that stated instantaneous maximum temperature limit, there are several years of Discharge Monitoring Report (DMR) data showing that maximum summer discharge temperatures range from 90 ?F to 95 ?F (32.2 ?C to 35.0 ?C) (Exelon 2011a). These temperatures are below the stated optimal growing temperature of approximately 99?F (37?C); therefore, ambient river conditions are not likely to support the proliferation of the pathogenic organisms of concern. 15 16 17 18 19 20 21 22 23 Exelon requested PADEP to provide comments or concerns about LGS's contribution to potential health effects resulting from thermophilic organisms. Exelon requested PADEP to alternatively confirm Exelon's conclusion that operation of LGS during the period of extended operation would not enhance growth of thermophilic pathogens. In response, PADEP identified that it does not have any data associated with thermophilic organisms in the Schuylkill River nor has it conducted any investigations on the impact or potential impact of the LGS discharge on thermophilic organisms in the river. As a result, PADEP is unable to make any conclusions regarding the effect on public health from thermophilic organisms in the Schuylkill River (Exelon 2011a). 24 25 26 27 DRBC designated that uses to be maintained in the Schuylkill River in the vicinity of LGS include secondary contact recreation, in which body contact is either incidental or accidental, and in which the probability of ingesting appreciable quantities of water, particularly through nasal passages, is minimal. 28 29 30 LGS currently discharges sanitary sewage to the local publicly owned treatment works for treatment, which further reduces the potential for the facility's discharge to introduce pathogenic microorganisms that could present a threat to recreational users of the Schuylkill River. 31 32 33 34 35 36 The NRC staff reviewed all documents applicable to this Category 2 issue, including Exelon's ER and the LGS NPDES permit. The NRC staff concludes that for the reasons above, thermophilic microbiological organisms are unlikely to present a public health hazard as a result of LGS discharges to the Schuylkill River. The NRC staff concludes that impacts on public health from thermophilic microbiological organisms from continued operation of LGS in the license renewal period would be SMALL. 37 4.9.4. Electromagnetic Fields--Acute Effects 38 39 40 41 42 43 Based on the GEIS, the Commission found that electric shock resulting from direct access to energized conductors or from induced charges in metallic structures has not been found to be a problem at most operating plants and generally is not expected to be a problem during the license renewal term. However, site-specific review is required to determine the significance of the electric shock potential along the portions of the transmission lines that are within the scope of this SEIS. 44 45 46 In the GEIS (NRC 1996), the Commission found that without a review of the conformance of each nuclear plant transmission line with National Electrical Safety Code (NESC) criteria, it was not possible to determine the significance of the electric shock potential (IEEE 2002). 4-26 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 Additionally, the Commission found that evaluation of individual plant transmission lines is necessary because the issue of electric shock safety was not addressed in the licensing process for some plants. For other plants, land use in the vicinity of transmission lines may have changed, or power distribution companies may have chosen to upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), Exelon must provide an assessment of the impact of the proposed action on the potential shock hazard from the transmission lines if the transmission lines that were constructed for the specific purpose of connecting the plant to the transmission system do not meet the recommendations of the NESC for preventing electric shock from induced currents. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Limerick Units 1 and 2 electrical outputs are delivered to the PJM Interconnection by the LGS transmission system. Each Limerick unit is provided with an independent substation, which are 230 kilovolts (kV) for Unit 1 and 500 kV for Unit 2. Four 230-kV transmission lines, the Limerick-Cromby 220-60 line, the Limerick-Cromby 220-61 line, the Cromby-North Wales 220-62 line, and the Cromby-Plymouth Meeting 220-63/64 line, were constructed to connect the Limerick Unit 1 substation to the electric grid. One 500-kV transmission line, the Limerick-Whitpain 5031 line, was constructed to connect the Limerick Unit 2 substation to the electric grid. These are the lines that are within scope of license renewal. Exelon developed an electric field strength policy for the design and operation of its transmission system. The policy is intended to minimize shock hazards consistent with the NESC criteria. Exelon used the Electric Power Research Institute (EPRI) HERB 2.0 software to determine NESC compliance. Their analysis determined that there are no locations within the right-of-way under these transmission lines that have the capacity to induce more than 5 milliamperes (mA) to a vehicle parked beneath the lines. Therefore, the lines meet the NESC 5 mA criterion. The maximum induced current calculated for the power lines was 4.6 mA on the Cromby-Plymouth Meeting 220-63/64 line (Exelon 2011a). 26 27 28 29 30 31 32 33 34 35 36 The LGS transmission line corridor crosses over highways, streets, other public places, or property owned by others for which PECO, a subsidiary of Exelon Corporation, has permits, grants, easements, or licenses. PECO, and owners and operators of the transmission lines, conduct surveillance and maintenance activities to verify that design ground clearances will not change. These procedures include routine inspection for clearance problems by aircraft periodically. Ground inspections are conducted yearly for clearance problems, which are brought to the attention of the appropriate organizations for maintenance. Exelon expects that it, as well as PECO, will continue to use these or similar processes during the period of extended operation. No land use changes are anticipated in the vicinity of the corridor. Exelon's and PECO's periodic surveillance of the transmission system assures that ground clearances would remain in compliance with NESC criteria (Exelon 2011a). 37 38 39 The NRC staff reviewed the available information, including Exelon's evaluation and results. Based on this information, the NRC staff concludes that the potential impacts from electric shock during the renewal period would be SMALL. 40 4.9.5. Electromagnetic Fields--Chronic Effects 41 42 43 In the GEIS, the effects of chronic exposure to 60 Hertz electromagnetic fields from power lines were not designated as Category 1 or 2 and will not be until a scientific consensus is reached on the health implications of these fields. 44 45 46 The potential effects of chronic exposure from these fields continue to be studied and are not known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs related research through the U.S. Department of Energy (DOE). 4-27 Environmental Impacts of Operation 1 The report by NIEHS (NIEHS 1999) contains the following conclusion: 2 3 4 5 6 7 8 9 10 11 The NIEHS concludes that ELF EMF (extremely low frequency electromagnetic field) exposure cannot be recognized as entirely safe because of weak scientific evidence that exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to warrant aggressive regulatory concern. However, because virtually everyone in the United States uses electricity and therefore is routinely exposed to ELF EMF, passive regulatory action is warranted such as continued emphasis on educating both the public and the regulated community on means aimed at reducing exposures. The NIEHS does not believe that other cancers or non cancer health outcomes provide sufficient evidence of a risk to currently warrant concern. 12 13 14 This statement is not sufficient to cause the NRC staff to change its position with respect to the chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of "UNCERTAIN" still appropriate and will continue to follow developments on this issue. 15 4.10. Socioeconomics 16 17 Section 2.2.9 of this SEIS describes socioeconomics in the vicinity of the LGS site. Table 4-9 lists the Category 1 and Category 2 issues related to socioeconomics. Table 4-9. Socioeconomics Issues 18 Issues GEIS Section Housing impacts Category 4.7.1 2 4.7.3, 4.7.3.3, 4.7.3.4, 4.7.3.6 1 Public services: public utilities 4.7.3.5 2 Public services: education (license renewal) 4.7.3.1 1 4.7.4 2 4.7.3.2 2 Historic and archaeological resources 4.7.7 2 Aesthetic impacts (license renewal term) 4.7.6 1 Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1 To be (a) determined 2 Public services: public safety, social services, and tourism and recreation Offsite land use (license renewal term) Public services: transportation Environmental justice minority and low-income populations Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2012b 19 4.10.1. Generic Socioeconomic Issues 20 21 22 23 24 25 The NRC staff did not identify any new and significant information during the review of the applicant's ER (Exelon 2011a), the NRC staff's site audit, the scoping process, or the evaluation of other available information. Therefore, there are no impacts related to Category 1 socioeconomic issues beyond those discussed in the GEIS. For these issues, the GEIS concluded that the impacts are SMALL, and additional site-specific mitigation measures are not likely to be sufficiently beneficial to warrant implementation. 4-28 Environmental Impacts of Operation 1 4.10.2. Housing 2 3 4 5 6 Appendix C of the GEIS presents a population characterization method based on two factors, sparseness and proximity (GEIS Section C.1.4). Sparseness measures population density within 20 mi (32 km) of the site, and proximity measures population density and city size within 50 mi (80 km). Each factor has categories of density and size (GEIS Table C.1). A matrix is used to rank the population category as low, medium, or high (GEIS Figure C.1). 7 8 9 10 11 12 13 14 15 16 17 According to the 2010 Census, an estimated 1,365,850 people live within 32.2 km (20 mi) of the LGS plant site, producing a population density of 420 persons per square kilometer (1,087 persons per square mile) (Exelon 2011a). This translates to a Category 4, "least sparse" population density using the GEIS measure of sparseness (greater than or equal to 120 persons per square mile within 20 miles). Approximately 8,311,616 people live within 80.4 kilometers (50 miles) of LGS, which equates to a population density of 409 persons per square kilometer (1,058 persons per square mile) (Exelon 2011a). As the region of influence (ROI) has a population greater than or equal to 190 persons per square mile within 80.4 kilometers (50 miles), this translates to a Category 4 (greater than or equal to 190 persons per square mile within 50 miles). Therefore, LGS is classified as being located in a high population area based on the GEIS sparseness and proximity matrix. 18 19 20 21 22 23 24 25 26 27 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability are expected to be of small significance in a medium or high density population area where growth-control measures are not in effect. Since LGS is located in a high population area and Montgomery, Berks, and Chester Counties are not subject to growth-control measures that would limit housing development; any changes in employment at LGS, Units 1 and 2 would have little noticeable effect on housing availability in these counties. Since Exelon has no plans to add non-outage employees during the license renewal period, employment levels at LGS, Units 1 and 2 would remain relatively constant with no new demand for permanent housing during the license renewal term. Based on this information, there would be no additional impact on housing during the license renewal term beyond what has already been experienced. 28 4.10.3. 29 30 31 32 33 Impacts on public utility services (e.g., water, sewer) are considered SMALL if the public utility has the ability to respond to changes in demand and would have no need to add or modify facilities. Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak demand. Impacts are considered LARGE if additional system capacity is needed to meet ongoing demand. 34 35 36 Analysis of impacts on the public water systems considered both plant demand and plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and actual use of water for reactor cooling at LGS, Units 1 and 2. 37 38 39 40 41 42 Since Exelon has no plans to add non-outage employees during the license renewal period, employment levels at LGS, Units 1 and 2 would remain relatively unchanged with no additional demand for public water services. Public water systems in the region are adequate to meet the demands of residential and industrial customers in the area. Therefore, there would be no impact to public water services during the license renewal term beyond what is currently being experienced. Public Services--Public Utilities 4-29 Environmental Impacts of Operation 1 4.10.4. Offsite Land Use 2 3 4 5 6 7 8 9 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, Subpart A, Appendix B, Table B-1). Table B-1 notes that "significant changes in land use may be associated with population and tax revenue changes resulting from license renewal." Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant operation during the license renewal term as SMALL when there will be little new development and minimal changes to an area's land-use pattern, as MODERATE when there will be considerable new development and some changes to the land-use pattern, and LARGE when there will be large-scale new development and major changes in the land-use pattern. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Tax revenue can affect land use because it enables local jurisdictions to provide the public services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of the GEIS states that the assessment of tax-driven land-use impacts during the license renewal term should consider: (1) the size of the plant's tax payments relative to the community's total revenues, (2) the nature of the community's existing land-use pattern, and (3) the extent to which the community already has public services in place to support and guide development. If the plant's tax payments are projected to be small relative to the community's total revenue, tax-driven land-use changes during the plant's license renewal term would be SMALL, especially where the community has pre-established patterns of development and has provided public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax payments by the plant owner are less than 10 percent of the taxing jurisdiction's revenue, the significance level would be SMALL. If tax payments are 10 to 20 percent of the community's total revenue, new tax-driven land-use changes would be MODERATE. If tax payments are greater than 20 percent of the community's total revenue, new tax-driven land-use changes would be LARGE. This would be especially true where the community has no pre-established pattern of development or has not provided adequate public services to support and guide development. 27 4.10.4.1. 28 29 30 31 Since Exelon has no plans to add non-outage employees during the license renewal period, there would be no plant operations-driven population increase in the vicinity of LGS, Units 1 and 2. Therefore, there would be no population-related offsite land use impacts during the license renewal term beyond those already being experienced. 32 4.10.4.2. 33 34 35 36 37 38 39 40 41 As discussed in Chapter 2, Exelon pays property taxes for LGS to the following entities in Montgomery and Chester Counties: Limerick Township, Spring-Ford Area School District, Lower Pottsgrove Township, Pottsgrove School District, Chester County, East Coventry Township, and Owen J. Roberts School District. Exelon also makes tax payments to taxing authorities in Bucks County, but the amounts are relatively minor. Since Exelon started making property tax payments to local jurisdictions, population has increased steadily and land has continued to be converted to residential and commercial uses in the affected counties--adding to the tax base of affected jurisdictions. Therefore, tax revenue from LGS as a proportion of total tax revenue has had little or no effect on land use conditions within these counties. 42 43 44 45 46 Since employment levels would remain relatively unchanged with no increase in the assessed value of LGS, annual property tax payments also would be expected to remain relatively unchanged throughout the license renewal period. Based on this information, there would be no tax-revenue-related offsite land use impacts during the license renewal term beyond those already being experienced. Population-Related Impacts Tax Revenue-Related Impacts 4-30 Environmental Impacts of Operation 1 4.10.5. Public Services--Transportation 2 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following: 3 4 5 6 Transportation impacts (level of service) of highway traffic generated during the term of the renewed license are generally expected to be of SMALL significance. However, the increase in traffic associated with additional workers and the local road and traffic control conditions may lead to impacts of MODERATE or LARGE significance at some sites. 7 8 9 10 11 12 13 The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of highway traffic generated by the proposed project on the level of service of local highways during the term of the renewed license. Since Exelon has no plans to add non-outage employees during the license renewal period; traffic volume and levels of service on roadways in the vicinity of LGS, Units 1 and 2 would not change. Therefore, there would be no transportation impacts during the license renewal term beyond those already being experienced. 14 4.10.6. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 This section provides the NRC staff's assessment of the effects on historic and archaeological resources from the proposed license renewal action for LGS, Units 1 and 2. The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects of their undertakings on historic properties. Historic properties are defined as resources that are eligible for listing on the National Register of Historic Places (NRHP). The criteria for NRHP eligibility are listed in 36 CFR 60.4 and include, among other things, (1) association with significant events that have made a significant contribution to the broad patterns of history, (2) association with the lives of persons significant in the past, (3) embodiment of distinctive characteristics of type, period, or method of construction, and (4) sites or places that have yielded or may be likely to yield important information in history or prehistory. The historic preservation review process (Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA)) is outlined in regulations issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800. In accordance with 36 CFR 800.8(c), the NRC has elected to use the National Environmental Policy Act of 1969, as amended (NEPA), process to comply with its obligations under Section 106 of the NHPA. 30 31 32 33 34 35 36 37 38 39 In accordance with 36 CFR 800.8(c), on September 16, 2011, and September 15, 2011, respectively, the NRC staff initiated consultations on the proposed action by writing to the Advisory Council on Historic Preservation and the Pennsylvania Bureau of Historic Preservation (BHP), which houses the Pennsylvania State Historic Preservation Office (NRC 2011a, 2011b). Previously, Exelon, outside of the NHPA process, consulted with the BHP on January 19, 2011, regarding the renewal of operating licenses for LGS, Units 1 and 2. Exelon stated in its letter to the BHP that there would be no effect on historic properties from license renewal and associated operation and maintenance activities (Exelon 2011a). The BHP responded to LGS on February 16, 2011, concluding that "due to the nature of the activity, it is our opinion that there will be no effect on these properties" (Exelon 2011a). 40 41 42 43 44 45 46 On September 13, 2011, the NRC staff initiated consultation with 15 Federally recognized tribes: the Absentee-Shawnee Tribe of Oklahoma, the Heron Clan, the Delaware Nation (located in Anadarko, Oklahoma), the Delaware Tribe (located in Emporia, Kansas), the Eastern Shawnee Tribe of Oklahoma, the Oneida Indian Nation, the Oneida Nation of Wisconsin, the Onondaga Nation, the Seneca Nations of Indians, the Seneca-Cayuga Tribe of Oklahoma, the St. Regis Mohawk Tribe, the Shawnee Tribe, the Stockbridge-Munsee Band of the Mohican Tribe, the Tonawanda Seneca Nation, and the Tuscarora Nation (see Appendix D for a list of Historic and Archaeological Resources 4-31 Environmental Impacts of Operation 1 2 3 4 5 these letters). In its letters, the NRC staff provided information about the proposed action, the definition of APE, and indicated that the NHPA review would be integrated with the NEPA process, according to 36 CFR 800.8(c). The NRC staff invited participation in the identification and possible decisions concerning historic properties and also invited participation in the scoping process. 6 7 8 Before the site audit in May 2011, the NRC staff contacted the BHP concerning license renewal for LGS and concluded there was no need to meet during the environmental audit to discuss cultural resources (NRC 2011c). 9 10 11 12 13 The NRC staff received scoping comments from two tribes, the Delaware Tribe and the Stockbridge Munsee Tribe, in September 2011, and one comment from the Onondaga Nation in October 2011. The tribes did not raise any concerns in their scoping comments and indicated there are no religious or culturally significant sites in the project area (see Appendix D). The NRC responded to the tribes concerning their scoping comments. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Section 2.2.10 describes the historic and cultural resources at the LGS site. Exelon currently has no planned changes or ground-disturbing activities associated with license renewal at LGS site (Exelon 2011a). Exelon is presently working with East Coventry Township and Chester County to rehabilitate and mothball the Fricks Lock Historic District located on its property. The rehabilitation and mothballing activities are specified to meet the Secretary of Interior's Standards for Rehabilitation and have been approved by the Pennsylvania Historical and Museum Commission Bureau for Historic Preservation (BHP 2011). Construction activity is expected to begin in 2012 (Exelon 2011a). Exelon has also developed a cultural resources management plan to manage known and potentially existing, or discovered archaeologically or historically significant cultural resources within the Owner-Controlled Area (OCA) of the LGS. The Plan addresses possible impacts from land-disturbing activities or other actions within the OCA that could introduce new noise, air, or visual element impacts to known cultural resources outside the OCA. The plan describes the process for initiating informal consultation with BHP and provides guidance on how to manage an unexpected discovery (Exelon 2012a). 28 29 30 31 32 33 34 For the purposes of NHPA Section 106 consultation, based on the (1) historic and cultural resources located within the APE, (2) tribal input, (3) Exelon's Cultural Resources Management Plan and the status of the Fricks Lock rehabilitation and mothball project, (4) the fact that there will be no changes or ground-disturbing activities that will occur as part of the relicensing of LGS, Units 1 and 2, (5) BHP finding of "no effect," and (6) the NRC staff's cultural resource analysis and consultation, the NRC staff concludes that license renewal will have no effect on historic properties (36 CFR 800.4(d)(1)). 35 36 37 For the purposes of the NRC staff's NEPA analysis, based on the items that lead to the above finding of no effect, the NRC staff concludes that potential impacts on historic and cultural resources related to operating LGS, Units 1 and 2 during the renewal term would be SMALL. 38 4.10.7. 39 40 41 42 43 44 45 46 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to environmental justice concerns, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, "Minority and low-income populations," to evaluate the impacts of continued operations and any refurbishment activities during the license renewal term on minority populations and low-income populations living in the vicinity of the plant. Environmental justice was listed in Table B-1 as a concern before this revised rule, but it was not evaluated in the 1996 GEIS and, therefore, is addressed in each SEIS. Environmental Justice 4-32 Environmental Impacts of Operation 1 2 3 4 5 6 7 Under Executive Order (EO) 12898 (59 FR 7629, February 16, 1994), Federal agencies are responsible for identifying and addressing, as appropriate, potential disproportionately high and adverse human health and environmental impacts on minority and low-income populations. In 2004, the NRC issued a Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040, August 24, 2004), which states that "[t]he Commission is committed to the general goals set forth in EO 12898, and strives to meet those goals as part of its NEPA review process." 8 9 The Council of Environmental Quality (CEQ) provides the following information in Environmental Justice: Guidance under the National Environmental Policy Act (CEQ 1997): 10 11 12 13 14 15 16 17 18 Disproportionately High and Adverse Human Health Effects. Adverse health effects are measured in risks and rates that could result in latent cancer fatalities, as well as other fatal or nonfatal adverse impacts on human health. Adverse health effects may include bodily impairment, infirmity, illness, or death. Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant (as employed by NEPA) and appreciably exceeds the risk or exposure rate for the general population or for another appropriate comparison group. 19 20 21 22 23 24 25 26 27 28 29 Disproportionately High and Adverse Environmental Effects. A disproportionately high environmental impact that is significant (as defined by NEPA) refers to an impact or risk of an impact on the natural or physical environment in a low-income or minority community that appreciably exceeds the environmental impact on the larger community. Such effects may include ecological, cultural, human health, economic, or social impacts. An adverse environmental impact is an impact that is determined to be both harmful and significant (as employed by NEPA). In assessing cultural and aesthetic environmental impacts, impacts that uniquely affect geographically dislocated or dispersed minority or low-income populations or American Indian tribes are considered. 30 31 32 33 34 The environmental justice analysis assesses the potential for disproportionately high and adverse human health or environmental effects on minority populations and low-income populations that could result from the operation of LGS during the renewal term. In assessing the impacts, the following definitions of minority individuals and populations and low-income population were used (CEQ 1997): 35 36 37 38 39 40 ? Minority individuals. Individuals who identify themselves as members of the following population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, or two or more races--meaning individuals who identified themselves on a Census form as being a member of two or more races (e.g., Hispanic and Asian). 41 42 43 44 45 ? Minority populations. Minority populations are identified when the minority population of an affected area exceeds 50 percent or the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general population or other appropriate unit of geographic analysis. 46 47 48 ? Low-income population. Low-income populations in an affected area are identified with the annual statistical poverty thresholds from the Census Bureau's Current Population Reports, Series P60, on Income and Poverty. 4-33 Environmental Impacts of Operation 1 4.10.7.1. 2 3 4 5 According to 2010 Census data, 34.5 percent of the population residing within a 50-mi (80-km) radius of LGS identified themselves as minority individuals. The largest minority group was Black or African American (17 percent), followed by Hispanic or Latino (of any race) (9.1 percent) (CAPS 2012). 6 7 8 9 According to 2010 Census data, minority populations in the socioeconomic ROI (Berks, Chester, and Montgomery Counties) comprised 20.6 percent of the total three-county population (see Table 2-9) (USCB 2011). Figure 4-1 shows minority population block groups, using 2010 Census data for race and ethnicity, within a 50-mile (80-kilometer) radius of LGS. 10 11 12 13 14 15 16 Census block groups were considered minority population block groups if the percentage of the minority population within any block group exceeded 34.5 percent (the percent of the minority population within the 50-mi radius of LGS). A minority population block group exists if the percentage of the minority population within the block group is meaningfully greater than the minority population percentage in the 50-mi (80-km) radius. Approximately 2,030 of the 5,800 census block groups located within the 50-mi (80-km) radius of LGS were determined to have meaningfully greater minority populations. 17 18 19 20 21 Minority population block groups are concentrated in the Philadelphia Metropolitan Area, with smaller concentrations in Reading and Allentown, Pennsylvania. The minority population block group nearest to LGS is located in Sanatoga, Limerick Township, Pennsylvania. According to the 2010 Census, approximately 20.7 percent of the total Sanatoga population (which includes more than one census block group) identified themselves as minority. Minority Population 4-34 Environmental Impacts of Operation 1 Figure 4-1. 2010 Census Minority Block Groups within a 50-mi Radius of the LGS * D Cities . . Aggregate Minority plus Hispanic Limerick Generating Station D County Boundaries 0 3 6 12 18 24 llocio-=i--iC==:::.i-- Miles 50 mile Boundary Source: USCB 2011 4-35 Environmental Impacts of Operation 1 4.10.7.2. 2 3 4 5 6 7 8 According to 2010 American Community Survey Census data, an average of 7.7 percent of families and 10.4 percent of individuals residing in counties within a 50-mile radius of LGS (Burlington, Camden, Gloucester, Hunterdon, Mercer, Salem, Somerset, and Warren, New Jersey; Berks, Bucks, Carbon, Chester, Delaware, Lancaster, Lebanon, Lehigh, Monroe, Montgomery, Northampton, Philadelphia, and Schuylkill, Pennsylvania; Cecil, Maryland; and New Castle, Delaware) were identified as living below the Federal poverty threshold in 2010. The 2010 Federal poverty threshold was $22,314 for a family of four (USCB 2011). Low-Income Population 9 10 11 12 13 14 15 16 17 18 19 According to the 2010 Census, 9.3 percent of families and 13.4 percent of individuals in Pennsylvania were living below the Federal poverty threshold in 2010, and the median household income for Pennsylvania was $49,288 (USCB 2011). All three counties in the immediate ROI of LGS had higher median household incomes and Montgomery and Chester Counties had lower percentages of families and individuals living below the poverty level when compared to the state average. Berks County had a median household income average of $51,719 and 14.1 percent of individuals and 10.9 percent of families living below the poverty level. Chester County had a median household income average of $82,284 and 6.2 percent of individuals and 3.6 percent of families living below the poverty level. Montgomery County had a median household income of $75,448 and 5.5 percent of individuals and 3.6 percent of families living below the poverty level (USCB 2011). 20 21 22 23 24 25 26 Figure 4-2 shows low-income census block groups within a 50-mile (80-kilometer) radius of LGS. Census block groups were considered low-income population block groups if the percentage of individuals living below the Federal poverty threshold within any block group exceeded the percent of the individuals living below the Federal poverty threshold within the 50-mile radius of LGS. Approximately 2,070 of the 5,800 census block groups located within the 50-mile (80-kilometer) radius of LGS were determined to have meaningfully greater low-income populations. 27 28 29 30 Similar to the locations of minority population block groups, the majority of low-income population block groups are located in the Philadelphia metropolitan area, with smaller concentrations in Reading and Allentown, Pennsylvania. The nearest low-income population to LGS is located in Sanatoga, Limerick Township, Pennsylvania. 4-36 Environmental Impacts of Operation 1 Figure 4-2. 2010 Census Low-Income Block Groups within a 50-mi Radius of LGS * D Cities . . Low Income Population Limerick Generating Station D 50 mile Boundary County Boundaries 0 _ State Boundaries _i Source: UCSB 2011 4-37 3 6 12 18 24 J.::i.::::i.-..:::::==o-oMiles Environmental Impacts of Operation 1 4.10.7.3. 2 3 4 5 6 7 The NRC addresses environmental justice matters for license renewal through (1) identifying the location of minority and low-income populations that may be affected by the continued operation of the nuclear power plant during the license renewal term, and (2) determining whether there would be any potential human health or environmental effects to these populations and special pathway receptors, and (3) determining if any of the effects may be disproportionately high and adverse. Analysis of Impacts 8 9 10 11 12 13 Figures 4-1 and 4-2 identify the location of minority and low-income block group populations residing within a 50-mi (80-km) radius of LGS. This area of impact is consistent with the impact analysis for public and occupational health and safety, which also focuses on populations within a 50-mi (80-km) radius of the plant. Chapter 4 presents the assessment of environmental and human health impacts for each resource area. The analyses of impacts for all environmental resource areas indicated that the impact from license renewal would be SMALL. 14 15 16 17 18 19 20 21 22 23 Potential impacts to minority and low-income populations (including migrant workers or Native Americans) would mostly consist of socioeconomic and radiological effects; however, radiation doses from continued operations during the license renewal term are expected to continue at current levels and would remain within regulatory limits. Socioeconomic effects were likewise found to be SMALL. Chapter 5 of this SEIS discusses the environmental impacts from postulated accidents that might occur during the license renewal term, which include both design-basis and severe accidents. The Commission has generically determined that impacts associated with design-basis accidents are small because nuclear plants are designed and operated to successfully withstand such accidents, and the probability weighted impact risks associated with severe accidents are also small. 24 25 26 27 Therefore, based on this information and the analysis of human health and environmental impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high and adverse impacts to minority and low-income populations from the continued operation of LGS during the license renewal term. 28 29 30 31 32 33 34 As part of addressing environmental justice concerns associated with license renewal, the NRC also assessed the potential radiological risk to special population groups (such as migrant workers or Native Americans) from exposure to radioactive material received through their unique consumption and interaction with the environment patterns, including subsistence consumption of fish, native vegetation, surface waters, sediments, and local produce; absorption of contaminants in sediments through the skin; and inhalation of airborne radioactive material released from the plant during routine operation. This analysis is presented below. 35 4.10.7.4. 36 37 38 The special pathway receptors analysis is an important part of the environmental justice analysis because consumption patterns may reflect the traditional or cultural practices of minority and low-income populations in the area, such as migrant workers or Native Americans. 39 40 41 42 43 44 45 46 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and appropriate, to collect, maintain, and analyze information on the consumption patterns of populations that rely principally on fish and/or wildlife for subsistence and to communicate the risks of these consumption patterns to the public. In this SEIS, the NRC staff considered whether there were any means for minority or low-income populations to be disproportionately affected, and it considered this by examining impacts to American Indians, Hispanics, migrant workers, and other traditional lifestyle special pathway receptors. Special pathways took into account the levels of radiological and nonradiological contaminants in native vegetation, crops, Subsistence Consumption of Fish and Wildlife 4-38 Environmental Impacts of Operation 1 2 soils and sediments, groundwater, surface water, fish, and game animals on or near LGS were considered. 3 4 5 The following is a summary discussion of the NRC staff's evaluation from Section 4.9.2 of the radiological environmental monitoring programs (REMPs) that assess the potential impacts for subsistence consumption of fish and wildlife near the LGS site. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Exelon has an ongoing comprehensive REMP to assess the impact of LGS operations on the environment. To assess the impact of nuclear power plant operations, samples are collected annually from the environment and analyzed for radioactivity. A plant effect would be indicated if the radioactive material detected in a sample was significantly larger than background levels. Two types of samples are collected. The first type, control samples, are collected from areas that are beyond the measurable influence of the nuclear power plant or any other nuclear facility. These samples are used as reference data to determine normal background levels of radiation in the environment. These samples are then compared with the second type of samples, indicator samples, collected near the nuclear power plant. Indicator samples are collected from areas where any contribution from the nuclear power plant will be at its highest concentration. These samples are then used to evaluate the contribution of nuclear power plant operations to radiation or radioactivity levels in the environment. An effect would be indicated if the radioactivity levels detected in an indicator sample was significantly larger than the control sample or background levels. 20 21 22 23 24 25 26 27 Samples of environmental media are collected from the aquatic and terrestrial pathways in the vicinity of LGS. Nine hundred and twenty-six radiological environmental samples were collected and analyzed in 2010. The aquatic pathways include groundwater, surface water, drinking water, fish, and shoreline sediment. The terrestrial pathways include airborne particulates, milk, food products (i.e., leafy vegetables, such as cabbage, collards, Swiss Chard, collected from gardens in the vicinity of LGS), and wild animal feed (i.e., broad leaf vegetation). During 2010, analyses performed on samples of environmental media at LGS showed no significant or measurable radiological impact above background levels from site operations (Exelon 2011b). 28 4.10.8. 29 30 31 32 Based on the radiological environmental monitoring data from LGS, the NRC staff finds that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations in the region as a result of subsistence consumption of water, local food, fish, and wildlife. 33 4.11. Evaluation of New and Potentially Significant Information 34 35 36 37 38 New and significant information is: (1) information that identifies a significant environmental issue not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, or (2) information that was not considered in the analyses summarized in the GEIS and that leads to an impact finding that is substantially different from the finding presented in the GEIS and codified in 10 CFR Part 51. 39 40 41 42 43 44 45 The new and significant assessment that Exelon conducted during the preparation of the license renewal application included: (1) interviews with Exelon subject-matter experts on the validity of the conclusions in the GEIS as they relate to LGS, (2) review of the results of LGS environmental monitoring and reporting, as required by regulations and oversight of plant facilities and operations by state and Federal regulatory agencies, (3) a review of correspondence with state and Federal agencies to determine if agencies had concerns relevant to their resource areas that had not been addressed in the GEIS, (4) a review for Conclusion 4-39 Environmental Impacts of Operation 1 2 3 4 issues relevant to the LGS application of certain license renewal applications that operators of other nuclear plants have previously submitted to the NRC, (5) an extensive review of documents related to environmental issues at LGS, and (6) a review of information related to severe accident mitigation. 5 6 7 8 9 10 11 12 13 14 15 16 The NRC also has a process for identifying new and significant information, which is described in NUREG-1555, Supplement 1, "Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1; Operating License Renewal" (NRC 1999b). The search for new information includes: (1) review of an applicant's ER and the process for discovering and evaluating the significance for new information, (2) review of records for public comments, (3) review of environmental quality standards and regulations, (4) coordination with Federal, state, and local environmental protection and resource agencies, and (5) review of the technical literature. New information discovered by the NRC staff is evaluated for significance using criteria set forth in the GEIS. For Category 1 issues in which new and significant information is identified, reconsideration of the conclusions for those issues is limited in scope to the assessment for the relevant new and significant information; the scope of the assessment does not include other facets of an issue that are not affected by the new information. 17 18 19 20 21 22 23 24 25 Exelon reported in its ER (Exelon 2011a) that it was aware of one new radiological issue associated with the renewal of the LGS operating license--tritium in groundwater. In 2006, Exelon implemented a fleet-wide program to proactively review the environmental status of its nuclear power generating stations, specifically to identify the potential for releases of radionuclides. The program is consistent with the guidance provided in NEI 07-07, "Industry Ground Water Protection Initiative-Final Guidance Document." As part of this program, Exelon commissioned a hydrogeologic investigation of LGS to evaluate any groundwater impact from radionuclides that may have been released from the plant. Exelon also developed its RGPP during this time. 26 27 28 29 30 31 A groundwater monitoring well network for LGS's groundwater protection program was designed and installed to gather any radionuclide release data. Monitoring was initiated in 2006 and performed at least semi-annually on each monitoring well. The results of the program, including trending data, program modifications, reporting protocols, and other information are included in the annual LGS radiological environmental operating reports. Neither Sr-90 nor any LGS-related gamma-emitting radionuclides have been identified in any groundwater sample. 32 33 34 35 The reporting level for tritium in groundwater specified in the Exelon Offsite Dose Calculation Manual (ODCM) is equal to the EPA drinking water standard of 20,000 picocuries per liter (pCi/L). The ODCM specifies a detection capability of 200 pCi/L for analyzing tritium concentrations in groundwater samples. 36 37 38 39 40 41 42 43 The groundwater monitoring data are reported in the annual LGS REMP reports. Sampling of the monitoring well network at LGS has not identified any tritium concentration greater than 20,000 pCi/L. Tritium was detected during a 2006 site investigation at a concentration of 2,020 ? 154 pCi/L in a sample collected from the power block foundation sump, which accumulates water from the drain system around the power block. This water is not in direct contact with groundwater and, therefore, also is not reflective of groundwater quality beneath LGS. Tritium concentrations greater than 2,000 pCi/L, but below the reporting level of 20,000 pCi/L, have been detected in power block foundation sump samples on other occasions since 2006. 44 45 46 47 48 Exelon's evaluation of the groundwater monitoring data concluded that there are no significant impacts associated with tritium in groundwater down gradient of LGS. This conclusion is based on the following information. Sampling of the monitoring well network at LGS has not identified tritium concentrations greater than the reporting level of 20,000 pCi/L. There is no groundwater connectivity with the monitoring points that have shown tritium concentrations greater than 4-40 Environmental Impacts of Operation 1 2 3 4 5 6 7 2,000 pCi/L. None of the wells that have detectable tritium are used by workers or members of the public for drinking water. The applicant's groundwater protection monitoring program and REMP will continue to monitor the groundwater and report the results in the annual radioactive effluent operating reports. Also, NRC inspectors will periodically review the REMP data for compliance with NRC radiation protection standards. Based on the above, the NRC staff concludes that the issue of tritium contamination of the groundwater on the LGS site is not significant. 8 4.12. Cumulative Impacts 9 10 11 12 13 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to cumulative impacts, the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, "Cumulative impacts," to evaluate the potential cumulative impacts of license renewal. 14 15 16 17 18 19 20 21 22 23 The NRC staff considered potential cumulative impacts in the environmental analysis of continued operation of the LGS nuclear plant during the 20-year license renewal period. Cumulative impacts may result when the environmental effects associated with the proposed action are overlaid or added to temporary or permanent effects associated with other past, present, and reasonably foreseeable actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time. It is possible that an impact that may be SMALL by itself could result in a MODERATE or LARGE cumulative impact when considered in combination with the impacts of other actions on the affected resource. Likewise, if a resource is regionally declining or imperiled, even a SMALL individual impact could be important if it contributes to or accelerates the overall resource decline. 24 25 26 27 28 29 30 31 For the purposes of this cumulative analysis, past actions are those before the receipt of the license renewal application. Present actions are those related to the resources at the time of current operation of the power plant, and future actions are those that are reasonably foreseeable through the end of plant operation, including the period of extended operation. Therefore, the analysis considers potential impacts through the end of the current license terms as well as the 20-year renewal license term. The geographic area over which past, present, and reasonably foreseeable actions would occur depends on the type of action considered and is described below for each resource area. 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described in Sections 4.1 to 4.10, are combined with other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such actions. The NRC staff used the information provided in the ER; responses to requests for additional information; information from other Federal, state, and local agencies; scoping comments; and information gathered during the visits to the LGS site to identify other past, present, and reasonably foreseeable actions. To be considered in the cumulative analysis, the NRC staff determined if the project would occur within the noted geographic areas of interest and within the period of extended operation, was reasonably foreseeable, and if there would be potential overlapping effect with the proposed project. For past actions, consideration within the cumulative impacts assessment is resource and project-specific. In general, the effects of past actions are included in the description of the affected environment in Chapter 2, which serves as the baseline for the cumulative impacts analysis. However, past actions that continue to have an overlapping effect on a resource potentially affected by the proposed action are considered in the cumulative analysis. 4-41 Environmental Impacts of Operation 1 2 3 Other actions and projects identified during this review and considered in the NRC staff's independent analysis of the potential cumulative effects are described in Appendix F. Examples of other actions that were considered in this analysis include the following: 4 5 6 7 8 9 o o o o o o Cromby Generating Station, Titus coal plant, independent spent fuel storage installation, transmission lines future urbanization, and Schuylkill River greenway. 10 4.12.1. Air Quality 11 12 13 14 15 16 17 18 19 20 21 22 This section addresses the direct and indirect effects of license renewal on air quality resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. As described in Section 4.2, the incremental impacts on air quality from the proposed license renewal would be SMALL, as there is no planned refurbishment associated with the LGS license renewal. The geographic area considered in the cumulative air quality analysis is the county of the proposed action because air quality designations for criteria air pollutants are generally made at the county level. Counties are further grouped together based on a common air shed--known as an air quality control region (AQCR)--to provide for the attainment and maintenance of the National Ambient Air Quality Standards (NAAQS). The LGS site is located in Montgomery and Chester Counties, Pennsylvania, and is part of the Metropolitan Philadelphia Intrastate AQCR (40 CFR 81.15). Additional counties in this AQCR include Bucks, Delaware, and Philadelphia Counties. 23 24 25 26 27 28 29 Section 2.2.2 presents a summary of the air quality designation status for Montgomery and Chester Counties. As noted in Section 2.2.2, EPA regulates six criteria pollutants under the NAAQS, including carbon monoxide, lead, nitrogen dioxide, ozone, sulfur dioxide, and particulate matter. Montgomery and Chester Counties are designated unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). All other counties in this AQCR are similarly designated with respect to the NAAQS criteria pollutants. 30 31 32 33 34 35 36 37 Criteria pollutant air emissions from the LGS site are presented in Section 2.2.2.1; these emissions are principally from standby diesel generators, boilers, two cooling towers, and a spray pond. Air pollutants from these sources are permitted under a Title V operating permit (TVOP-46-00038) (Exelon 2011a). In Section 4.2, it was noted that there would be no new air emissions associated with the LGS license renewal because there is no planned site refurbishment. Therefore, cumulative changes to air quality in Montgomery and Chester Counties would be the result of changes to present-day emissions from other existing facilities as well as future projects and actions within the county. 38 39 40 41 42 43 44 45 46 Appendix F provides a list of present and reasonably foreseeable projects that could contribute to cumulative impacts to air quality. Continued air emissions from existing projects and actions listed in Appendix F as well as proposed new source activities would contribute to air emissions in Montgomery and Chester Counties and will affect air quality within the region. Development and construction activities associated with regional growth of housing, business, and industry, as well as associated vehicular traffic, also will result in additional air emissions. Project timings and locations, which are difficult to predict, affect cumulative impacts to air quality. However, permitting and licensing requirements, efficiencies in equipment, cleaner fuels, and various mitigation measures can be used to minimize cumulative air quality impacts. 4-42 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 The effects of global climate change are already being felt in the northeastern United States, including an increase in annual average temperatures since 1970. This warming has resulted in many other climate-related changes, such as more frequent days over 90 ?F (32 ?C), increased heavy precipitation, less snow and more rain in winter, reduced snowpack, earlier spring snowmelt, and rising sea temperatures and sea level. The Northeast is projected to face continued warming and more extensive climate-related changes. Extreme heat and declining air quality (notably ozone) could affect human health. States, however, must continue to comply with the Clean Air Act, so it is likely that additional limitations on ozone precursors could help counteract this effect. 10 11 12 13 14 15 16 The overall warming trend also affects patterns of agricultural production and fisheries in the region, and the projected reduction in snow cover would adversely affect winter recreation and its related industries. Above all, more frequent flooding due to the sea-level rise and heavy downpours would have severe impacts on densely populated coastal areas, resulting in storm surges, coastal flooding, erosion, losses of life, property damage, and loss of wetlands (Karl et al. 2009). While these impacts are the result of changing atmospheric conditions, most of them are not, in and of themselves, air quality impacts. 17 18 19 20 21 22 23 24 Given that there is no planned plant refurbishment associated with the LGS license renewal, and therefore no expected changes in air emissions, cumulative air quality impacts in Montgomery and Chester Counties would be the result of changes to present-day emissions and emissions from reasonably foreseeable projects and actions. As NRC staff noted above, project timings and locations, which are difficult to predict, affect cumulative impacts to air quality. However, various strategies and techniques are available to limit air quality impacts. Therefore, the NRC staff concludes that the cumulative air quality impacts from the proposed license renewal and other past, present, and reasonably foreseeable projects would be SMALL. 25 4.12.2. 26 27 28 29 30 31 32 33 34 35 36 37 38 This section addresses the direct and indirect effects of license renewal on water resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. As described in Sections 4.4 and 4.5, the incremental impacts on water resources from continued operations of LGS, Units 1 and 2 during the license renewal term would be SMALL. NRC staff also conducted an assessment of other projects and actions for consideration in determining their cumulative impacts on water resources (see Appendix F). The geographic area considered for the surface water resources component of the cumulative impacts analysis spans the Delaware River Basin. For groundwater, the area considered encompasses the local groundwater basin relative to LGS in which groundwater is recharged and flows to discharge points, or is withdrawn through wells. As such, this review focused on those projects and activities that would (1) withdraw water from or discharge wastewater to the Delaware River or its tributaries (i.e., the Schuylkill River) and/or (2) would use groundwater or could otherwise affect the bedrock aquifer beneath the LGS site. 39 4.12.2.1. 40 41 42 43 44 45 46 47 Water resource managers must balance multiple conflicting water management objectives. Within the Delaware River Basin, this includes demands for power generation, municipal water, industrial water, agricultural water, mining, recreation, flood protection, and instream flow requirements to sustain aquatic life (see Section 4.12.2). The Delaware River Basin Commission (DBRC) was formed to balance these objectives. These tradeoff decisions reflect an understanding of the inevitable uncertainty in regulated flows that result from inter-annual and intra-annual variability. Based on the USGS gage on the Schuylkill River at Pottstown, Pennsylvania, for water years 1928 to 2010, the highest annual mean flow and lowest annual Water Resources Cumulative Impacts on Surface Water Resources 4-43 Environmental Impacts of Operation 1 2 3 4 mean flow recorded are 3,211cfs (90.7 m3/s) and 843 cfs (23.8 m3/s), respectively. The highest daily mean flow and the lowest daily mean flow recorded are 71,200 cfs (2,011 m3/s) and 175 cfs (4.9 m3/s), respectively (USGS 2010). This magnitude of variability reflects climate variability and no other projects within the basin. 5 6 7 8 9 10 11 To support full operations of LGS, Units 1 and 2, Exelon must withdraw up to 42 mgd or 29,200 gpm (65 cfs or 1.8 m3/s) of water from either the Schuylkill River or other sources for consumptive cooling water use, as further described in Section 2.1.7.1 of this SEIS. Surface water withdrawals by LGS, like other similar surface water users in the basin, are subject to limits and conditions imposed by DRBC dockets. Relative to the cited magnitude of variability of flows in the Schuylkill River, the hydrologic impacts of surface water withdrawals associated with LGS operations are very small. 12 13 14 15 16 17 18 19 20 21 22 In general, water quality across the Delaware River Basin has dramatically improved over the past several decades. The water quality of the Delaware River and its main tributaries, such as the Schuylkill River, was profoundly impaired by municipal and industrial waste discharges and mining activities. Regulatory changes, including implementation of the Clean Water Act, have eliminated many of the largest point and nonpoint sources of water quality degradation. Still, within this context, the trend in urban and suburban development in the immediate LGS region (see Sections 4.12.3 and 4.12.4) and associated corridor-type development (e.g., roads) to keep pace with overall population growth in the Delaware River Basin has introduced a different impact dynamic. From the perspective of water quality, these types of development generally substitute more diffuse sources of pollution (i.e., nonpoint) and their impacts for point sources traditionally associated with industry. 23 24 25 26 27 28 29 30 Nevertheless, the segment of the Schuylkill River near LGS meets all established water quality standards at present, as further described in Section 2.2.4.1. The DRBC is responsible for classifying all waters in the basin as to use, setting basin-wide water quality standards, establishing pollutant treatment and control regulations, and reviewing projects or other undertakings with the potential to affect basin water resources for conformance with the DRBC Comprehensive Plan (DRBC 2001). DRBC acts in coordination with the states and other parties that are signatories to the DRBC Compact (DRBC 1961) to include the imposition of necessary effluent limitations on industrial wastewater discharges to surface water. 31 32 33 34 35 36 37 38 39 40 In addition, the NRC staff considered the U.S. Global Change Research Program's (USGCRP's) most recent compilation of the state of knowledge relative to global climate change effects (Karl 2009). Temperatures in the Northeastern United States are projected to rise an additional 2.5 to 4 ?F (1.4 to 2.2 ?C) in winter and 1.5 to 3.5 ?F (0.8 to 1.9 ?C) in the summer by about 2050. This would be in addition to the 2 ?F (1.1 ?C) increase in annual average temperature that has occurred since 1970. Sea level is expected to continue to rise. While there is great uncertainty, sea levels are expected to rise between 3 and 4 ft (0.9 to 1.2 m) by the end of this century. Meanwhile, precipitation and runoff are projected to increase in the winter and spring across the Northeast. Increased runoff generally equates to increased streamflow (Karl et al. 2009). 41 42 43 44 45 46 47 Without an offsetting increase in discharge in the Delaware River, any sea level rise associated with climate change will cause increased upstream saltwater migration and potentially affect fresh water withdrawals upstream of the salt line (see Section 2.2.4.1). This could lead to fresh water availability and water use conflicts. Moreover, permitting agencies, principally the PADEP and the DRBC, could have to consider imposing more stringent effluent limits on power plant discharges, should water temperatures rise. These predictions, if borne out, have important implications for the Delaware River Basin as a whole, but the overall interaction of predicted 4-44 Environmental Impacts of Operation 1 2 hydrologic changes and their effect on water users in the Delaware River Basin is highly speculative at the present time. 3 4 5 6 7 8 9 10 Surface water withdrawals for LGS operations are a small fraction of the mean annual flow of the Schuylkill River, and the discharge of cooling tower blowdown has not significantly affected ambient surface water quality. The NRC staff did not identify any exceptional limitations to water resources. The NRC staff concludes that the cumulative impacts from past, present, and reasonably foreseeable future actions on surface water resources during the license renewal term would be SMALL. This conclusion is based on the regulatory framework established by the DBRC and PADEP in managing surface water use and quality and the generally improving trend in conditions in the Schuylkill River and within the Delaware River Basin. 11 4.12.2.2. 12 13 14 15 16 The Brunswick bedrock aquifer is the most widespread source of groundwater in the plant region and across the Triassic lowlands of the Newark Basin. LGS's four groundwater production wells are completed in the Brunswick aquifer system along with over 50 domestic and several other commercial/industrial supply wells within a 1-mi (1.6-km) radius of LGS (see Section 2.2.5.1). 17 18 19 20 The DRBC promulgated its Ground Water Protected Area Regulations (DRBC 1999; 18 CFR 430) to manage groundwater resources in the Triassic lowland and adjacent areas in southeastern Pennsylvania. LGS and its regulated production wells are located in the Schuylkill-Sprogels Run Subbasin, as delineated by the DRBC (DRBC 1999; Exelon 2011a). 21 22 23 24 25 26 27 28 29 The DRBC has established a total maximum withdrawal limit of 1,455 million gal/yr (mgy) (5.49 million m3/yr) for the subbasin. It has also set a withdrawal level of 1,091 mgy (4.12 million m3/yr) as that level where groundwater resources of the subbasin would be "potentially stressed" (DRBC 1999; 18 CFR 430). Nonetheless, total net annual groundwater withdrawals in the subbasin are currently well below the DRBC limits at 174.89 mgy (0.66 million m3/yr) (DRBC 2011). As described in Section 2.1.7.2, total LGS site groundwater withdrawals have averaged about 31,500 gpd or 11.5 mgy (0.04 million m3/yr). This withdrawal is about 0.8 and 1.1 percent, respectively, of the DRBC established thresholds for groundwater withdrawals in the Schuylkill-Sprogels Run Subbasin. 30 31 32 33 34 35 36 37 38 39 LGS operations have resulted in inadvertent releases of liquids containing tritium to the bedrock aquifer, as described in Sections 4.5.2 and 2.2.5.2 of this SEIS. However, there has been no migration of tritium in groundwater exceeding 2,000 pCi/L, and tritium levels have been well below the EPA primary drinking water standard (i.e., 20,000 pCi/L) at all onsite monitoring wells. In addition, there are no potable water users downgradient of the LGS power block that have been affected by the inadvertent releases. As site groundwater locally discharges to the Schuylkill River and Possum Hollow Run where rapid mixing and dilution occurs, there is no drinking water pathway to other groundwater users. Meanwhile, Exelon maintains an ongoing RGPP at LGS to detect and correct the source of inadvertent releases of radionuclide-containing liquids. 40 41 42 43 44 45 46 47 In summary, the DRBC has established limits on total groundwater withdrawals in the local groundwater subbasin, and current total withdrawals for all projects identified in this review are a small percentage of the established thresholds for the subbasin. LGS groundwater withdrawals are not expected to increase during the license renewal term. Further, inadvertent releases of liquids containing tritium have not impacted groundwater quality beyond the site boundary, and there is no pathway to other drinking water users. Tritium levels as measured in groundwater on site are well below the EPA drinking water standard and a program is in place to safeguard groundwater quality. Based on the above considerations, the NRC staff concludes that the Cumulative Impacts on Groundwater Resources 4-45 Environmental Impacts of Operation 1 2 cumulative impacts from past, present, and reasonably foreseeable future actions on groundwater use and quality during the license renewal term would be SMALL. 3 4.12.3. Aquatic Resources 4 5 6 7 8 9 10 11 This section addresses the direct and indirect effects of license renewal on aquatic resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. As described in Section 4.6, the incremental impacts on aquatic biota from the proposed license renewal would be SMALL. The geographic area considered in the cumulative aquatic resources analysis includes the LGS cooling water sources in the vicinity of intake and discharge structures on the Schuylkill River, the Perkiomen Creek, the Delaware River, and along the East Branch Perkiomen Creek and Perkiomen Creek where water from the Delaware River is discharged to augment flows to the Perkiomen Creek. 12 13 14 The benchmark for assessing cumulative impacts on aquatic resources takes into account the preoperational environment as recommended by the EPA (1999), for its review of NEPA documents, as follows: 15 16 17 18 19 20 21 22 23 24 25 26 27 Designating existing environmental conditions as a benchmark may focus the environmental impact assessment too narrowly, overlooking cumulative impacts of past and present actions or limiting assessment to the proposed action and future actions. For example, if the current environmental condition were to serve as the condition for assessing the impacts of relicensing a dam, the analysis would only identify the marginal environmental changes between the continued operation of the dam and the existing degraded state of the environment. In this hypothetical case, the affected environment has been seriously degraded for more than 50 years with accompanying declines in flows, reductions in fish stocks, habitat loss, and disruption of hydrologic functions. If the assessment took into account the full extent of continued impacts, the significance of the continued operation would more accurately express the state of the environment and thereby better predict the consequences of relicensing the dam. 28 29 30 31 32 33 34 35 36 37 38 Sections 2.2.4 and 2.2.6 present an overview of the condition of the Schuylkill River, Perkiomen Creek, East Branch Perkiomen Creek, and the Delaware River at the Point Pleasant Pumping Station, and the history and factors that led to current conditions. The direct and indirect impacts from water use and industrial discharge, such as mining waste water, are some of the most influential human activities on the Delaware River Basin (DRBC 2010a). Within the Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek, increased urbanization over the past 100 years has also led to increased runoff and elevated levels of pollutants within (Rhoads and Block 2008). On the Schuylkill River, the construction of dams beginning in the early 1800s blocked anadromous fish migrations and resulted in the decline of American shad, river herring, and blueback herring, which require movement between freshwater and marine waters to complete their life cycles (Perillo and Butler 2009). 39 40 41 42 Many natural and anthropogenic activities can influence the current and future aquatic biota in the area surrounding the LGS site and the Delaware River Basin. Potential biological stressors include operational impacts from LGS (as described in Section 4.6), increasing urbanization, energy development, and climate change. 43 4.12.3.1. 44 45 46 47 Interlandi and Crockett (2003) reported an increase in residential and commercial development for the area surrounding LGS along the Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek, and a decrease in population near Philadelphia. Increased urbanization has led to increases in dissolved nitrate and chloride levels in the Schuylkill River. Urbanization will Urbanization and Water Quality 4-46 Environmental Impacts of Operation 1 2 3 4 likely continue to contribute significant organic and metal pollutants to the river through runoff (Interlandi and Crockett 2003). The DRBC and EPA manage and set total maximum daily load (TMDL) limits for contaminants, such as polychlorinated biphenyl (PCBs), to help control future pollution of waters within the Delaware River Basin (DRBC 2008, EPA 2007). 5 6 7 8 9 10 11 12 13 14 15 Several other facilities within 10 miles (16 km) of LGS have NPDES permits to discharge into the Schuylkill River, which contributes to the cumulative impacts to aquatic habitats (EPA 2012a). For example, six municipal wastewater treatment facilities discharge treated wastewater to the Schuylkill River for a total discharge of less than 9 mgd (Appendix F). In addition, at least seven major industrial facilities, such as industrial laundry facilities, chemical production facilities, and aluminum die casting facilities, discharge into the Schuylkill River. Two municipal and one industrial treatment facilities discharge to Perkiomen Creek with a maximum total discharge of 2.0 mgd (Appendix F). Three major industrial facility NPDES permits for water discharge to Perkiomen Creek exist within a 10-mi (16-km) radius of LGS. Little effect to aquatic habitats from industrial and wastewater discharges is expected assuming that facilities comply with NPDES permit limitations. 16 4.12.3.2. 17 18 19 20 21 22 23 24 25 26 27 A number of energy plants withdraw water from the Schuylkill and Delaware Rivers. Within 30 miles (48 km) of LGS, one oil plant and one natural-gas plant also withdraw and discharge to the Schuylkill River. In 2011, Exelon decommissioned two coal-fired units on the Schuylkill River at Cromby Generating Station (Appendix F). Two coal and two natural-gas plants operate near the confluence of the Delaware and Schuylkill Rivers, and use tidal Delaware River water as the main water source. In 2005, DRBC annual consumptive surface water use records show Eddystone Generating Station Coal Plant at 897 million gallons per year (MGY) (3.4 million m3), Florida Power & Light Energy Marcus Hook gas plant at 1,018 MGY (3.85 million m3), and Fairless Energy at 495 MGY (1.87 million m3) (DRBC 2012a). These energy plants use water resources shared by LGS, but do not affect habitats or aquatic biota directly associated with the LGS cooling system. 28 29 30 31 32 33 34 35 36 37 38 39 40 Marcellus shale formation underlies approximately 36 percent of the Delaware River Basin and energy companies are actively seeking to mine the natural gas deposits within the Marcellus Shale (DRBC 2012b). Several impacts to aquatic habitat could occur during the mining process, including physical habitat disturbance at the drill site; the potential to add, discharge, or cause the release of pollutants into waterbodies near the drill site; reduced water flow where water is withdrawn to support mining operations; and degradation of aquatic habitat if recovered "frac water" is not properly treated before discharge into waterbodies (DRBC 2012b). Direct impacts to aquatic biota could occur if aquatic organisms are immobile or unable to avoid the drill site. On May 5, 2010, DRBC voted to postpone its consideration of well pad dockets until DRBC has developed and implemented regulations for natural gas development within Marcellus Shale. As of May 2012, DRBC was in the process of developing these regulations, which would likely provide protection of aquatic resources during drilling activities (DRBC 2012b). 41 4.12.3.3. 42 43 44 45 46 47 48 Within the northeast region, climate models predict increasing average annual temperatures that foster rising sea surface temperatures and sea levels, increased heavy precipitation, reduced snowpack, and earlier spring peak river flows (Karl et al. 2009). The impacts of climate change on aquatic communities within the Delaware River Basin may be substantial and subsequently affect aquatic resources in the region. For example, seasonal spawning may shift earlier to coincide with earlier spring flows from higher temperatures melting snowpack earlier in the season. Increased water temperatures and higher sea levels may result in anadromous fish Energy Development Climate Change 4-47 Environmental Impacts of Operation 1 2 3 migrations further up the Delaware or Schuylkill Rivers. Further degradation of water quality from increased runoff following heavy precipitation events may compromise sensitive life stages of aquatic species in associated watersheds and have noticeable effects on aquatic populations. 4 5 6 7 8 9 10 Interlandi and Crockett (2003) examined the relative influences of climate change and stormwater discharge on the Schuylkill River Basin from 1895 to 1999 using temperature, precipitation, and river discharge data. While seasonal variations exist, the overall influence of long-term climate change showed marginal influence as increasing urbanization and increased stormwater discharge had a larger direct effect on water quality (Interlandi and Crockett 2003). Therefore, stormwater discharges may play a larger role than climate change in cumulative changes to aquatic biota in the future. 11 4.12.3.4. 12 13 14 15 16 17 The stresses from past river flow alterations, increasing urbanization, and demand for water resources across the geographic area of interest depend on many factors that the NRC staff cannot quantify, but they are likely to noticeably alter aquatic resources when all stresses on the aquatic communities are assessed cumulatively. Therefore, the NRC staff concludes that the cumulative impacts from the proposed license renewal and other past, present, and reasonably foreseeable projects would be SMALL to MODERATE. 18 4.12.4. 19 20 21 22 23 This section addresses past, present, and future actions that could result in cumulative impacts on the terrestrial species and habitats described in Section 2.2.7. For purposes of this analysis, the geographic area considered in the evaluation includes the LGS site, the in-scope transmission line corridors, and the offsite facilities associated with the LGS makeup water system. See Section 2.2.8.1 for a description of these areas. 24 Historic Conditions 25 26 27 28 29 30 31 32 Section 2.2.7 discusses the ecoregion in which the LGS site is located--the Triassic Lowlands portion of the Northern Piedmont ecoregion--which is dominated by Appalachian oak forest. In the region surrounding the LGS site, much of what would be forest has been cleared and cultivated for crops, hayfields, and pastureland. Forest remains on marginal land, such as steep slopes and land with poorer quality soils. From 1973 to 2000, about 6.2 percent of land in the Northern Piedmont ecoregion changed in land use type. New development surrounding urban areas accounted for about 70 percent of this change. This rate of land development is one of the highest in the Eastern ecoregions over the time period (Auch 2003). 33 34 35 36 On the immediate site, PECO cleared about 270 ac (110 ha; 42 percent of the current LGS site) for construction of the facility's buildings, parking lots, roads, and other infrastructure (AEC 1973). The terrestrial habitats on the undeveloped portions of the site have not changed significantly since LGS's construction (Exelon 2011a). 37 Energy-Producing Facilities 38 39 A number of operating energy-producing facilities within the vicinity of the LGS site could affect the terrestrial environment now and in the future. 40 41 42 43 44 Two bituminous coal plants operate near LGS: the Cromby Generating Station (6 mi [10 km] southeast) and the Titus Coal Plant (18 mi [29 km] northwest). Coal-fired plants are a major source of air pollution in the United States because they release sulfur dioxide, nitrogen oxides, mercury, carbon dioxide, and particulates. Nitrous oxides and sulfur dioxides combine with water to form acid rain, which can lead to erosion and changes in soil pH levels. Mercury Conclusion Terrestrial Resources 4-48 Environmental Impacts of Operation 1 2 deposits onto soil and surface water, which may then be taken up by terrestrial and aquatic plant or animal species and poses the risk of bioaccumulation. 3 4 5 6 7 8 Several natural gas plants operate in the region as well, including Linfield Energy Center, which lies 3 mi (5 km) northwest of LGS. Natural gas plants emit nitrous oxides and sulfur dioxides, though at much lower levels than coal plants. Methane, a primary component of natural gas and also a greenhouse gas, can be released when natural gas is not burned completely or as a result of leaks or losses during transportation. The release of methane contributes to climate change, the terrestrial resource impacts of which are discussed below. 9 10 Additionally, a number of distillate oil facilities in the area contribute to air emissions, which can result in bioaccumulation of chemicals and contribute to climate change, as discussed above. 11 Urbanization and Habitat Fragmentation 12 13 14 15 16 17 18 19 As the region surrounding the LGS site becomes more developed, habitat fragmentation will increase. Species that require larger ranges, especially predators, will likely suffer reductions in their populations. In contrast, herbivores will experience less predation pressure and their populations are likely to increase. Edge species will benefit from the fragmentation, while species that require interior forest or swamp habitat will likely suffer. The transmission line corridors established for LGS's transmission lines represent habitat fragmentation, though all of the LGS transmission lines were constructed along existing utility or railroad corridors; therefore, these lines likely did not contribute measurable cumulative impacts. 20 Agricultural Runoff 21 22 23 24 25 26 27 28 29 30 31 As of 2000, agriculture accounted for about 20 percent of Montgomery County's land acreage (MCPCB 2005). As development continues, the county's agricultural lands are being converted to residential and commercial uses; however, a significant portion of the county continues to be used for agriculture. The 2000 National Water Quality Inventory reported that agricultural nonpoint source pollution accounted for the second largest source of impairments to wetlands (EPA 2012b). Fertilizers and pesticides can affect wetlands in a variety of ways. Because wetlands are often at lower elevation than surrounding land, they receive much of the runoff first, and that runoff persists because it is unable to drain to lower ground. This can result in pollutant loadings and bioaccumulation and changes to species composition and abundance and increases. Species that rely on wetlands, such as birds and amphibians, are more sensitive to environmental stressors, which exacerbate these effects. 32 Parks and Conservation Areas 33 34 35 36 Eleven National and state parks occur within 30 mi (50 km) of the LGS site (see Appendix F). These areas will continue to provide valuable habitat to native wildlife and migratory birds. As habitat fragmentation resulting from various types of development occurs, these areas will become ecologically more important because they will provide large areas of natural habitat. 37 38 39 40 41 42 43 44 45 46 The Montgomery County Planning Commission (MCPC) has designated about 24 percent of the county as conservation landscapes. Conservation landscapes provide a focus for the county's restoration and native habitat management efforts. The MCPC has designated 13 of these landscapes, which total about 75,000 ac (30,000 ha). These conservation landscapes include relatively large forested tracts, stream corridors, wetlands, known sites of rare plant and animal species, and areas of high natural biodiversity. The large tracts of forest support native bird and wildlife diversity throughout the county, and the wetland habitats are critical to maintaining native amphibian and reptile populations (Rhoads and Block 2008). In addition, terrestrial habitats within the Schuylkill River corridor are protected by the Schuylkill River National and State Heritage Area. 4-49 Environmental Impacts of Operation 1 Climate Change 2 3 4 5 6 7 8 9 10 11 12 13 Over the next several decades, the U.S. Global Change Research Program (Karl et al. 2009) estimates that summer temperatures within the Northeast will rise 1.5 to 3.5 ?F (0.8 to 1.9 ?C) and winter temperatures will rise 2.5 to 4 ?F (1.4 to 2.2 ?C). By late this century, the Northeast is likely to experience shorter winters with more precipitation; short-term droughts in the summer months; longer, hotter summers; and sea-level rise, among other effects. Changes in the climate will shift many wildlife population ranges and alter migratory patterns. Such changes could favor non-native invasive species and promote the population increases of insect pests and plant pathogens. Climate change will likely alter disturbance regimes as the severity or frequency of precipitation, flooding, and fire change. Climate change may also exacerbate the effects of existing stresses in the natural environment, such as those caused by habitat fragmentation, invasive species, nitrogen deposition and runoff from agriculture, and air emissions. 14 Conclusion 15 16 17 18 19 20 21 22 The NRC staff examined the cumulative effects of the construction of LGS, neighboring energy-producing facilities, continued urbanization and habitat fragmentation, agricultural runoff, nearby parks and conservation areas, and climate change. The NRC staff concludes that the minimal terrestrial impacts from the continued LGS operations would not contribute to the overall decline in the condition of terrestrial resources. The NRC staff believes that the cumulative impacts of other and future actions during the term of license renewal on terrestrial habitat and associated species, when added to past, present, and reasonably foreseeable future actions, would be MODERATE. 23 4.12.5. 24 25 26 27 28 29 30 31 32 The radiological dose limits for protection of the public and workers have been developed by the NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation and radioactive material. These dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. For the purpose of this analysis, the area within a 50-mi (80-km) radius of LGS was included. The REMP conducted by Exelon in the vicinity of the LGS site measures radiation and radioactive materials from all sources (i.e., hospitals and other licensed users of radioactive material); therefore, the monitoring program measures cumulative radiological impacts. Within the 50-mi (80-km) radius of the LGS site there are currently no other nuclear power reactors or uranium fuel cycle facilities. 33 34 35 36 37 38 Radioactive effluent and environmental monitoring data for the 5-year period from 2006 to 2010 were reviewed as part of the cumulative impacts assessment. In Section 4.9.2 of this SEIS, the NRC staff concluded that impacts of radiation exposure to the public and workers (occupational) from operation of LGS during the renewal term are SMALL. The NRC and the State of Pennsylvania would regulate any future actions in the vicinity of the LGS site that could contribute to cumulative radiological impacts. 39 40 41 42 43 44 45 46 Exelon constructed an Independent Spent Fuel Storage Installation (ISFSI) on the LGS site in 2008 for the storage of its spent fuel. The installation and monitoring of this facility is governed by NRC requirements in 10 CFR Part 72, "Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste." Radiation from this facility, as well as from the operation of LGS, is required to be within the radiation dose limits in 10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 72. The NRC carries out periodic inspections of the ISFSI to verify its compliance with its licensing and regulatory requirements. Human Health 4-50 Environmental Impacts of Operation 1 2 3 The cumulative radiological impacts from LGS, Units 1 and 2 and the ISFSI are required to meet the radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. Therefore, the NRC staff concludes that cumulative radiological impacts would be SMALL. 4 4.12.6. 5 Socioeconomics Socioeconomics 6 7 8 9 10 11 12 13 14 15 16 17 This section addresses socioeconomic factors that have the potential to be directly or indirectly affected by changes in operations at LGS, Units 1 and 2 in addition to the aggregate effects of other past, present, and reasonably foreseeable future actions. The primary geographic areas of interest considered in this cumulative analysis include Montgomery, Berks, and Chester Counties where approximately 84 percent of LGS, Units 1 and 2 employees reside (see Section 2.2.9). This is where the economy, tax base, and infrastructure would most likely be affected since LGS workers and their families reside, spend their income, and use their benefits within these counties. As previously discussed in Section 4.1, onsite land use conditions at LGS are expected to remain unchanged during the license renewal term. Therefore, activities associated with continued reactor operations during the license renewal term are not expected to affect the use and management of LGS lands identified as part of the Schuylkill River Greenway. 18 19 20 21 22 23 24 25 26 27 28 29 As discussed in Section 4.10 of this SEIS, continued operation of LGS would have no impact on socioeconomic conditions in the region during the license renewal term beyond what is already being experienced. Since Exelon has no plans to hire additional workers during the license renewal term, overall expenditures and employment levels at LGS, Units 1 and 2 would remain relatively unchanged with no new, additional, or increased demand for permanent housing and public services. In addition, since employment levels and tax payments would not change, there would be no population or tax revenue-related land use impacts. Based on this and other information presented in Chapter 4 of this SEIS, there would be no contributory effect from continued operations of LGS, Units 1 and 2 on socioeconomic conditions in the region beyond what is currently being experienced. Therefore, the only cumulative contributory effects would come from the other planned activities in the region independent of LGS, Units 1 and 2 operations. 30 Environmental Justice 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 The environmental justice cumulative impact analysis assesses the potential for disproportionately high and adverse human health and environmental effects on minority and low-income populations that could result from past, present, and reasonably foreseeable future actions including LGS, Units 1 and 2 operations during the renewal term. Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant and exceeds the risk or exposure rate for the general population or for another appropriate comparison group. Disproportionately high environmental effects refer to impacts or risk of impact on the natural or physical environment in a minority or low-income community that are significant and appreciably exceeds the environmental impact on the larger community. Such effects may include biological, cultural, economic, or social impacts. Some of these potential effects have been identified in resource areas presented in Chapter 4 of this SEIS. Minority and low-income populations are subsets of the general public residing in the area and all would be exposed to the same hazards generated from LGS operations. As previously discussed in this chapter, the impact from license renewal for all resource areas (e.g., land, air, water, ecology, and human health) would be SMALL. 4-51 Environmental Impacts of Operation 1 2 3 4 5 6 7 8 9 As discussed in Section 4.10.7 of this SEIS, there would be no disproportionately high and adverse impacts to minority and low-income populations from the continued operation of LGS, Units 1 and 2 during the license renewal term. Since Exelon has no plans to hire additional workers during the license renewal term, employment levels at LGS, Units 1 and 2 would remain relatively constant with no new, additional, or increased demand for housing or increased traffic. Based on this information and the analysis of human health and environmental impacts presented in Chapters 4 and 5, it is not likely there would be any disproportionately high and adverse contributory effect on minority and low-income populations from the continued operation of LGS during the license renewal term. 10 4.12.7. 11 12 13 14 15 This section addresses the direct and indirect effects of license renewal on historic and cultural resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. The geographic area considered in this analysis is the Area of Potential Effect (APE) associated with the proposed undertaking, as described in Section 2.2.10. 16 17 18 19 20 21 22 23 24 Substantial archeological records indicate that there was historic occupation of the LGS area. Surveys were performed in the 1970s and 1980s. Section 2.2.10 presents an overview of the existing historic and archaeological resources located on the LGS site. Past land development has resulted in impacts on and the loss of cultural resources near and at the LGS site. As described in Section 4.10.6, no cultural resources would be affected by relicensing activities associated with the LGS site because there will be no changes or ground-disturbing activities that will occur as part of the relicensing of LGS, Units 1 and 2 (Exelon 2011a). Cultural resources are being managed through Exelon's Cultural Resources Management Plan and the Fricks Lock rehabilitation and mothball project (Exelon 2012a). 25 26 27 28 The present and reasonably foreseeable projects reviewed in conjunction with license renewal are noted in Appendix F of this document. Direct impacts would occur if archaeological sites in the APE are physically removed or disturbed. The following projects are located within the geographic area considered for cumulative impacts: 29 30 31 Cultural Resources o o o decommissioning of LGS Units 1 and 2, transmission lines, and future urbanization. 32 33 34 35 36 37 38 Decommissioning of LGS Units 1 and 2, transmission lines, and future urbanization have the potential to result in impacts on cultural resources through inadvertent discovery during ground-disturbing activities. However, as discussed above in Section 4.10.6, the contribution from the proposed license renewal action would not incrementally affect historic or cultural resources. Therefore, the NRC staff concludes that the cumulative impacts of the proposed license renewal plus other past, present, and reasonable foreseeable future activities on historic and cultural resources would be SMALL. 39 4.12.8. 40 41 42 43 44 The NRC staff considered the potential impacts resulting from the operation of LGS during the period of extended operation and other past, present, and reasonably foreseeable future actions near LGS. The preliminary determination is that the potential cumulative impacts would range from SMALL to MODERATE, depending on the resource. Table 4-10 summarizes the cumulative impacts on resources areas. Summary of Cumulative Impacts 4-52 Environmental Impacts of Operation Table 4-10. Summary of Cumulative Impacts on Resource Areas 1 Resource Area Cumulative Impact Air Quality Because there are no planned site refurbishments with the LGS license renewal, and no expected changes in air emissions, cumulative impacts in Montgomery and Chester Counties would be the result of changes to present-day emissions and emissions from reasonably foreseeable projects and actions. Various strategies and techniques are available to limit air quality impacts. Therefore, the cumulative impacts from the continued operation of LGS would be SMALL. Surface water withdrawals by LGS and other surface water users in the basin are subject to limits and conditions imposed by DRBC. The DRBC and PADEP established a regulatory framework to manage surface water use and quality. The Water Resources water quality of Delaware River and its main tributaries, such as the Schuylkill, has improved over the past several decades. The annual net groundwater withdrawals in the Schuylkill-Sprogels Run Subbasin are currently below the DRBC limits. Therefore, the cumulative impacts from the continued operations of LGS would be SMALL. The stresses from past river flow, alterations, increasing urbanization, and demand of water resources across the geographic area of interest are likely to alter aquatic Aquatic Ecology resources when stresses on the aquatic communities are assessed cumulatively. Therefore, the cumulative impacts from the continued operation of LGS would be SMALL to MODERATE. Terrestrial Ecology A number of operating energy-producing facilities within the vicinity of LGS have the potential to affect terrestrial resources. Habitat fragmentation will increase as the region surrounding the LGS site becomes more developed. Therefore, the cumulative impacts from the continued operation of LGS would be MODERATE. Human Health The NRC staff reviewed the radioactive effluent and environmental monitoring data from 2006 to 2010, and concluded the impacts of radiation exposure to the public from operation of LGS during the renewal term are SMALL. The cumulative radiological impacts from LGS and the Independent Spent Fuel Storage Installation would be required to meet radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. Therefore, the cumulative impacts from the continued operation of LGS would be SMALL. As discussed in Section 4.9, continued operation of LGS during the license renewal term would have no impact on socioeconomic conditions in the region beyond those already experienced. Exelon has no plans to hire additional workers during the license renewal term; employment levels at LGS would remain relatively constant with no new Socioeconomics demands for housing or increased traffic. Combined with other past, present, and reasonably foreseeable future activities, there will be no additional contributory effect on socioeconomic conditions from the continued operation of LGS during the license renewal period beyond what is currently being experienced. Cultural Resources Transmission lines, future urbanization, and decommissioning of LGS have the potential to affect cultural resources through inadvertent discovery during ground-disturbing activities. However, no cultural resources would be affected by relicensing activities associated with the LGS site because there will be no changes or ground-disturbing activities that will occur as part of the relicensing of LGS, Units 1 and 2. Therefore, combined with other past, present, and reasonable foreseeable future activities, the potential cumulative impacts on historic and cultural resources would be SMALL. 4-53 Environmental Impacts of Operation 1 4.13. References 2 3 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for protection against radiation." 4 5 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of production and utilization facilities." 6 7 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental protection regulations for domestic licensing and related regulatory functions." 8 9 10 10 CFR Part 72. Code of Federal Regulations. Title 10, Energy, Part 72, "Licensing requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related greater than Class C waste." 11 12 18 CFR Part 430, Code of Federal Regulations, Title 18, Conservation of Power and Water Sources, Part 430, "Ground water protected area: Pennsylvania." 13 14 36 CFR Part 60. Code of Federal Regulations, Title 36, "Parks, Forests, and Public Property," Part 60, "National Register of Historic Places." 15 16 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part 800, "Protection of historic properties." 17 18 40 CFR Part 81. Code of Federal Regulations. Title 40, Protection of Environment, Part 81, "Designation of areas for air quality planning purposes." 19 20 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, "Environmental radiation protection standards for nuclear power operations." 21 22 50 CFR Part 402. Code of Federal Regulations. Title 50, Wildlife and Fisheries, Part 402, "Interagency cooperation--Endangered Species Act of 1973, as amended. 23 24 25 59 FR 7629. Executive Order 12898. Federal actions to address environmental justice in minority populations and low-income populations. Federal Register 59(32):7629-7634, February 16, 1994. 26 27 28 69 FR 41576. Environmental Protection Agency. "National Pollutant Discharge Elimination System-Final Regulations to Establish Requirements for Cooling Water Intake Structures at Phase II Existing Facilities." Federal Register 69(131):41576-41593. July 9, 2004. 29 30 31 69 FR 52040. U.S. Nuclear Regulatory Commission. Policy statement on the treatment of environmental justice matters in NRC regulatory and licensing actions. Federal Register 69(163):52040-52048. August 24, 2004. 32 33 34 35 [AEC] U.S. Atomic Energy Commission. 1973. Final Environmental Statement Related to the Proposed Limerick Generating Station Units 1 and 2. Washington, DC: AEC. June 1973. 700 p. Agencywide Documents Access and Management System (ADAMS) Accession No. ML11313A215. 36 37 Auch RF. 2003. "Northern Piedmont." Available at (accessed 12 May 2012). 38 39 40 41 42 [BHP] Bureau of Historic Preservation. 2011. Letter from D.C. McLearen, Pennsylvania Historical and Museum Commission Bureau for Historic Preservation, to D.H. Frens, Frens and Frens. Subject: NRC: Limerick Generating Station Relicensing Project, Fricks Lock Village Rehabilitation and Mothballing, E. Coventry Twp., Chester Co. October 19, 2011. ADAMS Accession No. ML11318A295. 4-54 Environmental Impacts of Operation 1 2 3 [CAPS] Missouri Census Data Center Circular Area Profiling System. Version 10C. Using Data from Summary File 1, 2010 Census Summary of Census Tracts in a 50-mile radius around the South Texas Project (40.22 Lat., -75.58 Long.). March 2012. 4 5 6 7 [CEQ] Council on Environmental Quality. 1997. Environmental Justice: Guidance Under the National Environmental Policy Act. Available at (accessed 22 May 2012). ADAMS Accession No. ML082520150. 8 9 10 [CRA] Conestoga-Rovers & Associates. 2006. Hydrogeologic Investigation Report, Fleetwide Assessment Limerick Generating Stations, Pottstown, Pennsylvania. September 2006. ADAMS No. ML12110A228. 11 12 [DRBC] Delaware River Basin Commission. 1961. Delaware River Basin Compact. 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Section 6.3-Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS Accession No. ML04069720. 18 19 20 [NRC] U.S. Nuclear Regulatory Commission. 1999b. Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. Washington, DC: NRC. NUREG-1555, Supplement 1. October 1999. ADAMS Accession No. ML003702019. 21 22 23 24 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Letter from D.J. Wrona, NRC, to J. Cutler, Bureau of Historic Preservation, dated September 15, 2011, "Limerick Generating Station License Renewal Environmental Review (SHPO File No. ER 2004-2024-091-B)." ADAMS Accession No. ML1121A265. 25 26 27 28 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from D.J. Wrona, NRC, to T. McCulloch, Advisory Council on Historic Preservation, dated September 16, 2011, "Limerick Generating Station License Renewal Environmental Review (SHPO File No. ER 2004-2024-091-B)." ADAMS Accession No. ML11245A083. 29 30 31 [NRC] U.S. Nuclear Regulatory Commission. 2011c. E-mail from Ann, BHP, to T.K. O'Neil, PNNL, dated November 1, 2012. "LGS License Renewal-SHPO Meeting." ADAMS Accession No. ML12255A291. 32 33 34 35 36 [NRC] U.S. Nuclear Regulatory Commission. 2011d. Letter from D. Wrona, RPB2 Branch Chief, NRC, to M. Roberts, Pennsylvania Field Office, U.S. Fish and Wildlife Service. Subject: Request for list of protected species within the area under evaluation for the Limerick Generating Station, Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession No. ML11258A248. 37 38 39 40 41 [NRC] U.S. Nuclear Regulatory Commission. 2011e. Letter from D. Wrona, RPB2 Branch Chief, NRC, to C. Urban, Division of Environmental Services, Pennsylvania Fish and Boat Commission. Subject: Request for list of protected species within the area under evaluation for the Limerick Generating Station, Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession No. ML11234A024. 42 43 44 45 46 [NRC] U.S. Nuclear Regulatory Commission. 2011f. Letter from D. Wrona, RPB2 Branch Chief, NRC, to C. Firestone, Bureau of Forestry Plant Program, Pennsylvania Department of Conservation and Natural Resources. Subject: Request for list of protected species within the area under evaluation for the Limerick Generating Station, Units 1 and 2, license renewal application review. September 16, 2011. ADAMS Accession No. ML11230B346. 4-59 Environmental Impacts of Operation 1 2 3 4 5 [NRC] U.S. Nuclear Regulatory Commission. 2011g. Letter from D. Wrona, RPB2 Branch Chief, NRC, to O. Braun, Environmental Planner, Pennsylvania Game Commission. Subject: Request for list of protected species within the area under evaluation for the Limerick Generating Station, Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession No. ML11234A065. 6 7 8 9 10 [NRC] U.S. Nuclear Regulatory Commission. 2012a. Letter from J. Susco, RERB Acting Branch Chief, NRC, to D. Morris, Acting Regional Administrator, National Marine Fisheries Service. Subject: Request for list of Federal protected species within the area under evaluation for the Limerick Generating Station, Units 1 and 2, license renewal application review. May 30, 2012. ADAMS Accession No. ML12138A347. 11 12 13 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Staff Requirements, SECY-12-0063, "Final Rule: Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating Licenses (10 CFR Part 51; RIN 3150-AI42)." December 6, 2012. ADAMS No. ML12341A134. 14 15 O'Herron, JC, Able, KW, Hastings, RW. 1993. Movements of shortnose sturgeon (Acipenser brevirostrum) in the Delaware River. Estuaries 16(2):235-240. 16 17 18 19 [PADEP] Pennsylvania Department of Environmental Protection Bureau of Radiation Protection (BRP). Environmental Radiation in Pennsylvania 2003 and 2004 Annual Reports. Available at (accessed 18 April 2012). 20 21 22 23 24 [PADEP] Pennsylvania Department of Environmental Protection. 2006c. General Permit BWM-GP-11, Maintenance, Testing, Repair, Rehabilitation, or Replacement of Water Obstructions or Encroachments. Revision 12/2006. Harrisburg, PA: PADEP. Available at (accessed 18 April 2012). 25 26 27 28 29 30 31 [PDCNR] Pennsylvania Department of Conservation and Natural Resources. 2011. Letter from R. Bowen, Environmental Review Manager, for C. Firestone, Wild Plant Program Manager, Bureau of Forestry, PDCNR, to M. Gallagher, Exelon Nuclear. Subject: Pennsylvania Natural Diversity Inventory review for renewal of operating licenses for Limerick Generating Station, Units 1 and 2, Chester, Montgomery & Bucks Counties. March 9, 2011. In Appendix C to Applicant's Environmental Report--Operating License Renewal Stage, Limerick Generating Station, Units 1 and 2. ADAMS Accession No. ML11179A104. 32 33 34 [PECO] Philadelphia Electric Company. 1984. Environmental Report Operating License Stage Limerick Generating Station Units 1 & 2, Vol. 1. Philadelphia, PA: PECO. September 30, 1984. ADAMS Accession No. ML11299A113. 35 36 37 Perillo J.A. and Butler L.H. 2009. "Evaluating the use of Fairmount Dam fish passage facility with application to anadromous fish restoration in the Schuylkill River, Pennsylvania." Journal of the Pennsylvania Academy of Science 83(1):24-33. 38 39 40 41 42 [PFBC] Pennsylvania Fish and Boat Commission. 2011a. Letter from C.A. Urban, Natural Diversity Section Chief, PFBC, to N. Ranek, Exelon Nuclear. Subject: Species impact review for renewal of operating licenses for Limerick Generating Station, Units 1 and 2, Montgomery and Chester County, Pennsylvania. February 11, 2011. In Appendix C of "Exelon 2011a." ADAMS Accession No. ML11179A104. 4-60 Environmental Impacts of Operation 1 2 3 4 5 [PFBC] Pennsylvania Fish and Boat Commission. 2011b. Letter from C.A. Urban, Natural Diversity Section Chief, PFBC, to D. Wrona, RPB2 Branch Chief, NRC. Subject: Species impact review for renewal of operating licenses for Limerick Generating Station, Units 1 and 2, Montgomery and Chester County, Pennsylvania. October 5, 2011. ADAMS Accession No. ML11291A077. 6 7 8 9 10 [PGC] Pennsylvania Game Commission. 2011. Letter from O.A. Mowery, Environmental Planner, Division of Environmental Planning and Habitat Protection, PGC, to D. Wrona, RPB2 Chief, NRC. Subject: Re: Limerick Generating Station and transmission lines--license renewal, Montgomery and Chester Counties, Pennsylvania. November 17, 2011. ADAMS Accession No. ML11329A060. 11 12 13 [PNHP] Pennsylvania Natural Heritage Program. 2012a. "State Species List Database-Bucks, Chester, and Montgomery Counties." Available at (accessed 10 April 2012). 14 15 16 [PNHP] Pennsylvania Natural Heritage Program. 2012b. "Species Fact Sheet, Farwell's Water-milfoil (Myriophyllum farwellii)." Available at (accessed 10 April 2012). 17 18 19 [PNHP] Pennsylvania Natural Heritage Program. 2012c. "Species Fact Sheet, Floating-heart (Nymphoides cordata)." Available at (accessed 10 April 2012). 20 21 22 [PNHP] Pennsylvania Natural Heritage Program. 2012d. "Species Fact Sheet, Spotted Pondweed (Potamogeton pulcher)." Available at (accessed 10 April 2012). 23 24 25 26 Rhoads AF, Block TA. 2008. Montgomery County, Pennsylvania: Natural Areas Inventory Update. Philadelphia, PA: Morris Arboretum of the University of Pennsylvania. Submitted to the Montgomery County Planning Commission. June 30, 2007. 401 p. Available at (accessed 8 May 2012). 27 28 [RMC] RMC-Environmental Services. 1984. Progress Report, Non-radiological Environmental Monitoring for Limerick Generating Station 1979-1983. Pottstown, PA: RMC. October 1984. 29 30 [RMC] RMC-Environmental Services. 1985. Progress Report, Non-radiological Environmental Monitoring for Limerick Generating Station 1984. Pottstown, PA: RMC. December 1985. 31 32 [RMC] RMC-Environmental Services. 1986. Progress Report, Non-radiological Environmental Monitoring for Limerick Generating Station 1985. Pottstown, PA: RMC. September 1986. 33 34 [RMC] RMC-Environmental Services. 1987. Progress Report, Non-radiological Environmental Monitoring for Limerick Generating Station 1986. Pottstown, PA: RMC. November 1987. 35 36 [RMC] RMC-Environmental Services. 1988. Progress Report, Non-radiological Environmental Monitoring for Limerick Generating Station 1987. Pottstown, PA: RMC. September 1988. 37 38 [RMC] RMC-Environmental Services. 1989. Progress Report, Non-radiological Environmental Monitoring for Limerick Generating Station 1988. Pottstown, PA: RMC. December 1989. 39 40 41 42 43 Simpson, PC, Fox, DA. undated. Atlantic sturgeon in the Delaware River: contemporary population status and identification of spawning areas. Dover, DE: Delaware State University. Available at (accessed 6 August 2012). 4-61 Environmental Impacts of Operation 1 2 Todar, K. 2012. "Todar's Online Textbook of Bacteriology." Available at (accessed August 2012). 3 4 5 6 7 8 [USCB] U.S. Census Bureau. 2011. American FactFinder, 2010 American Community Survey and Data Profile Highlights Information on New Castle, Cecil, Burlington, Camden, Gloucester, Hunterdon, Mercer, Salem, Somerset, Warren, Berks, Bucks, Carbon, Chester, Delaware, Lancaster, Lebanon, Lehigh, Monroe, Montgomery, Northhampton, Philadelphia, and Schuylkill Counties and State of Pennsylvania. Available at and (accessed March 2012). 9 10 11 [USGS] U.S. Geological Survey. 2010. Water-Data Report 2010, 01472000 SCHUYLKILL RIVER AT POTTSTOWN, PA, Lower Delaware Basin Schuylkill Subbasin. Available at (accessed 16 May 2011). 12 13 14 15 Wallace Roberts & Todd, LLC. 2003. Living with the River, Schuylkill River National and State Heritage Area, Final Management Plan and Environmental Impact Statement. Pottstown, PA: Schuylkill River Greenway Association. Available at (accessed 19 April 2012). 4-62 1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 2 3 4 5 6 7 8 This chapter describes the environmental impacts from postulated accidents that Limerick Generating Station, Units 1 and 2 (LGS) might experience during the period of extended operation. The term "accident" refers to any unintentional event outside the normal plant operational envelope that results in a release or the potential for release of radioactive materials into the environment. The two classes of postulated accidents listed in Table 5-1 are evaluated in detail in the generic environmental impact statement (GEIS). These two classes of accidents are: 9 10 ? ? design-basis accidents (DBAs), and severe accidents. Table 5-1. Issues Related to Postulated Accidents 11 Issues GEIS Section Category DBAs 5.3.2; 5.5.1 1 Severe accidents 5.3.3; 5.3.3.2; 5.3.3.3; 5.3.3.4; 5.3.3.5; 5.4; 5.5.2 2 12 5.1. Design-Basis Accidents 13 14 15 16 17 18 19 20 In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear power plant, an applicant for an initial operating license must submit a safety analysis report (SAR) as part of its application. The SAR presents the design criteria and design information for the proposed reactor and comprehensive data on the proposed site. The SAR also discusses various hypothetical accident situations and the safety features that prevent and mitigate accidents. The NRC staff (the staff) reviews the application to determine if the plant design meets the NRC's regulations and requirements and includes, in part, the nuclear plant design and its anticipated response to an accident. 21 22 23 24 25 26 27 DBAs are those accidents that both the licensee and the staff evaluate to ensure that the plant can withstand normal and abnormal transients and a broad spectrum of postulated accidents, without undue hazard to the health and safety of the public. Many of these postulated accidents are not expected to occur during the life of the plant but are evaluated to establish the design basis for the preventive and mitigative safety systems of the nuclear power plant. Title 10 of the Code of Federal Regulations (10 CFR) Part 50 and 10 CFR Part 100 describe the acceptance criteria for DBAs. 28 29 30 31 32 33 34 35 36 37 38 39 The environmental impacts of DBAs are evaluated during the initial licensing process, and the ability of the nuclear power plant to withstand these accidents is demonstrated to be acceptable before issuance of the operating license. The results of these evaluations are found in license documentation such as the applicant's final safety analysis report (FSAR), the staff's safety evaluation report (SER), the final environmental statement (FES), and Section 5.1 of this supplemental environmental impact statement (SEIS). A licensee is required to maintain the acceptable design and performance criteria throughout the life of the nuclear power plant, including any period of extended operation. The consequences for these events are evaluated for the hypothetical maximum exposed individual. Because of the requirements that continuous acceptability of the consequences and aging management programs be in effect for license renewal, the environmental impacts, as calculated for DBAs, should not differ significantly from initial licensing assessments over the life of the nuclear power plant, including the license 5-1 Environmental Impacts of Postulated Accidents 1 2 3 renewal period. Accordingly, the design of the nuclear power plant, relative to DBAs during the extended period, is considered to remain acceptable; therefore, the environmental impacts of those accidents were not examined further in the GEIS. 4 5 6 7 8 9 10 11 The NRC has determined in the GEIS that the environmental impacts of DBAs are of SMALL significance for all nuclear power plants because the plants were designed to successfully withstand these accidents. Therefore, for the purposes of license renewal, DBAs are designated as a Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The early resolution of the DBAs makes them a part of the current licensing basis (CLB) of the plant; the CLB of the plant is to be maintained by the licensee under its current license and, therefore, under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This issue is applicable to LGS. 12 13 14 15 16 17 Exelon Generation Company, LLC (Exelon) stated in its environmental report (ER) (Exelon 2011c) that it is not aware of any new and significant information related to DBAs associated with the renewal of the LGS. The staff has not noted any new and significant information during its independent review of Exelon's ER, the scoping process, or its evaluation of other available information. Therefore, the staff concludes that there are no impacts related to DBAs beyond those discussed in the GEIS (NRC 1996). 18 5.2. Severe Accidents 19 20 21 22 23 24 Severe nuclear accidents are those that are more severe than DBAs because they could result in substantial damage to the reactor core, whether or not there are serious offsite consequences. In the GEIS, the staff assessed the effects of severe accidents during the period of extended operation, using the results of existing analyses and site-specific information to conservatively predict the environmental impacts of severe accidents for each plant during the period of extended operation. 25 26 27 28 29 30 31 32 33 34 35 The impacts from severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, fires, and sabotage were specifically considered in the GEIS. The GEIS evaluated existing impact assessments--performed by the staff and by the industry at 44 nuclear power plants (including LGS) in the United States--and concluded that the risk from beyond design-basis earthquakes at existing nuclear power plants is SMALL. The GEIS also performed a discretionary analysis of sabotage, in connection with license renewal, and concluded that the core damage and radiological release from such acts would be no worse than the damage and release expected from internally initiated events. In the GEIS, the NRC concludes that the risk from sabotage at existing nuclear power plants is SMALL and, additionally, that the risks from other external events are adequately addressed by a generic consideration of internally initiated severe accidents (NRC 1996). 36 Based on information in the GEIS, the NRC determined in its regulations that: 37 38 39 40 The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to ground water, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives. 41 42 43 44 The staff found no new and significant information related to postulated accidents during the review of Exelon's ER (Exelon 2011c), the scoping process, or evaluation of other available information. Therefore, there are no impacts related to these issues, beyond those already discussed in the GEIS. 5-2 Environmental Impacts of Postulated Accidents 1 5.3. Severe Accident Mitigation Alternatives 2 3 4 5 6 7 8 9 10 11 12 The purpose of the evaluation of severe accident mitigation alternatives (SAMAs) is to identify design alternatives, procedural modifications, or training activities that are cost-beneficial and further reduce the risks of severe accidents (NRC 1999a). The analysis of SAMAs includes the identification and evaluation of alternatives that reduce the radiological risk from a severe accident by preventing substantial core damage (i.e., preventing a severe accident) or by limiting releases from containment in the event that substantial core damage occurs (i.e., mitigating the impacts of a severe accident) (NRC 1999b). In accordance with 10 CFR 51.53(c)(3)(ii)(L) and Table B-1 of Part 51, license renewal ERs must provide a consideration of alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's plant in an environmental impact statement (EIS) or related supplement or in an environmental assessment. 13 14 15 16 17 18 19 20 21 22 23 24 The staff has previously performed a site-specific analysis of severe accident mitigation in a NEPA document for LGS in the Final Environmental Statement Related to Operation of LGS, Units 1 and 2 in NUREG-0974, Supplement 1 (NRC 1989) ("1989 SAMDA Analysis"). Therefore, no analysis of SAMAs for LGS is required in Exelon's ER or the staff's SEIS. The NRC Staff uses the term SAMA to refer to severe accident mitigation alternatives at the license renewal phase. In contrast, the term severe accident mitigation design alternatives (SAMDA) refers to severe accident mitigation alternatives at the initial licensing phase. The site-specific SAMDAs reviewed for applicability to LGS were evaluated in the 1989 SAMDA Analysis and also documented in GEIS Table 5.35. The staff examined each SAMDA (individually and, in some cases, in combination) to determine the potential SAMDA individual risk reduction potential. This risk reduction was then compared with the cost of implementing the SAMDA to provide cost-benefit evidence of its value. The staff concluded that: 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 The risks of early fatality from potential accidents at the site are small in comparison with risks of early fatality from other human activities in a comparably sized population, and the accident risk will not add significantly to population exposure and cancer risks. Accident risks from Limerick are expected to be a small fraction of the risks the general public incurs from other sources. Further, the best estimates show that the risks of potential reactor accidents at Limerick are within the range of such risks from other nuclear power plants. However, in the LGS specific 1989 SAMDA Analysis, the staff acknowledged: In the longer term, these same severe accident issues are currently being pursued by the NRC in a systematic way for all utilities through the Severe Accident Program described in SECY-88-147, "Integration Plan for Closure of Severe Accident Issues" (NRC 1988c). The plan includes provisions for an Individual Plant Examination (IPE) for each operating reactor, a Containment Performance Improvement (CPI) program, and an Accident Management (AM) program. These programs will produce a more complete picture of the risks of operating plants and the benefits of potential design improvements, including SAMDAs. The staff believes that the severe accident program is the proper vehicle for further review of severe accidents at nuclear power plants, including Limerick. Therefore, the Commission considers ways to mitigate severe accidents at a given site more than once. The Commission has considered alternatives for mitigating severe accidents at many sites, including LGS, multiple times through a variety of NRC programs. When it promulgated Table B-1 of 10 CFR Part 51, the Commission explained, The Commission has considered containment improvements for all plants pursuant to its Containment Performance Improvement (CPI) program...and the 5-3 Environmental Impacts of Postulated Accidents 1 2 3 4 Commission has additional ongoing regulatory programs whereby licensees search for individual plant vulnerabilities to severe accidents and consider costbeneficial improvements [(the individual plant examination "IPE" and individual plant examination of external events "IPEEE" programs)] (61 Fed. Reg. 28,467). 5 6 7 8 9 10 11 12 13 14 15 In light of these studies, the Commission believed it was "unlikely that any site-specific consideration of SAMAs for license renewal will identify major plant design changes or modifications that will prove to be cost-beneficial for reducing severe accident frequency or consequences" (61 FR 28467). Given the significant costs of a major plant design change, such an improvement must result in a substantial reduction in risk to be cost-beneficial. As discussed below, these studies already thoroughly considered severe accidents and ways to mitigate their impacts and did not identify cost-beneficial major plant design changes or modifications for mitigating the impacts of severe accidents. Regulations in 10 CFR 51.53(c)(3)(ii)(L) and Table B-1 reflect the Commission's judgment that in light of these ongoing studies, reconsideration of SAMAs at license renewal would be unlikely to uncover major costbeneficial plant modifications and is unnecessary. 16 Containment Performance Improvement Program 17 18 19 20 21 22 23 24 25 26 One of the programs the Commission relied on in determining that SAMAs need not be performed at license renewal if the staff had already performed a SAMA review in an earlier NEPA document is the CPI program. With this program, the NRC examined each of five U.S. reactor containment types (BWR Mark I, II, and III; PWR Ice Condenser; and PWR Dry) with the purpose of examining the potential failure modes, potential fixes, and the cost benefit of such fixes. Tables 5.32 through 5.34 in the GEIS summarize the results of this program. As can be seen from these tables, many potential changes were evaluated but only a few containment improvements were identified for site-specific review. The items evaluated in the CPI program were also included in the list of plant-specific SAMDAs examined in the LGS FES supplement (NRC 1996). 27 Individual Plant Examination 28 29 30 31 32 33 34 35 Another program the Commission relied on in determining that SAMAs need not be performed at license renewal if the staff had already performed a SAMA review in an earlier NEPA document is the Individual Plant Examination (IPE). The IPE's specific objective was to develop an appreciation of severe accident behavior, and to identify ways in which the overall probabilities of core damage and fission product releases could be reduced if deemed necessary. In general, the IPEs have resulted in plant procedural and programmatic improvements (i.e., accident management) and, in only a few cases, minor plant modifications, to further reduce the risk and consequences of severe accidents (NRC 1996). 36 37 38 39 40 41 42 43 44 45 46 47 In accordance with NRC's policy statement on severe accidents, the licensee performed an IPE to look for vulnerabilities to both internal and external initiating events (NRC 1988a). This examination considered potential improvements on a plant-specific basis. The CDF was found to be considerably less in the LGS IPE (4.3x10-6) than in the original CDF value provided in NUREG-1068 (1.0x10-5) for LGS and the 1989 PRA Update (1.0x10-5) used in the 1989 SAMDA Analysis review. The staff further notes that the 2009 PRA Update (3.2x10-6) is approximately an order of magnitude less than the 1989 PRA Update (Exelon ER). Plant improvements identified and implemented for LGS as a result of the IPE included: (1) relaxing restrictions on the drywell spray initiation curve in the Emergency Operating Procedures; (2) creating a procedure to cross-tie the 4 kV safeguards electrical buses; (3) creating a procedure to power Unit 2 emergency service water pumps from Unit 1; and (4) creating a cross-connection between the fire water and residual heat removal systems (PECO 1992). 5-4 Environmental Impacts of Postulated Accidents 1 Individual Plant Examination of External Events 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Another program the Commission relied on in determining that SAMAs need not be performed at license renewal if the staff had already performed a SAMA review in an earlier NEPA document is the Individual Plant Examination of External Events (IPEEE) program. The IPEEE program was initiated in the early 1990s. All operating plants in the United States (including LGS) performed an assessment to identify vulnerabilities to severe accidents initiated by external events and reported the results to the NRC, along with any identified improvements and/or corrective actions. Perspectives Gained from the Individual Plant Examination of External Events (IPEEE) Program, NUREG-1742 documents the perspectives derived from the technical reviews of the IPEEE results (NRC 2002). As a result of conducting the LGS IPEEE, PECO Energy identified seismic event and fire event findings. Actions were taken to address minor housekeeping and maintenance issues related to the seismic analysis such as unrestrained tools, lockers, hoist controllers and lifting devices for low voltage switchgear. In addition, Fire brigade drill activities and fire brigade awareness were increased for 3 areas in the common control structure. Furthermore, actions credited in the fire analysis such as improved transient combustible controls, creation of transient combustible free zones and formal designation of certain fire rated doors as "fire" doors were implemented at LGS (PECO 1995). 18 Accident Management Program 19 20 21 22 23 24 25 26 27 28 The staff specifically relied on the Accident Management Program as the proper avenue for addressing the improvements considered in the 1989 SAMDA Analysis. Accident management involves the development of procedures that promote the most effective use of available plant equipment and staff in the event of an accident. The staff indicated its intent (NRC 1988a) that licensees develop an accident management framework that will include implementation of accident management procedures, training, and technical guidance. Insights gained as a result of the IPE were factored into the accident management program at LGS. As discussed earlier, the majority of improvements identified from the completed IPEs to date have been in the area of accident management or other procedural and programmatic improvements (NRC 1996 and NRC 1997). 29 NRC Efforts to Address Severe Accident-Related Issues since the Publication of the 1996 GEIS 30 31 32 33 34 35 36 The NRC has continued to address accident-related issues since the GEIS was published and 10 CFR Part 51 changes related to license renewal were promulgated. The NRC's efforts have reduced risks from accidents beyond that considered in the 1996 GEIS. As discussed below, in some cases, such as the agency response to Fukushima, these activities are ongoing. Each of the activities applied or continues to apply to all reactors, including LGS. The specific requirement for any given reactor was based either on a site-specific evaluation or a design-specific requirement. 37 38 10 CFR 50.54(hh) Conditions of License Regarding Loss of Large Areas of the Plant Due to Fire or Explosions 39 40 41 42 43 44 45 46 47 Following September 11, 2001, the Commission issued Order EA-02-026 and ultimately a new regulation (10 CFR 50.54(hh)), which required commercial power reactor licensees to, among other things, adopt mitigation strategies using readily available resources to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities to cope with the loss of large areas of the facility due to large fires and explosions from any cause, including beyond-design-basis aircraft impacts (See 74 FR 13926). The final rule also added several new requirements developed as a result of insights gained from implementation of the security orders, reviews of site security plans, and implementation of the enhanced baseline inspection program, and updated the NRC's security regulatory framework for the licensing of new nuclear 5-5 Environmental Impacts of Postulated Accidents 1 2 3 4 5 6 7 8 9 10 11 12 13 power plants. Compliance with the final rule was required by March 31, 2010, for licensees, including Exelon, currently licensed to operate under 10 CFR Part 50. Exelon has updated its plant and procedures accordingly, and the NRC has inspected the guidelines and strategies that Exelon has implemented to meet the requirements of 10 CFR 50.54(hh)(2). The specifics of the enhancements are security related and not publicly available but in general include: (1) significant reinforcement of the defense capabilities for nuclear facilities, (2) better control of sensitive information, (3) enhancements in emergency preparedness to further strengthen the NRC's nuclear facility security program, and (4) implementation of mitigating strategies to deal with postulated events potentially causing loss of large areas of the plant due to explosions or fires, including those that an aircraft impact might create. These measures are outlined in greater detail in NUREG/BR-0314 (NRC 2004), NUREG-1850 (NRC 2006a), and Sandia National Laboratory's "Mitigation of Spent Fuel Loss-of-Coolant Inventory Accidents and Extension of Reference Plant Analyses to Other Spent Fuel Pools" (NRC 2006b). 14 Severe Accident Mitigation Guidelines 15 16 17 18 19 20 Exelon has also developed and implemented severe accident mitigation guidelines (SAMGs) at LGS, which further reduce risk at the facility. SAMGs were developed by the industry during the 1980s and 1990s in response to the Three Mile Island (TMI) Nuclear Station accident and follow-up activities. SAMGs are meant to "enhance the ability of the operators to manage accident sequences that progress beyond the point where emergency operating procedures (EOPs) and other plant procedures are applicable and useful" (NRC 2011a). 21 Fukushima-Related Activities 22 23 24 25 26 27 The Commission also considered additional measures to enhance plant severe accident performance throughout the nuclear fleet, including LGS, following the March 11, 2011, Fukushima Dai-ichi accident. The Commission established a Task Force to "conduct a methodical and systematic review of the NRC's process and regulations to determine whether the agency should make additional improvements to its regulatory system and to make recommendations to the Commission for its policy direction." 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 As a result of this review, the Task Force issued SECY-11-0093 (NRC 2011c), "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan;" SECY-11-0124 (NRC 2011d), "Recommended Actions to be Taken Without Delay from the Near-Term Task Force Report;" and SECY-11-0137 (NRC 2011f), "Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned," to establish the staff's prioritization of the recommendations. The Commission's direction is provided in SRM-SECY-11-0124 (NRC 2011e) and SRM-SECY-11-0137 (NRC 2011g). In March 2012, three Orders were issued to U.S. nuclear power plants. The first Order requires all U.S. plants to better protect portable safety equipment put into place after the 9/11 terrorist attacks and to obtain sufficient equipment to support all reactors at a given site simultaneously (NRC 2012a). The second Order applies only to U.S. boiling water reactors that have "Mark I" or "Mark II" (such as LGS) containment structures. Mark I reactors must improve installed venting systems that help prevent or mitigate core damage in the event of a serious accident; Mark II reactors must install these venting systems (NRC 2012b). The third Order requires all plants to install enhanced equipment for monitoring water levels in each plant's spent fuel pool (NRC 2012c). The NRC also issued an information request in March 2012, including earthquake and flooding hazard "walkdowns," during which skilled engineers verify that the plants conform to their current license requirements (NRC 2012d). 46 47 48 Under 10 CFR 51.53(c)(3)(ii)(L) and 10 CFR Part 51 Table B-1, the NRC does not need to reconsider SAMAs for LGS at the license renewal phase. As provided above, those regulations rely on more than just the prior 1989 SAMDA Analysis; they also rest on the IPE, IPEEE, and 5-6 Environmental Impacts of Postulated Accidents 1 2 3 4 5 6 7 8 CPI programs, to consider SAMAs in cases like LGS in which the NRC has already analyzed SAMAs. These studies did not identify major cost-beneficial mitigation measures that could substantially reduce offsite risk. Rather, they mostly uncovered minor improvements and programmatic fixes. The volume of studies cited by the Commission, and their ongoing nature, provide the type of "hard look" the Commission understood it must apply to the issue of severe accident mitigation alternatives in its NEPA review for every license renewal proceeding (61 FR 28481). This approach is all the more reasonable in light of the Commission's finding that the probability-weighted environmental impacts of severe accidents are small. 9 Evaluation of New Information 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Additionally, both the applicant and the NRC must consider whether new and significant information affects environmental determinations in the NRC's regulations, including the determination in 10 CFR 51.53(c)(3)(ii)(L) and Table B-1 that the agency need not reconsider SAMAs at license renewal if it has already done so in a NEPA document for the plant. New information is significant if it provides a seriously different picture of the impacts of the Federal action under consideration. Thus, for mitigation alternatives such as SAMAs, new information is significant if it indicates that a mitigation alternative would substantially reduce an impact of the Federal action on the environment. Consequently, with respect to SAMAs, new information may be significant if it indicated a given cost-beneficial SAMA would substantially reduce the impacts of a severe accident, the probability or consequences (risk) of a severe accident occurring. As discussed below, none of the information identified by the applicant or the staff indicates that any SAMAs would be cost beneficial and likely to result in such a reduction of risk. Rather, new information indicates that further SAMA analyses are unlikely to identify a SAMA that substantially reduces the risk of a severe accident, such as major, cost-beneficial plant improvements, and that the overall probability of a severe accident has decreased at LGS. The following evaluation for new and significant information is to determine whether any new and significant information exists that provides a "seriously different picture of the environmental impacts than what was previously envisioned" regarding the determination in 10 CFR 51.53(c)(3)(ii)(L), Table B-1, and the clarifications in the statement of considerations. As explained above, the Commission determined that no new SAMA analysis is required for plants such as LGS at the license renewal stage. 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 The applicant relied on this and did not submit a SAMA analysis for license renewal. Specifically, the applicant cited 10 CFR 51.53(c)(3)(ii)(L) and stated that no SAMA was submitted as none was required as a matter of law (Entergy 2011c). Thus, the applicant's treatment of SAMA in its ER is in accordance with the Commission's regulations, and the applicant evaluated the new and significant information evaluation with respect to the Commission's regulation (Exelon 2011c). The applicant analyzed whether potentially new and significant information would change the results of its 1989 SAMDA Analysis review. The Commission had indicated that if the Staff identifies information that could invalidate the 1989 SAMDS Analysis, it should determine if that information is significant. The staff reviewed the applicant's submitted information and also assessed if any new and significant information has been found that would change the generic conclusion codified by the NRC that Exelon need not reassess SAMAs at LGS for license renewal (10 CFR 51.53(c)(3)(ii)(L)) and the staff need not reconsider SAMAS at this stage (10 CFR 51, Table B-1). The following summarizes Exelon's evaluation and the staff's review of this information. In addition, the staff's independent assessment did not identify any other new and significant information with respect to those regulations. Hence, no new and significant information has been found with respect to the generic conclusion codified by the NRC that LGS need not reassess SAMAs for license renewal (10 CFR 51.53(c)(3)(ii)(L)) because neither the Staff nor applicant uncovered any new and 5-7 Environmental Impacts of Postulated Accidents 1 2 significant information that suggested another cost beneficial SAMA that could substantially reduce the risk of a severe accident at Limerick. 3 The Applicant's Evaluation of New and Significant Information 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 The applicant explained the process it used to identify any potentially new and significant information related to its existing 1989 SAMA review in Section 5.3.1 of the ER (Exelon 2011c). As provided in Section 5.1 of Appendix E of the ER (Exelon 2011c), the new and significant assessment that Exelon conducted during preparation of this license renewal application included: (1) interviews with Exelon Generation subject-matter experts on the validity of the conclusions in the GEIS as they relate to LGS, (2) an extensive review of documents related to environmental issues at LGS, (3) a review of correspondence with State and Federal agencies to determine if the agencies had concerns relevant to their resource areas that had not been addressed in the GEIS, (4) a review of the results of LGS environmental monitoring and reporting, as required by regulations and oversight of plant facilities and operations by State and Federal regulatory agencies (i.e., the results of ongoing routine activities that could bring significant issues to Exelon Generation's attention), (5) a review for issues relevant to the LGS application of certain license renewal applications that have previously been submitted to the NRC by the operators of other nuclear plants, and (6) a review of information related to severe accident mitigation. The significance and materiality of the new information identified through this process was discussed further in ER Section 5.3.2, "Significance of New Information." Exelon used a methodical approach to identify new and significant information and the staff finds Exelon's process adequate to ensure a reasonable likelihood that the applicant would be aware of any new and significant information. 23 24 25 The following four items of new information were identified and evaluated by the applicant by comparing assumptions for the 1989 SAMDA Analysis with assumptions used for current-day assessments of SAMAs: 26 27 28 29 (1) (2) (3) (4) population increase consideration of offsite economic cost risk changed criteria for assigning cost per person-rem averted changed seismic hazard proposed by GI-199 30 31 32 33 34 35 36 37 38 39 40 Each item of new information was evaluated by the applicant and reviewed by the staff to determine whether it would materially alter the NRC's conclusions, as documented in the 1989 SAMDA Analysis, which is one of the documents that supports the determination in 10 CFR 51.53(c)(3)(ii)(L). None of the items of new information led to the identification of a SAMA that was cost-beneficial. Consequently, the applicant's and staff's review of new and significant information with respect to the 1989 SAMA review did not uncover any cost beneficial plant improvements or SAMAs that would substantially decrease the risk of a severe accident. Instead, it confirmed that no plant improvements that led to a substantial reduction in risk would be cost-beneficial. Therefore, the staff finds that none of the new information identified by the applicant significantly affects the generic conclusion codified by the NRC that applicants need not reassess SAMAs for license renewal at facilities like LGS (10 CFR 51.53(c)(3)(ii)(L)). 41 Risk 42 43 44 45 46 47 As provided in the discussion earlier regarding LGS's IPE, the CDF in the 2009 PRA Update (3.2x10-6) is more than an order of magnitude less than the 1989 PRA Update (Exelon ER). Any change in the likelihood of accidents that release substantial amounts of radioactive material to the environment not only affects the human impact but also any environmental impact. For LGS, this decrease in CDF would demonstrate less impact to dose, economic, and environmental impact. The overall reduction in risk indicates that further SAMA analyses for 5-8 Environmental Impacts of Postulated Accidents 1 2 3 4 LGS would be unlikely to uncover cost-beneficial major plant improvements or plant improvements that could substantially reduce risk. In light of the significant reduction in CDF, no new information is likely to significantly affect the Commission's generic determination that the NRC need not reanalyze SAMAs at LGS for license renewal. 5 Population Increase 6 7 8 9 10 11 A summary of Exelon's evaluation of population increase provided in the ER is as follows. Exelon provided population values within 50 miles growing from 6,819,505 in 1980 to 9,499,925 in 2030. They further assumed that this 39 percent increase in population would yield an approximate 39 percent increase in dose values. Hence, even assuming 2030 population numbers, the highest benefit/cost ratio SAMDA (ATWS Vent) based on cost per person-rem averted would still not be cost beneficial in the 1989 SAMDA Analysis. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 The staff reviewed the calculation provided by the applicant and agrees that the population increase would not make any of the 1989 SAMDA's cost effective. The staff acknowledges that a more precise estimate of this relationship could be obtained by using the MACCS2 code, performing a level III PRA, and completing a SAMA analysis. However, NEPA does not require the NRC to completely reanalyze issues it has resolved generically, only look for information that provides a "seriously different picture" of those considered generically. Notably, additional conservatisms not mentioned by the applicant include that converting the $3,000,000 cost of the anticipated transient without scram (ATWS) Vent SAMDA to 2012 dollars would increase the cost of the SAMDA to over $5,000,000(assuming similar construction and engineering practices) and the current CDF for LGS is nearly an order of magnitude smaller than the one used in the 1989 SAMDA Analysis. Considering the large conservatisms in the analysis with respect to CDF, the applicant's analysis is reasonable. Moreover, even if population increase led to another SAMA becoming cost beneficial, that SAMA would still not likely result in a substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick since the 1989 SAMDA analysis. Consequently, the population increase within 50 miles of LGS does not suggest that additional cost beneficial SAMAs could substantially reduce the risk of severe accidents and therefore does not constitute new and significant information with respect to the generic conclusion codified by the NRC that SAMAs need not be reassessed at facilities like LGS for license renewal (10 CFR 51.53(c)(3)(ii)(L)). 31 Consideration of Offsite Economic Cost Risk 32 33 34 35 36 37 38 39 The applicant indicated that the 1989 SAMDA Analysis did not consider offsite economic cost risk. To account for the offsite economic cost risk, the applicant estimated these impacts by using data from the Three Mile Island (TMI) license renewal application (Amergen 2008). Using TMI data, the offsite economic cost risk was approximately 70 percent larger than the offsite exposure cost risk at TMI. In order to apply the TMI data to LGS, the applicant applied a factor of 3 (300 percent) to analyze the impact on the 1989 SAMDA Analysis for LGS. Applying a factor of 3 reduction to the closest potential cost beneficial SAMDA (ATWS Vent) would not result in a cost beneficial SAMDA (Exelon 2011c). 40 41 42 43 44 45 46 47 48 The staff assessed the calculation provided by the applicant. The staff also used similar ratios to evaluate the cost impact of onsite exposure and economic costs for LGS ($2,000 and $400,000, respectively) to obtain the total offsite and onsite economic and exposure cost. The net value was -$284,000, indicating the ATWS Vent SAMDA was still not cost effective. Since this was applied to the SAMDA (ATWS Vent) that was closest to being cost effective, none of the SAMDAs identified in the 1989 SAMDA Analysis would be cost effective. Additional conservatisms not mentioned by the applicant include converting the $3,000,000 cost of the ATWS Vent SAMA to 2012 dollars that would increase the cost of the SAMDA to over $5,000,000 (assuming similar engineering and construction practices). Considering the large 5-9 Environmental Impacts of Postulated Accidents 1 2 3 4 5 6 7 8 conservatisms in the Exelon analysis, it is reasonable. Moreover, even if consideration of offsite economic risk increase led to another SAMA becoming cost beneficial, that SAMA would still not likely result in a substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick since the 1989 SAMDA analysis. Therefore, consideration of offsite costs would not likely lead to discovery of a cost beneficial SAMA that would substantially reduce risk of severe accidents and, therefore, does not constitute new and significant information with respect to the generic conclusion codified by the NRC that applicants need not reassess SAMAs for facilities such as LGS for license renewal. 9 Changed Criterion for Assigning Cost per Person-Rem Averted 10 11 12 13 14 15 16 17 18 19 The 1989 SAMDA Analysis calculated the benefit of each proposed SAMDA based on a criterion of $1,000 per person-rem averted. Using a value of $2,000 per person-rem averted would increase the threshold and potentially result in new cost beneficial SAMDAs. As described in 1989 SAMDA Analysis, changing the cost/benefit threshold using the $2,000 per person-rem averted conversion would still not result in this or any other of the SAMDAs becoming cost beneficial. Therefore, Exelon concludes that changing the criterion for assigning benefit (i.e., cost per person-rem averted) from $1,000 per person-rem averted to $2,000 per person-rem averted would not change the conclusions in the 1989 SAMDA Analysis. Hence, the new information represented by the changed criterion for assigning cost per person-rem averted was judged not to be significant by Exelon. 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 The staff reviewed the LGS analysis provided in the License Renewal ER and agrees that changing the criterion for assigning cost per person-rem averted would not result in a cost beneficial SAMA. As provided above, the ATWS Vent has the lowest cost/benefit ratio for the set, and it represents the SAMDA with the largest benefit potential. Even for this limiting SAMDA, changing the cost/benefit threshold to $2,000 per person-rem averted would still not result in this or any other of the SAMDAs becoming cost beneficial. Since this was applied to the SAMDA (ATWS Vent) closest to being cost effective, none of the SAMDAs are cost effective. Additional conservatisms not mentioned by the applicant include that converting the $3,000,000 cost of the ATWS Vent SAMA to 2012 dollars would increase the cost of the SAMDA to over $5,000,000 (assuming similar engineering and construction practices). Considering all of the large conservatisms in the analysis, the applicant's analysis is reasonable. Moreover, even if the increase in cost per person-rem averted led to another SAMA becoming cost beneficial, that SAMA would still not likely result in a substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick since the 1989 SAMDA analysis. Therefore, consideration of offsite costs would not likely lead to discovery of a cost-beneficial SAMA, let alone one that would substantially reduce offsite risk and therefore does not constitute new and significant information with respect to the generic conclusion codified by the NRC that Exelon need not reassess LGS SAMAs for license renewal. 38 Changed Seismic Hazard Proposed in GI-199 39 40 The staff is investigating the implication of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States in GI-199. 41 42 43 44 45 46 47 48 The applicant indicated that GI-199 issues related to the seismic hazard will not result in postulated accident scenarios not already considered for LGS. Seismologists are frequently refining seismic methodologies and results, which may increase the estimated frequency of seismic events with very low probability. Results from the LGS June 1989 PRA Update indicate that the contribution from seismic risk to the total CDF is approximately 25 percent, with fire risk contributing 31 percent to the total risk (Exelon 2011c). Therefore, based on the June 1989 Update, the major risk contributors for external hazards are approximately equal to the CDF computed for internal events only. Based on the ER, total CDF for internal and external events 5-10 Environmental Impacts of Postulated Accidents 1 2 3 4 5 6 7 8 9 10 can generally be approximated by multiplying the CDF for internal events by a factor of 2. With a multiplication factor of 2 applied to the CDF estimated by the current model of record (CDF=3.2 x10-6), the revised CDF that accounts for both internal and external hazards (CDF=6.4 x10-6) would still be a factor of 6.5 below the value used in the 1989 SAMDA Analysis (CDF=4.2 x10-5 ). This demonstrates the excess margin in the 1989 SAMDA Analysis. A possible increase in risk beyond this assumption due to an even larger seismic CDF would be more than offset by the factor of 6.5 reduction in the current CDF. Therefore, Exelon concludes that the new information represented by the changed seismic hazard proposed in GI-199 is not significant because it would not materially alter the SAMDA conclusions in the 1989 SAMDA (Exelon 2011c). 11 12 13 14 15 16 17 18 19 20 21 22 23 The staff reviewed the method the applicant used in determining the external events multiplier and its use and determined that it was consistent with the guidance provided in NEI 05-01. The staff also confirmed that the risk has decreased since the 1989 SAMDA and agrees with Exelon's analysis that the new information represented by the changed seismic hazard proposed in GI-199 is not significant because it would not materially alter the SAMDA conclusions in the 1989 SAMDA Analysis. Considering the large conservatism in the 1989 SAMDA Analysis, the applicant's approach is reasonable. Moreover, even if the change in seismic hazard led to another SAMA becoming cost beneficial, that SAMA would still not likely result in a substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick since the 1989 SAMDA analysis. Therefore, consideration of GI-199 is not likely to lead to the discovery of a cost-beneficial SAMA that would substantially reduce offsite risk and, therefore, does not constitute new and significant information with respect to the generic conclusion codified by the NRC that SAMAs need not be reassessed at LGS for license renewal. 24 Additional staff evaluation for new and significant information 25 26 27 28 29 The staff reviewed records of public meetings and correspondence related to the application and compared information presented by the public with information considered in NUREG-1437 to determine if there was any new and significant information with respect to the generic conclusion codified by the NRC, which indicates that SAMAs need not be reassessed at LGS for license renewal (10 CFR 51.53(c)(3)(ii)(L)). 30 Cost-effective SAMAs Identified at Other Plants 31 32 33 34 35 36 37 38 39 40 41 42 43 44 From the scoping comments (NRDC 2011), there was a recommendation that potential cost-effective SAMAs identified at other similar plants be addressed at LGS. Many of the SAMA recommendations identified from other plants are compiled in an NRC published paper (NRC 2009). The paper concludes that, "SAMAs that are found to be potentially cost-beneficial tend to be low-cost improvements such as modifications to plant procedures or training, minimal hardware changes, and use of portable equipment." These potential cost-beneficial SAMAs are further evaluated and many times not found cost beneficial because sufficient risk is not eliminated by the modification (which was assumed) or other factors. Furthermore, the staff found that SAMA analyses that have been performed to date have found SAMAs that were cost-beneficial, or at least possibly cost-beneficial subject to further analysis, in approximately half of the plants. In general, the cost-beneficial SAMAs were identified and considered by the licensee under the current operating license. In several cases, SAMA-related modifications were implemented at LGS, further reducing that probability of an additional SAMA substantially reducing severe accident risk. (PECO 1992)(Exelon 2011c) 45 46 47 48 As provided in the statement of considerations for 10 CFR 51.53(c)(3)(ii)(L), in forming its basis for determining which plants needed to submit a SAMA, the Commission noted that all licensees had undergone, or were in the process of undergoing, more detailed site-specific severe accident mitigation analyses through processes separate from license renewal, specifically the 5-11 Environmental Impacts of Postulated Accidents 1 2 3 4 5 6 7 8 9 10 CPI, IPE, and IPEEE programs (61 FR 28467). These programs for LGS were discussed earlier. In light of these studies, the Commission stated that it did not expect future SAMA analyses in the license renewal stage to uncover "major plant design changes or modifications that will prove to be cost-beneficial" (61 FR 28467). As discussed above, the NRC's experience in completed license renewal proceedings has confirmed this assumption (NRC 2009). As a result, potentially cost-beneficial SAMAs at other facilities do not constitute new and significant information with respect to the NRC's determination not to perform a second SAMA analysis at license renewal in the event the agency has previously considered the issue because even if cost beneficial the NRC staff's experience show that they will not likely yield a major reduction of risk, particularly in light of the many improvements already implemented at Limerick. 11 Current State of the Art Knowledge for Performing SAMA Analysis 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 A current detailed SAMA analysis has the ability to analyze numerous plant-specific variables and the sensitivity of a SAMA analysis to these variables. In the scoping comments, numerous variables were identified that might cast doubt on the results of the initial 1989 SAMDA Analysis. To thoroughly evaluate all of these variables would require a de novo SAMA analysis, which is not required by 51.53(c)(3)(ii)(L) and Table B-1. However, the applicant evaluated some of the changes at LGS that could have a significant impact on the SAMA evaluation such as population increase, consideration of offsite economic cost risk, changed criteria for assigning cost per person-rem averted, and changed seismic hazard proposed by GI-199 and concluded that the changes or new information did not have a significant effect on the analysis. As provided earlier, the staff independently confirmed this information to be reasonable and moreover determine that they would not lead to identification of a SAMA that would substantially reduce offsite risks but acknowledges that a more precise answer could be found with a detailed SAMA analysis. However, the staff believes that this more precise answer would still not identify significant cost beneficial SAMAs. As explained above, new and significant information must provide a seriously different picture of the consequences of the Federal action under consideration. With respect to SAMAs, new information may be significant if it indicated a given SAMA would substantially reduce the probability or consequences of a severe accident. None of the information identified by the applicant or the staff indicates that any SAMAs would be likely to result in such a reduction of risk. Instead, as discussed above, new information indicates that further SAMA analyses are unlikely to identify such major, cost-beneficial plant improvements particularly in light of the substantial reduction in the CDF for Limerick since the 1989 SAMDA analysis. Nonetheless, the staff discusses another significant variable in contemporary SAMA analyses, fuel enrichment, further below. 35 Enrichment of Fuel (Power Uprates) 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Another potentially new and significant item that could impact the 1989 SAMA analysis is increases in the enrichment of the fuel in the core. The following is the staff's review for any significant changes to the fuel enrichment design basis at LGS by reviewing LGS docketed information regarding power uprates. Extended power uprates require using fuel with a higher percentage of uranium-235 or additional fresh fuel to derive more energy from the operation of the reactor. This results in a larger radionuclide inventory (particularly short-lived isotopes, assuming no change in burnup limits) in the core, than the same core at a lower power level. The larger radionuclide inventory represents a larger source term for accidents and can result in higher doses to offsite populations in the event of a severe accident. Typically, short-lived isotopes are the main contributor to early fatalities. As stated in NUREG-1449 (NRC 1993), short-lived isotopes make up 80 percent of the dose following early release. The staff found that LGS had received two power uprate approvals since 1989. One uprate occurred in 1995. In 1993, an amendment request was submitted to the NRC that would increase the licensed thermal power level of the reactor from 3,293 megawatts thermal (MWt) to 3,458 MWt, primarily 5-12 Environmental Impacts of Postulated Accidents 1 2 3 4 5 6 7 8 9 10 by increasing the licensed core flow. In the staff's Environmental Assessment and Finding of No Significant Impact related to the LGS application for the amendment, the staff found, "the radiological and nonradiological environmental impacts associated with the proposed small increase in power are very small and do not change the conclusion in the FES that the operation of LGS, Units 1 and 2, would cause no significant adverse impact upon the quality of the human environment." Furthermore, in the January 23, 1995 submittal relating to increasing core flow, the licensee indicated that while fuel burnup and enrichment levels may increase as a result of operation at uprated power, the burnup and enrichment will remain within the 5 percent enrichment and 60,000 MWd/MT value previously evaluated by the staff. Thus, the fuel enrichment did not exceed the previously licensed value (NRC 1995). 11 12 13 14 15 16 17 18 19 20 By application dated March 25, 2010 (Exelon 2010), Exelon submitted a license amendment request for the LGS Units 1 and 2 Facility Operating Licenses and Technical Specifications. The proposed amendment consisted of a 1.65 percent measurement uncertainty recapture (MUR) power uprate that will increase each unit's rated thermal power from 3,458 megawatts (MWt) to 3,515 MWt. The proposed amendment was characterized as a MUR power uprate, which uses a Cameron International (formerly Caldon) CheckPlusTM Leading Edge Flow Meter (LEFM) system to improve plant calorimetric heat balance measurement accuracy. This flowmeter provides a more accurate measurement of feedwater (FW) flow and thus reduces the uncertainty in the FW flow measurement. This submittal did not change the fuel enrichment design basis. 21 22 23 24 25 26 27 Neither of these power uprates increased the fuel enrichment any higher than was previously evaluated by the staff before the 1989 SAMDA Analysis was completed. Since the fuel enrichment was not increased, further SAMA analyses for LGS would be unlikely to uncover cost-beneficial major plant improvements or plant improvements that could substantially result in lower doses to offsite populations in the event of a severe accident. Also, it reinforces the Commission's generic determination that the NRC need not reanalyze SAMAs at LGS for license renewal. 28 Conclusion 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 In conclusion, 10 CFR 51.53(c)(3)(ii)(L) states that, "[i]f the staff has not previously considered SAMAs for the applicant's plant, in an environmental impact statement or related supplement or in an environmental assessment, a consideration of alternatives to mitigate severe accidents must be provided." Table B-1 in 10 CFR Part 51, which governs the scope of the staff's environmental review for license renewal, echoes this regulation. Applicants for plants that have already had a SAMA analysis considered by the NRC as part of an EIS, supplement to an EIS, or EA, do not need to have a SAMA analysis reconsidered for license renewal. In forming its basis for determining which plants needed to submit a SAMA at license renewal, the Commission noted that all licensees had undergone, or were in the process of undergoing, more detailed site-specific severe accident mitigation analyses through processes separate from license renewal, specifically the CPI, IPE, and IPEEE programs (61 FR 28467). In light of these studies, the Commission stated that it did not expect future SAMA analyses to uncover "major plant design changes or modifications that will prove to be cost-beneficial" (61 FR 28467). The NRC's experience in completed license renewal proceedings has confirmed this assumption. 44 45 46 47 48 LGS is a plant that had a previous SAMA documented in a NEPA document. Therefore, Exelon was not required to, and did not, submit a SAMA in its license renewal ER. Exelon did evaluate whether there was new and significant information with respect to the Commission's prior determination not to require a SAMA analysis at license renewal for those plants that were already the subject of a SAMA analysis by the staff. 5-13 Environmental Impacts of Postulated Accidents 1 2 3 4 5 6 7 8 9 10 11 12 The staff analyzed information in the applicant's ER with respect to the 1989 SAMDA Analysis for LGS, public comments, and its own review of information relevant to LGS to search for new and significant information with respect to the NRC's determination not to conduct a second SAMA analysis at LGS for license renewal and the studies and assumptions underlying that determination. In conducting that search, the staff considered whether new information provided a seriously different view of the consequences of renewing the LGS operating license than previously contemplated. For a mitigation analysis, such as a SAMA analysis, such information would need to demonstrate a substantial change in the environmental impact sought to be mitigated, in this case severe accidents. Given the discussion above, it is unlikely that further SAMA analyses for LGS could uncover cost beneficial SAMAs that would substantially reduce the risk of severe accidents because the reduction in severe accident risk at Limerick from the use of new information outweighs any increases resulting from new considerations. 13 14 15 16 17 18 19 20 21 The staff also did not identify any new and significant information that rises to a level that requires staff to seek Commission approval to conduct a new SAMA analysis (similar to the waiver requirement that applies for Category 1 issues when staff identifies new and significant information). The impacts of all other new information do not contribute sufficiently to the environmental impacts to warrant their inclusion in a SAMA analysis, since the likelihood of finding cost-effective plant improvements that substantially reduce risk is small. Additionally, the staff did not identify a significant environmental issue not covered in the GEIS, or that was not considered in the analysis in the GEIS and leads to an impact finding that is different from the finding presented in the GEIS. 22 23 24 25 26 27 The staff identified no new and significant information related to postulated accidents during the review of LGS's ER (Exelon 2011c) or evaluation of other available information. Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. In accordance with 10 CFR 51.53(c)(3)(ii)(L), the staff did not repeat the review of SAMAs for LGS. While another SAMA is not required, the applicant provided and the staff reviewed considerations of new and significant information. 28 5.4. References 29 30 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of production and utilization facilities." 31 32 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental protection regulations for domestic licensing and related regulatory functions." 33 34 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for renewal of operating licenses for nuclear power plants." 35 36 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor site criteria." 37 38 61 FR 28467. U.S. Nuclear Regulatory Commission. Environmental review for renewal of nuclear power plant operating licenses. Federal Register 61(109):28467-28481. June 5, 1996. 39 40 74 FR 13926. U.S. Nuclear Regulatory Commission. Power reactor security requirements. Federal Register 74(58): 13926-13993. March 27, 2009. 41 42 43 44 [Amergen] Amergen Energy Company, LLC. 2008. "Three Mile Island Nuclear Station, Applicant's Environmental Report, License Renewal Operating Stage." Kennett Square, PA: Amergen. Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML080220255, ML080220257, ML080220261, and ML080220282. 5-14 Environmental Impacts of Postulated Accidents 1 2 3 4 Energy Northwest. 2011. Letter from A. Javorik, Vice President, to NRC Document Control Desk. Subject: Columbia Generating Station, Docket No. 50-397, Response to request for additional information, license renewal application. November 17, 2011. ADAMS Accession No. ML11325A067. 5 6 7 8 [Exelon] Exelon Generation Company, LLC. 2010. Letter from M. Jesse, Manager, Licensing-Power Uprate, to NRC Document Control Desk. Limerick Generating Station, Units 1 and 2: Request for license amendment regarding measurement uncertainty recapture power uprate. March 25, 2010. ADAMS Accession No. ML100850380. 9 10 11 12 [Exelon] Exelon Generation Company, LLC. 2011a. Letter from M.P. Gallagher, Vice President, License Renewal Projects, to NRC Document Control Desk. Limerick Generating Station, Units 1 and 2: Application for renewed operating licenses. June 22, 2011. ADAMS Accession No. ML11179A096. 13 14 15 [Exelon] Exelon Generation Company, LLC. 2011b. License Renewal Application [LRA], Limerick Generating Station, Units 1 and 2. June 22, 2011. ADAMS Accession No. ML11179A101. 16 17 18 [Exelon] Exelon Generation Company, LLC. 2011c. Environmental Report-Operating License Renewal Stage, Limerick Generating Station, Units 1 and 2. June 22, 2011. ADAMS Accession No. ML11179A104. 19 20 21 Ghosh T, Palla R, Helton D. 2009. Perspectives on Severe Accident Mitigation Alternatives for U.S. Plant License Renewal. U.S. Nuclear Regulatory Commission. September 2009. ADAMS Accession No. ML092750488. 22 23 24 [NRC] U.S. Nuclear Regulatory Commission. 1988a. Generic Letter No. 88-20, "Individual Plant Examination for Severe Accident Vulnerabilities." November 23, 1988. ADAMS Accession No. ML031150465. 25 26 27 [NRC] U.S. Nuclear Regulatory Commission. 1988b. Generic Letter No. 88-20, Supplement No. 4, "Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities -10 CFR 50.54(f)." June 28, 1991. ADAMS Accession No. ML031150485. 28 29 [NRC] U.S. Nuclear Regulatory Commission. 1988c. SECY-88-147, "Integration Plan for Closure of Severe Accident Issue." May 25, 1988. 30 31 32 [NRC] U.S. Nuclear Regulatory Commission. 1989. Final Environmental Statement Related to Operation of LGS, Units 1 and 2. Washington, DC: NRC. NUREG-0974, Supplement 1. August 1989. ADAMS Accession No. ML112221A204. 33 34 35 [NRC] U.S. Nuclear Regulatory Commission. 1991. Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. Washington, DC: NRC. NUREG-1407. June, 1991. ADAMS Accession No. ML063550238. 36 37 38 [NRC] U.S. Nuclear Regulatory Commission. 1993. Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States. Washington, DC: NRC. NUREG-1449. September 1993. ADAMS Accession No. ML063470582. 39 40 41 42 43 [NRC] U.S. Nuclear Regulatory Commission. 1995. Letter from F. Rinaldi, Project Director, Division of Reactor Projects, to G. Hunger, Director-Licensing, PECO Energy Company. Environmental assessment and finding of no significant impact, power uprate with increased core flow, Limerick Generating Station, Unit Nos. 1 and 2 (TAC Nos. M88392 and M88393). February 7, 1995. ADAMS Accession No. ML011560483. 5-15 Environmental Impacts of Postulated Accidents 1 2 3 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 4 5 6 [NRC] U.S. Nuclear Regulatory Commission. 1997. Status of the Integration Plan for Closure of Severe Accident Issues and the Status of Severe Accident Research. Washington, DC: NRC. SECY 97-132. June 1997. ADAMS Accession No. ML992930144 7 8 9 [NRC] U.S. Nuclear Regulatory Commission. 1999a. Standard Review Plans For Environmental Reviews for Nuclear Power Plants, Supplement 1. Washington, DC: NRC. NUREG-1555. October 1999. ADAMS Accession No. ML003702019. 10 11 12 13 14 [NRC] U.S. Nuclear Regulatory Commission. 1999b. Section 6.3 - Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS Accession No. ML04069720. 15 16 17 [NRC] U.S. Nuclear Regulatory Commission. 2002. Perspectives Gained from the Individual Plant Examination of External Events (IPEEE) Program. Washington, DC: NRC. NUREG-1742. April 2002. ADAMS Accession No. ML021270070. 18 19 [NRC] U.S. Nuclear Regulatory Commission. 2004. Protecting Our Nation-Since 9-11-01. Washington, DC: NRC. NUREG/BR-0314. September 2004. 20 21 [NRC] U.S. Nuclear Regulatory Commission. 2006a. Frequently Asked Questions on License Renewal of Nuclear Power Reactors. Washington, DC: NRC. NUREG-1850. March 2006. 22 23 24 [NRC] U.S. Nuclear Regulatory Commission. 2006b. Mitigation of Spent Fuel Loss-of-Coolant Inventory Accidents and Extension of Reference Plant Analyses to Other Spent Fuel Pools. Sandia Letter Report, Revision. November 2, 2006. 25 26 27 [NRC] U.S. Nuclear Regulatory Commission. 2011a. "Recommendations for Enhancing Reactor Safety in the 21st Century: The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident." July 12, 2011. ADAMS Accession No. ML111861807 28 29 30 31 32 33 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from P. Bamford, Project Manager, Division of Operating Reactor Licensing, to MJ Pacilio, President and Chief Nuclear Officer, Exelon Nuclear. Limerick Generating Station, Units 1 and 2 - Issuance of amendments re: measurement uncertainty recapture power uprate and standby liquid control system changes (Tac Nos. ME3589, ME3590, ME3591, and ME3592). April 8, 2011. ADAMS Accession No. ML110691095. 34 35 36 [NRC] U.S. Nuclear Regulatory Commission. 2011c. SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan." ADAMS Accession No. ML 11186A950. 37 38 39 40 41 [NRC] U.S. Nuclear Regulatory Commission. 2011d. SECY-11-0124, "Recommended Actions to be taken Without Delay from the Near-Term Task Force Report." ADAMS Accession No. ML112911571.[NRC] U.S. Nuclear Regulatory Commission. 2011e. SRM-SECY-11-0124, "Staff Requirements-SECY-11-0124: Recommended Actions to Be Taken Without Delay from the Near-Term Task Force Report." October 18, 2011. 42 43 44 [NRC] U.S. Nuclear Regulatory Commission. 2011f. SECY-11-0137, "Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned." October 3, 2011. ADAMS Accession No. ML11272A111. 5-16 Environmental Impacts of Postulated Accidents 1 2 3 [NRC] U.S. Nuclear Regulatory Commission. 2011g. Staff Requirements- Secy-11-0137 - "Prioritization of Recommended Actions to Be Taken in Response to Fukushima Lessons Learned." December 15, 2011. 4 5 6 [NRC] U.S. Nuclear Regulatory Commission. 2012a. Order EA-12-049, Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. March 12, 2012. ADAMS Accession No. ML012054A735 7 8 9 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Order EA-12-050, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents." March 12, 2012. ADAMS Accession No. ML012054A694. 10 11 12 [NRC] U.S. Nuclear Regulatory Commission. 2012c. Order EA-12-051, "Subject: Issuance of Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation." March 12, 2012. ADAMS Accession No.ML012054A679. 13 14 15 16 [NRC] U.S. Nuclear Regulatory Commission. 2012d. "Request For Information Pursuant to Title 10 of The Code of Federal Regulations 50.54(F) Regarding Recommendations 2.1,2.3, and 9.3, of The Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident." March 12, 2012. ADAMS Accession No. ML012053A340. 17 18 19 20 [NRC] U.S. Nuclear Regulatory Commission. 2012e. Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Columbia Generating Station (NUREG-1437, Supplement 47) Final Report for Comment. Washington, DC: NRC. NUREG-1437. April 2012. ADAMS Accession No. ML11227A007. 21 22 23 [NRDC] Natural Resources Defense Council. 2011. Letter from NRDC to C. Bladey. Natural Resources Defense Council comments on Limerick EIS scoping process." October 28, 2011. ADAMS Accession No. ML11307A456 24 25 26 [PECO] Philadelphia Electric Company. 1992. Limerick Generating Station, Units 1 and 2: Individual plant examination volume 1. July 1992. ADAMS Accession No. ML080030106 and ML080030104. 27 28 29 30 [PECO] Philadelphia Electric Company. 1995. Limerick Generating Station, Units 1 and 2 response to NRC Generic Letter 88-20, supplement 4, "Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities." June 1995. ADAMS Accession No. ML073610238. 31 32 33 34 [PECO] Philadelphia Electric Company. 1996. Letter from G.A. Hungar, Jr., Director-Licensing, to NRC Document Control Desk. Limerick Generating Station, Units 1 and 2: Response to request for additional information regarding review of individual plant examination of external events. June 28, 1996. ADAMS Accession No. ML073610237. 5-17 1 2 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS 3 4 This chapter addresses issues related to the uranium fuel cycle, solid waste management, and greenhouse gas emissions during the proposed 20-year period of extended operation. 5 6.1. The Uranium Fuel Cycle 6 7 8 9 10 11 12 13 14 15 16 The uranium cycle includes uranium mining and milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation of radioactive materials, and management of low-level wastes and high-level wastes related to uranium fuel cycle activities. The generic potential impacts of the radiological and nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear fuel and wastes are described in detail in NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996, 1999) based, in part, on the generic impacts given in Table S-3, "Table of Uranium Fuel Cycle Environmental Data," located in Title 10 of the Code of Federal Regulations 51.51 (10 CFR 51.51) and in 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor." 17 18 19 In the GEIS, the U.S. Nuclear Regulatory Commission staff (the staff) identified nine Category 1 issues related to the fuel cycle and waste management, which appear in Table 6-1. There are no Category 2 issues related to the fuel cycle and waste management. 20 Table 6-1. Issues Related to the Uranium Fuel Cycle and Waste Management Issues GEIS Sections Category Offsite radiological impacts (individual effects from other than the disposal of spent 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 fuel and high-level waste) 1 Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 Offsite radiological impacts (spent fuel and high-level waste disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 Nonradiological impacts of the uranium fuel 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; cycle 6.2.4; 6.6 1 Low-level waste storage and disposal 6.1; 6.2.2.2;6.4.2; 6.4.3; 6.4.3.1; 6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1; 6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5; 6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3; 6.4.4.5.4; 6.4.4.6;6.6 1 Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 6.4.5.5; 6.4.5.6; 6.4.5.6.1; 6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6 1 Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 6.4.6.4; 6.4.6.5; 6.4.6.6; 6.4.6.7; 6.6 1 Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 1 Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, Addendum 1 1 6-1 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 2 3 4 5 6 7 The NRC staff's evaluation of the environmental impacts associated with spent nuclear fuel is addressed in two issues in Table 6-1, "Offsite radiological impacts (spent fuel and high-level waste disposal)" and "Onsite spent fuel." However, as explained later in this section, the scope of the evaluation of these two issues in this SEIS has been revised. The issue, "Offsite radiological impacts (spent fuel and high-level waste disposal)," is not evaluated in this SEIS. In addition, the issue, "Onsite spent fuel" only evaluates the environmental impacts during the license renewal term. 8 9 10 11 12 13 14 For the term of license renewal, the staff did not find any new and significant information related to the remaining uranium fuel cycle and solid waste management issues listed in Table 6-1 during its review of the Limerick Generating Station environmental report (ER) (Exelon 2011), the site visit, and the scoping process. Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the impacts are SMALL, except for the issue, "Offsite radiological impacts (collective effects)," which the NRC concluded are acceptable. 15 16 17 18 19 20 21 However, the offsite radiological impacts resulting from spent fuel and high-level waste disposal and the onsite storage of spent fuel, which will occur after the reactors have been permanently shutdown, are addressed in the Commission's Waste Confidence Decision Rule (WCD), 10 CFR 51.23. In 2010, the Commission revised the WCD (i.e., WCD Update) to reflect information gained based on experience in the storage of spent nuclear fuel and the increased uncertainty in the siting and construction of a permanent geologic repository for the disposal of spent nuclear fuel. 22 23 24 25 26 27 28 29 On June 8, 2012, in response to a legal challenge to the WCD, the U.S. Court of Appeals for the District of Columbia Circuit (New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012)) vacated the NRC's WCD Update (75 Federal Register (FR) 81032, 75 FR 81037). The court decision was based on grounds relating to aspects of the National Environmental Policy Act (NEPA). The court decision held that the WCD Update is a major Federal action necessitating either an environmental impact statement (EIS) or a finding of no significant environmental impact (FONSI), and the Commission's evaluation of the risks associated with the storage of spent nuclear fuel for at least 60 years beyond the licensed life for reactor operation is deficient. 30 31 32 33 34 In response to the court's ruling, the Commission, in CLI-12-16 (NRC 2012a), determined that it would not issue licenses dependent upon the WCD, until the issues identified in the court's decision are appropriately addressed. In CLI-12-16, the Commission also noted that this determination extends only to final license issuance; all current licensing reviews and proceedings should continue to move forward. 35 36 37 38 39 40 41 42 43 44 In addition, the Commission directed in SRM-COMSECY-12-0016 (NRC 2012b) that the NRC staff proceed with a rulemaking that includes the development of an EIS to support an updated WCD within 24 months (by September 2014). The Commission indicated that the EIS used to support the revised rule should build on the information already documented in various NRC studies and reports on the impacts associated with the storage of spent nuclear fuel that were developed as part of the 2010 WCD Update, and should primarily focus additional analyses on the deficiencies identified in the D.C. Circuit's decision. The NRC considers the WCD to be a generic issue that is best addressed through rulemaking, and that the NRC rulemaking process provides an appropriate forum for public review and comment on both the draft EIS and the proposed WCD. 45 46 47 48 The updated rule and supporting EIS will provide the necessary NEPA analyses of waste confidence-related human health and environmental issues. As directed by the Commission, the NRC will not issue a renewed license before the resolution of waste confidence-related issues. This will ensure that there would be no irretrievable or irreversible resource 6-2 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 2 commitments or potential harm to the environment before waste confidence impacts have been addressed. 3 4 5 If the results of the WCD EIS identify information that requires a supplement to this EIS, the NRC staff will perform any appropriate additional NEPA review for those issues before the NRC makes a final licensing decision. 6 6.2. Greenhouse Gas Emissions 7 8 9 10 This section discusses the potential impacts from greenhouse gases (GHGs) emitted from the nuclear fuel cycle. The GEIS does not directly address these emissions, and its discussion is limited to an inference that substantial carbon dioxide (CO2) emissions may occur if coal- or oil-fired alternatives to license renewal are carried out. 11 6.2.1. Existing Studies 12 13 14 15 16 17 Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other electricity generating methods have been widely studied. However, estimates and projections of the carbon footprint of the nuclear power lifecycle vary depending on the type of study done. Additionally, considerable debate also exists among researchers on the relative effects of nuclear and other forms of electricity generation on GHG emissions. Existing studies on GHG emissions from nuclear power plants generally take two different forms: 18 19 (1) qualitative discussions of the potential to use nuclear power to reduce GHG emissions and mitigate global warming, and 20 21 22 23 (2) technical analyses and quantitative estimates of the actual amount of GHGs generated by the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the operational or life cycle emissions from other energy generation alternatives. 24 6.2.1.1. Qualitative Studies 25 26 27 28 The qualitative studies consist primarily of broad, large-scale public policy, or investment evaluations of whether an expansion of nuclear power is likely to be a technically, economically, or politically workable means of achieving global GHG reductions. Studies the staff found during the subsequent literature search include the following: 29 30 31 32 33 34 35 ? Evaluations to determine if investments in nuclear power in developing countries should be accepted as a flexibility mechanism to assist industrialized nations in achieving their GHG reduction goals under the Kyoto Protocols (IAEA 2000, NEA 2002, Schneider 2000). Ultimately, the parties to the Kyoto Protocol did not approve nuclear power as a component under the clean development mechanism (CDM) because of safety and waste disposal concerns (NEA 2002). 36 37 38 ? Analyses developed to assist governments, including the United States, in making long-term investment and public policy decisions in nuclear power (Hagen et al. 2001, Keepin 1988, MIT 2003). 39 40 41 42 Although the qualitative studies sometimes reference and critique the existing quantitative estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally rely heavily on discussions of other aspects of nuclear policy decisions and investment, such as safety, cost, waste generation, and political acceptability. Therefore, these studies typically are 6-3 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 2 not directly applicable to an evaluation of GHG emissions associated with the proposed license renewal for a given nuclear power plant. 3 6.2.1.2. Quantitative Studies 4 5 6 7 8 9 10 11 12 13 14 15 16 A large number of technical studies, including calculations and estimates of the amount of GHGs emitted by nuclear and other power generation options, are available in the literature and were useful in the staff's efforts to address relative GHG emission levels. Examples of these studies include--but are not limited to--Mortimer (1990), Andseta et al. (1998), Spadaro (2000), Storm van Leeuwen and Smith (2008), Fritsche (2006), Parliamentary Office of Science and Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), Fthenakis and Kim (2007), and Dones (2007). In addition, Sovacool (2008) provides a review and synthesis of studies in existence through 2008; however, the Sovacool synthesis ultimately uses only 19 of the 103 studies initially considered (the remaining 84 were excluded because they were more than 10 years old, not publicly available, available only in a language other than English, or they presented methodological challenges by relying on inaccessible data, providing overall GHG estimates without allocating relative GHG impacts to different parts of the nuclear lifecycle, or they were otherwise not methodologically explicit). 17 18 19 Comparing these studies and others like them is difficult because the assumptions and components of the lifecycles that the authors evaluate vary widely. Examples of areas in which differing assumptions make comparing the studies difficult include the following: 20 ? energy sources that may be used to mine uranium deposits in the future, 21 ? reprocessing or disposal of spent nuclear fuel, 22 23 ? current and potential future processes to enrich uranium and the energy sources that will power them, 24 ? estimated grades and quantities of recoverable uranium resources, 25 ? estimated grades and quantities of recoverable fossil fuel resources, 26 27 ? estimated GHG emissions other than CO2, including the conversion to CO2 equivalents per unit of electric energy produced, 28 ? performance of future fossil fuel power systems, 29 ? projected capacity factors for alternatives means of generation, and 30 ? current and potential future reactor technologies. 31 32 33 34 35 36 In addition, studies may vary with respect to whether all or parts of a power plant's lifecycle are analyzed (i.e., a full lifecycle analysis will typically address plant construction, operations, resource extraction--for fuel and construction materials, and decommissioning), whereas a partial lifecycle analysis primarily focuses on operational differences. In addition, as Sovacool (2008) noted, studies vary greatly in terms of age, data availability, and methodological transparency. 37 38 39 40 41 42 43 44 In the case of license renewal, a GHG analysis for the portion of the plant's lifecycle attributable to license renewal (operation for an additional 20 years) would not involve GHG emissions associated with construction because construction activities already have been completed at the time of relicensing. In addition, the proposed action of license renewal also would not involve additional GHG emissions associated with facility decommissioning because that decommissioning must occur whether the facility is relicensed or not. However, in many studies, the specific contribution of GHG emissions from construction, decommissioning, or other portions of a plant's lifecycle cannot be clearly separated from one another. In such 6-4 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 2 3 4 5 6 cases, an analysis of GHG emissions would overestimate the GHG emissions attributed to a specific portion of a plant's lifecycle. As Sovacool (2008) noted, many of the available analyses provide markedly lower GHG emissions per unit of plant output when one assumes that a power plant operates for a longer period of time. Nonetheless, available studies supply some meaningful information on the relative magnitude of the emissions among nuclear power plants and other forms of electric generation, as discussed in the following sections. 7 8 9 10 11 12 13 14 15 16 In Tables 6-2, 6-3, and 6-4, the staff presents the results of the above-mentioned quantitative studies to supply a weight-of-evidence evaluation of the relative GHG emissions that may result from the proposed license renewal compared to the potential alternative use of coal-fired, natural gas-fired, and renewable generation. Most studies from Mortimer (1990) onward (through Sovacool 2008) indicate that uranium ore grades and uranium enrichment processes are leading determinants in the ultimate GHG emissions attributable to nuclear power generation. These studies show that the relatively lower order of magnitude of GHG emissions from nuclear power, when compared to fossil-fueled alternatives (especially natural gas), could potentially disappear if available uranium ore grades drop sufficiently while enrichment processes continued to rely on the same technologies. 17 18 19 20 Sovacool's synthesis of 19 existing studies found that nuclear power generation causes carbon emissions in a range of 1.4 grams of carbon equivalent per kilowatt-hour (g Ceq/kWh) to 288 g Ceq/kWh, with a mean value of 66 g Ceq/kWh. The results of his synthesis and the results of others' efforts are included in the tables in this section. 21 6.2.1.3. Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 22 23 24 25 26 27 28 29 Considering that coal fuels the largest share of electricity generation in the United States and that its burning results in the largest emissions of GHGs for any of the likely alternatives to nuclear power generation, including CGS, many of the available quantitative studies focused on comparing the relative GHG emissions of nuclear to coal-fired generation. The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the nuclear lifecycle), as compared to an equivalent coal-fired plant, are presented in Table 6-2. The following table does not include all existing studies, but it gives an illustrative range of estimates that various sources have developed. 6-5 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal 1 Source GHG Emission Results Mortimer (1990) Nuclear--230,000 tons CO2 Coal--5,912,000 tons CO2 Note: Future GHG emissions from nuclear to increase because of declining ore grade. Andseta et al. (1998) Nuclear energy produces 1.4% of the GHG emissions compared to coal. Note: Future reprocessing and use of nuclear-generated electrical power in the mining and enrichment steps are likely to change the projections of earlier authors, such as Mortimer (1990). Spadaro (2000) Nuclear--2.5-5.7 g Ceq/kWh Coal--264-357 g Ceq/kWh Storm van Leeuwen and Smith Authors did not evaluate nuclear versus coal. (2008) Fritsche (2006) (values estimated from graph in Figure 4) Nuclear--33 g Ceq/kWh Coal--950 g Ceq/kWh POST (2006) (nuclear calculations from AEA, 2006) Nuclear--5 g Ceq/kWh Coal-->1,000 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce coal-fired GHG emissions by 90%. Weisser (2006) (compilation of Nuclear--2.8-24 g Ceq/kWh results from other studies) Coal--950-1,250 g Ceq/kWh Fthenakis and Kim (2007) Authors did not evaluate nuclear versus coal. Dones (2007) Author did not evaluate nuclear versus coal. Sovacool (2008) Nuclear--66 g Ceq/kWh Coal --960 to 1,050 g Ceq/kWh (coal adopted from Gagnon et al. 2002) 2 6.2.1.4. 3 4 5 6 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the nuclear lifecycle), as compared to an equivalent natural gas-fired plant, are presented in Table 6-3. The following table does not include all existing studies, but it gives an illustrative range of estimates various sources have developed. Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 6-6 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas 1 Source GHG Emission Results Mortimer (1990) Author did not evaluate nuclear versus natural gas. Andseta et al. (1998) Author did not evaluate nuclear versus natural gas. Spadaro (2000) Nuclear--2.5-5.7 g Ceq/kWh Natural gas--120-188 g Ceq/kWh Nuclear fuel cycle produces 20-33% of the GHG emissions compared to Storm van Leeuwen and Smith natural gas (at high ore grades). (2008) Note: Future nuclear GHG emissions will increase because of declining ore grade. Fritsche (2006) (values estimated from graph in Figure 4) Nuclear--33 g Ceq/kWh Cogeneration combined cycle natural gas--150 g Ceq/kWh POST (2006) (nuclear calculations from AEA, 2006) Nuclear--5 g Ceq/kWh Natural gas--500 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce natural gas GHG emissions by 90%. Weisser (2006) (compilation of Nuclear--2.8-24 g Ceq/kWh results from other studies) Natural gas--440-780 g Ceq/kWh Fthenakis and Kim (2007) Dones (2007) 4 5 6 7 8 9 10 11 12 13 14 15 Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005), and concluded that the nuclear fuel cycle produces 15-27% of the GHG emissions of natural gas. Sovacool (2008) 2 3 Authors did not evaluate nuclear versus natural gas. Nuclear--66 g Ceq/kWh Natural gas--443 g Ceq/kWh (natural gas adopted from Gagnon et al. 2002) 6.2.1.5. Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the nuclear lifecycle), as compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of GHG emissions associated with these sources is more difficult than the calculations for nuclear energy and fossil fuels because of the large variation in efficiencies and capacity factors because of their different technologies, sources, and locations. For example, the efficiency of solar and wind energy is highly dependent on the wind or solar resource in a particular location. Similarly, the range of GHG emissions estimates for hydropower varies greatly depending on the type of dam or reservoir involved (if used at all). Therefore, the GHG emissions estimates for these energy sources have a greater range of variability than the estimates for nuclear and fossil fuel sources. As noted in Section 6.2.1.2, the following table does not include all existing studies, but it gives an illustrative range of estimates various sources have developed. 6-7 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources Source GHG Emission Results Mortimer (1990) Nuclear--230,000 tons CO2 Hydropower--78,000 tons CO2 Wind power--54,000 tons CO2 Tidal power--52,500 tons CO2 Note: Future GHG emissions from nuclear are expected to increase because of declining ore grade. Andseta et al. (1998) Author did not evaluate nuclear versus renewable energy sources. Spadaro (2000) Nuclear--2.5-5.7 g Ceq/kWh Solar PV--27.3-76.4 g Ceq/kWh Hydroelectric--1.1-64.6 g Ceq/kWh Biomass--8.4-16.6 g Ceq/kWh Wind--2.5-13.1 g Ceq/kWh Storm van Leeuwen and Smith Author did not evaluate nuclear versus renewable energy sources. (2008) Fritsche (2006) (values estimated from graph in Figure 4) Nuclear--33 g Ceq/kWh Solar PV--125 g Ceq/kWh Hydroelectric--50 g Ceq/kWh Wind--20 g Ceq/kWh POST (2006) (nuclear calculations from AEA, 2006) Nuclear--5 g Ceq/kWh Biomass--25-93 g Ceq/kWh Solar PV--35-58 g Ceq/kWh Wave/Tidal--25-50 g Ceq/kWh Hydroelectric--5-30 g Ceq/kWh Wind--4.64-5.25 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Nuclear--2.8-24 g Ceq/kWh Solar PV--43-73 g Ceq/kWh Weisser (2006) (compilation of Hydroelectric--1-34 g Ceq/kWh results from other studies) Biomass--35-99 g Ceq/kWh Wind--8-30 g Ceq/kWh Fthenakis and Kim (2007) Nuclear--16-55 g Ceq/kWh Solar PV--17-49 g Ceq/kWh Dones (2007) Author did not evaluate nuclear versus renewable energy sources. Nuclear--66 g Ceq/kWh Wind--9-10 g Ceq/kWh Hydroelectric (small, distributed)--10-13 g Ceq/kWh Biogas digester--11 g Ceq/kWh Sovacool (2008) (adopted from Solar thermal--13 g Ceq/kWh other studies) Biomass--14-35 g Ceq/kWh Solar PV--32 g Ceq/kWh Geothermal (hot, dry rock)--38 g Ceq/kWh (solar PV value adopted from Fthenakis et al. 2008; all other renewable generation values adopted from Pehnt 2006) 6-8 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 6.2.2. Conclusions: Relative Greenhouse Gas Emissions 2 3 4 5 6 7 The sampling of data presented in Tables 6-2, 6-3, and 6-4 demonstrates the challenges of any attempt to determine the specific amount of GHG emission attributable to nuclear energy production sources because different assumptions and calculation methods will yield differing results. The differences and complexities in these assumptions and analyses will further increase when they are used to project future GHG emissions. Nevertheless, several conclusions can be drawn from the information presented. 8 9 10 11 12 13 14 15 16 17 First, the various studies show a general consensus that nuclear power currently produces fewer GHG emissions than fossil-fuel-based electrical generation (e.g., GHG emissions from a complete nuclear fuel cycle currently range from 2.5-66 grams of carbon equivalent per kilowatt hour (g Ceq/kWh), as compared to the use of coal plants (264-1,250 g Ceq/kWh) and natural gas plants (120-780 g Ceq/kWh)). The studies also provide estimates of GHG emissions from five renewable energy sources based on current technology. These estimates included solar-photovoltaic (17-125 g Ceq/kWh), hydroelectric (1-64.6 g Ceq/kWh), biomass (8.4-99 g Ceq/kWh), wind (2.5-30 g Ceq/kWh), and tidal (25-50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion is that current GHG emissions from nuclear power generation are of the same order of magnitude as from these renewable energy sources. 18 19 20 21 22 23 24 25 26 27 Second, the studies show no consensus on future relative GHG emissions from nuclear power and other sources of electricity. There is substantial disagreement among the various authors about the GHG emissions associated with declining uranium ore concentrations, future uranium enrichment methods, and other factors, including changes in technology. Similar disagreement exists about future GHG emissions associated with coal and natural gas for electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle currently produces fewer GHG emissions than fossil-fuel-based sources and is expected to continue to do so in the near future. The primary difference between the authors is the projected cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed those of fossil-fuel-based sources) or whether cross-over will actually occur. 28 29 30 31 Considering current estimates and future uncertainties, it appears that GHG emissions associated with the proposed LGS relicensing action are likely to be lower than those associated with fossil-fuel-based energy sources. The staff bases this conclusion on the following rationale: 32 33 34 ? As shown in Tables 6-2 and 6-3, current estimates of GHG emissions from the nuclear fuel cycle are far below those for fossil-fuel-based energy sources. 35 36 37 38 39 ? License renewal of a nuclear power plant such as LGS may involve continued GHG emissions caused by uranium mining, processing, and enrichment, but will not result in increased GHG emissions associated with plant construction or decommissioning (since the plant will have to be decommissioned at some point whether the license is renewed or not). 40 41 42 43 44 ? Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels within a timeframe that includes the LGS periods of extended operation. Several studies suggest that future extraction and enrichment methods, the potential for higher-grade resource discovery, and technology improvements could extend this timeframe. 6-9 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 2 With respect to the comparison of GHG emissions among the proposed LGS license renewal action and renewable energy sources: 3 4 5 ? It appears likely that there will be future technology improvements and changes in the type of energy used for mining, processing, manufacturing, and constructing facilities of all types. 6 7 ? Currently, the GHG emissions associated with the nuclear fuel cycle and renewable energy sources are within the same order of magnitude. 8 9 10 11 12 ? Because nuclear fuel production is the most significant contributor to possible future increases in GHG emissions from nuclear power--and since most renewable energy sources lack a fuel component--it is likely that GHG emissions from renewable energy sources will be lower than those associated with LGS at some point during the period of extended operation. 13 14 The staff provides additional discussion on the contribution of GHG to cumulative air quality impacts in Section 4.11.2 of this supplemental EIS. 15 6.3. References 16 17 18 75 FR 81032. U.S. Nuclear Regulatory Commission. Consideration of environmental impacts of temporary storage of spent fuel after cessation of reactor operation. Federal Register 75(246):81032-81037. December 23, 2010. 19 20 75 FR 81037. U.S. Nuclear Regulatory Commission. Waste confidence decision update. Federal Register 75(246):81037-81076. December 23, 2010. 21 22 23 [AEA] AEA Technology. 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note." East Kilbride. UK: British Energy Group. March 2006. Available at (accessed 21 May 2012). 24 25 26 27 Andseta S, Thompson MJ, Jarrell JP, Pendergast DR. 1998. CANDU Reactors and Greenhouse Gas Emissions. Proceedings of the 19th Annual Conference, Canadian Nuclear Society; 1998 October 18-21; Toronto, Ontario. Available at (accessed 21 May 2012). 28 29 30 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. ADAMS Accession No. ML11179A104. 31 32 33 34 Dones R. 2007. Critical Note on the Estimation by Storm Van Leeuwen JW and Smith P of the Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain. Villigen, Switzerland: Paul Sherer Institute. April 2007. Available at (accessed 21 May 2012). 35 36 37 38 Fritsche UR. 2006. Comparison of Greenhouse-Gas Emissions and Abatement Cost of Nuclear and Alternative Energy Options from a Life-Cycle Perspective. Freiburg, Germany: Oko-Institut. January 2006. Available at (accessed 21 May 2012). 39 40 Fthenakis VM, Kim HC. 2007. Greenhouse-gas emissions from solar-electric and nuclear power: A life cycle study. Energy Policy 35(4):2549-2557. 6-10 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 1 2 3 4 [IAEA] International Atomic Energy Agency. 2000. Nuclear Power for Greenhouse Gas Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM). Vienna, Austria: IAEA. November 2000. Available at (accessed 22 May 2012). 5 6 7 Mortimer N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal Dec 89/Jan90. Available at (accessed 22 May 2012). 8 9 10 [NEA and OECD] Nuclear Energy Agency and the Organization for Economic Co-operation and Development. 2002. Nuclear Energy and the Kyoto Protocol. Paris, France: OECD. Available at (accessed 22 May 2012). 11 12 13 [NRC] U.S. Nuclear Regulatory Commission. Code Manual for MACCS2: Volume 1, User's Guide. Washington, DC. NRC. NUREG/CR-6613. May 1998. Agencywide Documents Access and Management System (ADAMS) Accession No. ML063550020. 14 15 16 17 18 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3-Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS Accession No. ML04069720. 19 20 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Commission, Memorandum and Order CLI-12-16." August 7, 2012. ADAMS Accession No. ML12220A094. 21 22 23 [NRC] U.S. Nuclear Regulatory Commission. 2012b. "SRM-COMSECY-12-0016-Approach for Addressing Policy Issues Resulting from Court Decision To Vacate Waste Confidence Decision and Rule." September 6, 2012. ADAMS Accession No. ML12250A032. 24 25 26 [POST] Parliamentary Office of Science and Technology. 2006. Carbon footprint of electricity generation. Postnote 268. October 2006. Available at (accessed 22 May 2012). 27 28 29 Schneider M. 2000. Climate Change and Nuclear Power. Gland, Switzerland: WWF-World Wildlife Fund for Nature. April 2000. Available at (accessed 22 May 2012). 30 31 Sovacool, BK. 2008. "Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical Survey." Energy Policy 36:2940-2953. 32 33 34 Spadaro JV, Langlois L, Hamilton B. 2000. "Greenhouse Gas Emissions of Electricity Generation Chains: Assessing the Difference." Vienna, Austria: International Atomic Energy Agency. 35 36 37 Storm van Leeuwen JW, Smith P. 2008. Nuclear Power--The Energy Balance. Chaam, Netherlands: Ceedata Consultancy. February 2008. Available at (accessed 22 May 2012). 38 39 40 41 Weisser D. 2006. A guide to life-cycle greenhouse gas (GHG) emissions from electric supply technologies. Energy 32(9): 1543-1559. Available at (accessed 22 May 2012). 6-11 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 1 2 3 4 5 6 7 8 Environmental impacts from the activities associated with the decommissioning of any reactor before or at the end of an initial or renewed license are evaluated in Supplement 1 of NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The U.S. Nuclear Regulatory Commission (NRC) staff's evaluation of the environmental impacts of decommissioning--presented in NUREG-0586, Supplement 1--notes a range of impacts for each environmental issue. 9 10 11 12 13 14 15 16 17 18 19 20 Additionally, the incremental environmental impacts associated with decommissioning activities resulting from continued plant operation during the renewal term are discussed in NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996, 1999). The GEIS includes a determination of whether the analysis of the environmental issue could be applied to all plants and whether additional mitigation measures would be warranted. Issues were then assigned a Category 1 or a Category 2 designation. Section 1.4 in Chapter 1 explains the criteria for Category 1 and Category 2 issues and defines the impact designations of SMALL, MODERATE, and LARGE. The NRC staff analyzed site-specific issues (Category 2) for Limerick Generating Station, Units 1 and 2 (LGS) and assigned them a significance level of SMALL, MODERATE, or LARGE, or not applicable to LGS because of site characteristics or plant features. There are no Category 2 issues related to decommissioning. 21 7.1. Decommissioning 22 23 24 Table 7-1 lists the Category 1 issues in Table B-1 of Title 10, Part 51 of the Code of Federal Regulations (10 CFR Part 51), Subpart A, Appendix B that are applicable to LGS decommissioning following the renewal term. Table 7-1. Issues Related to Decommissioning 25 Issues GEIS section Category Radiation doses 7.3.1; 7.4 1 Waste management 7.3.2; 7.4 1 Air quality 7.3.3; 7.4 1 Water quality 7.3.4; 7.4 1 Ecological resources 7.3.5; 7.4 1 Socioeconomic impacts 7.3.7; 7.4 1 26 27 28 Decommissioning would occur either if LGS were shut down at the end of its current operating license or at the end of the period of extended operation. There are no site-specific issues related to decommissioning. 29 30 A brief description of the NRC staff's review and the GEIS conclusions, as codified in Table B-1 of 10 CFR Part 51, for each of the issues follows: 31 32 Radiation doses. Based on information in the GEIS, the NRC noted that "[d]oses to the public will be well below applicable regulatory standards regardless of which decommissioning method 7-1 Environmental Impacts of Decommissioning 1 2 is used. Occupational doses would increase no more than 1 person-rem (1 person-millisievert) caused by buildup of long-lived radionuclides during the license renewal term." 3 4 5 6 Waste management. Based on information in the GEIS, the NRC noted that "[d]ecommissioning at the end of a 20-year license renewal period would generate no more solid wastes than at the end of the current license term. No increase in the quantities of Class C or greater than Class C wastes would be expected." 7 8 9 Air quality. Based on information in the GEIS, the NRC noted that "[a]ir quality impacts of decommissioning are expected to be negligible either at the end of the current operating term or at the end of the license renewal term." 10 11 12 13 Water quality. Based on information in the GEIS, the NRC noted that "[t]he potential for significant water quality impacts from erosion or spills is no greater whether decommissioning occurs after a 20-year license renewal period or after the original 40-year operation period, and measures are readily available to avoid such impacts." 14 15 16 Ecological resources. Based on information in the GEIS, the NRC noted that "[d]ecommissioning after either the initial operating period or after a 20-year license renewal period is not expected to have any direct ecological impacts." 17 18 19 20 Socioeconomic Impacts. Based on information in the GEIS, the NRC noted that "[d]ecommissioning would have some short-term socioeconomic impacts. The impacts would not be increased by delaying decommissioning until the end of a 20-year relicense period, but they might be decreased by population and economic growth." 21 22 23 24 25 26 27 28 Exelon Generation Company, LLC (Exelon) stated in its environmental report (ER) (Exelon 2011) that it is not aware of any new and significant information on the environmental impacts of LGS license renewal. The NRC staff has not found any new and significant information during its independent review of Exelon's ER, the site visit, the scoping process, or its evaluation of other available information. Therefore, the NRC staff concludes that there are no impacts related to these issues, beyond those discussed in the GEIS. For all of these issues, the NRC staff concluded in the GEIS that the impacts are SMALL, and additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted. 29 7.2. References 30 31 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." 32 33 34 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. ADAMS Accession No. ML11179A104. 35 36 37 38 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996. Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML040690705 and ML040690738. 39 40 41 42 43 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3-Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS Accession No. ML04069720. 7-2 Environmental Impacts of Decommissioning 1 2 3 4 [NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of Nuclear Power Reactors. Washington, DC: NRC. NUREG-0586, Supplement 1. November 2002. ADAMS Accession Nos. ML023470304 and ML023500295. 7-3 1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 2 3 4 5 6 The National Environmental Policy Act (NEPA) requires that Federal agencies consider reasonable alternatives to the proposed action in an environmental impact statement (EIS). In this case, the proposed action is the issuance of renewed licenses for the Limerick Generating Station (LGS), which will allow the plant to operate for 20 years beyond its current license expiration dates. 7 8 9 10 11 12 13 An operating license, however, is just one of a number of authorizations that an applicant must obtain to operate a nuclear plant. Energy-planning decisionmakers and owners of the nuclear power plant ultimately decide whether the plant will continue to operate, and economic and environmental considerations play important roles in this decision. In general, the U.S. Nuclear Regulatory Commission's (NRC's) responsibility is to ensure the safe operation of nuclear power facilities and not to formulate energy policy or encourage or discourage the development of alternative power generation. 14 15 16 17 18 The license renewal review process is designed to ensure safe operation of the nuclear power plant during the license renewal term. Under the NRC's environmental protection regulations in Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51), which implement Section 102(2) of NEPA, renewal of a nuclear power plant operating license also requires the preparation of an EIS. 19 20 21 22 23 24 25 26 27 To support the preparation of these EISs, the NRC prepared the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, in 1996. The license renewal GEIS was prepared to assess the environmental impacts of continued nuclear power plant operations during the license renewal term. The intent was to determine which environmental impacts would result in essentially the same impact at all nuclear power plants and which ones could result in different levels of impacts at different plants and would require a plant-specific analysis to determine the impacts. For those issues that could not be generically addressed, the NRC develops a plant-specific supplemental environmental impact statement (SEIS) to the GEIS. 28 29 NRC regulations in 10 CFR 51.71(d) implementing NEPA for license renewal require that a SEIS must do the following: 30 31 32 33 ...include a preliminary analysis that considers and weighs the environmental effects of the proposed action [license renewal]; the environmental impacts of alternatives to the proposed action; and alternatives available for reducing or avoiding adverse environmental effects. 34 35 36 37 While the 1996 GEIS reached generic conclusions on many environmental issues associated with license renewal, it did not determine which alternatives are reasonable and did not reach conclusions about site-specific environmental impact levels. As such, the NRC must evaluate the environmental impacts of alternatives on a site-specific basis. 8-1 Environmental Impacts of Alternatives 1 2 As stated in Chapter 1 of this document, alternatives to renewing the LGS operating licenses must meet the purpose and need for the proposed action; they must do the following: 3 4 5 6 ...provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet other future system generating needs, as such needs may be determined by State, utility, and where authorized, Federal (other than NRC) decision makers. (NRC 1996) 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 The NRC ultimately makes no decision about which alternative (or the proposed action) to carry out because that decision falls to utility, state, or other Federal officials. Comparing the environmental effects of these alternatives, however, will help the NRC decide whether the adverse environmental impacts of license renewal are so great as to deny the option of license renewal for energy-planning decisionmakers Alternatives Evaluated In-Depth: (10 CFR 51.95(c)(4)). If the NRC acts to issue a renewed license, then all of the alternatives o natural-gas-fired combined-cycle (NGCC) considered in this SEIS, including the o supercritical pulverized coal (SCPC) proposed action, will be available to o new nuclear energy-planning decisionmakers. If the NRC o wind power decides not to renew the license (or takes no action at all), then energy-planning o purchased power decisionmakers may no longer elect to continue operating LGS and will have to resort Other Alternatives Considered: to another alternative (or combination of alternatives)--which may or may not be one of o solar power, o combination alternative of wind, solar, and the alternatives considered in this section--to NGCC, meet the energy needs that LGS now satisfies. 25 26 27 28 29 30 31 32 33 34 35 36 37 38 In evaluating alternatives to license renewal, the NRC considered energy technologies or options currently in commercial operation, as well as some technologies not currently in commercial operation but likely to be commercially available by the time the current LGS operating licenses expire. The current operating licenses for LGS reactors will expire on October 26, 2024, and June 22, 2029, and reasonable alternatives must be available (constructed, permitted, and connected to the grid) by the time the current LGS licenses expire to be considered likely to become available. 39 40 41 42 43 44 45 46 47 Alternatives that cannot meet future system needs by providing amounts of baseload power equivalent to LGS's current generating capacity and, in some cases, those alternatives whose costs or benefits do not justify inclusion in the range of reasonable alternatives, were eliminated from detailed study. The staff evaluated the environmental impacts of the remaining alternatives and discusses them in depth in this chapter. Each alternative eliminated from detailed study is briefly discussed, and a basis for its removal is provided at the end of this section. In total, 18 alternatives to the proposed action were considered (see text box) and then narrowed to the 5 alternatives considered in Sections 8.1-8.5. 48 49 The 1996 GEIS presents an overview of some energy technologies but does not reach any conclusions about which alternatives are most appropriate. Since 1996, many energy o o wood waste, o conventional hydroelectric power, o ocean wave and current energy, o geothermal power, o municipal solid waste (MSW), o biofuels, o oil-fired power, o fuel cells, o demand-side management (DSM), and o 8-2 combination alternative of wind and compressed-air energy storage (CAES), delayed retirement. Environmental Impacts of Alternatives 1 2 technologies have evolved significantly in capability and cost while regulatory structures have changed to either promote or impede development of particular alternatives. 3 As a result, the analyses may include updated information from the following sources: 4 o Energy Information Administration (EIA), 5 o other offices within the U.S. Department of Energy (DOE), 6 o U.S. Environmental Protection Agency (EPA), 7 o industry sources and publications, and 8 9 o information submitted by Exelon Generation Company, LLC (Exelon) in its environmental report (ER). 10 11 12 13 14 15 16 17 18 The evaluation of each alternative considers the environmental impacts across several impact categories: air quality, groundwater use and quality, surface water use and quality, terrestrial ecology, aquatic ecology, human health, land use, socioeconomics, transportation, aesthetics, historic and archaeological resources, environmental justice, and waste management. A three-level standard of significance--SMALL, MODERATE, or LARGE--is used to indicate the intensity of environmental effects for each alternative undergoing in-depth evaluation. The order of presentation is not meant to imply increasing or decreasing level of impact. Nor does it imply that an energy-planning decisionmaker would be more likely to select any given alternative. 19 20 21 22 23 24 25 26 27 28 29 In some cases, the NRC considers the environmental effects of locating a replacement power alternative at the existing nuclear plant site. Selecting the existing plant site allows for the maximum use of existing transmission and cooling system infrastructures and minimizes the overall environmental impact. However, LGS does not have a sufficient amount of land available for all the replacement power alternatives because LGS would continue to operate while the replacement alternative is being built to prevent a gap in energy generation during the period of construction, which would take several years. As a result, the NRC evaluated the impacts of locating replacement power facilities at other existing power plant sites within the PJM Interconnection (PJM). Installing replacement power facilities at existing power plants and connecting to existing transmission and cooling system infrastructure would reduce the overall environmental impact. 30 31 32 33 34 To ensure that the alternatives analysis is consistent with state or regional energy policies, the NRC reviewed energy-related statutes, regulations, and policies within the Commonwealth of Pennsylvania and PJM, including, for example, state renewable portfolio standards (RPSs). As a result, the staff considers several alternatives that include wind power or solar photovoltaic power, as well as combinations that include them. 35 36 37 Exelon is wholly-owned by Exelon Corporation, which also owns companies that provide electric transmission, power marketing, and energy delivery. Exelon Generation does not directly serve any customers, but sells its output through existing markets, and in particular, through PJM. 38 39 40 41 42 43 44 45 The NRC considered the current generation capacity and electricity production within the Commonwealth of Pennsylvania, as well as, where pertinent, the territory covered by PJM. Pennsylvania is similar to the U.S. average in reliance on coal, natural gas, and nuclear power as its primary electric generation fuels. Pennsylvania is slightly more reliant on coal, less reliant on natural gas, and more reliant on nuclear power than the U.S. average. Pennsylvania diverged most from national averages in renewable generation. Pennsylvania hydropower and other renewables provided 2.8 percent of electricity in the Commonwealth compared to 10.4 percent nationwide (EIA 2012). 8-3 Environmental Impacts of Alternatives 1 2 3 Pennsylvania is one of the nation's top generators of electricity and a net exporter of power. While the staff generally considers alternatives located within Pennsylvania, it acknowledges that alternatives could also be located elsewhere in PJM. 4 5 6 7 8 9 10 11 12 13 14 The Commonwealth of Pennsylvania has established an alternative energy portfolio standard (AEPS, similar to a renewable portfolio standard) that requires electricity providers to obtain a minimum percentage of their power through renewable energy resources, energy efficiency measures, or one of several nonconventional coal-fired or natural-gas-fired alternatives, including waste coal, coal-mine methane, coal gasification, and combined-heat-and-power generation. The AEPS also includes a solar-power set-aside. Pennsylvania first adopted the AEPS requirement in 2004. It currently requires 18 percent of all electricity sold in the Commonwealth to come from qualifying sources by 2020-2021. The standard allows renewable energy credit trading within PJM (DSIRE 2011). Other states in PJM also have similar policies, which typically take the form of binding standards. Some, however, have implemented non-binding goals, as Virginia has done. 15 16 17 18 19 20 21 22 23 Sections 8.1-8.7 describe the environmental impacts of alternatives to license renewal. These include a natural gas combined-cycle (NGCC) in Section 8.1; a supercritical pulverized coal (SCPC) alternative in Section 8.2; a new nuclear alternative in Section 8.3; and a wind-power alternative in Section 8.4. A summary of these alternatives considered in depth is provided in Table 8-1. In Section 8.5, the staff discusses purchased power as an alternative, and in Section 8.6, the staff addresses alternatives considered but dismissed. Finally, the environmental effects that may occur if NRC takes no action and does not issue renewed licenses for LGS are described in Section 8.7. Section 8.8 summarizes the impacts of each of the alternatives considered. 8-4 Environmental Impacts of Alternatives Table 8-1. Summary of Alternatives Considered In Depth 1 Natural Gas (NGCC) Alternative Supercritical Pulverized Coal (SCPC) Alternative New Nuclear Alternative Wind Alternative Summary of Alternative Four 530-MW units, for a total of 2,120 MW Two to four SCPC Units, for a total of 2,120 MW Two unit nuclear plant 2,250 to 9,000 2-MW wind turbines, for a total of 4,500 to 18,000 MW Location An existing power plant site (other than LGS) in PJM. Some infrastructure upgrades may be required; would require construction of a new or upgraded pipeline. An existing power plant site (other than LGS) in PJM. Some infrastructure upgrades may be required. An existing nuclear Spread across plant site (other than multiple sites LGS) in PJM. Some throughout PJM. infrastructure upgrades may be required. Cooling System Closed-cycle with mechanical-draft cooling towers. Consumptive water use would be approximately 1/3 less than LGS. Closed-cycle with natural-draft cooling towers. Consumptive water use would be slightly less than LGS. Closed-cycle with N/A natural-draft cooling towers. Consumptive water use would be similar to LGS. Land Requirements 35 ac (14 ha) for the plant (Exelon 2011); 7,630 ac (3,090 ha) for wells, collection site, pipeline (NRC 1996) 280 ac (113 ha) for the plant (Exelon 2011); 49,600 ac (20,100 ha) for coal mining and waste disposal (NRC 1996); 464 ac (188 ha) for ash and scrubber sludge (Exelon 2011) 630 ac to 1,260 ac (255 ha to 510 ha) (Exelon 2011); 1,000 ac (400 ha) for uranium mining and processing (NRC 1996) Wind farms would be spread across 130,000 to 534,000 ac (53,000 to 216,000 ha) of land, but only 3,200 to 13,300 ac (1,300 to 5,400 ha), would be directly affected by the wind turbines (Exelon 2011, NREL 2009) Work Force 800 during construction; 2,500 during 45 during operations construction; 141 (Exelon 2011) during operations (Exelon 2011) 3,650 during construction; 820 during operations (Exelon 2011) 200 during construction; 50 during operations (Exelon 2011) 2 8.1 Natural Gas Combined-Cycle Alternative 3 4 5 Natural gas combined-cycle (NGCC) systems represent the large majority of the total number of plants currently under construction or planned in the United States. Factors that contribute to the popularity of NGCC facilities include high capacity factors, low relative construction costs, 8-5 Environmental Impacts of Alternatives 1 2 3 4 5 low gas prices, and relatively low air emissions. Development of new NGCC plants may be affected by uncertainties about the continued availability and price of natural gas (though less so than in the recent past) and future regulations that may limit greenhouse gas (GHG) emissions. A gas-fired power plant, however, produces markedly fewer GHGs per unit of electrical output than a coal-fired plant of the same electrical output. 6 7 8 9 10 11 12 13 14 15 16 Combined-cycle power plants differ significantly from most coal fired and all existing nuclear power plants. Combined-cycle plants derive the majority of their electrical output from a gas turbine and then generate additional power--without burning any additional fuel--through a second, steam turbine cycle. The exhaust gas from the gas turbine is still hot enough to boil water to steam. Ducts carry the hot exhaust to a heat recovery steam generator, which produces steam to drive a steam turbine and produce additional electrical power. The combined-cycle approach is significantly more efficient than any one cycle on its own; thermal efficiency can exceed 60 percent versus 38 percent for conventional single-cycle facilities (NETL 2007, Siemens 2007). In addition, because the natural gas-fired alternative derives much of its power from a gas-turbine cycle, and because it wastes less heat than the existing LGS unit, it requires significantly less cooling water. 17 18 19 20 21 22 While nuclear reactors, on average, operate with capacity factors above 90 percent (LGS Units 1 and 2 operated at 97 percent and 96 percent capacity factors, respectively, from 2003 to 2010 [NRC 2011]), the staff expects that an NGCC alternative would operate with roughly an 85 percent capacity factor. Nonetheless, the staff assumes that a similar-sized NGCC facility would be capable of providing adequate replacement power for the purposes of this NEPA analysis. 23 24 25 26 27 28 29 30 31 32 Typical power trains for large-scale NGCC power generation would involve one, two, or three combined-cycle units, available in a variety of standard sizes, mated to a heat-recovery steam generator. To complete the assessment of an NGCC alternative, the NRC presumes that appropriately sized units could be assembled to annually produce electrical power in amounts equivalent to LGS. For purposes of this review, the staff evaluated an alternative that consists of four General Electric (GE) Advanced F Class units, 530 MW(e) each, equipped with dry-low-nitrogen-oxide combustors to suppress nitrogen oxide formation and selective catalytic reduction (SCR) of the exhaust with ammonia for post-combustion control of nitrogen oxide emissions. This alternative provides 2,120 MW(e) of capacity, and thus slightly underestimates the potential environmental impacts of replacing the full 2,340 MW(e) produced by LGS. 33 34 35 36 37 38 39 40 41 42 43 While siting an alternative on the LGS site would allow for the fullest use of existing ancillary infrastructure, such as transmission and support buildings, and minimizes the use of undisturbed land, space constraints on the LGS site preclude that option. In its ER, Exelon proposed that the NGCC alternative could be constructed at another existing power plant site elsewhere in Pennsylvania or PJM, which would mitigate construction impacts in a similar way to building the alternative at the LGS site (Exelon 2011). The staff finds this to be a reasonable approach and adopts it for purposes of this analysis. It is possible that an NGCC alternative constructed at an existing power plant site would require some infrastructure upgrades, such as improved transmission lines or modifications to existing intake or cooling systems, but the staff expects that these impacts would be smaller than those necessary to support an NGCC alternative constructed on an undeveloped site. 44 45 46 47 Wherever the NGCC alternative is constructed, it is likely to require a new or upgraded pipeline to supply natural gas to the facility. Some of the natural gas supplied to this alternative is likely to come from Pennsylvania or neighboring states, but the NGCC alternative is unlikely to directly trigger new natural gas development in Pennsylvania or the region. 8-6 Environmental Impacts of Alternatives 1 2 3 4 NGCC power plants are feasible, commercially available options for providing electric generating capacity beyond the current LGS license expiration dates. Environmental impacts from the NGCC alternative are summarized in Table 8-2 and discussed in depth in Sections 8.1.1-8.1.9. 5 8.1.1. Air Quality 6 7 8 9 10 11 12 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control Region (AQCR, 40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in attainment for carbon monoxide (CO), lead, sulfur dioxide (SO2), and PM10 (particulate matter 10 microns or less in diameter) and nonattainment for ozone and PM2.5 (particulate matter 2.5 microns or less in diameter) (40 CFR 81.339). 13 14 15 16 17 18 A new NGCC generating plant would qualify as a new major-emitting industrial facility and would be subject to Prevention of Significant Deterioration (PSD) under requirements of the Clean Air Act (CAA) (EPA 2012a). The Pennsylvania Department of Environmental Protection (PADEP) has adopted 25 Pa. Code Chapter 127, which implements the EPA's PSD review. The NGCC plant would need to comply with the standards of performance for stationary combustion turbines set forth in 40 CFR Part 60 Subpart KKKK. 19 20 21 22 23 24 25 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, including review of the new sources that may affect visibility in any Federal Class I area. If an NGCC alternative was located close to a mandatory Class I area, additional air pollution control requirements would be required. As noted in Section 2.2.2.1, there are no mandatory Class I Federal areas within 50 miles (80 km) of the LGS site. However, there are a total of 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 26 27 28 29 30 A new NGCC plant would have to comply with Title IV of the CAA (42 USC ?7651) reduction requirements for sulfur dioxides (SO2) and nitrogen oxides (NOx), which are the main precursors of acid rain and the major causes of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the existing plants and a system of SO2 emission allowances that can be used, sold, or saved for future use by the new plants. 31 32 33 34 35 36 More recently, EPA has promulgated additional rules and requirements that apply to certain fossil-fuel-based power plants, such as NGCC generation. The Cross-State Air Pollution Rule (CSAPR) and the Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) Tailoring Rule impose several additional standards to limit ozone, particulate, and GHG emissions from fossil-fuel based power plants (EPA 2012c). A new NGCC plant would be subject to these additional rules and regulations. 37 38 39 The EPA has developed standard emission factors that relate the quantity of released air pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the staff projects the following air emissions for the NGCC alternative: 40 41 42 43 44 o o o o o sulfur oxides (SOx) - 167 tons (151 MT) per year, nitrogen oxides (NOx) - 485 tons (440 MT) per year, carbon monoxide (CO) - 735 tons (667 MT) per year, PM10 and PM2.5- 323 tons (293 MT) per year, and carbon dioxide (CO2) - 5,390,097 tons (4,889,896 MT) per year 8-7 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 Activities associated with the construction of the new NGCC plant on or off the LGS site would cause some additional, temporary air effects as a result of equipment emissions and fugitive dust from operation of the earth-moving and material-handling equipment. Emissions from workers' vehicles and motorized construction equipment exhaust would be temporary. The construction crews would use dust-control practices to control and reduce fugitive dust. The staff concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of the earth-moving and material-handling equipment would be SMALL. 8 Greenhouse Gas Emissions 9 10 11 12 13 14 Combustion of fossil fuels, including natural gas, is the greatest anthropogenic source of GHG emissions in the United States. Greenhouse gas emissions during construction of an NGCC alternative would result primarily from the consumption of fossil fuels in the engines of construction vehicles and equipment, workforce vehicles used in commuting to and from the work site, and delivery vehicles. Analogous impacts would occur in association with offsite pipeline construction. All such impacts, however, would be temporary. 15 16 17 18 Although natural gas combustion in the combustion turbines (CTs) would be the primary source of GHGs during operations, other miscellaneous ancillary sources such as truck and rail deliveries of materials to the site and commuting of the workforce would make minor contributions. 19 20 21 22 23 24 25 26 27 28 29 30 31 32 The National Energy Technology Laboratory (NETL) estimates that carbon capture and storage (CCS) will capture and remove as much as 90 percent of the CO2 from the exhausts of CTs, but it will result in a power production capacity decrease of approximately 14 percent, a reduction in net overall thermal efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a potential increase in the levelized cost of electricity produced in NGCC units so equipped by as much as 30 percent (NETL 2007). Further, permanent sequestering of the CO2 would involve removing impurities (including water) and pressurizing it to meet pipeline specifications and transferring the gas by pipeline to acceptable geologic formations. Even when opportunities exist to use the CO2 for enhanced oil recovery (rather than simply dispose of the CO2 in geologic formations), permanent disposal costs could be substantial, especially if the NGCC units are far removed from acceptable geologic formations. With CCS in place, the NGCC alternative would release 539,000 tons per year (489,000 MT) of CO2. Without CCS in place, the staff's projected CO2 emissions for the NGCC alternative would be 5,390,097 tons (4,889,896 MT) per year. 33 34 35 36 Given the expected relatively small workforce, relatively short construction period for both the NGCC facility and the pipeline, and CO2 emissions of operation for the NGCC alternative, the overall impact from the releases of GHGs of a natural gas-fired alternative would be SMALL to MODERATE. 37 Conclusion 38 39 Based on the above review, the overall air quality impacts of a new NGCC plant located at the LGS site are SMALL to MODERATE and based largely on operational impacts. 40 8.1.2. Groundwater Resources 41 42 43 44 45 46 Construction activities associated with the NGCC alternative could require groundwater dewatering of foundation excavations. This activity might require the use of cofferdams, sumps, wells, or other methods to address high water-table conditions. However, because of the relatively shallower depth of excavation for the NGCC plant as compared to other alternatives, any impacts would be expected to be minor at most sites; however, dewatering needs could be greater at some sites. Facility construction would increase the amount of impervious surface at 8-8 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 the site location as well as alter the subsurface strata because of excavation work and the placement of backfill following facility completion. While an increase in impervious surface would reduce infiltration and reduce groundwater recharge, the effects on water-table elevations at most sites would likely be very small. Below-grade portions of the new NGCC plant could also alter the direction of groundwater flow beneath a site. Such effects would likely be very localized at most site locations and would not be expected to affect offsite wells. Application of best management practices (BMPs) in accordance with a state-issued NPDES general permit, including appropriate waste management, water discharge, and spill prevention practices, would prevent or minimize any groundwater quality impacts during construction. 10 11 12 13 14 15 16 17 18 19 20 For the construction period, the NRC has conservatively assumed that groundwater would be used. However, it is more likely that water would be supplied via a temporary utility connection, if available, or trucked to the point of use from offsite sources. Regardless, groundwater use for construction of a new NGCC plant would be substantially less than the volume required for the coal-fired or nuclear alternatives because of the smaller footprint involved for excavation, earthwork, and structural work. This would encompass such uses as potable and sanitary uses, concrete production, dust suppression, and soil compaction. The workforce at the NGCC would be slightly smaller than the existing LGS workforce, which uses substantially less than 100 gpm (380 L/min) for both potable water supply and fire suppression uses. The GEIS has found that pumping rates of less than 100 gpm (380 L/min) have not been shown to adversely affect groundwater availability (NRC 1996). 21 22 23 24 25 26 27 28 For NGCC plant operations, the NRC assumed that the NGCC alternative would entail the same relative ratio of groundwater use to surface water use as that used at LGS Units 1 and 2. This includes the use of groundwater for service water makeup and potable and sanitary uses. Consequently, the staff expects that total groundwater usage and associated aquifer effects would be much less under this alternative than those under current LGS operations because of the smaller number of auxiliary systems requiring groundwater and the much smaller operational workforce under the NGCC alternative. Based on this assessment, the impacts on groundwater use and quality under the NGCC alternative would be SMALL. 29 8.1.3. Surface Water Resources 30 31 32 33 34 35 36 37 Construction activities associated with the NGCC alternative would be similar to construction activities for most large industrial facilities. A new NGCC plant would occupy a much smaller footprint (about 35 ac [14 ha]) than the current LGS or the proposed coal-fired or new nuclear alternatives. This would also result in less extensive excavation and earthwork than under either of the other conventional replacement power facility alternatives. The staff assumes that no surface water would be used during construction for the NGCC alternative because the staff assumed groundwater would be used or water would be supplied by a water utility or trucked in, as explained above in Section 8.1.2. 38 39 40 41 42 43 44 45 46 47 Some temporary impacts to surface water quality may result from increased sediment loading and from any pollutants in stormwater runoff from disturbed areas and from dredging activities. During facility construction, runoff from disturbed areas in the plant footprint would be controlled under a state-issued NPDES general permit that would require implementation of a stormwater pollution prevention plan and associated BMPs to prevent or significantly mitigate soil erosion and contamination of stormwater runoff. Depending on the path of the gas pipeline to supply the NGCC plant, some creeks and streams would likely be crossed. However, because of the short-term nature of the dredging activities, the hydrologic alterations and sedimentation would be localized and temporary. In addition, modern pipeline construction techniques, such as horizontal directional drilling, would further minimize the potential for water quality impacts in the 8-9 Environmental Impacts of Alternatives 1 2 affected streams. Dredging would be conducted under a permit from the U.S. Army Corps of Engineers (COE) requiring the implementation of BMPs to minimize impacts. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 For facility operations, the NGCC alternative would require much less cooling water than LGS Units 1 and 2, and consumptive water use would be much less. Assuming a typical ratio of 2 to 1 for electrical generation from gas turbine (Brayton cycle) to electrical generation from steam turbine (Rankine cycle) for a combined-cycle plant, the staff estimated that the consumptive water loss for an equivalent-sized combined-cycle plant would be about one-third the LGS water use. For the purposes of comparison, and as described in Section 2.2.4.1, the mean annual flow and 90 percent exceedance flows of the Schuylkill River are 1,935 cfs (54.8 m3/s) and 482 cfs (13.6 m3/s), respectively. At the mean annual flow and the 90 percent exceedance flow, the projected rate of consumptive water use for the NGCC plant (i.e., 22 cfs [0.62 m3/s]) represents a 1 percent and a 4 percent reduction in the streamflow in the Schuylkill River downstream of the NGCC alternative location, if sited at or near the LGS site. This reduced demand for water would substantially reduce the need for low-flow augmentation from either the Delaware River or the Wadesville Mine Pool. Effects may vary at other sites, but the net consumption of water would be less than that associated with existing LGS operations. 17 18 19 20 21 22 23 24 25 26 27 28 29 The NRC assumed that water treatment additives for the NGCC alternative would be essentially identical to LGS because similar additives are required for water conditioning to operate NGCC and nuclear plants. The NRC also assumed that the proposed site's existing intake and discharge infrastructure would be used, as described above. While the quality would be chemically similar, the discharge volume would be about one-third less than current LGS operations. Surface water withdrawals would be subject to applicable water allocation requirements in Pennsylvania and other states, and effluent discharges and stormwater discharges associated with industrial activity would be subject to a state-issued NPDES permit under this alternative. The NRC also assumes that facility operations would be subject to and would be conducted in accordance with a spill prevention, control, and countermeasures (SPCC) plan, stormwater pollution prevention plan, or equivalent plans and associated BMPs and procedures to prevent and respond to accidental releases of non-nuclear fuels, chemicals, and other materials to soil, surface water, and groundwater. 30 31 Therefore, based on the above assessment, the impacts on surface water use and quality under the NGCC alternative would be SMALL. 32 8.1.4. Aquatic Resources 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Construction activities for the NGCC alternative (such as construction of heavy-haul roads, a new pipeline, and the power block) could affect drainage areas or other onsite aquatic features. Minimal impacts on aquatic ecology resources are expected because the plant operator would likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, which would be required to comply with Pennsylvania NPDES permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the available infrastructure at the selected site, the NGCC alternative may require modification or expansion of the existing intake or discharge structures. Because of the relatively low withdrawal rates compared to the SCPC or new nuclear alternatives, it is unlikely that the operators would need to construct new intake and discharge structures for the NGCC alternative at an existing power plant site. Dredging activities that result from infrastructure construction would require BMPs for in-water work to minimize sedimentation and erosion. Because of the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats likely would be localized and temporary. 8-10 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 11 During operations, the NGCC alternative would require approximately one-third less cooling water to be withdrawn from the Schuylkill River, or other similar water body, than required for LGS Units 1 and 2. Because of the lower withdrawal rates, the number of fish and other aquatic resources affected by cooling-water intake and discharge operations, such as entrainment, impingement, and thermal stress, would be less for an NGCC alternative than for those associated with license renewal. The cooling system for a new NGCC plant would have similar chemical discharges as LGS, but the air emissions from the NGCC plant would emit particulates that could settle onto the river surface and introduce a new source of pollutants as described in Section 8.1.1. However, the flow of the Schuylkill River (or other water source) would likely dissipate and dilute the concentration of pollutants, resulting in minimal exposure to aquatic biota. 12 13 14 15 16 17 The impacts on aquatic ecology would be minor because construction activities would require BMPs and stormwater management permits, and because surface water withdrawal and discharge for this alternative would be less than for LGS Units 1 and 2. Deposition of pollutants into aquatic habitats from the plant's air emissions would be minimal because the concentration of pollutants would be diluted with the river flow. Therefore, the staff concluded that impacts on aquatic ecology would be SMALL. 18 19 20 21 22 23 24 25 26 27 28 Consultation with National Marine Fisheries Service (NMFS), and the U.S. Fish and Wildlife Service (FWS) under the Endangered Species Act (ESA) would ensure that the construction and operation of an NGCC plant would not adversely affect any Federally listed species or adversely modify or destroy designated critical habitat. Consultation with NMFS under the Magnuson-Stevens Act would require the NRC to evaluate impacts to essential fish habitat (EFH). NMFS would provide conservation recommendations if there would be adverse impacts to EFH. Coordination with state natural resource agencies would further ensure that the plant operator would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of an NGCC plant on protected species and habitats would be SMALL. 29 8.1.5. Terrestrial Resources 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Construction of an NGCC plant would occur at the site of an existing power station other than LGS and would require about 35 ac (14 ha) of land for the plant itself and about 7,630 ac (3,090 ha) of additional land off site for wells, collection stations, and pipelines to bring the gas to the plant (see Section 8.1.7). Because the onsite land requirement is relatively small, Exelon would likely be able to site most of the construction footprint in previously disturbed, degraded habitat, which would minimize impacts to terrestrial habitats and species. Offsite construction would occur mostly on land where gas extraction is occurring already. To the extent practicable, Exelon would route gas pipelines along existing, previously disturbed utility corridors (Exelon 2011). Erosion and sedimentation, fugitive dust, and construction debris impacts would be minor with implementation of appropriate BMPs (Exelon 2011). Impacts to terrestrial habitats and species from transmission line operation and corridor vegetation maintenance, and operation of the mechanical draft cooling towers would be similar in magnitude and intensity as those resulting from operating nuclear reactors and would, therefore, be SMALL (NRC 1996). Overall, the impacts of construction and operation of an NGCC plant to terrestrial habitats and species would be SMALL. 45 46 47 48 Consultation with FWS under the ESA would ensure that the construction and operation of an NGCC plant would not adversely affect any Federally listed terrestrial species or adversely modify or destroy designated critical habitat. Coordination with state natural resource agencies would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 8-11 Environmental Impacts of Alternatives 1 2 3 state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of an NGCC plant on protected species and habitats would be SMALL. 4 8.1.6. Human Health 5 6 7 8 9 10 Impacts on human health from construction of the NGCC alternative would be similar to effects associated with the construction of any major industrial facility. Compliance with worker protection rules would control those impacts on workers at acceptable levels. Impacts from construction on the general public would be minimal since crews would limit active construction area access to authorized individuals. Impacts on human health from the construction of the NGCC alternative would be SMALL. 11 12 13 14 15 16 17 18 19 Human health effects of gas-fired generation are generally low, although in Table 8-2 of the GEIS (NRC 1996), the staff identified cancer and emphysema as potential health risks from gas-fired plants. Nitrogen oxide emissions contribute to ozone formation, which in turn contributes to human health risks. Emission controls for the NGCC alternative can be expected to maintain NOx emissions well below air quality standards established for the purposes of protecting human health, and emissions trading or offset requirements mean that overall NOx releases in the region will not increase. Health risks for workers may also result from handling spent catalysts used for NOx control that may contain heavy metals. Impacts on human health from the operation of the NGCC alternative would be SMALL. 20 8.1.7. Land Use 21 22 23 24 25 26 The GEIS generically evaluates the impacts of constructing and operating various replacement power plant alternatives on land use, both on and off each power plant site. The analysis of land use impacts focuses on the amount of land area that would be affected by the construction and operation of a four-unit NGCC plant at the LGS site. Locating the new NGCC power plant near an existing power plant site would maximize the availability of support infrastructure and reduce the need for additional land. 27 28 29 30 31 32 33 34 35 Exelon estimated 35 ac (14 ha) for new unit construction (Exelon 2011). Based on GEIS estimates, approximately 243 ac (98.3 ha) of land would be needed to support an NGCC alternative to replace the LGS (NRC 1996). This amount of land use would include other plant structures and associated infrastructure and is unlikely to exceed the 243 ac (98.3 ha) estimate, excluding land for natural-gas wells and collection stations. Exelon's estimate appears reasonable and is a more site-specific estimate than the GEIS estimate. Depending on the site location and availability of existing natural gas pipelines, a 100-feet (ft)-wide (30.5-meter [m]-wide) right-of-way would be needed for a new pipeline. Land-use impacts from NGCC construction would be SMALL to MODERATE depending on location. 36 37 38 39 40 In addition to onsite land requirements, land would be required off site for natural-gas wells and collection stations. Scaling from GEIS (NRC 1996) estimates, approximately 7,630 ac (3,090 ha) would be required for wells, collection stations, and pipelines to bring the gas to the plant. Most of this land requirement would occur on land where gas extraction already occurs. Some natural gas could come from within Pennsylvania or nearby states. 41 42 43 44 The elimination of uranium fuel for LGS could partially offset some, but not all, of the land requirements for the NGCC. Scaling from GEIS (NRC 1996) estimates, approximately 1,640 ac (664 ha) would no longer be needed for mining and processing uranium during the operating life of the plant. Operational land-use impacts from a NGCC power plant would be SMALL. 8-12 Environmental Impacts of Alternatives 1 8.1.8. Socioeconomics 2 3 4 5 6 7 8 9 10 Socioeconomic impacts are defined in terms of changes to the demographic and economic characteristics and social conditions of a region. For example, the number of jobs created by the construction and operation of a power plant could affect regional employment, income, and expenditures. Two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of the NGCC alternative were evaluated to measure their possible effects on current socioeconomic conditions. 11 12 13 14 15 16 17 18 19 20 21 22 23 Scaling from GEIS estimates, the construction workforce would peak at 2,650 workers. Exelon estimated 800 workers at the peak of construction (Exelon 2011). Exelon's estimate appears to be reasonable and is consistent with trends toward lowering labor costs by reducing the size of plant workforces. Therefore, Exelon's estimate of 800 workers is used throughout this analysis. The relative economic impact of this many workers on the local economy and tax base would vary, with the greatest impacts occurring in the communities where the majority of construction workers would reside and spend their income. As a result, local communities could experience a short-term economic "boom" from increased tax revenue and income generated by construction expenditures and the increased demand for temporary (rental) housing and business services. Some construction workers could relocate in order to be closer to the construction work site. However, given the proximity of many existing power plants to metropolitan areas, workers could commute to the construction site, thereby reducing the need for rental housing. 24 25 26 27 After completing the installation of the four-unit NGCC plant, local communities could experience a return to pre-construction economic conditions. Based on this information and given the number of construction workers, socioeconomic impacts during construction in communities near the new NGCC site could range from SMALL to MODERATE. 28 29 30 31 32 33 34 35 36 37 38 39 Scaling from GEIS estimates, the plant operations workforce would be 331 workers. Exelon estimated a plant operations workforce of approximately 45 workers (Exelon 2011). Exelon's estimate appears to be reasonable and is consistent with trends toward lowering labor costs by reducing the size of plant operations workforces. Therefore, Exelon's estimate of 45 workers is used throughout this analysis. The reduction in employment at LGS from operations to decommissioning and shut down could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the region. However, the amount of property taxes paid to local jurisdictions under the NGCC alternative may increase if additional land is required to support this alternative. Based on the above discussion, socioeconomic impacts during operations could range from SMALL to MODERATE. 8-13 Environmental Impacts of Alternatives 1 8.1.9. Transportation 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Transportation impacts associated with construction and operation of a four-unit, NGCC power plant would consist of commuting workers and truck deliveries of construction materials to the power plant site. During periods of peak construction activity, up to 800 workers could be commuting daily to the site (Exelon 2011), as described in Section 8.1.8. Workers commuting to the construction site would arrive by site access roads, and the volume of traffic on nearby roads could increase substantially during shift changes. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Pipeline construction and modification to existing natural gas pipeline systems could also have a temporary impact. Some power plant components and materials could also be delivered by train or barge, depending on location. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from SMALL to MODERATE. 16 17 18 19 20 21 22 23 Traffic-related transportation impacts would be greatly reduced after completing the installation of the new NGCC units. Transportation impacts would include daily commuting by the operating workforce, equipment and materials deliveries, and the removal of commercial waste material to offsite disposal or recycling facilities by truck. The NGCC alternative is estimated to require an operational workforce of 45 (Exelon 2011), as described in Section 8.1.8. Since fuel is transported by pipeline, the transportation infrastructure would experience little to no increased traffic from plant operations. Overall, transportation impacts would be SMALL during power plant operations. 24 8.1.10. Aesthetics 25 26 27 28 29 30 31 The analysis of aesthetic impacts focuses on the degree of contrast between the NGCC alternative and the surrounding landscape and the visibility of the new NGCC plant at an existing power plant site. During construction, all of the clearing and excavation would occur on the existing power plant site. These activities could be visible from offsite roads. Since the existing power plant site would already appear industrial, construction of the NGCC power plant would appear similar to other ongoing onsite activities. The power block of the NGCC alternative could look similar to the existing power plant. 32 33 34 35 36 37 38 The four NGCC units could be approximately 100 ft (30 m) tall, with two exhaust stacks up to 150 ft (46 m) tall with two cooling towers over 500 ft (152 m) high (Exelon 2011). The facility would be visible off site during daylight hours, and some structures may require aircraft warning lights. The addition of mechanical draft cooling towers and associated condensate plumes could add to the visual impact. Noise generated during NGCC power plant operations would be limited to routine industrial processes and communications. Pipelines delivering natural gas fuel could be audible offsite near gas compressor stations. 39 40 41 42 43 In general, given the industrial appearance of the existing power plant site, the new NGCC power plant would blend in with the surroundings and the NGCC power plant could be similar in appearance to the existing power plant. Aesthetic changes therefore would be limited to the immediate vicinity of the existing power plant site, and any impacts would be SMALL depending on its location and surroundings. 8-14 Environmental Impacts of Alternatives 1 8.1.11. Historic and Archaeological Resources 2 3 4 5 6 7 8 9 10 11 12 13 To consider effects on historic and archaeological resources, any areas potentially affected by the construction of the NGCC alternative would need to be surveyed to identify and record historic and archaeological resources. An inventory of a previously disturbed former plant (brownfield) site may still be necessary if the site has not been previously surveyed or to verify the level of disturbance and evaluate the potential for intact subsurface resources. Plant operators would need to survey all areas associated with operation of the alternative (e.g., a new pipeline, roads, transmission corridors, other ROWs). Any resources found in these surveys would need to be evaluated for eligibility on the National Register of Historic Properties (NRHP), and mitigation of adverse effects would need to be addressed if eligible resources were encountered. Areas with the greatest sensitivity should be avoided. Visual impacts on significant cultural resources--such as the viewsheds of historic properties near the site--also should be assessed. 14 15 16 17 18 19 20 21 The potential for impacts on historic and archaeological resources from the NGCC alternative would vary greatly depending on the location of the proposed site. Given that the preference is to use a previously disturbed former plant site, avoidance of significant historic and archaeological resources should be possible and effectively managed under current laws and regulations. However, historic and archaeological resources could potentially be affected, depending on the resource richness of the land required for a new pipeline. Therefore, the impacts on historic and archaeological resources from the NGCC alternative would range from SMALL to MODERATE. 22 8.1.12. Environmental Justice 23 24 25 26 27 The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the construction and operation of a new power plant. Minority and low-income populations are subsets of the general public living near the proposed power plant site. 28 29 30 31 32 33 34 35 36 37 38 Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant and exceeds the risk or exposure rate for the general population or for another appropriate comparison group. Disproportionately high environmental effects refer to impacts or risk of impact on the natural or physical environment in a minority or low-income community that are significant and appreciably exceed the environmental impact on the larger community. Such effects may include biological, cultural, economic, or social impacts. For example, increased demand for rental housing during replacement power plant construction could disproportionately affect low-income populations that rely on the previously inexpensive rental housing market. 39 40 41 42 43 44 45 46 47 Potential impacts to minority and low-income populations would mostly consist of environmental and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be directly affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects are not likely to be high and adverse and would be contained to a limited time period during certain hours of the day. Increased demand for rental housing during construction could cause rental costs to rise disproportionately affecting low-income populations living near the site who rely on inexpensive 8-15 Environmental Impacts of Alternatives 1 2 housing. However, given the proximity of some existing power plant sites to metropolitan areas, workers could commute to the construction site, thereby reducing the need for rental housing. 3 4 5 6 7 Emissions from the operation of a NGCC plant could affect minority and low-income populations as well as the general population living in the vicinity of the new power plant. However, all would be exposed to the same potential effects from NGCC power plant operations, and any impacts would depend on the magnitude of the change in ambient air quality conditions. Permitted air emissions are expected to remain within regulatory standards. 8 9 10 11 Based on this information and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of a new NGCC power plant would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations. 12 8.1.13. Waste Management 13 14 15 16 17 During the construction stage of the NGCC generation alternative, land clearing and other construction activities would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste disposal facility. Because the alternative would be constructed at power plant sites with existing infrastructure, the amount of wastes produced during land clearing would be reduced. 18 19 20 During the operational stage, spent selective catalytic reduction (SCR) catalysts, which are used to control NOx emissions from natural gas-fired plants, would make up most of the waste generated by this alternative (see Air Quality, Section 8.1.1) 21 22 According to the GEIS (NRC 1996), a natural gas-fired plant would generate minimal waste. Waste impacts therefore would be SMALL for an NGCC alternative. Table 8-2. Summary of Environmental Impacts of the NGCC Alternative Compared to Continued Operation of the Existing LGS 23 24 New NGCC at an Existing Power Plant Site Continued LGS Operation Air Quality SMALL to MODERATE SMALL Groundwater SMALL SMALL Surface Water SMALL SMALL Aquatic Resources SMALL SMALL Terrestrial Resources SMALL SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics SMALL SMALL Historic and Archaeological SMALL to MODERATE SMALL Waste Management SMALL SMALL (a) (a) As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 8-16 Environmental Impacts of Alternatives 1 8.2. Supercritical Pulverized Coal-Fired Alternative 2 3 4 5 6 7 8 9 10 11 In this section, the NRC evaluates the environmental impacts of a supercritical pulverized coal-fired alternative to the continued operation of LGS. In the Commonwealth of Pennsylvania, 48 percent of electricity was generated using coal-fired power plants in 2010 (EIA 2012). Throughout PJM, coal-fired units provided 47 percent of electricity in 2011 (Monitoring Analytics 2012). As noted by EIA in its Annual Energy Outlook (EIA 2011b), coal-fired generation historically has been the largest source of electricity in the United States and is expected to remain so through 2035. Baseload coal units have proven their reliability and can routinely sustain capacity factors of 85 percent or greater. Among the various boiler designs available, pulverized coal boilers producing supercritical steam (SCPC boilers) are the most likely variant for a coal-fired alternative given their generally high thermal efficiencies and overall reliability. 12 13 14 15 While nuclear reactors, on average, operate with capacity factors above 90 percent, the new SCPC coal-fired power plant would operate with roughly an 85 percent capacity factor. Despite the slightly lower capacity factor, a SCPC plant would be capable of providing adequate replacement power for a nuclear plant for the purposes of this NEPA analysis. 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 A myriad of sizes of pulverized coal boilers and steam turbine generators (STGs) are available; however, the staff presumes that four equal-sized boiler/STG powertrains, operating independently and simultaneously, would likely be used to match the power output of LGS. To complete this analysis, the staff presumes that all powertrains would have the same features, operate at generally the same conditions, have similar impacts on the environment, and be equipped with the same pollution-control devices such that once all parasitic loads are overcome, the net power available would be equal to 2,120 MWe. The staff assumes that 6 percent of an SCPC boiler's gross capacity is needed to supply typical parasitic loads (plant operation plus control devices for criteria pollutants to meet New Source Performance Standards). Introducing controls for GHG emissions (i.e., CCS) would cause the parasitic load to increase to 27 percent of the boiler's gross rated capacity (NETL 2010). However, because of uncertainty regarding future GHG regulations and the limited real-world experience in CCS at utility-scale power plants, parasitic loads associated with CCS are not considered. Various bituminous coal sources are available to coal-fired power plants in Pennsylvania. EIA reports that, in 2008, Pennsylvania produced electricity from coal with heating values of 11,549 British thermal units per pound (Btu/lb), sulfur content of 2.07 percent, and ash of 16.29 percent (EIA 2010a). For the purpose of this evaluation, the NRC presumes that coal burned in 2008 will be representative of coal that would be burned in a coal-fired alternative regardless of where it was located. Approximately 74 percent of the coal burned in Pennsylvania in 2008 came from mines in Pennsylvania. West Virginia, Wyoming, and Ohio supplied most of the remaining coal (EIA 2010a). Bituminous coals from Appalachian mines have CO2 emission factors ranging from 202.8 to 210.2 lb per million Btu of heat input (Hong and Slatick 1994). 8-17 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Exelon determined that the current LGS site was not viable to accommodate a coal-fired alternative with net generating capacity sufficient to meet the power production of LGS because of limited space on the LGS site, as explained in Section 8.0 (Exelon 2011). The staff concurs with that assessment and the analysis of the impacts of the coal-fired alternative assumes that the SCPC coal-fired power plant would be sited at an existing power plant site to take advantage of existing infrastructure. The site could be located in Pennsylvania or elsewhere in PJM. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 It is reasonable to assume that a coal-fired alternative would use supercritical steam (see text box). Supercritical steam technologies are increasingly common in new coal-fired plants. They are commercially available and feasible. Supercritical plants operate at higher temperatures and pressures than older subcritical coal-fired plants and, therefore, can attain higher thermal efficiencies. While supercritical facilities are more expensive to construct than subcritical facilities, they consume less fuel for a given output, reducing environmental impacts throughout the fuel life cycle. The staff expects that a new, supercritical coal-fired plant would operate at a heat rate of 8,844 Btu/kWh (EIA 2010b), or approximately 38 to 39 percent thermal efficiency. However, heat inputs could be less, depending on the coal source and whether fuel blending is practiced in order to remain compliant with emission limitations. 32 33 34 35 36 SCPC coal-fired power plants are currently commercially available and currently are feasible alternatives to LGS license renewal. The overall environmental impacts of a coal-fired alternative, as well as the environmental impacts of proposed LGS license renewal, are shown in Table 8-3. Additional details of the impacts on individual resources of the coal-fired alternative are provided in subsequent sections. 37 8.2.1. Air Quality 38 39 40 41 42 43 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 44 45 46 47 48 A new SCPC generating plant would qualify as a new major-emitting industrial facility and would be subject to PSD under requirements of the CAA (EPA 2012a). The PADEP has adopted 25 Pa. Code Chapter 127, which implements the EPA's PSD review. The SCPC plant would need to comply with the standards of performance for electric utility steam generating units set forth in 40 CFR Part 60 Subpart Da. Supercritical Steam "Supercritical" refers to the thermodynamic properties of the steam being produced. Steam whose temperature and pressure is below water's "critical point" (3,200 pounds per square inch absolute [psia; 221 bar] and 705 ?F [374 ?C]) is subcritical. Subcritical steam forms as water boils and both liquid and gas phases are observable in the steam. The majority of coal boilers currently operating in the United States produce subcritical steam with pressures around 2,400 psia (165 bar) and temperatures as high as 1,050 ?F (566 ?C). Above the critical point pressure, water expands rather than boils, and the liquid and gaseous phases of water are indistinguishable in the supercritical steam that results. More than 150 coal boilers currently operating in the United States produce supercritical steam with pressures between 3,300-3,500 psia (228 to 241 bar) and temperatures between 1,000-1,100 ?F (538- 593 ?C). Ultrasupercritical boilers produce steam at pressures above 3,600 psia (248 bar) and temperatures exceeding 1,100 ?F (593 ?C). There are only a few of these boilers in operation worldwide, and none in the United States. 8-18 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, including the review of the new sources that may affect visibility in any Federal Class I area. If an SCPC alternative was located close to a mandatory Class I area, additional air pollution control requirements would be required. As noted in Section 2.2.2.1, there are no mandatory Class I Federal areas within 50 miles (80 km) of the LGS site. There are a total of 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 8 9 10 11 12 A new SCPC plant would have to comply with Title IV of the CAA (42 USC ?7651) reduction requirements for SO2 and NOx, which are the main precursors of acid rain and the major cause of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the existing plants and a system of SO2 emission allowances that can be used, sold, or saved for future use by the new plants. 13 14 15 16 17 18 More recently, the EPA has promulgated additional rules and requirements for certain fossil-fuel based power plants, such as coal. The Cross-State Air Pollution Rule (CSAPR), the Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) Tailoring Rule, and the Mercury and Air Toxics Standards (MATS) for Power Plants impose several additional standards to limit ozone, particulate, mercury, and GHG emissions from fossil-fuel based power plants (EPA 2012c). A new SCPC plant would be subject to these additional rules and regulations. 19 20 21 The EPA has developed standard emission factors that relate the quantity of released air pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the staff projects the following air emissions for the SCPC alternative: 22 23 24 25 26 27 28 o o o o o o o sulfur oxides (SOx) - 14,876 tons (13,495 MT) per year, nitrogen oxides (NOx) - 1,891 tons (1,716 MT) per year, carbon monoxide (CO) - 1,891 tons (1,716 MT) per year, PM10 - 1,232 tons (1,118 MT) per year, PM2.5 - 616 tons (559 MT) per year carbon dioxide (CO2) - up to 18,363,843 tons (16,659,678 MT) per year, and mercury (Hg) - 0.31 tons (0.28 MT) per year. 29 30 31 32 33 The above emission estimates assume that the SCPC plant implements certain pollution control devices, including wet calcium carbonate scrubbers for SO2 control (operating at 95 percent removal efficiency), low-NOx burners with overfire air and selective catalytic reduction for nitrogen oxide controls capable of attaining a NOx removal of 86 percent, and fabric particulate filters with 99.9 percent removal efficiency. 34 35 36 37 38 39 40 Activities associated with the construction of the new SCPC plant would cause some additional, temporary air effects as a result of equipment emissions and fugitive dust from operation of the earth-moving and material-handling equipment. Emissions from workers' vehicles and motorized construction equipment exhaust would be temporary. The construction crews would use dust-control practices to control and reduce fugitive dust. The staff concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of the earth-moving and material-handling equipment would be SMALL. 41 Greenhouse Gas Emissions 42 43 44 45 46 47 The largest anthropogenic source of CO2 emissions is the combustion of fossil fuels, especially coal. After a thorough examination of the scientific evidence and careful consideration of public comments, the EPA announced on December 7, 2009, that GHGs threaten the public health and welfare of the American people and meet the CAA definition of air pollutants. The construction and operation of the coal-fired alternative would emit GHGs that likely contribute to climate change. 8-19 Environmental Impacts of Alternatives 1 2 3 4 Greenhouse gas emissions from the construction of a coal-fired alternative would result primarily from the consumption of fossil fuels in the engines of construction vehicles and equipment, workforce vehicles used in commuting to and from the work site, and delivery vehicles. All such impacts would be temporary. 5 6 7 8 9 10 11 12 13 14 The staff estimates that uncontrolled emissions of CO2-e (carbon dioxide equivalents) from operation of the coal-fired alternative would amount to 18.36 million tons per year (16.66 million metric tons per year). From a life-cycle perspective, Sovacool (2008) found that coal-burning plants can have GHG footprints as high as 1,050 grams of carbon dioxide equivalent per kWh. For comparison, nuclear facilities and NGCC facilities have life-cycle GHG footprints of 66 grams of CO2-e/kWh and 443 grams of CO2-e/kWh, respectively. Although coal combustion in the boilers would be the primary source, other miscellaneous ancillary sources, such as truck and rail deliveries of materials to the site, commuting of the workforce, and deliveries of wastes to offsite disposal or recycling facilities, would contribute to the CO2-e emissions from continued operations. 15 16 17 18 19 20 21 22 23 24 25 26 NETL estimates that further development could yield technologies that could capture and remove as much as 90 percent of the CO2 from the exhausts of SCPC boilers. However, NETL also estimates that such equipment imposes a significant parasitic load that would result in a power production capacity decrease of approximately 27 percent (NETL 2010). In addition, permanent sequestering of the CO2 would involve removing impurities (including water) and pressurizing it to meet pipeline specifications to transfer the gas, by pipeline, to acceptable geologic formations. Even when opportunities exist to use the CO2 for enhanced oil recovery (rather than simply disposing of the CO2 in geologic formations), permanent disposal costs could be substantial, especially if the SCPC units are far removed from acceptable geologic formations. With CCS in place, the coal-fired alternative would release 1.84 million tons of CO2 per year (1.67 million metric tons per year). Without CCS in place, the staff's projected CO2 emissions for the SCPC alternative would be 18,363,843 tons (16,659,678 MT) per year 27 28 29 The overall impact from the releases of GHGs of a coal-fired alternative would be MODERATE. Construction impacts would be temporary, but GHG emissions during operation would be noticeable. 30 Conclusion 31 32 33 Based on the above discussion, the overall air emissions and associated quality impacts from a new SCPC plant located at the LGS site would be MODERATE, primarily because of the noticeable impact during operations. 34 8.2.2. Groundwater Resources 35 36 37 38 39 40 41 42 43 44 45 46 47 Construction activities associated with the SCPC alternative could require more extensive groundwater dewatering as compared to the NGCC alternative, depending on the hydrogeologic conditions of the selected site. This is because of the more extensive excavation that would be required for the SCPC power block and the onsite disposal facility. Nevertheless, engineering measures, as described in Section 8.1.2, can be used to minimize impacts to facilitate construction. Facility construction would increase the amount of impervious surface at the site location and alter the subsurface strata because of excavation work and the placement of backfill following facility completion. At some sites, this could cause a localized decline in water-table elevation in a surficial aquifer, if present. However, recharge basins incorporated into the stormwater management system design can make such alterations undetectable at the site boundary. Below-grade portions of a new SCPC plant also could alter the direction of groundwater flow beneath a site, although such effects would likely be very localized at most site locations. Finally, application of BMPs in accordance with a state-issued NPDES general 8-20 Environmental Impacts of Alternatives 1 2 permit, including appropriate waste management, water discharge, and spill prevention practices, would prevent or minimize any groundwater quality impacts during construction. 3 4 5 6 7 8 9 10 During the construction period, groundwater could be used to provide water for potable and sanitary uses, concrete production, dust suppression, and soil compaction. However, it is more likely that water would be supplied via a temporary utility connection, if available, or trucked to the point of use from offsite sources. The SPCP alternative would require a peak construction workforce of 2,500 (Exelon 2011), as described in Section 8.2.8. While the potential demands for groundwater based on this workforce combined with construction uses might result in water demands nearing 100 gpm (380 L/min) during the peak construction period, the staff determined that any impacts would be very temporary and localized. 11 12 13 14 15 16 17 18 19 20 21 22 23 For SCPC plant operations, the NRC assumed that the SCPC alternative would entail the same relative ratio of groundwater use to surface water use as that used at LGS Units 1 and 2. This includes the use of groundwater for service water makeup and potable and sanitary uses. Consequently, it is expected that total groundwater usage and potential aquifer effects would be much less under this alternative than those under current LGS operations. This is because of the smaller number of auxiliary systems requiring groundwater and the much smaller workforce under this alternative. The only mechanism identified that could adversely affect groundwater quality under normal operations would be operation of the disposal facility. However, the leaching of contaminants from the fly ash and scrubber sludge and impacts to groundwater can be minimized in modern facilities with protective barriers, disposal cell liners, and leachate collection and treatment systems, along with groundwater monitoring systems. Therefore, based on the above assessment, the impacts on groundwater use and quality under this alternative would be SMALL. 24 8.2.3. Surface Water Resources 25 26 27 28 29 30 31 32 33 34 35 36 37 Impacts from construction activities associated with the SCPC alternative on surface water resources would be expected to be similar to but somewhat greater than those under the NGCC alternative. This is attributable to the additional land required for construction of the power block and for excavation and construction of an onsite disposal facility for coal ash and scrubber sludge. However, additional offsite impacts, including hydrologic changes in affected streams and contaminant runoff, would occur from coal mining (see Section 8.2.7). At the SCPC site, some temporary impacts to surface water quality may result from increased sediment loading and from any pollutants in stormwater runoff from disturbed areas and from dredging activities. There also would be the potential for water quality effects to occur from the extension or refurbishment of a rail spur to transport coal to the site location. Nevertheless, as described in Section 8.1.3, water quality impacts would be minimized by the application of BMPs and compliance with state-issued NPDES permits. Any dredging would be conducted under a permit from the COE requiring the implementation of BMPs to minimize impacts. 38 39 40 41 42 43 44 45 46 47 48 During operations, the SCPC alternative would use slightly less water than LGS because of the greater generation-efficiency of the SCPC technology. Therefore, the water resources impact assessment presented in Section 4.3.2 of this SEIS generally applies to the SCPC alternative. The NRC assumed that water treatment additives for the SCPC alternative would be essentially identical to LGS. Existing intake and discharge infrastructure would be used at the selected power plant site but it could require refurbishment or expansion. Similar to LGS, surface water withdrawals would be subject to applicable state water allocation requirements, and effluent discharges and stormwater discharges associated with industrial activity would be subject to a state-issued NPDES permit under this alternative. The NRC further assumes that the SCPC plant and waste disposal facility would be operated in accordance with appropriate management plans with adherence to appropriate BMPs and procedures to minimize the release of 8-21 Environmental Impacts of Alternatives 1 2 3 non-nuclear fuels, chemicals, and other materials to soil, surface water, and groundwater (see Section 8.1.3). As a result, the overall impacts on surface water use and quality from construction and operations under the SCPC alternative would be SMALL. 4 8.2.4. Aquatic Resources 5 6 7 8 9 10 11 12 13 14 15 Construction activities for the SCPC alternative (such as construction of heavy-haul roads and the power block) could affect drainage areas or other onsite aquatic features. Minimal impacts on aquatic ecology resources are expected because the plant operator would likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, which would be required to comply with Pennsylvania NPDES permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the available infrastructure at the selected site, the SCPC alternative may require modification or expansion of the existing intake or discharge structures, or construction of new intake and discharge structures. Dredging activities that result from infrastructure construction would require BMPs for in-water work to minimize sedimentation and erosion. Because of the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats likely would be localized and temporary. 16 17 18 19 20 21 22 23 During operations, the SCPC alternative would require slightly less cooling water to be withdrawn from the Schuylkill River or other similar water body than required for LGS Units 1 and 2. The number of fish and other aquatic resources affected by cooling water intake and discharge operations, such as entrainment, impingement, and thermal stress, would be equal or less for an SCPC alternative compared to LGS. The cooling system for a new SCPC plant would have similar chemical discharges as LGS, but the SCPC plant would emit small amounts of ash and particulates that would settle onto the river surface and introduce a new source of pollutants as described in Section 8.2.1. 24 25 26 27 The impacts on aquatic ecology would be minor because construction activities would require BMPs and stormwater management permits, and because the surface water withdrawal and discharge for this alternative would be slightly less compared to LGS Units 1 and 2. Therefore, impacts on aquatic ecology would be SMALL. 28 29 30 31 32 33 34 35 36 Consultation with NMFS and FWS under ESA would ensure that the construction and operation of an SCPC plant would not adversely affect any Federally listed species or adversely modify or destroy designated critical habitat. Consultation with NMFS under the Magnuson-Stevens Act would require the NRC to evaluate impacts to EFH. NMFS would provide conservation recommendations if there would be adverse impacts to EFH. Coordination with state natural resource agencies would further ensure that the plant operator would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation on protected species and habitats would be SMALL. 37 8.2.5. Terrestrial Resources 38 39 40 41 42 43 44 45 46 Construction of an SCPC plant would require approximately 280 ac (113 ha), as described in Section 8.2.7. The SCPC alternative may require up to 46,600 ac (18,860 ha) of additional land for coal mining and processing (NRC 1996). Approximately 464 ac (188 ha) of land also would be required for disposal of ash and scrubber sludge (Exelon 2011). However, land for disposal would likely be located on site (see Section 8.2.7). Because of the relatively large land requirement for the site, a portion of the site would likely be land that had not been previously disturbed, which would directly affect terrestrial habitat by removing existing vegetative communities and displacing wildlife. The level of direct impacts would vary substantially based on site selection. Offsite construction would occur mostly on land where coal extraction is 8-22 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 ongoing. To the extent practicable, Exelon would route the railroad spur along an existing, previously disturbed railroad corridor. Erosion and sedimentation, fugitive dust, and construction debris impacts would be minor with implementation of appropriate BMPs (Exelon 2011). Impacts to terrestrial habitats and species from transmission line operation and corridor vegetation maintenance, and operation of the cooling system would be similar in magnitude and intensity as those resulting from operating nuclear reactors and would, therefore, be SMALL (NRC 1996). Because of the potentially large area of undisturbed habitat that could be affected from construction of an SCPC plant, the impacts of construction on terrestrial habitats and species could range from SMALL to MODERATE depending on the specific site location. The impacts of operation would be SMALL. 11 12 13 14 15 16 17 As with the NGCC alternative, consultation with FWS under the ESA would avoid potential adverse impacts to Federally listed species or adverse modification or destruction of designated critical habitat. Coordination with state natural resource agencies would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of an SCPC plant on protected species and habitats would be SMALL. 18 8.2.6. Human Health 19 20 21 22 23 24 Impacts on human health from construction of the SCPC alternative would be similar to impacts associated with the construction of any major industrial facility. Compliance with worker protection rules would control those impacts on workers at acceptable levels. Impacts from construction on the general public would be minimal since limiting active construction area access to authorized individuals is expected. Therefore, impacts on human health from the construction of the SCPC alternative would be SMALL. 25 26 27 28 Coal-fired power plants introduce worker risks from coal and limestone mining, coal and limestone transportation, and disposal of coal combustion residues and scrubber wastes. In addition, there are public risks from inhalation of stack emissions and the secondary effects of eating foods grown in areas subject to deposition from plant stacks. 29 30 31 32 33 34 35 36 Human health risks of coal-fired power plants are described, in general, in Table 8-2 of the GEIS (NRC 1996). Cancer and emphysema as a result of the inhalation of toxins and particulates are identified as potential health risks to occupational workers and members of the public (NRC 1996). The human health risks associated with coal-fired power plants, both for occupational workers and members of the public, are greater than those of the current LGS reactors because of exposures to chemicals such as mercury, SOx, NOx, radioactive elements such as uranium and thorium contained in coal and coal ash, and polycyclic aromatic hydrocarbon (PAH) compounds, including benzo(a)pyrene. 37 38 39 40 41 42 43 44 Regulations restricting emissions enforced by either EPA or delegated state agencies have reduced potential health effects, but have not entirely eliminated them. These agencies also impose site-specific emission limits as needed to protect human health. Even if the coal-fired alternative were located in a nonattainment area, emission controls and trading or offset mechanisms could prevent further regional degradation; however, local effects could be visible. Many of the byproducts of coal combustion responsible for health effects are largely controlled, captured, or converted in modern power plants, although some level of health effects may remain. 45 46 47 Aside from emissions impacts, the coal-fired alternative introduces the risk of coal pile fires and for those plants that manage coal combustion residue liquids and sludge in waste impoundments, the release of the waste may result because of a failure of the impoundment. 8-23 Environmental Impacts of Alternatives 1 2 3 4 5 Good housekeeping practices to control coal dust greatly reduce the potential for coal dust explosions or coal pile fires. Although there have been several instances in recent years, sludge impoundment failures are still rare. Free water also could be recovered from such waste streams and recycled and the solid or semi-solid portions removed to permitted offsite disposal facilities. 6 7 8 Overall, given extensive health-based regulation and controls likely to be imposed as permit conditions applicable to waste handling and disposal, the staff expects human health impacts from operation of the coal-fired alternative at an alternate site to be SMALL. 9 8.2.7. Land Use 10 11 12 13 The GEIS generically evaluates the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each power plant site. The analysis of land-use impacts focuses on the amount of land area that would be affected by the construction and operation of an SCPC power plant at an existing power plant site. 14 15 16 17 18 19 20 21 22 23 Based on scaled GEIS estimates, more than 3,800 ac (1,540 ha) of land could be needed to support a coal-fired alternative to replace the LGS. This amount of land use would include other plant structures and associated infrastructure and is unlikely to exceed the 3,800 ac (1,540 ha) estimate, excluding land needed for coal mining and processing. Exelon estimated 280 ac (113 ha) for new unit construction (Exelon 2011). The NRC determined that this estimate is reasonable because it is consistent with land requirements for modern coal-fired facilities. It is expected that the SCPC alternative would be located at an existing power plant site or otherwise disturbed industrial site, and thus the land-use impacts from construction would range from SMALL to MODERATE. Depending on existing power plant infrastructure, additional land may be needed for frequent coal and limestone deliveries by rail or barge. 24 25 26 27 28 29 30 Offsite land-use impacts would occur from coal mining, in addition to land-use impacts from the construction and operation of the new power plant. Using the GEIS figure, the SCPC alternative might require up to 49,600 ac (20,100 ha) of land for coal mining and waste disposal during power plant operations. However, much of the land in existing coal mining areas already has experienced some level of disturbance. An additional 464 ac (188 ha) of land would be required for disposal of ash and scrubber sludge (Exelon 2011). It is likely that most of the land needed for disposal would be found within the 22,000 ac (8,900 ha) requirement estimated in the GEIS. 31 32 33 34 35 36 The elimination of uranium fuel for the LGS could partially offset some, but not all, of the land requirements for the SCPC alternative. Scaling from GEIS estimates, approximately 1,640 ac (660 ha) no longer would be needed for mining and processing uranium during the operating life of the SCPC plant. Since a substantial amount of land could be converted for coal and limestone delivery and waste disposal, land-use impacts could range from SMALL to MODERATE. 37 8.2.8. Socioeconomics 38 39 40 41 42 43 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of the SCPC alternative were evaluated to measure their possible effects on current socioeconomic conditions. 44 45 Scaling from GEIS estimates, the construction workforce would peak at 5,638 workers. Exelon estimated 2,500 workers at the peak of construction (Exelon 2011). This estimate appears to 8-24 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 11 12 13 14 be reasonable and is consistent with trends toward lowering labor costs by reducing the size of plant workforces. Therefore, Exelon's estimate of 2,500 workers is used throughout this analysis. The relative economic impact of this many workers on the local economy and tax base would vary, with the greatest impacts occurring in communities where the majority of construction workers reside and spend their income. As a result, local communities could experience a short-term "boom" from increased tax revenue and income generated by construction expenditures and the increased demand for temporary (rental) housing and business services. Some construction workers could relocate in order to be closer to the construction work site. However, given the proximity of many existing power plants to metropolitan areas, workers could commute to the construction site, thereby reducing the need for rental housing. After completing the installation of the subcritical coal-fired power plant, local communities could experience a return to pre-construction economic conditions. Based on this information and given the number of construction workers, socioeconomic impacts during construction in local communities could range from SMALL to MODERATE. 15 16 17 18 19 20 21 22 23 24 25 26 Scaling from GEIS estimates, the plant operations workforce would be 564 workers. Exelon estimated a plant operations workforce of approximately 141 workers (Exelon 2011). This estimate appears to be reasonable and is consistent with trends toward lowering labor costs by reducing the size of plant operations workforces. Therefore, Exelon's estimate of 141 workers is used throughout this analysis. This alternative would result in a loss of approximately 700 relatively high-paying jobs at LGS, with a corresponding reduction in purchasing activity and tax contributions to the regional economy. In addition, the permanent housing market also could experience increased vacancies and decreased prices if operations workers and their families move out of the region. However, a larger amount of property taxes may be paid to local jurisdictions under the SCPC alternative as more land may be required for coal-fired power plant operations than LGS. Therefore, socioeconomic impacts during operations could range from SMALL to MODERATE. 27 8.2.9. Transportation 28 29 30 31 32 33 34 35 36 37 38 39 40 Transportation impacts associated with construction and operation of a four-unit, SCPC power plant would consist of commuting workers and truck deliveries of construction materials to the power plant site. During periods of peak construction activity, up to 2,500 workers could be commuting daily to the site (Exelon 2011), as described in Section 8.2.8. Workers commuting to the construction site would arrive by site access roads and the volume of traffic on nearby roads could increase substantially during shift changes. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Some power plant components and materials could also be delivered by train or barge, depending on location. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from MODERATE to LARGE. 41 42 43 44 45 46 47 48 Traffic-related transportation impacts on local roads would be greatly reduced after the completion of the power plant. Transportation impacts would include daily commuting by the operating workforce, equipment and materials deliveries, and the removal of commercial waste material to offsite disposal or recycling facilities by truck. During operations, the estimated number of operations workers commuting to and from the power plant would be 141 workers (Exelon 2011), as described in Section 8.2.8. The increase in traffic on roadways would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Frequent deliveries of coal and limestone by rail would add to the overall 8-25 Environmental Impacts of Alternatives 1 2 3 4 5 6 transportation impact. Onsite coal storage would make it possible to receive several trains per day. Limestone delivered by rail could also add additional traffic (though considerably less traffic than that generated by coal deliveries). Coal and limestone delivery and ash removal by rail would cause levels of service impacts on certain roads because of delays at railroad crossings. Overall, transportation impacts would be SMALL to MODERATE during power plant operations. 7 8.2.10. Aesthetics 8 9 10 11 12 13 14 15 16 17 The analysis of aesthetic impacts focuses on the degree of contrast between the SCPC alternative and the surrounding landscape and the visibility of the new SCPC plant at an existing power plant site. During construction, all of the clearing and excavation would occur on the existing power plant site. These activities could be visible from offsite roads. The coal-fired power plant could be approximately 100 ft (30 m) tall, with two to four exhaust stacks several hundred feet tall with natural-draft cooling towers approximately 400 to 500 ft (122 to 152 m) in height. The facility would be visible off site during daylight hours, and some structures may require aircraft warning lights. The condensate plumes from the cooling towers could add to the visual impact. Noise generated during power plant operations would be limited to routine industrial processes and communications. 18 19 20 21 22 23 In general, given the industrial appearance of the existing power plant site on which it would be built, the new SCPC power plant would blend in with the surroundings. The power block of the SCPC alternative could look very similar to the existing power plant and construction would appear similar to other ongoing onsite activities. Aesthetic changes would therefore be limited to the immediate vicinity of the existing power plant site, and any impacts would be SMALL depending on its location and surroundings. 24 8.2.11. 25 26 27 28 29 30 31 32 33 34 35 36 The impacts of the construction of a new SCPC alternative on historic and archaeological resources are similar to those impacts associated with activities for constructing an NGCC facility. Any areas potentially affected by the construction of the SCPC alternative would need to be surveyed to identify and record historic and archaeological resources. An inventory of a previously disturbed former plant (brownfield) site may still be necessary if the site has not been previously surveyed or to verify the level of disturbance and evaluate the potential for intact subsurface resources. Plant operators would need to survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, other ROWs). Any resources found in these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse effects would need to be addressed if eligible resources were encountered. Areas with the greatest sensitivity should be avoided. Visual impacts on significant cultural resources--such as the viewsheds of historic properties near the site--should also be assessed. 37 38 39 40 41 42 The potential for impacts on historic and archaeological resources from the SCPS alternative would vary greatly depending on the location of the proposed site. However, given that the preference is to use a previously disturbed former plant site, avoidance of significant historic and archaeological resources should be possible and effectively managed under current laws and regulations. Therefore, the impacts on historic and archaeological resources from the SCPC alternative would be SMALL. 43 8.2.12. Environmental Justice 44 45 The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income Historic and Archaeological Resources 8-26 Environmental Impacts of Alternatives 1 2 3 populations that could result from the construction and operation of a new power plant. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. 4 5 6 7 8 9 10 11 12 13 14 Potential impacts to minority and low-income populations would mostly consist of environmental and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be directly affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects are not likely to be high and adverse and would be contained to a limited time period during certain hours of the day. Increased demand for rental housing during construction could cause rental costs to rise disproportionately affecting low-income populations who rely on inexpensive housing. However, given the proximity of some existing power plant sites to metropolitan areas, workers could commute to the construction site, thereby reducing the need for rental housing. 15 16 17 18 19 Emissions from the operation of a SCPC plant could affect minority and low-income populations as well as the general population living in the vicinity of the new power plant. However, all would be exposed to the same potential effects from SCPC power plant operations and any impacts would depend on the magnitude of the change in ambient air quality conditions. Permitted air emissions are expected to remain within regulatory standards. 20 21 22 23 Based on this information and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of a new SCPC power plant would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations. 24 8.2.13. Waste Management 25 26 27 28 29 30 31 32 33 34 35 36 37 Coal combustion generates several waste streams, including ash (a dry solid) and sludge (a semi-solid byproduct of emission control system operation). The staff estimates that a 2,120-MW(e) power plant would use approximately 7,340,000 tons (6,659,000 MT) of coal annually with an ash content of 16.29 percent. This would generate approximately 1,196,000 tons (1,085,000 MT) of ash and 559,000 tons (507,125 MT) of scrubber sludge each year. About 538,059 tons (488,119 MT) or 45 percent of the ash waste would be marketed for beneficial use (Exelon 2011). Therefore, approximately 559,000 tons (507,125 MT) of ash would be disposed of on site if space were available. According to Exelon (2011), disposal of the ash and sludge would require approximately 464 ac (187 ha) over 20 years. Disposal of the remaining waste could noticeably affect land use and ground water quality, but with proper siting and implementation of groundwater monitoring and management practices, in accordance with 25 Pa. Code 290, it would not destabilize important resources. After closure of the waste site and revegetation, the land could be available for other uses. 38 39 40 41 42 43 44 The impacts from waste generated during construction would be minor, although the waste generated during operation of this coal-fired alternative would be MODERATE; the impacts would be clearly visible, but would not destabilize any important resource. The amount of the construction waste would be small compared to the amount of waste generated during the operational stage and much of it could be recycled (i.e, marketed for beneficial use). Therefore, the staff concludes that the overall waste management impacts from construction and operation of this alternative would be MODERATE. 8-27 Environmental Impacts of Alternatives 1 2 Table 8-3. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative Compared to Continued Operation of LGS Supercritical Coal-Fired Generation Continued LGS Operation Air Quality MODERATE SMALL Groundwater SMALL SMALL Surface Water SMALL SMALL Aquatic Resources SMALL SMALL Terrestrial Resources SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL SMALL Historic and Archaeological SMALL SMALL Waste Management MODERATE SMALL (a) 3 (a) As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 8.3. New Nuclear 4 5 6 7 8 9 10 In this section, the NRC evaluates the environmental impacts of a new nuclear alternative to LGS. In the Commonwealth of Pennsylvania, 34 percent of electricity was generated using nuclear power plants in 2010 (EIA 2012). Throughout PJM, nuclear units also provided 34 percent of electricity in 2011 (Monitoring Analytics 2012). As noted by EIA in its Annual Energy Outlook (EIA 2011b), nuclear generation is expected to account for 3 percent of capacity additions through 2035. A new nuclear power plant is likely to be similar to LGS in terms of capacity factor. 11 12 13 14 15 Several designs are possible for a new nuclear facility. However, a two-unit nuclear power plant similar to the existing LGS in output is most likely. While two Westinghouse AP1000 reactors would provide an approximately equivalent output, it is possible that other designs also would be available. The new nuclear alternative would rely on a closed-cycle cooling system, similar to the cooling system currently in place at LGS. 16 17 18 19 20 21 22 23 24 In its ER, Exelon determined that the current LGS site was not viable to accommodate a new nuclear alternative with net generating capacity sufficient to meet the power production of LGS because of insufficient space at the LGS site (ER 2011). Exelon also indicated that a new nuclear alternative was most likely to be constructed on a site that already hosts a nuclear power plant. This placement would allow the new nuclear alternative to take advantage of existing site infrastructure, including transmission lines and some support facilities. The staff concurs that a new nuclear facility is most likely to be sited at the location of an existing nuclear power plant. Utilities in PJM have expressed interest in either early site permits or combined licenses for new nuclear facilities at several sites, including Calvert Cliffs (in Maryland), Hope 8-28 Environmental Impacts of Alternatives 1 2 Creek (New Jersey), North Anna (Virginia), and Bell Bend (adjacent to the Susquehanna site in Pennsylvania). 3 4 5 6 7 New nuclear power plants are commercially available and feasible alternatives to LGS license renewal. The overall environmental impacts of a nuclear alternative, as well as the environmental impacts of proposed LGS license renewal, are shown in Table 8-4. Additional details of the impacts on individual resources of the new nuclear alternative are provided in subsequent section. 8 8.3.1. Air Quality 9 10 11 12 13 14 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 15 16 17 18 19 20 A new nuclear generating plant would have similar air emissions to those of the existing LGS site; air emissions would be primarily from backup diesel generators and boilers as well as particulates from the cooling towers. As noted in Section 2.2.2.1, Exelon maintains a Title V operating permit (TVOP-46-00038) for sources of air pollution at the LGS site (Exelon 2011). Because air emissions would be similar for a new nuclear plant, the staff expects similar air permitting conditions and regulatory requirements. 21 22 23 24 25 26 27 28 29 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, including the review of the new sources that may affect visibility in any Federal Class I area. If a new nuclear plant were located close to a mandatory Class I area, additional air pollution control requirements may be required. As noted in Section 2.2.2.1, there are no Mandatory Class I Federal areas within 50 miles (80 km) of the LGS site. There are a total of 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. The following air emissions were reported by Exelon and are from the year 2011 for the existing LGS site (Exelon 2012). 30 31 32 33 o o o o sulfur oxides (SOx) - 7.8 T (7.1 MT) per year, nitrogen oxide (NOx) - 32.8 T (29.8 MT) per year, carbon monoxide (CO) - 24.2 tons (21.9 MT) per year, and PM10 and PM2.5 - 166.3 T (150.9 MT) per year. 34 35 The staff expects similar air emissions from a new nuclear plant because these emissions are primarily from backup diesel generators that would also be used at a new nuclear plant. 36 37 38 39 40 41 42 Activities associated with the construction of the new nuclear plant would cause some additional, temporary air effects as a result of equipment emissions and fugitive dust from operation of the earth-moving and material-handling equipment. Emissions from workers' vehicles and motorized construction equipment exhaust would be temporary. The construction crews could use dust-control practices to control and reduce fugitive dust. The staff concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of the earth-moving and material-handling equipment would be SMALL. 43 Greenhouse Gas Emissions 44 45 In Chapter 6, the staff discussed the relative GHG emissions of nuclear power compared to other electric generation technologies. This discussion, where applicable, addressed the 8-29 Environmental Impacts of Alternatives 1 2 3 4 nuclear lifecycle, including construction and operation. Impacts during construction of this alternative would result primarily from the consumption of fossil fuels in the engines of construction vehicles and equipment, workforce vehicles used in commuting to and from the work site, and delivery vehicles. However, all such impacts would be temporary. 5 6 7 Greenhouse gas emissions from the new nuclear alternative during operation arise primarily from operation of onsite diesel generators and other auxiliary equipment. For additional discussion of GHG emissions from nuclear generation, see Chapter 6. 8 9 10 Given the expected workforces, relatively short construction period , and minor GHG emissions during operation, the overall impact from the releases of GHGs of the new nuclear alternative would be SMALL. 11 Conclusion 12 13 The overall air quality impacts of a new nuclear plant located at the LGS site would be designated as SMALL. 14 8.3.2. Groundwater Resources 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Under this alternative, deep excavation work on the order of 70 ft (21 m) below ground surface for the nuclear island may require active dewatering during construction. Depending on the site and local hydrogeology, this dewatering could have localized drawdown effects on local wells and require the use of cofferdams, sumps, wells, or other methods to address high water-table conditions. However, grout injection and diaphragm walls can be installed to effectively eliminate offsite drawdown impacts and reduce the need for dewatering. Facility construction also would increase the amount of impervious surface at the site location and alter the subsurface strata because of excavation work and the placement of backfill following facility completion. This could cause a localized decline in water-table elevation in the surficial aquifer, but the incorporation of recharge basins into the stormwater management system design can make such alterations undetectable at the site boundary. Below-grade portions of a new nuclear power plant also could alter the direction of groundwater flow beneath a site. Such effects would likely be very localized at most site locations, encompassing the area around the nuclear island, and would not be expected to affect offsite wells at most sites. In addition, application of BMPs in accordance with a state-issued NPDES general permit, including appropriate waste management, water discharge, and spill prevention practices, would prevent or minimize any groundwater quality impacts during construction. 32 33 34 35 36 37 38 39 40 41 42 43 44 45 During the construction period, groundwater could be used to provide potable water for potable and sanitary uses, concrete production, dust suppression, and soil compaction. However, it is more likely that water would be supplied via a temporary utility connection, if available, or trucked to the point of use from offsite sources. Exelon (2011) estimated a peak construction workforce of 3,650. While the potential demands for groundwater based on this workforce combined with construction uses might result in water demands nearing 100 gpm (380 L/min) during the peak construction period, the staff determined that any effects would be temporary and localized. To support operations of a new nuclear power plant, the NRC assumed that this alternative would entail the same relative ratio of groundwater use to surface water use as that at LGS Units 1 and 2, along with a similar-sized workforce and operational activities. This includes the use of groundwater for service water makeup and potable and sanitary uses. Therefore, the groundwater resources impact assessment presented in Section 4.4 of this SEIS generally applies to the new nuclear alternative. Based on this assessment, impacts on groundwater use and quality under this alternative would be SMALL. 8-30 Environmental Impacts of Alternatives 1 8.3.3. Surface Water Resources 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Surface water resources impacts from construction activities associated with the new nuclear alternative at an alternative site would be similar to but somewhat greater in scale than those described for the SCPC alternative (see Section 8.2.3). While no ash and sludge disposal facility would be required as under the SCPC alternative, deep excavation work for the nuclear island and more extensive site clearing and larger laydown area for facility construction would have potentially greater impacts to water resources from water use and stormwater runoff. Thus, temporary impacts to surface water quality may result from increased sediment loading and from any pollutants in stormwater runoff from disturbed areas and from any required dredging activities. Nevertheless, as described in Section 8.1.3, water quality impacts would be minimized by the application of BMPs and compliance with state-issued NPDES permits. Any dredging would be conducted under a permit from the COE requiring the implementation of BMPs to minimize impacts. To support operations of a new nuclear power plant, the NRC has assumed that the new facility would consumptively use and discharge the same amount of water as LGS. Therefore, the water resources impact assessment presented in Section 4.3.2 of this SEIS applies to the new nuclear alternative. In Section 4.3.2, the NRC determined that the impacts of LGS operations on surface water resources are SMALL. The NRC assumed that water treatment additives for this alternative would be essentially identical to LGS. Existing intake and discharge infrastructure would be used at the selected power plant site, but it could require refurbishment or expansion. Similar to LGS, surface water withdrawals would be subject to applicable state water allocation requirements, and effluent discharges and stormwater discharges associated with industrial activity would be subject to a state-issued NPDES permit. The NRC further assumes that the new nuclear plant would be operated in accordance with appropriate management plans with adherence to appropriate BMPs and procedures to minimize the release of non-nuclear fuels, chemicals, and other materials to soil, surface water, and groundwater (see Section 8.1.3). Therefore, based on this assessment, the overall impacts on surface water use and quality from construction and operations under the new nuclear alternative would be SMALL. 29 8.3.4. Aquatic Resources 30 31 32 33 34 35 36 37 38 39 40 Construction activities for the new nuclear alternative (such as construction of heavy-haul roads and the power block) could affect drainage areas or other onsite aquatic features. Minimal impacts on aquatic ecology resources are expected because the plant operator would likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, which would be required to comply with state NPDES permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the available infrastructure at the selected site, the new nuclear alternative may require modification or expansion of the existing intake or discharge structures, or construction of new intake and discharge structures. Dredging activities that result from infrastructure construction would require BMPs for in-water work to minimize sedimentation and erosion. Because of the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would likely be localized and temporary. 41 42 43 44 45 46 47 During operations, the new nuclear alternative would require a similar amount of water from the Schuylkill River, or other similar water body, as is required for LGS Units 1 and 2. The number of fish and other aquatic resources affected by cooling water intake and discharge operations, such as entrainment, impingement, and thermal stress, would be similar for a new nuclear alternative as for those associated with LGS Units 1 and 2, provided the cooling-water intake and blowdown operations involve a water body similar in species composition and populations to the Schuylkill River. 8-31 Environmental Impacts of Alternatives 1 2 3 4 The impacts on aquatic ecology would be minor because construction activities would require BMPs and stormwater management permits, and because the surface water withdrawal and discharge for this alternative would be similar to LGS Units 1 and 2 (as discussed in Section 4.5). Therefore, the staff concluded that impacts on aquatic ecology would be SMALL. 5 6 7 8 9 10 11 12 13 Consultation with NMFS and FWS under ESA would ensure that the construction and operation of a new nuclear plant would not adversely affect any Federally listed species or adversely modify or destroy designated critical habitat. Consultation with NMFS under the Magnuson-Stevens Act would require the NRC to evaluate impacts to EFH. NMFS would provide conservation recommendations if there would be adverse impacts to EFH. Coordination with state natural resource agencies would further ensure that the plant operator would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation on protected species and habitats would be SMALL. 14 8.3.5. Terrestrial Resources 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 The new nuclear alternative, including the new reactor units and auxiliary facilities, would affect 630 ac to 1,260 ac (255 ha to 510 ha) of land at the site of an existing power station other than LGS (Exelon 2011), as described in Section 8.3.7. Because of the significant land requirement for the site, impacts to terrestrial species and habitats would vary depending on the amount of previously undisturbed land that would be cleared for the new nuclear alternative. By siting the new nuclear alternative at an existing nuclear site or adjacent to an existing site, the majority of land that would be affected by construction would be developed or previously disturbed. However, as with the SCPC alternative, the level of direct impacts would vary based on site selection. Erosion and sedimentation, fugitive dust, and construction debris impacts would be minor with implementation of appropriate BMPs (Exelon 2011). Impacts to terrestrial habitats and species from transmission line operation and corridor vegetation maintenance, and operation of the cooling system would be similar in magnitude and intensity to those resulting from operating nuclear reactors and would, therefore, be SMALL (NRC 1996). The offsite land requirement (1,000 ac (400 ha)) (NRC 1996) and impacts associated with uranium mining and fuel fabrication to support the new nuclear alternative would be no different from those occurring in support of LGS (see Section 8.3.7). Overall, the impacts of construction of a new nuclear facility on terrestrial species and habitats would be SMALL to MODERATE, and the impacts of operation would be SMALL. 33 34 35 36 37 38 39 As with the previously discussed alternatives, consultation with FWS under the ESA would avoid potential adverse impacts to Federally listed species or adverse modification or destruction of designated critical habitat. Coordination with state natural resource agencies would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of new nuclear generation on protected species and habitats would be SMALL. 40 8.3.6. Human Health 41 42 43 44 45 46 Impacts on human health from construction of two new nuclear units would be similar to impacts associated with the construction of any major industrial facility. Compliance with worker protection rules would control those impacts on workers at acceptable levels. Impacts from construction on the general public would be minimal since limiting active construction area access to authorized individuals is expected. Impacts on human health from the construction of two new nuclear units would be SMALL. 8-32 Environmental Impacts of Alternatives 1 2 3 4 The human health effects from the operation of two new nuclear power plants would be similar to those of the existing LGS Units 1 and 2. Most other noises during power plant operations would be limited to industrial processes and communications. Impacts on human health from the operation of two new nuclear units would be SMALL. 5 8.3.7. Land Use 6 7 8 9 10 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each plant site. The analysis of land-use impacts focuses on the amount of land area that would be affected by the construction and operation of a new two-unit nuclear power plant at or adjacent to an existing nuclear power plant site. 11 12 13 14 15 Based on GEIS estimates, approximately 1,000 ac (400 ha) of land would be needed for the new nuclear alternative. Exelon estimated 630 ac to 1,260 ac (255 ha to 510 ha) of land would be needed to construct and operate a new two-unit nuclear power plant (Exelon 2011). The NRC determined that Exelon's estimate is reasonable because it is consistent with land requirements for proposed new nuclear plants. 16 17 18 19 20 Locating the new units at or adjacent to an existing nuclear power plant would mean that the majority of the affected land area would already be zoned for industrial use. Making use of the existing infrastructure would reduce the amount of land needed to support the new units. Local residents are already accustomed to living near a nuclear power plant. Land-use impacts from constructing two new units at an existing nuclear power plant site would be SMALL. 21 22 23 24 25 26 27 28 29 30 The amount of land required to mine uranium and fabricate nuclear fuel during rector operations would be similar to the amount of land required to support LGS, although an additional amount of land would be required during the license renewal term. According to GEIS estimates, an additional 1,000 ac (400 ha) of land would be affected by uranium mining and processing during the life of the new nuclear power plant. Impacts associated with uranium mining and fuel fabrication to support the new nuclear alternative would generally be no different from those occurring in support of the existing LGS reactors. Overall land-use impacts from nuclear power plant operations would range from SMALL to MODERATE depending on whether the nuclear plant is sited entirely contained within an existing nuclear power plant site or if it located on open land. 31 8.3.8. Socioeconomics 32 33 34 35 36 37 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of a new nuclear power plant were evaluated in order to measure their possible effects on current socioeconomic conditions. 38 39 40 41 42 43 44 Exelon estimated 3,650 workers at the peak of construction (Exelon 2011). The relative economic impact of this many workers on the local economy and tax base would vary, with the greatest impacts occurring in communities where the majority of construction workers reside and spend their income. As a result, local communities could experience a short-term economic "boom" from increased tax revenue and income generated by construction expenditures and the increased demand for temporary (rental) housing and business services. Some construction workers could relocate in order to be closer to the construction work site. However, given the 8-33 Environmental Impacts of Alternatives 1 2 proximity of many existing power plants to metropolitan areas, workers could commute to the construction site, thereby reducing the need for rental housing. 3 4 5 6 After completing the installation of the two new reactor units, local communities could experience a return to pre-construction economic conditions. Based on this information and given the number of construction workers, socioeconomic impacts during construction in local communities could range from SMALL to LARGE. 7 8 9 10 11 12 13 14 15 Exelon estimated that the number of operations workers at the new nuclear power plant would be similar to the number of operations workers at LGS (Exelon 2011). The amount of property taxes paid under the new nuclear alternative may increase if additional land is required to support this alternative. However, the reduction in employment at LGS from operations to decommissioning and shut down could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the region. Therefore, socioeconomic impacts during operations could range from SMALL to MODERATE. 16 8.3.9. Transportation 17 18 19 20 21 22 23 24 25 26 27 28 Transportation impacts associated with construction and operation of a new nuclear power plant would consist of commuting workers and truck deliveries of construction materials to the power plant site. During periods of peak construction activity, up to 3,650 workers could be commuting daily to the site (Exelon 2011). Workers commuting to the construction site would arrive by site access roads and the volume of traffic on nearby roads could increase substantially during shift changes. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Some power plant components and materials could also be delivered by train or barge, depending on location. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from MODERATE to LARGE. 29 30 31 32 33 34 35 36 37 Traffic-related transportation impacts on local roads would be greatly reduced after the completion of the power plant. Transportation impacts would include daily commuting by the operating workforce, equipment and materials deliveries, and the removal of commercial waste material to offsite disposal or recycling facilities by truck. During operations, the estimated number of operations workers commuting to and from the power plant would be 820 workers (Exelon 2011). Traffic-related transportation impacts would be similar to current operations at LGS, because the new units would employ the same number of workers as currently employed at LGS. Overall, transportation impacts would be SMALL to MODERATE during power operations. 38 8.3.10. Aesthetics 39 40 41 42 The analysis of aesthetic impacts focuses on the degree of contrast between the new nuclear power plant and the surrounding landscape and the visibility of the new units at an existing nuclear power plant site. The power block of the two new units would look very similar to the power block(s) at the existing nuclear power plant. 43 44 During construction, all of the clearing and excavation would occur on site. These activities may be visible from offsite roads. Since the existing power plant site already appears industrial, 8-34 Environmental Impacts of Alternatives 1 2 construction of the new nuclear power plant would appear similar to other ongoing onsite activities. 3 4 5 6 7 Located near an existing power plant, the tallest power plant structures, the natural draft cooling towers could be 400 to 500 ft (122 to 152 m) tall. Visible off site during daylight hours, they may require aircraft warning lights. Associated condensate plumes could add to the visual impact. Noise generated during power plant operations would mostly be limited to routine industrial processes and communications. Natural draft cooling towers would also generate noise. 8 9 10 11 In general, given the industrial appearance of an existing power plant site, the new nuclear power plant would blend in with the surroundings. Aesthetic changes would therefore be limited to the immediate vicinity of the existing power plant site, and any impacts would be SMALL to MODERATE, depending on its location and surroundings. 12 8.3.11. Historic and Archaeological Resources 13 14 15 16 17 18 19 20 21 22 23 24 The impacts of constructing the new nuclear alternative on historic and archaeological resources are similar to those impacts associated with activities for constructing an NGCC facility. Any areas potentially affected by the construction of the SCPC alternative would need to be surveyed to identify and record historic and archaeological resources. An inventory of a previously disturbed former plant (brownfield) site may still be necessary if the site has not been previously surveyed or to verify the level of disturbance and evaluate the potential for intact subsurface resources. Plant operators would need to survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, other ROWs). Any resources found in these surveys would need to be evaluated for eligibility on the NRHP, and mitigation of adverse effects would need to be addressed if eligible resources were encountered. Areas with the greatest sensitivity should be avoided. Visual impacts on significant cultural resources--such as the viewsheds of historic properties near the site--should also be assessed. 25 26 27 28 29 30 The potential for impacts on historic and archaeological resources from the new nuclear alternative would vary greatly depending on the location of the proposed site. However, given that the preference is to use a previously disturbed former plant site, avoidance of significant historic and archaeological resources should be possible and effectively managed under current laws and regulations. Therefore, the impacts on historic and archaeological resources from the new nuclear alternative would be SMALL. 31 8.3.12. Environmental Justice 32 33 34 35 36 The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the construction and operation of a new power plant. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. 37 38 39 40 41 42 43 44 45 Potential impacts to minority and low-income populations would mostly consist of environmental and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be directly affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects are not likely to be high and adverse and would be contained to a limited time period during certain hours of the day. During construction, increased demand for rental housing in the vicinity of the site could affect low-income populations living near the plant site. However, given the proximity of some existing 8-35 Environmental Impacts of Alternatives 1 2 nuclear power plant sites to metropolitan areas, workers could commute to the construction site, thereby reducing the need for rental housing. 3 4 5 6 7 8 Potential impacts to minority and low-income populations from new nuclear power plant operations would mostly consist of radiological effects; however, radiation doses are expected to be well below regulatory limits. All people living near the nuclear power plant would be exposed to the same potential effects from power plant operations, and any impacts would depend on the magnitude of the change in ambient air quality conditions. Permitted air emissions are expected to remain within regulatory standards. 9 10 11 12 Based on this information and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of a new nuclear power plant would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations. 13 8.3.13. Waste Management 14 15 16 17 18 19 During the construction stage of the new nuclear alternative, land clearing and other construction activities would generate waste that could be recycled, disposed of on site, or shipped to the offsite waste disposal facility. Because the new nuclear plants would be constructed at a location on and adjacent to an existing nuclear power plant (although not at LGS because of space limitations), the amount of wastes produced during land clearing would be reduced. 20 21 22 23 24 During the operational stage, normal plant operations, routine plant maintenance, and cleaning activities would generate nonradioactive waste as well as mixed waste, low-level waste, and high-level waste. Quantities of nonradioactive waste (discussed in Section 2.3.1 of this SEIS) and radioactive waste (discussed in Section 6.1 of this SEIS) generated by Units 1 and 2 would be comparable to that generated by the new nuclear plants. 25 26 27 28 29 According to the GEIS (NRC 1996), the generation and management of solid nonradioactive waste during the terms of an extended license are not expected to result in significant environmental impacts. Two new nuclear plants would generate waste streams similar to those at nuclear plants that have undergone license renewal. Based on this information, the waste impacts would be SMALL for the new nuclear alternative. 8-36 Environmental Impacts of Alternatives 1 2 Table 8-4. Summary of Environmental Impacts of the New Nuclear Alternative Compared to Continued Operation of the Existing LGS New Nuclear Alternative Continued LGS Operation Air Quality SMALL SMALL Groundwater SMALL SMALL Surface Water SMALL SMALL Aquatic Resources SMALL SMALL Terrestrial Resources SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to LARGE SMALL Transportation SMALL to MODERATE SMALL Aesthetics SMALL to MODERATE SMALL Historic and Archaeological SMALL SMALL Waste Management (a) (a) SMALL (a) SMALL As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 3 8.4. Wind Alternative 4 5 6 The feasibility of wind as a baseload power source depends on the availability, accessibility, and constancy of the wind resource within the region of interest. Wind power, in general, cannot be stored without first being converted to electrical energy. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Wind power installations, which may consist of several hundred turbines, produce variable amounts of electricity. LGS, however, produces electricity almost constantly. Because wind power installations deliver variable output when wind conditions change, wind power cannot substitute for existing baseload generation on a one-to-one basis. In its ER, Exelon discusses the need for "firming capacity" to provide support to the variable wind resource and provide consistent baseload power. Firming capacity could come from other generators, from compressed air energy storage (CAES), from pumped hydroelectric storage, or from interconnected wind installations. Archer and Jacobsen (2007), indicates that an array of interconnected wind sites (19 in their study), spread across significant distances (with approximately 850 km (530 mi) distance from north to south and east to west) could provide 21 percent of installed capacity 79 percent of the time. While the sites in Archer and Jacobsen's study, in most cases, accessed higher power-class wind resources than are readily available onshore in PJM, the approach suggests that approximately 20 percent of the installed capacity in a series of interconnected wind installations could provide baseload power. Therefore, this study indicates that interconnecting windfarms, as assumed in this alternative, may provide a source of consistent, baseload power. In this alternative, the staff considers a wind alternative that relies on numerous, interconnected wind installations scattered across PJM. This arrangement ensures that generators are sufficiently dispersed so that low-wind or no-wind conditions are unlikely to occur at all or most locations at any given time. 8-37 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 11 Wind farms currently operate at much lower capacity factors than nuclear power. For example, LGS Unit 1 has operated at a 97 percent capacity factor over the years 2003 to 2010, while LGS Unit 2 has operated at a 96 percent capacity factor over the same period (NRC 2011). Currently, Department of Energy (DOE) estimates that wind turbine installations operate at 39 percent or lower capacity factors because of the variability of wind resources. As Exelon indicated in its ER, this capacity factor is likely to increase as wind turbine technology advances and as operators become more experienced in maximizing output. DOE indicates that, by 2020, onshore wind turbines may reach a 52 percent capacity factor, while offshore units may reach a 55 percent capacity factor (DOE 2008). As described in more detail below, the staff finds it likely that all wind turbines in this alternative will be land-based and, therefore, used the 52 percent capacity factor as an upper range of the capacity factor for this analysis. 12 13 14 15 16 17 For a lower range of the capacity factor used in this analysis, the staff reviewed PJM's 13 percent "capacity credit" to wind power. Capacity credit is the amount of a generator's nameplate capacity that counts toward the total generating capacity of the PJM system for system planning purposes. Assuming a 13 percent "capacity credit" for wind power, 18,000 MW(e) of wind power would be necessary to replace 2,340 MW(e) of LGS because of the intermittency of wind power. 18 19 20 21 22 23 24 25 26 27 28 29 30 Wind power is a commercially available and feasible means of generating electricity. Assuming a range of 13 to 52 percent capacity factor, the staff, in this alternative, evaluates a wind-powered alternatives that contains between 4,500 MW(e) and 18,000 MW(e) of installed capacity. Relying on commonly available 2-MW(e) turbines, 2,250 to 9,000 turbines would be required to replace LGS. The NRC staff determined this was a reasonable alternative because wind power is currently a source of energy generation within PJM. As of October 2012, approximately 6,000 MW of installed wind capacity exists within PJM (PJM 2012a). The installed wind capacity within Pennsylvania, Delaware, Maryland, New Jersey, Ohio, and West Virginia has grown on average 50 percent per year from 2000 through 2011 (DOE 2012). Similar growth is likely within the next several years. For example, as of January 2012, a total of 37,792 MW of wind energy generation is proposed within PJM (PJM 2012b). Similarly, in a recent update of PJM's renewable portfolio standards, PJM (2012a) estimated that 35,600 MW of wind energy would be installed by 2027. 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 As described above, this alternative assumes all wind power would be generated onshore because it is currently commercially available and a feasible means of generating electricity. While some offshore wind development is possible by 2024, no commercial offshore wind installations currently operate in the United States, despite more than a decade of development efforts. In the Atlantic Ocean, several commercial wind-power projects have been proposed, but none have yet received final approvals or begun construction. The most prominent of these projects, Cape Wind would consist of 130 turbines with a maximum installed capacity of 468 MW. The project was initially proposed in 2001; however, because of significant delays related to permitting and the NEPA process, the project is currently scheduled to begin construction in 2013. Cape Wind is the first and only U.S. offshore wind farm to have received all required Federal and State approvals, a commercial lease, and an approved construction and operations plan (BOEMRE, 2012b). Other projects offshore of Rhode Island and New Jersey are smaller than Cape Wind (Wald 2011), and another organization has proposed-- though not yet constructed--a high-voltage direct-current powerline on the seafloor to connect offshore projects (Atlantic Wind Connection undated, Wald 2011). Finally, a group working near Long Island proposed an installation of 700 MW(e) of wind capacity (Con Edison 2009). While wind data suggest there is potential for offshore wind farms along the coast of the mid-Atlantic and in the Great Lakes, project costs likely limit the future potential of large-scale projects (NREL 2010). NREL (2010) estimated that offshore project costs would run approximately 8-38 Environmental Impacts of Alternatives 1 2 3 4 5 200 to 300 percent higher than land-based systems. Also, based on current prices for wind turbines, the 20-year levelized cost of electricity produced from an offshore wind farm would be above the current production costs from existing power generation facilities. In addition to cost, other barriers include the immature status of the technology, limited resource area, and high risks and uncertainty (NREL 2010). 6 Environmental impacts from the wind alternative are summarized in Table 8-5. 7 8.4.1. Air Quality 8 9 10 11 12 13 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 14 15 16 17 18 Beyond maintenance of the wind turbines, there would be no routine air emissions associated with operations from wind generation. Activities associated with the construction and installation of the wind turbines would cause some temporary air pollutant emissions. However, emissions from workers' vehicles and construction equipment exhaust would be temporary. The staff concludes that the air quality impact from construction would be SMALL. 19 Greenhouse Gas Emissions 20 21 22 23 24 25 Wind power releases no GHGs during operation, although some GHG emissions occur during component manufacturing, transportation, and installation, as well as during site preparation. Impacts from the construction of components of this alternative would result primarily from the consumption of fossil fuels in the engines of construction vehicles and equipment, workforce vehicles used in commuting to and from the work site, and delivery vehicles. However, all such impacts would be temporary. 26 27 In general, wind power is one of the least carbon-intensive electric generation options available. For a comparison to other means of electric generation, see the discussion in Chapter 6. 28 29 30 Given the expected relatively small workforces, short construction period, and GHG emissions resulting from site preparation and installation, ,the overall impact from the release of GHGs of the wind alternative would be SMALL. 31 Conclusions 32 33 Based on the above discussion, the overall air emissions and air quality impacts from the wind alternative would be designated as SMALL. 34 8.4.2. Groundwater Resources 35 36 37 38 Groundwater dewatering, where required for installation of wind turbines on land, would be minimal because of the small footprint of foundation structures and piling emplacements. For all construction activities, appropriate BMPs, including spill prevention practices, would be used during wind turbine construction to prevent or minimize impacts on groundwater quality. 39 40 41 Little or no groundwater use would be expected for operation of wind turbines, and no impacts on groundwater quality would be expected from routine operations. Consequently, the impacts on groundwater use and quality under this alternative would be SMALL. 8-39 Environmental Impacts of Alternatives 1 8.4.3. Surface Water Resources 2 3 4 5 6 7 8 Small amounts of water would be required during the construction phase for each of the 2,250 wind turbines, including for dust suppression and soil compaction during site clearing and for concrete production for pad and piling construction, as appropriate. Although surface water from nearby water bodies may be used for pad site construction at some locations, it is likely that water would be procured from offsite sources and trucked to the point of use on an as needed basis. Use of ready-mix concrete also would reduce the need for onsite use of nearby water sources. 9 10 11 12 13 14 15 16 17 Further, the installation of land-based wind turbines would require installation of access roads and possibly transmission lines (especially for turbine sites not already proximal to transmission line corridors). Access road construction also would require some water for dust suppression and roadbed compaction and would have the potential to result in soil erosion and stormwater runoff from cleared areas. Water would likely be trucked to the point of use from offsite locations along with road construction materials. Construction activities would be conducted in accordance with state-issued NPDES or equivalent permits for stormwater discharges associated with construction activity, which would require the implementation of appropriate BMPs to prevent or mitigate water quality impacts. 18 19 20 21 22 23 24 25 To support operations of individual wind turbine installations, only very small amounts of water would be needed to periodically clean turbine blades and motors as part of routine servicing. It would be expected that water would be trucked to the point of use and procured from nearby sources. Adherence to appropriate waste management and minimization plans, spill prevention practices, and pollution prevention plans during servicing would minimize the risks to soils and surface water resources from spills of petroleum, oil, and lubricant products and runoff associated with the turbine installations. Therefore, the impacts on surface water use and quality under the wind alternative would be SMALL. 26 8.4.4. Aquatic Resources 27 28 29 30 31 32 33 Construction activities for the land-based wind alternative (such as construction of heavy-haul roads and the wind turbines) could affect drainage areas and other onsite aquatic features. Minimal impacts on aquatic ecology resources are expected because the plant operator would likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, which would be required if an NPDES permit was necessary, would minimize the flow of disturbed soils into aquatic features. During operations, the land-based wind alternative would not require consumptive water use. 34 35 36 37 The impacts on aquatic ecology would be minor because construction activities would likely require BMPs and stormwater management permits. During operations, the land-based wind alternative would not require consumptive water use. Therefore, impacts on aquatic ecology from the land-based wind alternative would be SMALL. 38 39 40 41 42 43 44 45 46 Consultation with NMFS and FWS under ESA would ensure that the construction and operation of wind farms would not adversely affect any Federally listed species or adversely modify or destroy designated critical habitat. If wind farms were located near EFH, consultation with NMFS under the Magnuson-Stevens Act would require the NRC to evaluate impacts to EFH. NMFS would provide conservation recommendations if there would be adverse impacts to EFH. Coordination with state natural resource agencies would further ensure that the wind farm operators would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation on protected species and habitats would be SMALL. 8-40 Environmental Impacts of Alternatives 1 8.4.5. Terrestrial Resources 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 The wind alternative would contain between 2,250 and 9,000 wind turbines requiring approximately 3,200 to 13,300 ac (1,300 to 5,400 ha) of land. This land estimate includes only the area directly affected by placement of turbines, and about two-thirds of this land area would only experience temporary disturbance during construction. The logistics of delivering heavy or oversized components to ideal locations such as hilltops or ridgelines would be challenging and might require extensive modifications to existing road infrastructures and construction of access roads that take circuitous routes to their destination to avoid unacceptable grades. However, once construction was completed, many access roads could be reclaimed and replaced with more-direct access to the wind farm for maintenance purposes. Likewise, land used for equipment laydown and turbine component assembly and erection could be returned to its original state. BMPs following construction that include plans to restore disturbed land would also reduce the impact of construction on terrestrial habitats. Because wind turbines require ample spacing between one another to avoid inter-turbine air turbulence, the footprint of utility-scale wind farms could be quite large. The turbines would be spread across a total area of 200 to 830 mi2 (520 to 2,150 km2), and most of this area will remain in compatible land uses, such as agriculture and forests (Exelon, 2011). During operations, only 5 to 10 percent of the total acreage within the footprint of wind installations would actually be occupied by turbines, access roads, support buildings, and associated infrastructure while the remaining land areas could be put to other compatible uses, including agriculture. Habitat loss and some habitat fragmentation may occur as a result, especially for wind turbines installed in forested areas. Overall, construction impacts on terrestrial species and habitats could range from SMALL to MODERATE. 24 25 26 27 28 29 30 31 32 33 34 35 Operation of wind turbines could uniquely affect terrestrial species through noise, collision with turbines and meteorological towers, site maintenance activities, disturbance associated with activities of the project workforce, and interference with migratory behavior. Bat and bird mortality from turbine collisions is a concern for operating wind farms; however, recent developments in turbine design have reduced the potential for bird and bat strikes. Additionally, impacts to those bird and bat species protected by the ESA, the Migratory Bird Treaty Act, or the Bald and Golden Eagle Protection Act would be mitigated through consultation with the appropriate agencies as discussed below. Impacts to terrestrial habitats and species from transmission line operation and corridor vegetation maintenance would be similar in magnitude and intensity to those resulting from operating nuclear reactors and would, therefore, be SMALL (NRC 1996). Overall, operation impacts to terrestrial species and habitats could range from SMALL to MODERATE. 36 37 38 39 40 41 42 As with the previously discussed alternatives, consultation with FWS under the ESA would avoid potential adverse impacts to Federally listed species or adverse modification or destruction of designated critical habitat. Coordination with state natural resource agencies would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of a wind alternative on protected species and habitats would be SMALL. 43 8.4.6. Human Health 44 45 46 47 Impacts on human health from construction of the wind alternative would be similar to impacts associated with the construction of any major industrial facility. Compliance with worker protection rules would control those impacts on workers at acceptable levels. Impacts from construction on the general public would be minimal since limiting active construction area 8-41 Environmental Impacts of Alternatives 1 2 access to authorized individuals is expected. Impacts on human health from the construction of the wind alternative would be SMALL. 3 4 5 6 7 8 9 10 The Massachusetts Department of Environmental Protection (MassDEP), in collaboration with the Massachusetts Department of Public Health (MDPH), convened a panel of independent experts to identify any documented or potential health impacts of risks that may be associated with exposure to wind turbines (MassDEP and MDPH 2012). The panel conducted an extensive literature review of scientific literature as well as other reports, popular media, and the public comments received by MassDEP to write its report. Based on its review, the panel presented findings relative to three factors associated with the operation of wind turbines: noise and vibration, shadow flicker, and ice throw. 11 Noise and Vibration 12 13 14 15 16 17 18 19 20 21 Noise produced by wind turbines during operation depends on the design of the wind turbine. Propagation of the sound is primarily a function of distance from the wind turbine, but can also be affected by placement of the wind turbine, surrounding terrain, and atmospheric conditions. Infrasound refers to vibrations with frequencies below 20 Hertz (Hz). Infrasound at amplitudes over 100-110 Decibels (dB) can be heard and felt. Research has shown that vibrations below these amplitudes are not felt. Through its research, the panel found that the highest infrasound levels measured near turbines are under 90 dB at 5 Hz and lower at higher frequencies for locations as close as 100 meters (m). The panel found that there was not sufficient evidence to conclude that noise and vibration from wind turbines cause negative impacts on human health (MassDEP and MDPH 2012). 22 Shadow Flicker 23 24 25 26 27 28 Shadow flicker results from the passage of the blades of a rotating wind turbine between the sun and the observer. The occurrence of shadow flicker depends on the location of the observer relative to the turbine and the time of day and year, and is found to only be present at distances of less than 1,400 m (4,600 ft) from the turbine. The panel found through its research that there was not sufficient evidence to conclude that shadow flicker causes negative impacts (such as seizures from photic stimulation) on human health (MassDEP and MDPH 2012). 29 Ice Throw 30 31 32 33 34 35 36 37 38 39 Ice can fall or be thrown from a wind turbine during or after an event when ice forms or accumulates on the blades. The distance that a piece of ice may travel from the turbine is a function of the wind speed, the operating conditions, and the shape of the ice. The panel found that in most documented cases of ice throw, the ice falls within a distance from the turbine equal to the tower height, and very seldom does the distance exceed twice the total height of the turbine (tower height plus blade length). The panel found that there is sufficient evidence that falling ice is a human health impact, and measures should be taken to ensure proper hazard minimization. Proper siting of the wind turbines, limitation of access by members of the public, and adequate training of persons in charge of maintenance of the facility will help to minimize the danger of ice throw (MassDEP and MDPH 2012). 40 41 42 Overall, given proper health-based regulation through procedures and access limitations, the staff expects human health impacts from operation of the wind alternative at an alternate site to be SMALL. 43 8.4.7. Land Use 44 45 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each power 8-42 Environmental Impacts of Alternatives 1 2 3 4 plant site. The analysis of land-use impacts focuses on the amount of land area that would be affected by the construction and operation of new land-based wind farms in the PJM territory. Most of the wind farms would likely be located on open agricultural cropland, which would remain largely unaffected by the wind turbines. 5 6 7 8 9 10 11 12 13 Since wind turbines require ample spacing between one another to avoid air turbulence, the footprint of a utility scale wind farm could be quite large. Under the wind alternative, land-based turbines would be located on multiple wind farms spread across approximately 130,000 to 534,000 ac (53,000 to 216,000 ha or 200 to 830 mi2 [520 to 2,150 km2]) of land. A small portion of this land, approximately 3,200 to 13,300 ac (1,300 to 5,400 ha), would be directly affected by the placement of the wind turbines (Exelon 2011). This land would be temporarily affected during the installation of the turbines and the construction of support facilities, and about one-third of the land across a very wide area would be permanently impacted during the operation. Land in between the turbines can be used for farming or grazing. 14 15 16 17 18 19 20 21 22 Delivering heavy and oversized wind turbine components would also require the construction of temporary site access roads, some of which may require a circuitous route to their destination. However, once construction is completed, many temporary access roads can be reclaimed and replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land used for equipment and material lay down areas, turbine assembly, and installation could be returned to its original state. During operations, however, only 5-10 percent of the total acreage within the wind farm is actually occupied by turbines, access roads, support buildings, and associated infrastructure while the remaining land area can be returned to its original condition or some other compatible use, such as farming or grazing. 23 24 25 26 The elimination of uranium fuel for LGS could partially offset some, but not all, of the land requirements for the wind farms. Scaling from GEIS estimates, approximately 1,640 ac (660 ha) would no longer be needed for mining and processing uranium during the operating life of the wind farms. 27 28 29 The wind farms would require a substantial amount of open land, although only a small portion would be used for wind turbines, access roads, and infrastructure. Therefore, land use impacts from the wind alternative would range from MODERATE to LARGE. 30 8.4.8. Socioeconomics 31 32 33 34 35 36 As previously explained in Section 8 1.8, two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of the wind alternative were evaluated in order to measure their possible effects on current socioeconomic conditions. 37 38 39 40 41 42 43 Exelon estimated 200 construction and 50 operations workers would be required for this alternative (Exelon 2011). These numbers appear reasonable and in line with current construction and operational trends. Because of the relatively small number of construction workers and the large area covered by the wind farms (i.e., 200 to 830 mi2 [520 to 2,160 km2]), the relative economic impact of this many workers on local communities and the tax base would be SMALL. Given the small number of operations workers, socioeconomic impacts associated with operation of the wind farms would also be SMALL. 44 45 46 The reduction in employment at LGS could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of 8-43 Environmental Impacts of Alternatives 1 2 3 the LGS region. However, the increased property taxes paid by wind farms may offset lost tax revenues in local jurisdictions. Based on this information, socioeconomic impacts during wind farm operations could range from SMALL to MODERATE. 4 8.4.9. Transportation 5 6 7 8 Transportation impacts during the construction and operation of the wind alternative would be less than the impacts for the NGCC, SCPC, and new nuclear alternatives, discussed in the previous sections, because of a smaller construction workforce and smaller volume of materials and equipment needed to be transported to the construction site. 9 10 11 12 13 14 15 16 17 18 19 20 21 As described in 8.4.7, up to 200 workers could be commuting daily to the site during periods of peak construction activity (Exelon 2011). Workers commuting to the construction site would arrive by site access roads and the volume of traffic on nearby roads could increase during shift changes. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Transporting heavy and oversized wind turbine components on local roads could have a noticeable impact over a large area. Some components and materials could also be delivered by train or barge, depending on location. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from SMALL to MODERATE depending on the location of the wind farm site, road capacities, and traffic volumes. 22 23 24 During plant operations, transportation impacts would not be noticeable. Exelon estimated an operational workforce of 50 workers (Exelon 2011). Given the small number of operations workers, transportation impacts on local roads would be SMALL. 25 8.4.10. Aesthetics 26 27 28 29 30 31 32 33 34 35 36 The analysis of aesthetic impacts focuses on the degree of contrast between the wind farms and the surrounding landscape and the visibility of wind turbines. In general, aesthetic changes would be limited to the immediate vicinity of the wind farms. However, wind turbines would have the greatest visual impact. At 400 ft (122 m) tall (Exelon 2011) and spread across multiple sites, wind turbines would dominate the view and would likely become the major focus of attention. Because wind farms are generally located in rural or remote areas, the introduction of wind turbines will be in sharp contrast to the visual appearance of the surrounding environment. Placing turbines along ridgelines would maximize their visibility. Wind turbines also generate noise. Most other noises would be limited to industrial processes and communications. Based on this information, aesthetic impacts from the construction and operation of a land-based wind alternative would range from MODERATE to LARGE depending on location and surroundings. 37 8.4.11. Historic and Archaeological Resources 38 39 40 41 42 43 44 To consider effects on historic and archaeological resources, any areas potentially affected by the construction of a wind alternative would need to be surveyed to identify and record historic and archaeological resources. Any resources found in these surveys would need to be evaluated for eligibility on the NRHP, and mitigation of adverse effects would need to be addressed if eligible resources were encountered. The owner of the wind farms would need to survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, other ROWs). Areas with the greatest sensitivity should be avoided. Visual impacts on 8-44 Environmental Impacts of Alternatives 1 2 significant cultural resources--such as the viewsheds of historic properties near the sites--also should be assessed. 3 4 5 6 7 8 9 10 The potential for impacts on historic and archaeological resources from the wind alternative would vary greatly, depending on the location of the proposed sites. Areas with the greatest sensitivity could be avoided or effectively managed under current laws and regulations. However, construction of wind farms and their support infrastructure have the potential to notably impact historic and archaeological resources because of earthmoving activities (e.g., grading and digging) and the aesthetic changes they may bring to the viewshed of historic properties located nearby. Therefore, depending on the resource richness of the site chosen for the wind farms and associated infrastructure, the impacts could range from SMALL to LARGE. 11 8.4.12. Environmental Justice 12 13 14 15 16 The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the construction and operation of new wind farms. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Potential impacts to minority and low-income populations would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects are not likely to be high and adverse and would be contained to a limited time period during certain hours of the day. Increased demand for rental housing during construction could affect low-income populations. However, given the small number of construction workers and the possibility that workers could commute to the construction site, the need for rental housing would not be significant. Minority and low-income populations living in close proximity to the wind farms could be disproportionately affected by wind farm operations. However, operational impacts would mostly be limited to noise and aesthetic effects. The general public living near the wind farms would also be exposed to the same effects. 31 32 33 34 Based on this information and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of new wind farms would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations. 35 8.4.13. Waste Management 36 37 38 39 40 41 During the construction stage of the wind alternative facility, land clearing and other construction activities would produce minor quantities of waste. Only small quantities of waste, such as dielectric fluids used during maintenance activities, would be produced during operation (Exelon 2011). In addition, Table 8-2 of the GEIS (NRC 1996), the staff identified very minor amounts of waste from maintenance of equipment and potentially removing vegetation. Based on this information, waste impacts would be SMALL for a wind turbine site. 8-45 Environmental Impacts of Alternatives Table 8-5. Summary of Environmental Impacts of the Wind Alternative Compared to Continued Operation of the Existing LGS 1 2 Wind Power Continued LGS Operation Air Quality SMALL SMALL Groundwater SMALL SMALL Surface Water SMALL SMALL Aquatic Resources SMALL SMALL Terrestrial Resources SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use MODERATE to LARGE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics MODERATE to LARGE SMALL Historic and Archaeological SMALL to LARGE SMALL Waste Management SMALL SMALL (a) (a) As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 3 8.5. Purchased Power 4 5 6 7 8 The impacts from purchased power would depend substantially on the generation technologies used to supply the purchased power. Given PJM's market-based system operations, replacement power could come from different generators at different times of the year, so impacts are not necessarily predictable. Impacts from operation of other generators would likely occur in Pennsylvania or elsewhere in PJM. 9 10 11 12 13 14 15 16 17 18 19 20 21 Exelon assumed that purchased power would be available as a reasonable alternative for meeting load obligations if the LGS licenses are not renewed (Exelon 2011). The NRC staff finds this assessment reasonable given the large size of PJM and wide range of existing and potential energy-producing facilities available to purchase power. Purchased power would likely come from one or more of the other types of alternatives considered in this chapter. As a result, operational impacts would be similar to the operational impacts of the alternatives considered in this chapter. Unlike the alternatives considered in this chapter, however, facilities from which power would be purchased would not likely be constructed solely to replace LGS. Purchased power may, however, require new transmission lines (which may require new construction), and may also rely on slightly older and less efficient power plants' operating at higher capacities than they currently operate. Exelon, in the ER, states that impacts would be "incremental and reflective of the increased amount of power being produced," and may vary based on fuels used, waste management practices, and facility locations (Exelon 2011). 22 23 24 25 At some times, some portion of replacement power needs may be addressed by PJM's demand-response program, which the staff discusses in Section 8.6.14. As noted in Section 8.6.14, impacts from DSM programs are generally small, although backup generators could impact air quality. 8-46 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 During operations, impacts from new nuclear, coal-fired, and natural gas-fired plants and wind energy projects would be similar to that described under the new nuclear, coal, natural gas, and wind alternatives described in the previous sections. Impacts from the operations of existing coal and natural gas-fired plants would likely be greater than the operations of new plants because older plants are more likely to be less efficient and without modern emissions controls. Air quality impacts from the combination of all sources would likely be greater than license renewal because a large portion of the purchased power would likely be from coal- and natural gas-fired plants. 9 10 11 12 13 While purchased power is a reasonable alternative, the potential impacts of constructing and operating new power generating facilities are addressed elsewhere in this chapter. In general, the impacts would likely be greater than license renewal because of potential new construction and because continued operation of older plants could result in higher emissions. A brief summary of the impacts for each resource area is provided below: 14 Air Quality: SMALL to MODERATE 15 16 17 18 19 New and continued nuclear and wind energy generation would not have noticeable impacts on air quality. New and continued natural gas- and coal-fired plants would have noticeable impacts on air quality; both natural gas- and coal-fired plants emit higher amounts of NOx, SOx, PM, PAHs, CO, CO2, and mercury as compared to LGS Units 1 and 2, and would have noticeable impacts. 20 Groundwater and Surface Water: SMALL 21 22 23 New and continued operation of nuclear, coal-fired, and natural gas-fired plants and wind energy projects would not have noticeable impacts on water resources assuming all energy generating facilities operate within their associated water quality and water use permits. 24 Terrestrial and Aquatic: SMALL to MODERATE 25 26 27 28 29 30 31 32 33 34 New and continued operation of existing natural gas-fired and nuclear plants would not have noticeable impacts on aquatic and terrestrial resources assuming plants are built in areas that avoid sensitive species and habitats. New land-based wind energy projects would not have noticeable impacts on aquatic resources assuming projects are built in areas that avoid sensitive species and habitats. New wind energy projects would have noticeable impacts on avian and bat communities. Any new transmission lines would likely be collocated with existing right-of-way, which would minimize impacts to ecological resources. New and continued operation of coal-fired plants would have noticeable impacts primarily because of the deposition of ash and other pollutants and because of the extent of terrestrial habitat disturbance associated with coal mining. 35 Human Health: SMALL 36 37 38 New and continued operation of existing nuclear, coal-fired, and natural gas-fired plants and wind energy projects would not have noticeable impacts on human health because of the extent of regulations to protect public health. 39 Land Use: SMALL to LARGE 40 41 42 43 44 45 46 Purchased power from existing nuclear power plants would not cause any land use changes. New power plants would be constructed at existing power plant sites. Purchased power from coal- and natural gas-fired plants could have a noticeable impact on land use because of the amount of land required for coal mining and gas drilling. Wind energy projects would have a noticeable land-use impact because of the large amount of land required for wind farms. Any new transmission lines would likely be collocated with existing right-of-way, which would minimize any land use impacts. 8-47 Environmental Impacts of Alternatives 1 Socioeconomics, Transportation, and Aesthetics: SMALL to LARGE 2 3 4 5 6 7 8 Purchased power from existing power plants would not have any socioeconomic impact, because there would be no change in power plant operations or workforce. Construction of new electrical power generating facilities could cause noticeable short-term socioeconomic and transportation impacts because of the number of construction workers required to build the new power plant. Traffic volumes would increase on local roads during shift changes. Continued operations of existing power plants would not have noticeable increased socioeconomic impacts as there would be no change in the number of workers at existing power generation facilities. 9 10 Wind energy projects would have the greatest visual impact; wind turbines would dominate the view and would likely become the major focus of attention. 11 Archaeological and Historic Properties: SMALL to LARGE 12 13 14 15 16 No direct impacts on historic and archaeological resources are expected from purchased power. If new transmission lines were needed to convey power to the PJM area, surveys similar to those discussed in Section 8.1.11 would need to be performed. However, transmission lines would likely be collocated with existing right-of-ways minimizing any impacts to historic and archaeological resources. 17 18 19 20 21 22 23 24 25 26 27 28 29 Indirectly, construction of new nuclear, coal-fired, and natural gas-fired plants, wind energy projects and any new transmission lines to support the purchased power alternative could affect archaeological and historic resources. Any areas potentially affected by the construction would need to be surveyed to identify and record historic and archaeological resources. Resources found in these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse effects would need to be addressed if eligible resources were encountered. Plant operators would need to survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, other ROWs). The potential for impacts on historic and archaeological resources would vary greatly depending on the location of the proposed sites; however, using previously disturbed sites could greatly minimize impacts to historic and archaeological resources. Areas with the greatest sensitivity could be avoided or effectively managed under current laws and regulations. Therefore, depending on the resource richness of the sites chosen, the impacts could range from SMALL to LARGE. 30 Environmental Justice 31 32 33 34 Low-income populations could be disproportionately affected by increased utility bills because of the cost of purchased power. However, programs, such as the low income home energy assistance program in Pennsylvania, are available to assist low-income families in paying for increased electrical costs. 35 Waste Management: SMALL to MODERATE 36 37 38 39 New and continued operations of existing nuclear and natural gas-fired plants and wind energy projects would not have noticeable impacts. However, new and continued generation of coal-fired plants would have noticeable impacts because of the accumulation of ash and scrubber sludge. 40 41 42 The impacts presented in Table 8-6 represent the potential range of impacts from relying on purchased power to replace LGS. Impacts from operation of other generators would likely occur elsewhere in PJM. The overall impacts would range from SMALL to MODERATE. 8-48 Environmental Impacts of Alternatives Table 8-6. Summary of Environmental Impacts of Purchased Power Compared to Continued Operation of the Existing LGS 1 2 Purchased Power Alternative Continued Operation of LGS Air Quality SMALL to MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aguatic & Terrestrial Resources SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to LARGE SMALL Socioeconomics (including transportation and aesthetics) SMALL to LARGE SMALL Historic and Archaeological SMALL to LARGE SMALL Waste Management SMALL to MODERATE SMALL (a) (a) As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 3 8.6. Alternatives Considered but Dismissed 4 5 6 7 Alternatives to LGS license renewal that were considered and eliminated from detailed study are presented in this section. These alternatives were eliminated because of technical, resource availability, or current commercial limitations. Many of these limitations would continue to exist when the current LGS licenses expire. 8 8.6.1. Solar Power 9 10 11 12 13 14 15 16 17 18 19 20 Solar technologies, including photovoltaic (PV) and solar thermal (also known as concentrated solar power (CSP)), use the sun's energy to produce electricity at a utility scale. In PV systems, special PV materials convert the energy contained in photons of sunlight incident to direct current (DC) electricity that can be aggregated, converted to alternating current (AC), and connected to the high-voltage transmission grid. Some PV installations, especially those located on existing buildings, provide power directly to consumers without first going onto the grid. CSP technologies produce electricity by capturing the sun's heat energy. CSP facilities are typically grid connected, and owing to their size and operational characteristics, are not located atop existing structures. Although some aspects of solar generation result in few environmental impacts, solar technology requires substantial land areas, and CSP technologies require roughly the same amount of water for cooling of the steam cycle as most other thermoelectric technologies. 21 22 23 24 25 26 27 28 The potential for solar technologies to serve as reliable baseload power alternative to LGS depends on the value, constancy, and accessibility of the solar resource. Both PV and CSP are enjoying explosive growth worldwide, especially for various off-grid applications or to augment grid-provided power at the point of consumption; however, discrete baseload applications still have technological limitations. As Exelon indicates in the ER, solar power generation typically requires backup generation or other means of balancing its variable output. Further, PV installations have no ability to provide power at night, and they provide reduced levels of power on overcast days, during fog events, and when snow accumulates. While their generation 8-49 Environmental Impacts of Alternatives 1 2 during summer months is high when electricity consumption is high, their capacity to generate electricity in winter declines before the evening electricity demand peaks. 3 4 5 6 7 8 9 EIA reports the total solar generating capacity (CSP and solar PV) in the United States in 2009 was 619 MW, 0.005 percent of the total nationwide generating capacity. Solar power produced 891,000 MWh of power in 2009, 0.02 percent of the nationwide production (EIA 2011a). The staff is not aware of any CSP facilities in the United States that are not located in the southwest, while many PV installations occur throughout the country. As a result, the staff determined that a solar-powered alternative in PJM would rely on solar PV technology rather than CSP technology. 10 11 12 13 14 15 Because PV does not produce electricity at night and produces diminished amounts of power during particular weather conditions, the staff does not consider solar PV to provide a viable, standalone alternative to license renewal. The staff considers a standalone PV alternative here, however, because Exelon includes solar PV in its range of alternatives to LGS license renewal in the ER, and because solar PV comprises a portion of the combination alternative in Section 8.6.2. 16 17 18 19 20 21 22 23 24 25 26 This section addresses only the solar PV impacts, and does not address impacts from load balancing or firming methods, which would be necessary for solar to serve as a standalone alternative to LGS. Technology to achieve load balancing or firming methods is not yet feasible or commercially available, which is part of the reason why the staff's determined that this alternative is not reasonable. As a result, this analysis likely understates potential impacts from a solar PV alternative because technology to achieve load balancing or firming methods would also result in environmental impacts. As discussed in the wind power section, pumped hydroelectric storage, compressed air energy storage, and backup generating capacity could all conceivably offset the variable power output of solar PV facilities. Unlike wind power, however, interconnected solar installations cannot span a sufficient area to provide consistent output at night. 27 28 29 30 31 32 33 34 Within PJM, solar PV installations receive a 38 percent capacity credit (PJM 2010). On this basis, approximately 6,160 MW(e) of solar capacity would be necessary to replace LGS. Exelon indicates that a utility-scale solar PV facility located in PJM receives 2.8 to 3.9 kWh of solar radiation per square meter per day (2011). (These estimates take into account average weather conditions, and they also account for solar unavailability at night. The estimate thus also accounts for solar capacity factors.) As a result, Exelon estimated that a solar PV facility would require approximately 6.5 ha (16 ac) per MW(e) of capacity (Exelon 2011). The total area necessary for solar PV installations, then, is approximately 40,000 ha (98,900 ac). 35 36 37 38 39 The staff notes that much of the solar capacity installed in PJM is likely to be in the form of rooftop installations. This type of installation minimizes land disturbance, can provide electricity directly to end-users, and minimizes the modifications necessary to the transmission system. Some land-based installations are also likely to occur. They are likely to be larger than rooftop installations, and they will require some degree of land disturbance for installation purposes. 40 Environmental impacts from the solar PV alternative are summarized in Table 8-7. 41 8.6.1.1. Air Quality 42 43 44 45 46 47 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, Pennsylvania, and is part of the Metropolitan Philadelphia Interstate Air Quality Control Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 8-50 Environmental Impacts of Alternatives 1 2 3 4 5 Beyond maintenance activities (e.g. serving equipment or repairs), there would be no routine air emissions associated with operations from solar PV. Activities associated with the construction and installation would cause some temporary air pollutant emissions. However, emissions from workers' vehicles and construction equipment exhaust would be temporary. The staff concludes that the air quality impact from construction would be SMALL. 6 Greenhouse Gas Emissions 7 8 9 10 11 12 13 14 Solar PV installations release no GHGs during operation, although some GHG emissions occur during component manufacturing, transportation, and installation, as well as during site preparation. Greenhouse gas emissions during construction of this alternative would result primarily from the consumption of fossil fuels in the engines of construction vehicles and equipment, workforce vehicles used in commuting to and from the work site, and delivery vehicles. However, all such impacts would be temporary. In general, solar PV installations are among the least carbon-intensive electric generation options available. For a comparison to other means of electric generation, see the discussion in Chapter 6. 15 16 17 Given the expected small workforces and GHGs emitted during construction, site preparation and installation, the overall impact from the release of GHGs of the solar PV alternative would be SMALL. 18 Conclusion 19 Based on the above analysis, the impact would be SMALL. 20 8.6.1.2. Groundwater Resources 21 22 23 24 25 26 27 For construction of solar PV installations, the need for groundwater dewatering likely would be minimal because of the small footprint and shallow depth of excavation for PV installations. For all construction activities, appropriate BMPs, including spill prevention practices, would be used during construction to prevent or minimize impacts on groundwater quality. Operation of PV units would not be expected to have any appreciable effect on groundwater resources. Based on the foregoing, the impacts on groundwater use and quality associated with the solar PV alternative would be SMALL. 28 8.6.1.3. Surface Water Resources 29 30 31 32 33 34 35 36 37 38 39 40 Siting and construction of solar PV installations would require relatively small amounts of water for dust suppression and soil compaction during site clearing and for concrete production. The NRC assumes that required water would be procured from offsite sources and trucked to the point of use on an as needed basis. Use of ready-mix concrete also would reduce the need for onsite use of nearby water sources. To support operations, water additionally would be required to clean PV panels. The staff expects that water would be trucked to the point of use and procured from nearby sources or could be supplied from a municipal water source. Adherence to appropriate waste management and minimization plans, spill prevention practices, and pollution prevention plans during servicing of PV installations would minimize the risks to soils and surface water resources from spills of petroleum, oil, and lubricant products and runoff. As a result, the impacts on surface water use and quality under this alternative would be SMALL. 41 8.6.1.4. Aquatic Resources 42 43 44 45 46 Construction activities for the solar PV alternative (such as construction of heavy-haul roads and the solar panels) could affect drainage areas or other onsite aquatic features. Minimal impacts on aquatic ecology resources are expected because BMPs would likely be used to minimize erosion and sedimentation at large facilities. Stormwater control measures, which would be required if an NPDES permit was necessary, would minimize the flow of disturbed soils into 8-51 Environmental Impacts of Alternatives 1 2 3 aquatic features. Many of the solar panels would be installed on rooftops. Because construction would occur within an existing structure, impacts to aquatic resources would be minimal. During operations, the solar PV alternative would not require consumptive water use. 4 5 6 7 8 9 10 For installations that do not occur on top of existing buildings, operators of the solar PV alternative would need to assess the occurrence and potential impacts to protected aquatic species within surface waters potentially affected during construction. In compliance with the ESA, FWCA, and the Magnuson-Stevens Act, the solar PV operators would need to consult with state officials, NMFS, and FWS to determine whether any avoidance or mitigation measures would be required and to ensure that construction and operation do not adversely affect any Federally listed species or adversely modify or destroy designated critical habitat. 11 12 13 14 The impacts on aquatic ecology would be minor because construction activities would likely require BMPs and stormwater management permits. During operations, the solar PV alternative would not require consumptive water use. Therefore, impacts on aquatic ecology from the solar PV alternative would be SMALL. 15 8.6.1.5. Terrestrial Resources 16 17 18 19 20 21 22 23 24 25 26 27 Up to 155 mi2 (420 km2) of land would be needed to support a solar PV alternative to replace LGS if all installations were located at standalone solar sites (see Section 8.6.1.7). Because the solar PV alternative would include many relatively small installations on building roofs or existing residential, commercial, or industrial sites, impacts to terrestrial species and habitats would be minimal. Some installations may be built on standalone solar sites, and impacts to terrestrial species and habitats on these sites would vary greatly depending on site selection and the allocation of installations on buildings versus standalone sites. Because many of the installations would likely be installed in developed areas that are already connected to the regional electric grid, construction of additional transmission lines or access roads to solar PV installation sites would likely be unnecessary. The impacts of construction to terrestrial habitats and species could range from SMALL to MODERATE, and the impacts of operation to terrestrial habitats and species would be SMALL. 28 29 30 31 32 33 34 35 36 Impacts to protected species and habitats would only occur in locations where solar PV installations are constructed on standalone solar sites. However, as with the previously discussed alternatives, consultation with FWS under the ESA would avoid any potential adverse impacts to Federally listed species or adverse modification or destruction of designated critical habitat. Coordination with state natural resource agencies would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of the solar PV alternative on protected species and habitats would be SMALL. 37 8.6.1.6. Human Health 38 39 40 41 42 43 44 45 46 47 The manufacture of solar cells involves the use of many hazardous chemicals, including toxic gases (e.g., arsine, phosphine, silane, sulfur hexafluoride, molybdenum hexafluoride, tungsten hexafluoride, hydrogen selenide, hydrochloric, and hydrofluoric acids), toxic metals (e.g., arsenic, cadmium, selenium, and various other heavy metals), and numerous flammable, corrosive, or highly reactive chemicals. In addition, the photocells contain cadmium, selenium, and other heavy metals. However, worker exposure to these hazards often are minimized. For example, a 2003 study conducted jointly by the Electric Power Research Institute (EPRI) and the California Energy Commission (CEC) concluded that the manufacture and use of photocells presented no significant health or environmental risk (EPRI and CEC 2003). In the study, EPRI and CEC (2003) state that the greatest possibility of human health risks comes from the 8-52 Environmental Impacts of Alternatives 1 2 3 4 manufacturing of the solar PV cells. The study states that, because of these health risks, extensive work has been done to reduce those hazards to plant workers. It also states that OSHA and similar state agencies set standards for allowable exposure limits to the various toxic chemicals used in the manufacturing process. 5 6 7 8 9 10 Impacts on human health from construction of the solar PV alternative would be similar to impacts associated with the construction of any major industrial facility. Compliance with worker protection rules would control those impacts on workers at acceptable levels. Impacts from construction on the general public would be minimal since limiting active construction area access to authorized individuals is expected. Impacts on human health from the construction of the solar PV alternative would be SMALL. 11 12 13 Solar PV panels are encased in heavy-duty glass or plastic. As a result, there is little risk that the small amounts of hazardous semiconductor material they contain will be released into the environment. 14 15 16 17 18 19 20 21 22 23 In the event of a fire, hazardous particulate matter could be released to the atmosphere. Given the short duration of fires and the high melting points of the materials found in the solar photovoltaic panels, the impacts from inhalation are minimal. Also, the risk of fire at ground-mounted solar installations is minimal because of precautions taken during site preparation, such as the removal of fuels and the lack of burnable materials contained in the solar photovoltaic panels. Another potential risk associated with photovoltaic systems and fire is the potential for shock or electrocution if a person would come in contact with a high-voltage conductor. Proper procedures and clear marking of system components should be used to provide emergency responders with appropriate warnings to diminish risk of shock or electrocution (OIPP 2010). 24 25 26 27 Photovoltaic solar panels do not produce electromagnetic fields at levels considered harmful to human health established by the International Commission on Non-Ionizing Radiation Protection. These small electromagnetic fields diminish significantly with distance and are indistinguishable from normal background levels within several yards (OIPP 2010). 28 29 30 Overall, given proper health-based regulation through procedures and access limitations, the staff expects human health impacts from operation of the Solar PV alternative at an alternate site to be SMALL. 31 8.6.1.7. Land Use 32 33 34 35 36 37 38 39 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each power plant site. The analysis of land-use impacts focuses on the amount of land area that would be affected by the installation and operation of solar PV technologies. PV technologies would generally be installed on building roofs at existing residential, commercial, or industrial sites. Some solar installations may also be built at standalone solar sites. Land use impacts may vary depending on the amount of additional land required and the actual allocation of solar installations. 40 41 42 43 44 45 46 47 The footprint of a utility scale standalone PV solar installation would be quite large. Based on Exelon's local PJM territory estimates, approximately 98,900 ac (40,000 ha or 155 mi2 [400 km2]) of land would be needed to support a solar PV alternative to replace the LGS (Exelon 2011). Land required for a standalone PV solar installation would alter the existing land to energy production, and would preclude most other land uses from coexisting. Land would also be needed for transmission lines to connect PV solar installations to the electrical power grid and site access roads for maintenance purposes. Installing PV solar technologies on building rooftops would reduce the amount of land required for standalone solar. 8-53 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 The elimination of uranium fuel for the LGS would partially offset some, but not all, of the land requirements for standalone PV solar sites. Scaling from GEIS estimates, approximately 1,640 ac (660 ha) (NRC 1996) would no longer be needed for mining and processing uranium during the operating life of the plant. Based on this information, overall land-use impacts from the construction and operation of a PV solar alternative could range from SMALL to LARGE, depending in part on the extent to which PV installations occur on existing buildings rather than standalone sites. 8 8.6.1.8. Socioeconomics 9 10 11 12 13 14 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of the PV alternative were evaluated in order to measure their possible effects on current socioeconomic conditions. 15 16 17 18 19 20 21 22 Exelon estimated 200 construction and 50 operations workers would be required for this alternative (Exelon 2011). These estimates appear reasonable and in line with current construction and operational trends. Because of the relatively small number of construction workers and the potentially large area covered by the PV solar installations at standalone sites and other locations, the relative economic impact of this many workers on local communities and the tax base would be SMALL. Given the small number of operations workers, socioeconomic impacts associated with operation of the PV solar installations would also be SMALL. 23 24 25 26 27 28 29 30 The reduction in employment at LGS could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the LGS region. However, the amount of property taxes paid for a utility-scale standalone PV solar installation may offset lost tax revenues in the socioeconomic region around local jurisdictions if more land is required for solar installations. Based on this information, socioeconomic impacts during PV solar power generating operations could range from SMALL to MODERATE. 31 8.6.1.9. Transportation 32 33 34 35 Transportation impacts during the construction and operation of the PV alternative would be similar to the wind alternative, discussed in Section 8.4.10, as a smaller construction workforce and smaller volume of materials and equipment would be needed to be transported to the construction site. 36 37 38 39 40 41 42 43 44 45 46 47 During periods of peak construction activity, up to 200 workers could be commuting daily to the sites (Exelon 2011). Workers commuting to the construction sites would arrive by site access roads and the volume of traffic on nearby roads could increase during shift changes. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksites, thus increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Delays may not be noticeable because the solar alternative may be spread across multiple sites. Some components and materials could also be delivered by train or barge, depending on the locations. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic related transportation impacts during construction could range from SMALL to MODERATE depending on the location of the standalone site, road capacities, and traffic volumes. 8-54 Environmental Impacts of Alternatives 1 2 3 4 5 During plant operations transportation impacts would not be noticeable because of the small estimated operational workforce spread across multiple sites. Exelon estimated an operational workforce of 50 workers (Exelon 2011), which appears reasonable. Given the small numbers of operations workers, the traffic impacts on local roads from PV solar installation operations would be SMALL. 6 8.6.1.10. 7 8 9 The analysis of aesthetic impacts focuses on the degree of contrast between PV solar installations and the surrounding landscape and the visibility of PV installed technologies. In general, aesthetic changes would be limited to the immediate vicinity of PV solar installations. Aesthetics 10 11 12 13 14 15 16 17 18 19 20 As previously discussed, the footprint of a utility scale standalone PV solar installation would be quite large, and could create a noticeable visual impact. Spread across a large site, the utility scale standalone PV solar installation could dominate the view and would likely become the major focus of attention. The introduction of a utility scale standalone PV solar installation would be in sharp contrast to the visual appearance of the surrounding environment. Installing PV solar technologies on building rooftops, although noticeable to a lesser degree in urban settings, would reduce the amount of land required for standalone solar sites. Any noise at utility scale standalone PV solar installation would be limited to industrial processes and communications. Based on this information, aesthetic impacts from the construction and operation of a PV alternative could range from MODERATE to LARGE depending on the type of solar technology installed and its location and surroundings. 21 8.6.1.11. 22 23 24 25 26 27 28 Any areas potentially affected by the construction of the solar alternative would need to be surveyed to identify and record historic and archaeological resources. Resources found in these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse effects would need to be addressed if eligible resources were encountered. Plant operators would need to survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, other ROWs). Visual impacts on significant cultural resources--such as the viewsheds of historic properties near the sites--should also be assessed. 29 30 31 32 33 34 35 36 37 38 39 40 41 The impacts of the construction of a new solar PV alternative on historic and archaeological resources will vary depending on the form of the solar capacity installed in PJM. Rooftop installations minimize land disturbance and the modifications necessary to the transmission system, thereby minimizing impacts to historic and archaeological resources. Land-based installations are larger than rooftop installations and will require some degree of land disturbance for installation purposes, potentially causing greater impacts to historic and archaeological resources. Aesthetic changes caused by the installation of both forms could have a noticeable effect on the viewshed of nearby historic properties. Using previously disturbed sites for land-based installations and collocating any new transmission lines with existing right-of-ways could minimize impacts to historic and archaeological resources. Areas with the greatest sensitivity could be avoided or effectively managed under current laws and regulations. Therefore, depending on the resource richness of the sites chosen and the type of solar technology installed, the impacts could range from SMALL to LARGE. 42 8.6.1.13. 43 44 45 46 47 The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the construction and operation of PV solar installations. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. Historic and Archaeological Resources Environmental Justice 8-55 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 11 Potential impacts to minority and low-income populations would mostly consist of environmental and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects would only occur during certain hours of the day and not likely to be high and adverse and would be contained to a limited time period during certain hours of the day. Increased demand for rental housing during construction could affect low-income populations. However, given the small number of construction workers and the possibility that workers could commute to the construction site, the need for rental housing would not be significant. 12 13 14 15 Minority and low-income populations living in close proximity to the PV solar installations could be disproportionately affected by operations. However, operational impacts would mostly be limited to aesthetic effects. The general public living near the PV solar installation would also be exposed to the same effects. 16 17 18 19 Based on this information and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of PV solar installations would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations. 20 8.6.1.14. 21 22 23 24 During the construction stage of a solar PV facility, land clearing and other construction activities would produce minor quantities of waste. During operation, very small quantities of waste might be produced when operators perform maintenance activities. Based on this information, waste impacts would be SMALL for the solar PV alternative. 25 26 Waste Management Table 8-7. Summary of Environmental Impacts of the Solar PV Alternative Compared to Continued Operation of the Existing LGS Solar PV Alternative Continued LGS Operation Air Quality SMALL SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to LARGE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics MODERATE to LARGE SMALL Historic and Archaeological SMALL to LARGE SMALL Waste Management SMALL SMALL (a) (a) As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS 8-56 Environmental Impacts of Alternatives 1 8.6.2. Combination Alternative: Wind, Solar, and NGCC 2 3 4 5 6 7 8 9 10 11 12 13 14 15 The combination alternative consists of 2,300 MW(e) of installed wind capacity, 3,000 MW(e) of solar PV capacity, and 400 MW(e) of NGCC capacity to provide the balance needed to replace LGS. The impacts of this alternative are similar to the combined and scaled impacts of the NGCC, wind, and solar PV alternatives considered in Sections 8.1, 8.4, and 8.6.1, respectively. The staff assumes that sufficient rooftop space exists throughout PJM to support installation of the solar-PV portion of this alternative solely on existing structures, thus minimizing potential for land-use and terrestrial ecology impacts from solar PV installations. The staff applied a capacity-factor-based approach to determining the relative amount of wind power (much as it did in Section 8.4), and applied a capacity-credit approach to solar-PV capacity (using PJM's 38 percent capacity credit) in this alternative. The NGCC capacity considered here provides backup and firming capacity to the variable wind and solar PV resources, though it may not be adequate to provide full firming capacity at all times (e.g., on nights with little wind across PJM). At the same time, this alternative may produce markedly more power than LGS on days that are both sunny and windy. 16 17 18 19 20 Because this alternative many not be able to generate 2,340 MW(e) because of the variable wind and solar PV resources, the staff does not consider the wind, solar, and NGCC combination alternative to provide a viable, standalone alternative to license renewal. The staff considers a standalone alternative here, however, because Exelon includes a wind, solar, and NGCC combination alternative in its range of alternatives to LGS license renewal in the ER. 21 22 Table 8-8 summarizes the environmental impacts of the combination alternative compared to the continued operation of LGS. 23 8.6.2.1. Air Quality 24 25 26 27 28 29 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, Pennsylvania, and is part of the Metropolitan Philadelphia Interstate Air Quality Control Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 30 31 32 33 34 35 36 This alternative includes a combination of generation from wind, solar, and NGCC capacity. Operational air emissions would only be associated with the NGCC portion (400 MW[e]) of this alternative. The NGCC component would qualify as a new major-emitting industrial facility and would be subject to PSD under CAA requirements (EPA 2012a). The Pennsylvania Department of Environmental Protection (PADEP) has adopted 25 Pa. Code Chapter 127, which implements the EPA's PSD review. The NGCC plant would need to comply with the standards of performance for stationary combustion turbines set forth in 40 CFR Part 60 Subpart KKKK. 37 38 39 40 41 42 43 44 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, including the review of the new sources that may affect visibility in any Federal Class I area. If the NGCC component of this combination alternative were located close to a mandatory Class I area, additional air pollution control requirements would be required. As noted in Section 2.2.2.1, there are no Mandatory Class I Federal areas within 50 miles (80 km) of the LGS site. There are a total of 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 45 46 47 A new NGCC plant would have to comply with Title IV of the CAA (42 USC ?7651) reduction requirements for SO2 and NOx, which are the main precursors of acid rain and the major cause of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the 8-57 Environmental Impacts of Alternatives 1 2 existing plants and a system of SO2 emission allowances that can be used, sold, or saved for future use by the new plants. 3 4 5 6 7 8 More recently, EPA has promulgated additional rules and requirements that apply to certain fossil-fueled power plants, such as NGCC generation. The Cross-State Air Pollution Rule (CSAPR) and the Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) Tailoring Rule impose several additional standards to limit ozone, particulate, and GHG emissions from fossil-fuel based power plants (EPA 2012c). A new NGCC plant would be subject to these additional rules and regulations. 9 10 11 The EPA has developed standard emission factors that relate the quantity of released air pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the staff projects the following air emissions for the NGCC portion of this alternative: 12 13 14 15 16 o o o o o sulfur oxides (SOx) - 31.4 tons (28.5 MT) per year, nitrogen oxides (NOx) - 91.5 tons (83.0 MT) per year, carbon monoxide (CO) - 138.7 tons (125.8 MT) per year, PM10 and PM2.5 - 61.0 tons (55.4 MT) per year, and carbon dioxide (CO2) - 1,016,100 tons (922,622 MT) per year. 17 18 19 20 21 22 23 Activities associated with the construction of the combination alternative, which includes wind, solar, and NGCC, would cause some additional, temporary air effects as a result of equipment emissions and fugitive dust from operation of the earth-moving and material-handling equipment. Emissions from workers' vehicles and motorized construction equipment exhaust would be temporary. Construction crews would use dust-control practices to control and reduce fugitive dust. The staff concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of the earth-moving and material-handling equipment would be SMALL. 24 Greenhouse Gas Emissions 25 26 27 28 As discussed in Sections 8.1.1 and 8.2.1, combustion of fossil fuels, including natural gas, is the greatest anthropogenic source of GHG emissions in the United States. As noted in Sections 8.4.1 and 8.6.1.1--and discussed in Section 6.2--wind power and solar PV generation are among the least GHG-intensive generation options available. 29 30 31 32 Greenhouse gas emissions during construction of this alternative would result primarily from the consumption of fossil fuels in the engines of construction vehicles and equipment, workforce vehicles used in commuting to and from the work site, and delivery vehicles. However, all such impacts would be temporary. 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Only the NGCC portion of this alternative would emit GHGs during operations, and it would emit approximately 25 percent of the emissions of the full NGCC alternative that the staff evaluated in Section 8.1.1. As discussed in Section 8.1.1, NETL estimates that CCS will capture and remove as much as 90 percent of the CO2 from the exhausts of combustion turbines but will result in a power production capacity decrease of approximately 14 percent, a reduction in net overall thermal efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a potential increase in the levelized cost of electricity produced in NGCC units so equipped by as much as 30 percent (NETL 2007). Further, permanent sequestering of the CO2 would involve removing impurities (including water) and pressurizing it to meet pipeline specifications and transferring the gas by pipeline to acceptable geologic formations. Even when opportunities exist to utilize the CO2 for enhanced oil recovery (rather than simply dispose of the CO2 in geologic formations), permanent disposal costs could be substantial, especially if the NGCC unit is far removed from acceptable geologic formations. With CCS in place, the NGCC portion of this alternative would release 92,262 MT per year (0.102 million tons) of CO2. Without CCS in place, 8-58 Environmental Impacts of Alternatives 1 2 the staff's projected CO2 emissions for the NGCC portion would be 922,622 MT (1,016,100 tons) per year. 3 4 5 6 Given the expected relatively small workforces, relatively short construction period for constructing the alternatives' components, and GHG emissions resulting from operations of the NGCC portion, the overall from the releases of GHGs of the combination alternative would be SMALL to MODERATE. 7 Conclusion 8 9 10 11 There would be no routine air emissions associated with the wind and solar component of this alternative. However, the NGCC component of this alternative would result in routine air emissions. Therefore, the overall air-quality impact from this combination alternative would be SMALL to MODERATE. 12 8.6.2.2. Groundwater Resources 13 14 15 16 17 18 19 20 Impacts on groundwater resources from constructing and operating a new NGCC plant under this alternative would be a fraction of those described in Section 8.1.2. For construction of wind turbine and solar PV installations, the need for groundwater dewatering likely would be minimal. For all construction activities, appropriate BMPs, including spill prevention practices, would be used during wind turbine construction to prevent or minimize impacts on groundwater quality. Operation of the wind turbine and PV components of this alternative would not be expected to have any appreciable effect on groundwater resources. Based on the above, the impacts on groundwater use and quality under this alternative would be SMALL. 21 8.6.2.3. Surface Water Resources 22 23 24 25 26 27 28 29 Impacts on surface water resources from constructing and operating a new NGCC plant under this alternative would be a fraction of those described in Section 8.1.3 because the NGCC component has been scaled back to 400 MW(e). Construction of the wind turbine and solar PV installations would each require relatively small amounts of water for dust suppression and soil compaction during site clearing and for concrete production. The NRC assumes that required water would be procured from offsite sources and trucked to the point of use on an as needed basis. Use of ready-mix concrete would also reduce the need for onsite use of nearby water sources. 30 31 32 33 34 35 36 37 To support operation of individual wind turbine installations, only very small amounts of water would be needed to periodically clean turbine blades and motors as part of routine servicing. Water also would be required to clean PV panels. The staff expects that water would be trucked to the point of use and procured from nearby sources. Adherence to appropriate waste management and minimization plans, spill prevention practices, and pollution prevention plans during servicing of turbine and PV installations would minimize the risks to soils and surface water resources from spills of petroleum, oil, and lubricant products and runoff. As a result, the impacts on surface water use and quality under the combination alternative would be SMALL. 38 8.6.2.4. Aquatic Resources 39 40 41 42 43 44 45 46 Construction activities for the wind, solar, and NGCC combination alternative (such as construction of heavy-haul roads, the NGCC power block, wind turbines, and solar panels) could affect drainage areas or other onsite aquatic features. Minimal impacts on aquatic ecology resources are expected because BMPs would likely be used to minimize erosion and sedimentation. Stormwater control measures, which would be required to comply with Pennsylvania NPDES permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the available infrastructure at the selected site, the NGCC plant may require modification or expansion of the existing intake or discharge structures. Because of the 8-59 Environmental Impacts of Alternatives 1 2 3 4 5 6 relatively low withdrawal rates compared to the NGCC, SCPC, or new nuclear alternatives, it is unlikely that the operators would need to construct new intake and discharge structures for the combination alternative. Dredging activities that result from infrastructure construction would require BMPs for in-water work to minimize sedimentation and erosion. Because of the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would likely be localized and temporary. 7 8 9 10 11 12 13 Similar to the NGCC alternative described in Section 8.1.4, during operations, the NGCC component of the combination alternative would require cooling water to be withdrawn from the Schuylkill River or other similar water body, would have chemical discharges, and would emit some pollutants that could settle onto the river surface. However, these impacts would be less than that described in Section 8.1.4 because NGCC would be a smaller portion of this alternative. During operations, the solar PV and wind components of the combination alternative would not require consumptive water use. 14 15 16 17 The impacts on aquatic ecology would be minor because construction activities would require BMPs and stormwater management permits, and because the surface water withdrawal and discharge for this alternative would be less than for LGS Units 1 and 2. Therefore, the staff concluded that impacts on aquatic ecology would be SMALL. 18 19 20 21 22 23 24 25 26 27 Consultation with NMFS and FWS under ESA would ensure that the construction and operation of wind, solar, NGCC plants would not adversely affect any Federally listed species or adversely modify or destroy designated critical habitat. If new infrastructure were located near EFH, consultation with NMFS under the Magnuson-Stevens Act would require NRC to evaluate impacts to EFH and NMFS would provide conservation recommendations if there would be adverse impacts to EFH. Coordination with state natural resource agencies would further ensure that the plant and wind farm operators would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation on protected species and habitats would be SMALL. 28 8.6.2.5. Terrestrial Resources 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Impacts to terrestrial species and habitats from construction and operation of this combined alternative would be similar to those described under each individual alternative in Sections 8.1.5, 8.4.5, and 8.6.1.5. The same is true of mitigation measures. The primary difference in this alternative is that each portion of this alternative is smaller than the full-replacement alternatives considered in Sections 8.1, 8.4, and 8.8.1. Also, solar PV capacity would be installed almost entirely at already-developed sites on building rooftops. The wind-power portion of this alternative would require approximately half of the area required for the standalone wind alternative in Section 8.4. The development of the solar component on land already in use for other purposes, combined with the reduced size of the wind-power component, would likely result in minimal additional impacts to terrestrial species and habitats during construction and operation. The NGCC component of this alternative would be smaller and require less land than the NGCC plant described in Section 8.1.5. This alternative still assumes that the NGCC plant would be sited on an already existing power station other than LGS, and predominantly previously developed or pre-disturbed land would be affected. The impacts of construction and operation of this alternative on terrestrial species and habitats would be SMALL because of this alternative's extensive use of developed or previously disturbed land. 46 47 48 Because the solar PV installations would be sited on buildings and other already-developed sites, impacts to protected species and habitats would be most likely to occur as a result of the wind or NGCC component of this alternative. As with the previously discussed alternatives, 8-60 Environmental Impacts of Alternatives 1 2 3 4 5 6 consultation with FWS under the ESA would avoid potential adverse impacts to Federally listed species or adverse modification or destruction of designated critical habitat. Coordination with state natural resource agencies would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of this alternative on protected species and habitats would be SMALL. 7 8.6.2.6. Human Health 8 9 10 11 12 13 14 Impacts on human health from construction of the wind alternative, the NGCC alternative, and the solar PV portion of this alternative would be similar to impacts associated with the construction of any major industrial facility. Compliance with worker protection rules would control those impacts on workers at acceptable levels. Impacts from construction on the general public would be minimal since limiting active construction area access to authorized individuals is expected. Impacts on human health from the construction of the wind alternative would be SMALL. 15 16 17 Given proper health-based regulation through procedures and access limitations, the staff expects human health impacts from operation of the solar PV and the wind portions of this alternative at an alternate site to be SMALL. 18 19 20 21 22 23 24 25 26 The staff notes that human health effects of gas-fired generation are generally low, although in Table 8-2 of the GEIS (NRC 1996), the staff identified cancer and emphysema as potential health risks from gas-fired plants. NOx emissions contribute to ozone formation, which in turn contributes to human health risks. Emission controls on the NGCC alternative can be expected to maintain NOx emissions well below air quality standards established for the purposes of protecting human health, and emissions trading or offset requirements mean that overall NOx releases in the region will not increase. Health risks for workers may also result from handling spent catalysts used for NOx control that may contain heavy metals. Impacts on human health from the operation of the NGCC alternative would be SMALL. 27 8.6.2.7. Land Use 28 29 30 31 32 As discussed in Section 8.1.7, the GEIS (NRC 1996) generically discusses the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each power plant site. The analysis of land-use impacts here focuses on the amount of land area that would be affected by the construction and operation of a combination of wind turbines, PV solar installations, and a NGCC power plant in the PJM territory. 33 34 35 36 37 38 39 40 Land-use impacts from this alternative would be similar those described for each of the alternatives described in Sections 8.1.7, 8.4.7, and 8.6.1.7. Because each component of this alternative would individually be generating less electricity, the magnitude of the impacts from each individual component would be less than those previously described. For example, under this combination alternative, solar PV technology would be installed on existing building rooftops, and approximately half the number of wind turbines would be installed as would be installed in the standalone wind alternative (Section 8.4). In addition, the NGCC component would be constructed at an existing power plant site. 41 42 43 44 45 The elimination of uranium fuel for the LGS would partially offset some, but not all, new land requirements. Scaling from GEIS estimates, approximately 1,640 ac (660 ha) would no longer be needed for mining and processing uranium during the operating life of the plant. Based on this information, overall land-use impacts from the construction and operation of a combination of wind, solar, and NGCC alternatives would range from SMALL to MODERATE. 8-61 Environmental Impacts of Alternatives 1 8.6.2.8. Socioeconomics 2 3 4 5 6 7 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of a combination of wind turbines, PV solar installations, and a NGCC power plant were evaluated in order to measure their possible effects on current socioeconomic conditions. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Approximately 200 construction and 50 operations workers would be required for the utility scale wind alternative and 200 construction and 50 operations workers would be required for the solar alternative (see Sections 8.4.8, and 8.6.1.8) (Exelon 2011). These estimates appear reasonable and in line with current construction and operational trends. The construction and operation workforce requirements for these two components of this combination alternative would be much less. The NGCC component scaled down to 400 MW(e) would require 150 (Exelon 2011) to 500 (NRC 1996) construction workers during peak construction and 8 to 60 operations workers. Socioeconomic impacts would be similar to those described for NGCC, wind, and solar alternatives discussed in Sections 8.1.8, 8.4.8, and 8.6.1.8, but on a smaller scale than each of the full alternatives. Because of the relatively small number of construction workers scattered over a large area at various locations, the relative economic impact of this many workers on local communities and the tax base would be SMALL. Given the small number of operations workers, socioeconomic impacts associated with operation of the NGCC, wind, and solar components of this combination alternative would also be SMALL. 22 23 24 25 26 27 The net reduction in employment at LGS could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the region. Nevertheless, the amount of property taxes paid under the combination alternative may offset lost tax revenues in the socioeconomic region around LGS. Based on this information, socioeconomic impacts during operations could range from SMALL to MODERATE. 28 8.6.2.9. Transportation 29 30 31 32 33 34 35 Transportation impacts during the construction and operation of the NGCC, wind, and solar components of this combination alternative would be less than the impacts for the NGCC, wind, and PV solar alternatives, discussed in Sections 8.1.7, 8.4.7, and 8.6.1.7. This is because the construction workforce for each component and the volume of materials and equipment needing to be transported to each respective construction site would be smaller than each of the individual alternatives. In other words, the transportation impacts would not be as concentrated as in the other alternatives, but spread out over a wider area. 36 37 38 39 40 41 42 43 44 45 46 47 As previously described for each alternative, workers commuting to the construction site would arrive by site access roads and the volume of traffic on nearby roads could increase during shift changes. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Transporting heavy and oversized wind turbine components on local roads could have a noticeable impact over a large area. Some components and materials could also be delivered by train or barge, depending on location. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from SMALL to MODERATE depending on the location of the NGCC power plant, wind farm, and PV solar installation; road capacities; and traffic volumes. 8-62 Environmental Impacts of Alternatives 1 2 3 4 During operations, transportation impacts would be less noticeable during shift changes and maintenance activities. Given the small number of operations workers, the levels of service traffic impacts on local roads from NGCC power plant, wind farm, and PV solar installation operations would be SMALL. 5 8.6.2.10. Aesthetics 6 7 8 9 10 The analysis of aesthetic impacts focuses on the degree of contrast between the wind, solar, and NGCC alternative and surrounding landscapes and the visibility of new wind turbines at existing wind farms, PV solar technologies on existing buildings, and the new NGCC plant at an existing power plant site. In general, aesthetic changes would be limited to the immediate vicinity of the wind farms, PV solar installations, and NGCC power plant. 11 12 13 14 15 16 17 Wind turbines would have the greatest potential visual impact. At 400 ft (122 m) tall (Exelon 2011) and spread across multiple sites, wind turbines often dominate the view and become the major focus of attention. However, adding additional wind turbines to existing wind farms at multiple sites is not likely to increase the visible impact of the wind farm unless it significantly increases the number of wind turbines at the wind farm. PV solar technologies located on building rooftops, depending on the angle of the roof, may or may not be seen offsite, and would be less noticeable in urban settings. 18 19 20 21 22 23 24 25 26 27 Located near an existing power plant site, the NGCC power plant could be approximately 100 ft (30 m) tall, with an exhaust stack up to 150 ft (46 m) tall and have two cooling towers over 500 ft (152 m) high (Exelon 2011). The facility would be visible off site during daylight hours, and some structures may require aircraft warning lights. The power block of the new NGCC power plant unit could look very similar to the existing power plant at the site where it would be constructed. The addition of mechanical draft cooling towers and associated condensate plumes could add to the NGCC power plant visual impact. Mechanical draft cooling towers also generate noise. Most other noises during power NGCC plant operations would be limited to industrial processes and communications. Pipelines delivering natural gas fuel could be audible off site near gas compressor stations. 28 29 30 Based on this information, aesthetic changes caused by this combination alternative would be limited to the immediate vicinity of the existing facilities and would therefore be SMALL to MODERATE depending on location and surroundings. 31 8.6.2.11. 32 33 34 35 36 37 38 39 40 41 42 Areas potentially affected by the construction of the NGCC, wind, and solar PV alternative would need to be surveyed to identify and record historic and archaeological resources. Any resources found in these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse effects would need to be addressed if eligible resources were encountered. An inventory of a previously disturbed former plant (brownfield) site may still be necessary if the site has not been previously surveyed or to verify the level of disturbance and evaluate the potential for intact subsurface resources. Plant operators would need to survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, other ROWs). Areas with the greatest sensitivity should be avoided. Visual impacts on significant cultural resources--such as the viewsheds of historic properties near the sites--should also be assessed. 43 44 45 46 47 The impacts of this alternative are similar to the combined and scaled impacts of the NGCC, wind, and solar PV alternatives considered in Sections 8.1, 8.4, and 8.6.1, respectively. The potential for impacts would vary greatly depending on the location of the proposed sites. Use of a previously disturbed site for the NGCC alternative and rooftop PV technology could minimize affects to historic and archaeological resources. Wind turbines could be installed in Historic and Archaeological Resources 8-63 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 pre-established wind farms. Areas with the greatest sensitivity could be avoided or effectively managed under current laws and regulations. However, construction of wind farms sites and their support infrastructure on developed sites, agricultural areas, or previously undisturbed have the potential to notably impact historic and archaeological resources because of earthmoving activities (e.g., grading and digging). Aesthetic changes from wind farms and solar technology may also impact the viewshed of historic properties located nearby. Therefore, depending on the resource richness of the site chosen for the NGCC, wind, and solar PV alternative, the impacts could range from SMALL to MODERATE. 9 8.6.2.12. Environmental Justice 10 11 12 13 14 15 The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the construction and operation of a combination of wind turbines, PV solar installations, and a NGCC power plant. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. 16 17 18 19 20 21 22 23 24 25 26 Potential impacts to minority and low-income populations would mostly consist of environmental and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects are not likely to be high and adverse and would be contained to a limited time period during certain hours of the day. During construction, increased demand for rental housing in the vicinity of the site could affect low-income populations living near the plant site. However, given the small number of construction workers and the possibility that workers could commute to the construction site, the need for rental housing would not be significant. 27 28 29 30 31 32 33 Minority and low-income populations living in close proximity to the power generating facilities could be disproportionately affected by wind farm, PV solar, and NGCC power plant operations. However, all would be exposed to the same potential effects from operations, and any effects would depend on the magnitude of the change in ambient conditions. Operational impacts from the wind turbines and PV solar installations would mostly be limited to noise and aesthetic effects. The general public living near the wind farms and PV solar installations would be exposed to the same effects. 34 35 36 37 Based on this information and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of new wind turbines, PV solar installations, and a NGCC power plant would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations. 38 8.6.2.13. 39 40 41 42 43 44 During the construction stage of this combination of alternatives (wind, solar, and NGCC), land clearing and other construction activities would generate wastes that could be recycled, disposed of on site, or shipped to the offsite waste disposal facility. During the operational stage, spent SCR catalysts, which control NOx emissions from the NGCC plant, would make up the majority of the waste generated by this alternative, along with some wastes generated during maintenance for the wind and solar operations. 45 46 47 The staff concludes that overall waste impacts from the combination of the NGCC unit constructed on an existing site, and renewable energy components such as wind and solar, would be SMALL. Waste Management 8-64 Environmental Impacts of Alternatives 1 2 Table 8-8. Summary of Environmental Impacts of the Combination Alternative Compared to Continued Operation of the Existing LGS Combination Alternative Continued Operation of LGS Air Quality SMALL to MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics SMALL to MODERATE SMALL Historic and Archaeological SMALL to MODERATE SMALL Waste Management SMALL SMALL (a) 3 (a) As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 8.6.3. Combination Alternative: Wind and Compressed Air Energy Storage 4 5 6 7 8 9 10 In compressed air energy storage (CAES), an electric motor uses electricity to pump air into an underground, pressurized cavity, and when electricity is needed, the operator releases the compressed air through a gas turbine generator. The compressed air provides some power to the generator (essentially, reducing the need for compression by the turbine), and burning natural gas provides heat to increase pressure and to power the turbine. Thus, CAES is not solely an energy storage technology, but also relies on additional fossil fuel (future, as-yet-undeveloped CAES technologies promise no reliance on natural gas). 11 12 13 CAES is a commercially viable technology for energy storage, though it is seldom-used on a utility scale. It is in use at one site in the United States and one site in Germany (with capacities of 110 MW[e] and 290 MW[e], respectively). 14 15 16 17 18 19 20 21 Currently, no state or utility in the United States is operating wind power in combination with compressed air energy storage, let alone doing so to offset baseload power supplies. A group of utilities had proposed a 270-MW(e) project of that type in Iowa but have since terminated the project because of geologic unsuitability of the proposed site (ISEPA 2011). The McIntosh facility in Alabama is the only existing U.S. compressed air energy storage installation; it provides peaking capacity to existing non-wind generation, and it is relatively small. It provides 110 MW(e) of power for up to 26 hours. The McIntosh facility and Germany's Huntorf facility are both based in salt domes. 22 23 24 25 Currently, no compressed air energy storage facilities exist in PJM. In Ohio, First Energy has acquired the Norton Energy Storage project, a proposed CAES facility that could be constructed in a retired limestone mine. The First Energy Nuclear Operating Company (FENOC) indicates that the Norton Energy Storage facility could have a maximum of 536 MW(e) of capacity 8-65 Environmental Impacts of Alternatives 1 2 3 4 5 6 available by 2017 (though it has not committed to install this capacity in that time period) and that it has an air permit for up to 804 MW(e) of capacity that the site (FENOC 2011). FENOC indicates that the maximum potential storage capacity at the Norton Energy Storage project is 2,700 MW(e) (FENOC 2011). However, the NRC is not aware of a CAES project coupled with wind generation that is providing baseload power. Therefore, the NRC concludes that the use of CAES in combination with wind turbines to generate 2,340 MW(e) in PMJ is unlikely. 7 8 9 10 11 Because the use of CAES in combination with wind turbines to generate 2,340 MW(e) in PMJ is unlikely, the staff does not consider CAES in combination with wind to provide a viable, standalone alternative to license renewal. The staff considers a standalone alternative here, however, because Exelon includes a CAES and wind combination alternative in its range of alternatives to LGS license renewal in the ER. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 This section analyzes the potential impacts from a CAES and wind combination alternative. NREL (2006) suggests that 2,000 MW(e) of wind power together with 900 MW(e) of CAES can provide a near-constant 900 MW(e) of output. Using the high capacity factors the staff applied to the windpower alternative in Section 8.4 (which exceeds current wind capacity factors), this alternative relies on 2,000 MW(e) of CAES capacity from a facility similar in operation to the Norton project and 4,500 MW(e) of onshore wind capacity. While the approach in NREL (2006) suggests that 2,340 MW(e) of CAES may be necessary to provide firming capacity that would provide similar baseload potential as that provided by LGS, this alternative underestimates the amount of CAES capacity necessary to provide for technological advances and avoid overstating the potential impacts from relying on a combination of wind and CAES. In general, the staff relies on information from the Norton project to describe the potential impacts of a CAES project, though the staff notes that projects at different sites may incur varying levels of environmental impacts. Where appropriate, the staff scales impacts from the Norton project to account for the size of the CAES project considered here. 26 27 Table 8-9 summarizes the environmental impacts of the wind and CAES alternative compared to the continued operation of LGS. 28 8.6.3.1. Air Quality 29 30 31 32 33 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, Pennsylvania, and is part of the Metropolitan Philadelphia Interstate Air Quality Control Region AQCR (40 CFR 81.15). With regard to the NAAQS, EPA has designated Montgomery and Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 34 35 36 37 38 39 40 This alternative relies on CAES to store electricity produced by wind turbines, which is then released during periods of low wind production. CAES facilities burn natural gas to heat the compressed air; therefore, they produce air emissions. The CAES facility would qualify as a new major-emitting industrial facility and would be subject to PSD under CAA requirements (EPA 2012). The PADEP has adopted 25 Pa. Code Chapter 127, which implements the EPA's PSD review. The CAES plant would need to comply with the standards of performance for stationary combustion turbines set forth in 40 CFR Part 60 Subpart KKKK. 41 42 43 44 45 46 47 Subpart P of 40 CFR Part 51.307 contains visibility protection regulatory requirements, including the review of the new sources that may affect visibility in any Federal Class I area. If the CAES component of this combination alternative were located close to a mandatory Class I area, additional air pollution control requirements would be required. As noted in Section 2.2.2.1, there are no Mandatory Class I Federal areas within 50 miles of the LGS site. There are a total of 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 8-66 Environmental Impacts of Alternatives 1 2 3 4 5 A new CAES facility would have to comply with Title IV of the CAA (42 USC ?7651) reduction requirements for SO2 and NOx, which are the main precursors of acid rain and the major cause of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the existing plants and a system of SO2 emission allowances that can be used, sold, or saved for future use by the new plants. 6 7 8 9 10 11 More recently, the EPA has promulgated additional rules and requirements that apply to certain fossil-fuel based power plants, such as the CAES portion of this alternative. The CSAPR and the Prevention of Significant Deterioration and Title V GHG Tailoring Rule impose several additional standards to limit ozone, particulate, and GHG emissions from fossil-fuel based power plants (EPA 2012c). A new CAES plant would be subject to these additional rules and regulations. 12 13 14 15 16 Air emission permits from the Norton CAES Project in Norton, Ohio, were used as a basis for estimating emissions for this alternative. The current Norton air emissions permit allows 804 MW(e), so the staff scales the values from the Norton CAES project to 2,000 MW(e) to determine air quality impacts associated with this alternative. The staff projects the following air emissions for the CAES alternative: 17 18 19 20 21 o o o o o sulfur oxides (SOx) - 105.5 tons (96.2 MT) per year, nitrogen oxides (NOx) - 233.0 tons (212.4 MT) per year, carbon monoxide (CO) - 224.8 tons (204.9 MT) per year, PM10 and PM2.5 - 116.0 tons (105.8 MT) per year, and carbon dioxide (CO2) - 1,694,279 tons (1,544,735 MT) per year. 22 23 24 25 26 27 28 Activities associated with the construction of the CAES alternative would cause some additional, temporary air effects as a result of equipment emissions and fugitive dust from operation of the earth-moving and material-handling equipment. Emissions from workers' vehicles and motorized construction equipment exhaust would be temporary. Construction crews could use dust-control practices to control and reduce fugitive dust. The staff concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of the earth-moving and material-handling equipment would be SMALL. 29 Greenhouse Gas Emissions 30 31 32 33 Greenhouse gas emissions during construction of this alternative would result primarily from the consumption of fossil fuels in the engines of construction vehicles and equipment, workforce vehicles used in commuting to and from the work site, and delivery vehicles. However, all such impacts would be temporary. 34 35 36 37 Greenhouse gas emissions during operation would primarily be from natural gas combustion in the combustion turbines (at both the NGCC facility and the CAES facility). However, other miscellaneous ancillary sources such as truck and rail deliveries of materials to the site and commuting of the workforce would make minor contributions. 38 39 40 41 42 43 44 45 46 47 NETL estimates that CCS will capture and remove as much as 90 percent of the CO2 from the exhausts of combustion turbines, but will result in a power production capacity decrease of approximately 14 percent, a reduction in net overall thermal efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a potential increase in the levelized cost of electricity produced in NGCC units so equipped by as much as 30 percent (NETL 2007). Further, permanent sequestering of the CO2 would involve removing impurities (including water) and pressurizing it to meet pipeline specifications and transferring the gas by pipeline to acceptable geologic formations. Even when opportunities exist to utilize the CO2 for enhanced oil recovery (rather than simply dispose of the CO2 in geologic formations), permanent disposal costs could be substantial, especially if the combustion turbines are far removed from acceptable geologic 8-67 Environmental Impacts of Alternatives 1 2 3 formations. With CCS in place, the CAES alternative would release 0.154 million MT per year (0.169 million tons) of CO2. Without CCS in place, the CAES alternative would release 1.54 million MT (1.69 million tons) of CO2 per year 4 5 6 Given the temporary impacts during the construction period and GHG emissions resulting from operations, the overall from the releases of GHGs of the CAES alternative would be SMALL to MODERATE. 7 Conclusion 8 9 The overall air quality impacts from CAES alternative would be similar to those of an NGCC facility and would be designated as SMALL to MODERATE. 10 8.6.3.2. Groundwater Resources 11 12 13 14 15 16 17 18 19 Impacts on groundwater resources of constructing and operating wind turbine installations under this alternative would be similar to those described in Section 8.4.2. Similarly, for construction and operation of the CAES facility, it is expected that overall impacts would be similar to and would be bounded by those described for the NGCC alternative (see Section 8.1.2) because construction and operations of the two facilities would be relatively similar, although the NGCC plant would be larger than the CAES facility. As an additional impact, pressurization of an underground cavity associated with CAES operations could affect groundwater flow on a localized basis. However, overall impacts on groundwater use and quality under this alternative would be SMALL. 20 8.6.3.3. Surface Water Resources 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Impacts on surface water resources of constructing and operating wind turbine installations under this alternative would be similar to those described in Section 8.4.3. For construction and operation of the CAES facility, it is expected that overall impacts on surface water would be similar to and would be bounded by those described for the NGCC alternative (see Section 8.1.3). The nature of potential surface water impacts of CAES would depend on the type of CAES reservoir. For CAES using hard rock caverns, makeup water would be required because of evaporation from the surface reservoir and some potential for leakage. With these systems, as well as with porous rock reservoirs, there is generally a provision for pumping of water into the caprock or zones above the caprock to ensure hydraulic overpressure that would counter the potential for air leakage. In general, however, the potential for effects from caprock overpressure requirements would be smaller than the makeup water required for cooling. As a result, the projected cooling water demands would be smaller than the requirement presented in Section 8.1.3 for the NGCC alternative; the demands would relate primarily to removing waste heat from compression of the stored air. In conclusion, the overall impacts on surface water use and quality under this alternative would be SMALL. 36 8.6.3.4. Aquatic Resources 37 38 39 40 41 42 43 44 45 46 Construction activities for the wind and CAES alternative (such as construction of heavy-haul roads, the wind turbines, and CAES facility) could affect drainage areas and other onsite aquatic features. Minimal impacts on aquatic ecology resources are expected as the plant operator would likely implement BMPs to minimize erosion and sedimentation elsewhere on the site. Stormwater control measures, which would be required to comply with Pennsylvania NPDES permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the available infrastructure at the selected site, the CAES facility may require modification or expansion of the existing intake or discharge structures. Because of the relatively low withdrawal rates compared to the NGCC, SCPC, or new nuclear alternatives, it is unlikely that the operators would need to construct new intake and discharge structures. Dredging activities 8-68 Environmental Impacts of Alternatives 1 2 3 that result from infrastructure construction would require BMPs for in-water work to minimize sedimentation and erosion. Because of the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would likely be localized and temporary. 4 5 6 7 8 During operations, the CAES alternative would require less cooling water to be withdrawn from the Schuylkill River, or other similar water body, than required for LGS Units 1 and 2. In addition, the cooling system for a CAES plant would have similar chemical discharges as LGS. The flow of the Schuylkill River, or other similar waterbody, would likely dissipate and dilute the concentration of pollutants resulting in minimal exposure to aquatic biota. 9 10 11 12 The impacts on aquatic ecology would be minor because construction activities would require BMPs and stormwater management permits, and because the surface water withdrawal and discharge for this alternative would be less than for LGS Units 1 and 2. Therefore, the staff concluded that impacts on aquatic ecology would be SMALL. 13 14 15 16 17 18 19 20 21 22 Consultation with NMFS and FWS under ESA would ensure that the construction and operation of wind farms and CAES facility would not adversely affect any Federally listed species or adversely modify or destroy designated critical habitat. If new infrastructure were located near EFH, consultation with NMFS under the Magnuson-Stevens Act would require NRC to evaluate impacts to EFH and NMFS would provide conservation recommendations if there would be adverse impacts to EFH. Coordination with state natural resource agencies would further ensure that the CAES and wind farm operators would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation on protected species and habitats would be SMALL. 23 8.6.3.5. Terrestrial Resources 24 25 26 27 28 29 30 31 Impacts to terrestrial species and habitats from construction and operation of this combined alternative would be similar in type, magnitude, and intensity as those described in Section 8.4.5 for the wind alternative. The primary difference in impact would result from the additional 92 ac (37 ha) required for the CAES facility. Impacts resulting from the CAES facility would vary depending on the site of the facility, but would generally not contribute considerably more impacts than the wind component because of the wind component's large land area requirements. Consequently, the impacts of construction and operation of this alternative to terrestrial habitats and species could range from SMALL to MODERATE. 32 33 34 35 36 37 38 As with the previously discussed alternatives, consultation with FWS under the ESA would avoid potential adverse impacts to Federally listed species or adverse modification or destruction of designated critical habitat. Coordination with state natural resource agencies would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other protected species and habitats. Consequently, the impacts of construction and operation of a wind and CAES alternative on protected species and habitats would be SMALL. 39 8.6.3.6. Human Health 40 41 42 43 44 45 CAES is a process by which air is compressed and forced into a holding area (like a large underground cavern) for later use in powering a gas turbine. Construction impacts of a CAES facility would be similar to impacts associated with the construction of any major industrial facility. Although constructing an energy facility with and near a suitable holding area (like a large underground cavern) would pose some unique challenges, proper regulation through state and Federal agencies would ensure that human health impacts are minimized. 8-69 Environmental Impacts of Alternatives 1 2 3 4 5 6 Impacts on human health from construction of the wind alternative would be similar to impacts associated with the construction of any major industrial facility. Compliance with worker protection rules would control those impacts on workers at acceptable levels. Impacts from construction on the general public would be minimal since limiting active construction area access to authorized individuals is expected. Impacts on human health from the construction of the wind alternative would be SMALL. 7 8 9 Given proper health-based regulation through procedures and access limitations, the staff expects human health impacts from operation of the CAES and the wind alternative at an alternate site to be SMALL. 10 8.6.3.7. Land Use 11 12 13 14 As discussed in Section 8.1.7, the GEIS generically discusses the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each power plant site. The analysis of land-use impacts focuses on the amount of land area that would be affected by the construction and operation of new wind turbines and CAES. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Land-use impacts from the wind turbines would be similar to the impacts described for the wind alternative (see Section 8.4.7). Most of the wind farms would be located on open agricultural cropland, which would remain largely unaffected by the presence of the wind turbines. Since wind turbines require ample spacing between one another to avoid air turbulence, the footprint of a utility scale wind farm could be quite large. Exelon estimates 3,200 ac (1,300 ha) of land would be directly affected by the placement of the wind turbines (Exelon 2011). These estimates appear reasonable based upon the size of current and proposed wind farms. Nevertheless, wind turbines would be located on multiple wind farms spread across approximately 130,000 ac (53,000 ha or 200 mi2 [520 km2]) of land. Most of this land would be temporarily affected during the installation of the turbines and the construction of support facilities, and about one-third of the land would be permanently impacted. Based on Exelon's estimates, approximately 3,200 ac (1,300 ha) of land would be needed to support the wind portion of the alternative to replace the LGS. This amount of land use would include the area directly affected by the placement of turbines. Turbines would be spread across about 200 mi2 (520 km2). Additional land would be needed for any new transmission lines to connect wind farms to the grid and for any needed access roads. 31 32 33 34 35 36 37 38 39 Delivering heavy and oversized wind turbine components would also require the construction of temporary site access roads, some of which may require a circuitous route to their destination. However, once construction is completed, many temporary access roads can be reclaimed and replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land used for equipment and material lay down areas, turbine assembly, and installation could be returned to its original state. During operations, only 5-10 percent of the total acreage within the wind farm is actually occupied by turbines, access roads, support buildings, and associated infrastructure while the remaining land area can be returned to its original condition or some other compatible use, such as farming or grazing. 40 41 42 43 44 45 Land-use impacts from the gas-fired portion of the energy recovery process associated with the CAES portion of this alternative would be similar to the impacts described for a NGCC power plant (see Section 8.1.7). Only a minor amount of land would be needed above the geologic storage formation. As a whole, construction and operation of a wind generation facility combined with the construction and operation of a CAES facility would have relatively greater impacts than the wind generation facilities alone. 46 47 The elimination of uranium fuel for LGS would partially offset some, but not all, of the land requirements for the wind farms. Scaling from GEIS estimates, approximately 1,640 ac 8-70 Environmental Impacts of Alternatives 1 2 3 (660 ha) would no longer be needed during the operating life of the wind farms and the CAES facility. Overall land-use impacts from the construction and operation of new wind farms and a CAES facility would range from MODERATE to LARGE. 4 8.6.3.8. Socioeconomics 5 6 7 8 9 10 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of a combination of wind turbines and a CAES facility were evaluated in order to measure their possible effects on current socioeconomic conditions. 11 12 13 14 15 16 17 18 19 20 21 Socioeconomic impacts from the wind turbine component would be similar to the impacts described for the wind alternative (see Section 8.4.8). Exelon estimated the wind alternative would require 200 construction and 50 operations workers (Exelon 2011). These estimates appear reasonable and in line with current construction and operational trends. Impacts from the construction and operation of the gas-fired portion of the energy recovery process associated with the CAES component would be similar to the impacts described for a NGCC power plant (see Section 8.1.8). Because of the relatively small number of construction workers at wind farms scattered over a large area at various locations, the relative economic impact of this many workers on local communities and the tax base would be SMALL. Given the small number of operations workers, socioeconomic impacts associated with operation of the wind and CAES components of this combination alternative would also be SMALL. 22 23 24 25 26 27 28 The reduction in employment at LGS could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the LGS region. However, the amount of property taxes paid by wind farms and CAES may offset lost tax revenues in the socioeconomic region around local jurisdictions if additional land is required to support this alternative. Based on this information, socioeconomic impacts during wind farm operations and CAES could range from SMALL to MODERATE. 29 8.6.3.9. Transportation 30 31 32 33 34 Transportation impacts during the construction and operation of the wind and CAES components of this combination alternative would be similar to the impacts for the NGCC and wind alternatives, discussed in Sections 8.1.7 and 8.4.7. This is because the construction workforce for each component and the volume of materials and equipment needing to be transported to each respective construction site would be the same. 35 36 37 38 39 40 41 42 43 44 45 46 As previously described for the NGCC and wind alternatives, workers commuting to the construction site would arrive by site access roads and the volume of traffic on nearby roads could increase during shift changes. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary traffic volume impacts and delays at intersections. Transporting heavy and oversized wind turbine components on local roads could have a noticeable impact over a large area. Some components and materials could also be delivered by train or barge, depending on location. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from SMALL to MODERATE depending on the location of the wind farm and CAES facility; road capacities; and traffic volumes. 8-71 Environmental Impacts of Alternatives 1 2 3 During operations, transportation impacts would be less noticeable during shift changes and maintenance activities. Given the small numbers of operations workers, traffic impacts on local roads from wind turbine and CAES facility operations would be SMALL. 4 8.6.3.10. 5 6 7 8 The analysis of aesthetic impacts focuses on the degree of contrast between the wind and CAES alternative and surrounding landscapes and the visibility of new wind turbines at existing wind farms and the new CAES facility. In general, aesthetic changes would be limited to the immediate vicinity of the wind farms and CAES facility. 9 10 11 12 13 14 15 16 Aesthetic impacts during the construction and operation of the wind and CAES components of this combination alternative would be similar to the impacts for the NGCC and wind alternatives, discussed in Sections 8.1.10 and 8.4.10. Wind turbines would have the greatest potential visual impact. At 400 ft (122 m) tall (Exelon 2011) and spread across multiple sites, wind turbines often dominate the view and become the major focus of attention. Because wind farms are generally located in rural or remote areas, the introduction of wind turbines will be in sharp contrast to the visual appearance of the surrounding environment. Placing turbines along ridgelines would maximize their visibility. Wind turbines also generate noise. 17 18 19 20 21 22 23 The new CAES facility could be sited at a previously undisturbed location. The mechanical draft cooling towers and associated condensate plumes along with the CAES facility surface structures would be the only significant visual for this part of the alternative. Mechanical draft cooling towers also generate noise. Most other noises during facility operations would be limited to industrial processes and communications. Based on this information, aesthetic impacts from the construction and operation of new wind farms and CAES facility would range from MODERATE to LARGE depending on location and surroundings. 24 8.6.3.11. 25 26 27 28 29 30 31 Any areas potentially affected by the construction of a wind and CAES alternative should be surveyed to identify and record historic and archaeological resources. Resources found in these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse effects would need to be addressed if eligible resources were encountered. Plant operators would need to survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, other ROWs). Visual impacts on significant cultural resources--such as the viewsheds of historic properties near the sites--should also be assessed. 32 33 34 35 36 37 38 39 40 The potential for impacts on historic and archaeological resources from the wind and CAES alternative would vary greatly depending on the location of the proposed sites. Areas with the greatest sensitivity could be avoided or effectively managed under current laws and regulations. However, construction of wind farms and CAES could have the potential to notably impact historic and archaeological resources because of ground disturbing activities (e.g., grading, digging an underground geologic repository). Aesthetic changes caused by the installation of wind turbines could also have a noticeable effect on the viewshed of nearby historic properties. Therefore, depending on the resource richness of the site chosen for the wind farm and CAES alternative, the impacts could range from SMALL to LARGE. 41 8.6.3.12. 42 43 44 45 The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the installation and operation of wind turbines and a CAES facility. As previously discussed in Section 8.1.12, such effects may include human health, Aesthetics Historic and Archaeological Resources Environmental Justice 8-72 Environmental Impacts of Alternatives 1 2 biological, cultural, economic, or social impacts. Some of these potential effects have been identified in resource areas discussed in this SEIS. 3 4 5 6 7 8 9 10 11 12 13 Potential impacts to minority and low-income populations would mostly consist of environmental and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects would only occur during certain hours of the day and are not likely to be high and adverse and would be contained to a limited time period during certain hours of the day. During construction, increased demand for rental housing in the vicinity of the site could affect low-income populations living near the alternatives. However, given the small number of construction workers and the possibility that workers could commute to the construction site, the need for rental housing would not be significant. 14 15 16 17 Minority and low-income populations living in close proximity to the wind farms and CAES facility could be disproportionately affected by operations. However, operational impacts would mostly be limited to noise and aesthetic effects. The general public living near the wind farms and CAES facility would also be exposed to the same effects. 18 19 20 21 Based on this information and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of new wind turbines and a CAES facility would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations. 22 8.6.3.13. 23 24 25 26 During the construction stage of the combination of wind and CAES alternative, land clearing and excavation, and other construction activities would generate wastes that could be recycled, disposed of on site, or shipped to the offsite waste disposal facility. During the operational stage, the wind and CAES alternative might generate minor amounts of waste. 27 28 The staff concludes that overall waste impacts from the combination of the wind and CAES alternative would be SMALL. Waste Management 8-73 Environmental Impacts of Alternatives Table 8-9. Summary of Environmental Impacts of the Wind and CAES Alternative Compared to Continued Operation of the Existing LGS 1 2 Wind and CAES Alternative Continued Operation of LGS Air Quality SMALL to MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use MODERATE to LARGE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics MODERATE to LARGE SMALL Historic and Archaeological SMALL TO LARGE SMALL Waste Management SMALL SMALL (a) 3 (a) As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 8.6.4. Wood Waste 4 5 6 7 8 9 10 11 12 13 14 15 16 17 As noted in the GEIS (NRC 1996), the use of wood waste to generate utility-scale baseload power is limited to those locations where wood waste is plentiful. Wastes from pulp, paper, and paperboard industries and from forest management activities can be expected to provide sufficient, reliable supplies of wood waste as feedstocks to external combustion sources for energy generation. Beside the fuel source, the technological aspects of a wood-fired generation facility are virtually identical to those of a coal-fired alternative--combustion in an external combustion unit such as a boiler to produce steam to drive a conventional STG. Given constancy of the fuel source, wood waste facilities can be expected to operate at equivalent efficiencies and reliabilities. Costs of operation would depend significantly on processing and delivery costs. Wood waste combustors would be sources of criteria pollutants and GHGs, and pollution control requirements would be similar to those for coal plants. Unlike coal plants, there is no potential for the release of HAPs such as mercury. Co-firing of wood waste with coal is also technically feasible. Processing the wood waste into pellets can improve the overall efficiency of such co-fired units. 18 19 20 21 22 23 Although co-fired units can have capacity factors similar to baseload coal-fired units, such levels of performance are dependent on the continuous availability of the wood fuel. In the Commonwealth of Pennsylvania, 2010 electricity generating capacity from wood waste was 108 MW(e) and produced 675,000 MWh (EIA 2011c). Given the limited capacity and modest actual electricity production, the staff has determined that production of electricity from wood waste at levels equivalent to LGS would not be a feasible alternative to LGS license renewal. 8-74 Environmental Impacts of Alternatives 1 8.6.5. Conventional Hydroelectric Power 2 3 4 5 6 7 8 9 10 11 12 13 Three technology variants of hydroelectric power exist--dam and release (also known as impoundment), run-of-the-river (also known as diversion), and pumped storage. In each variant, flowing water spins turbines of different designs to drive a generator to produce electricity. Dam and release facilities affect large amounts of land behind the dam to create reservoirs but can provide substantial amounts of power at capacity factors greater than 90 percent. Power generating capacities of run-of-the-river dams fluctuate with the flow of water in the river, and the operation of such dams is typically constrained (and stopped entirely during certain periods) so as not to create undue stress on the aquatic ecosystems present. Pumped storage facilities use electricity from other power sources to pump water from lower impoundments or flowing watercourses to higher elevations during off-peak load periods. Water is then released during peak load periods through turbines to generate electricity. Capacities of pumped storage facilities are dependent on the configuration and capacity of the elevated storage facility. 14 15 16 17 18 19 20 21 22 23 A comprehensive survey of hydropower resources in Pennsylvania was completed in 1997 by DOE's Idaho National Environmental Engineering Laboratory (now known as the Idaho National Laboratory). In the study, generating potential was defined by a model that considered the existing hydroelectric technology at developed sites or applied the most appropriate technology to undeveloped sites and introduced site-specific environmental considerations and limitations. Pennsylvania had modest hydroelectric potential, with a total generating potential of 703 MW(e) (INEEL 1997). This potential was spread across 104 sites, only one of which had the potential for more than 100 MW(e) of generation. Most other states in PJM have very limited potential (INEEL 1998b), with the exception of West Virginia, which has 1,149 MW(e) spread across 37 sites (INEEL 1998a) 24 25 26 27 28 29 30 31 32 More recently, EIA reported that, in 2010, conventional hydroelectric power (excluding pumped storage) was the principal electricity generation source among renewable sources in Pennsylvania (EIA 2011c). Nevertheless, only 747 MW(e) of hydroelectric capacity was installed in the Commonwealth. Those installations provided 2,332 gigawatt-hours of electricity (EIA 2011a). Although hydroelectric facilities can demonstrate relatively high capacity factors, the small potential capacities and actual recent power generation of hydroelectric facilities in Pennsylvania, combined with the diminishing public support for large hydroelectric facilities because of their potential for adverse environmental impacts, supports the staff's conclusion that hydroelectric is not a feasible alternative to LGS. 33 8.6.6. 34 35 36 37 38 39 40 41 42 43 44 45 46 Ocean waves, currents, and tides represent kinetic and potential energies. The total annual average wave energy off the U.S. coastlines at a water depth of 60 m (197 ft) is estimated at 2,100 terawatt-hours (TWh) (MMS 2006). Waves, currents, and tides are often predictable and reliable; ocean currents flow consistently, while tides can be predicted months and years in advance with well-known behavior in most coastal areas. Four principal wave energy conversion (WEC) technologies have been developed to date to capture the potential or kinetic energy of waves--point absorbers, attenuators, overtopping devices, and terminators. All have similar approaches to electricity generation but differ in size, anchoring method, spacing, interconnection, array patterns, and water depth limitations. Point absorbers and attenuators both allow waves to interact with a floating buoy, subsequently converting its motion into mechanical energy to drive a generator. Overtopping devices and terminators are also similar in their function. Overtopping devices trap some portion of the incident wave at a higher elevation than the average height of the surrounding sea surface, thus giving it higher potential Ocean Wave and Current Energy 8-75 Environmental Impacts of Alternatives 1 2 energy, which is then transferred to power generators. Terminators allow waves to enter a tube, compressing air trapped at the top of the tube, which is then used to drive a generator. 3 4 5 6 Capacities of point absorbers range from 80-250 kW, with capacity factors as high as 40 percent; attenuator facilities have capacities of as high as 750 kW. Overtopping devices have design capacities as high as 4 MW, while terminators have design capacities ranging from 500 kW-2 MW and capacity factors as high as 50 percent (MMS 2007). 7 8 9 10 11 12 13 The most advanced technology for capturing tidal and ocean current energy is the submerged turbine. Underwater turbines share many design features and functions with wind turbines, but because of the greater density of water compared to air, they have substantially greater power-generating potential than wind turbines with comparably sized blades. Only a small number of prototypes and demonstration units have been deployed to date, however. Underwater turbine "farms" are projected to have capacities of 2-3 MW, with capacity factors directly related to the constancy of the current with which they interact. 14 15 16 17 The staff is not currently aware of any plans to develop or deploy ocean wave and ocean current generation technologies on a scale similar to that of LGS. Consequently, the relatively modest power capacities, relatively high costs, and limited planned implementation support the staff's conclusion that water energy current technologies are not feasible substitutes for LGS. 18 8.6.7. 19 20 21 Geothermal technologies extract the heat contained in geologic formations to produce steam to drive a conventional steam-turbine generator. The following variants of the heat exchanging mechanism have been developed: Geothermal Power 22 23 24 25 o Hot geothermal fluids contained under pressure in a geological formation are brought to the surface where the release of pressure allows them to flash into steam (the most common of geothermal technologies applied to electricity production). 26 27 28 o Hot geothermal fluids are brought to the surface in a closed loop system and directed to a heat exchanger where they convert water in a secondary loop into steam. 29 30 o Hot dry rock technologies involve fracturing a rock formation and extracting heat through injection of a heat transfer fluid. 31 32 33 34 35 36 37 38 39 40 41 42 Facilities producing electricity from geothermal energy can routinely demonstrate capacity factors of 95 percent or greater, making geothermal energy clearly eligible as a source of baseload electric power. However, as with other renewable energy technologies, the ultimate feasibility of geothermal energy serving as a baseload power replacement for LGS depends on the quality and accessibility of geothermal resources within or proximate to the region of interest--in this case, Pennsylvania or PJM. As of April 2010, the United States had a total installed geothermal electricity production capacity of 3,087 MW(e) originating from geothermal facilities in nine states--Alaska, California, Hawaii, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming. Additional geothermal facilities are being considered for Colorado, Florida, Louisiana, Mississippi, and Oregon. Neither Pennsylvania nor PJM has adequate geothermal resources to support utility-scale electricity production (GEA 2010). NRC concludes, therefore, that geothermal energy does not represent a feasible alternative to LGS. 8-76 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 8.6.8. Municipal Solid Waste Municipal solid waste (MSW) combustors use three types of technologies--mass burn, modular, and refuse-derived fuel. Mass burning is currently the method used most frequently in the United States and involves no (or little) sorting, shredding, or separation. Consequently, toxic or hazardous components present in the waste stream are combusted, and toxic constituents are exhausted to the air or become part of the resulting solid wastes. Currently, approximately 86 waste-to-energy plants operate in 24 states, processing 97,000 tons (88,000 MT) of municipal solid waste per day. Approximately 26 million tons (24 million MT) of trash were processed in 2008 by waste-to-energy facilities. With a reliable supply of waste fuel, waste-to-energy plants have a nationwide aggregate capacity of 2,572 MW(e) (compared to 2,340 MW[e] capacity at LGS) and can operate at capacity factors greater than 90 percent (ERC 2010). The EPA estimates that, on average, air impacts from MSW-to-energy plants are as follows: o o o carbon dioxide (CO2) -3,685 lb (1,672 kg)/MWh, sulfur dioxide (SOX) -1.2 lb (0.54 kg)/MWh, and nitrogen oxide (NOx) - 6.7 lb (3.0 kg)/MWh. 17 18 19 Depending on the composition of the municipal waste stream, air emissions can vary greatly, and the ash produced may exhibit hazardous characteristics that require special treatment and handling (EPA 2010). 20 21 22 23 24 25 26 Estimates in the GEIS suggest that the overall level of construction impact from a waste-fired plant would be approximately the same as that for a coal-fired power plant. Additionally, waste-fired plants have the same or greater operational impacts as coal-fired technologies (including impacts on the aquatic environment, air, and waste disposal). The initial capital costs for municipal solid-waste plants are greater than those for comparable steam-turbine technology at coal-fired facilities or at wood-waste facilities because of the need for specialized waste separation and handling equipment (NRC 1996). 27 28 29 30 31 32 The decision to burn municipal waste to generate energy is usually driven by the need for an alternative to landfills, rather than energy considerations. The use of landfills as a waste disposal option is likely to increase in the near term as energy prices increase (and especially since such landfills, of sufficient size and maturity, can be sources of easily recoverable methane fuel); however, it is possible that municipal waste combustion facilities may become attractive again. 33 34 35 36 37 38 39 40 Regulatory structures that once supported municipal solid waste incineration no longer exist. For example, the Tax Reform Act of 1986 made capital-intensive projects, such as municipal waste combustion facilities, more expensive relative to less capital-intensive waste disposal alternatives such as landfills. Additionally, the 1994 Supreme Court decision C&A Carbone, Inc. v. Town of Clarkstown, New York, struck down local flow control ordinances that required waste to be delivered to specific municipal waste combustion facilities rather than landfills that may have had lower fees. In addition, environmental regulations have increased the capital cost necessary to construct and maintain municipal waste combustion facilities. 41 42 43 44 45 46 Given the limited nationwide implementation of MSW-based generation to date (only 10 percent greater than the capacity of LGS), small average installed size of municipal solid waste plants, the likelihood that additional stable streams of MSW are not likely to be available to support numerous new facilities, and the increasingly unfavorable regulatory environment, the staff does not consider municipal solid waste combustion to be a reasonable alternative to LGS license renewal. 8-77 Environmental Impacts of Alternatives 1 8.6.9. Biomass Fuels 2 3 4 5 6 7 8 9 10 11 12 13 14 15 When used here, "biomass fuels" include crop residues, switchgrass grown specifically for electricity production, forest residues, methane from landfills, methane from animal manure management, primary wood mill residues, secondary wood mill residues, urban wood wastes, and methane from domestic wastewater treatment. The feasibility of using biomass fuels for baseload power depends on its geographic distribution, available quantities, constancy of supply, and energy content. A variety of technical approaches has been developed for biomass-fired electric generators, including direct burning, conversion to liquid biofuels, and biomass gasification. In a study completed in December 2005, Milbrandt of NREL documented the geographic distribution of biomass fuels within the United States, reporting the results in metric tons available (dry basis) per year (NREL 2005). Most counties in Pennsylvania have limited potential biomass fuels, with the exception of Philadelphia and Bucks County. Use of biomass fuels in Pennsylvania is also limited. Beyond the wood and wood waste considered in Section 8.6.4, generators in the Commonwealth used biomass fuels to produce merely 3,000 MWh of electricity in 2010 (EIA 2011c). 16 17 18 19 20 21 In the GEIS, the NRC indicated that technologies relying on a variety of biomass fuels had not progressed to the point of being competitive on a large scale or of being reliable enough to replace a baseload plant such as LGS. After reevaluating current technologies, and after reviewing existing statewide capacities and the extent to which biomass is currently being used to produce electricity, the staff finds biomass-fueled alternatives are still unable to replace the LGS capacity and are not considered feasible alternatives to LGS license renewal. 22 8.6.10. Oil-Fired Power 23 24 25 26 27 Although oil has historically been used extensively in the Northeast for comfort heating, EIA projects that oil-fired plants will account for very little of the new generation capacity constructed in the United States during the 2008 to 2030 time period. In 2010, Pennsylvania generated 0.2 percent of its total electricity from oil (EIA 2012). Further, EIA does not project that oil-fired power will account for any significant additions to capacity (EIA 2011b). 28 29 30 31 32 33 The variable costs of oil-fired generation tend to be greater than those of nuclear or coal-fired operations, and oil-fired generation tends to have greater environmental impacts than natural gas-fired generation. In addition, future increases in oil prices are expected to make oil-fired generation increasingly expensive (EIA 2011b). The high cost of oil has prompted a steady decline in its use for electricity generation. Thus, the staff does not consider oil-fired generation as a reasonable alternative to LGS license renewal. 34 8.6.11. Delayed Retirement 35 36 37 38 Exelon currently plans to retire three coal-fired units and one oil-fired unit (Exelon 2011). These units total 946 MW(e) of capacity, far less than the 2,340 MW(e) LGS currently provides. In PJM, however, Exelon indicates that generators have retired 5,945 MW(e) from 2003 to 2009 (Exelon 2011). 39 40 41 42 43 44 45 Most retired units are dirtier and less efficient than new units. Often, units are retired because operation is no longer economical. In some cases, the cost of environmental compliance or necessary repairs and upgrades are too high to justify continued operation. As a result, the staff does not consider delayed retirement a reasonable alternative to license renewal. It is possible, however, that a site where a unit has been retired could play host to a new generation facility, like the NGCC and SCPC alternatives considered in Sections 8.1 and 8.2, and the NGCC portion of the combination alternative considered in Section 8.6.2. 8-78 Environmental Impacts of Alternatives 1 8.6.12. Fuel Cells 2 3 4 5 6 7 Fuel cells oxidize fuels without combustion and its environmental side effects. Power is produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) over a cathode and separating the two by an electrolyte. The only byproducts (depending on fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to steam reforming under pressure. Natural gas is typically used as the source of hydrogen. 8 9 10 11 12 13 14 15 16 17 18 Currently, fuel cells are not economically or technologically competitive with other alternatives for electricity generation. EIA projects that fuel cells may cost $5,478 per installed kW (total overnight costs, 2008 dollars) (EIA 2010c). This amount is substantially greater than coal ($2,223), advanced (natural gas) combustion turbines ($648), onshore wind ($1,966), or offshore wind ($3,937), but it is cost-competitive with solar PV ($6,171) or CSP solar ($5,132). Installed costs provided for PV and CSP solar are before application of Investment Tax Credits provided in Federal statutes. More importantly, fuel cell units are likely to be small in size (the EIA reference plant is 10 MWe). While it may be possible to use a distributed array of fuel cells to provide an alternative to LGS, it would be extremely costly to do so and would require many units and wholesale modifications to the existing transmission system. Accordingly, the staff does not consider fuel cell technology to be a reasonable alternative to LGS license renewal. 19 8.6.13. Coal-Fired Integrated Gasification Combined-Cycle 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Integrated gasification combined-cycle (IGCC) is an emerging technology for generating electricity with coal that combines modern coal gasification technology with both gas turbine and steam turbine power generation. Gasifiers, similar to those used in oil refineries, use heat pressure and steam to pyrolyze (thermally reform complex organic molecules without oxidation) coal to produce synthesis gases (generically referred to as syngas) typically composed of carbon monoxide, hydrogen, and other flammable constituents. After processing to remove contaminants and produce various liquid chemicals, the syngas is combusted in a combustion turbine to produce electric power. Separating the CO2 from the syngas before combustion is also possible. Latent heat is recovered both from the syngas as it exits the gasifier and from the combustion gases exiting the combustion turbine and directed to a heat recovery steam generator feeding a conventional Rankine cycle STG to produce additional amounts of electricity. Emissions of criteria pollutants would likely be slightly higher than those from an NGCC alternative but significantly lower than those from the supercritical coal-fired alternative. Depending on the gasification technology employed, IGCC would use less water than SCPC units but slightly more than NGCC (NETL 2007). Long-term maintenance costs of this relatively complex technology would likely be greater than those for a similarly sized SCPC or NGCC plant. 37 38 39 40 41 42 43 44 Only a few IGCC plants are operating at utility scale. Operating at higher thermal efficiencies than supercritical coal-fired boilers, IGCC plants can produce electrical power with fewer air pollutants and solid wastes than coal-fired boilers. To date, however, IGCC technologies have had limited application and have been plagued with operational problems such that its effective, long-term capacity factors are often not high enough for them to reliably serve as baseload units. Although IGCC technology may become more commonplace in the future, current operational problems that compromise reliability result in the dismissal of this technology as a viable alternative to LGS. 8-79 Environmental Impacts of Alternatives 1 8.6.14. Demand-Side Management 2 3 4 5 6 7 8 9 10 In its ER, Exelon indicates that DSM does not fulfill the stated purpose of license renewal because it does not provide power generation capacity (Exelon 2011). Exelon also notes that the purpose of LGS license renewal is to "allow Exelon to sell wholesale power generated by LGS to meet future demand." The ER continues to note that, because "Exelon engages solely in the sale of wholesale electric power, the Company has no business connection to end-users of its electricity and, therefore, no ability to implement DSM." While the staff finds this position reasonable for purposes of this analysis, it notes that DSM is an option for energy planners and decisionmakers--and it may be a potential consequence of no action--and so will discuss it in brief in this section. 11 12 DSM measures--unlike the energy supply alternatives discussed in previous sections--address energy end uses. DSM can include measures that do the following: 13 o reduce energy consumption; 14 o shift energy consumption to different times of the day to reduce peak loads; 15 o interrupt certain large customers during periods of high demand; 16 o interrupt certain appliances during high demand periods; and 17 18 o encourage customers to switch from gas to electricity for water heating and other similar measures that utilities use to boost sales. 19 20 21 22 23 24 25 26 27 28 29 30 In terms of overall ability to offset or replace an existing baseload power plant, DSM measures that reduce energy consumption, typically referred to as energy conservation and energy efficiency, are the most useful. Though often used interchangeably, energy conservation and energy efficiency are different concepts. Energy efficiency typically means deriving a similar level of service by using less energy, while energy conservation simply indicates a reduction in energy consumption. The GEIS directly addressed energy conservation, and noted that it is not a discrete power-generating source; it represents an option that states and utilities may use to reduce their need for power generation capability (NRC 1996). Conservation measures may include incentives to reduce overall energy consumption, while efficiency measures may include incentives to replace older, less efficient appliances, lighting, or heating and cooling systems. A variety of conservation or energy efficiency measures would likely be necessary to replace the capacity currently provided by LGS. 31 32 33 34 Another DMS approach is called demand-response. PJM currently has a robust demand-response program, which, unlike energy efficiency and energy conservation measures, generally aims to reduce consumption during times of high demand. This program also reduces stresses on the PJM transmission system. 35 36 37 38 39 40 41 42 43 44 PJM's demand-response program provides payments to participants who reduce demand (PJM 2012c, PJM undated). The payments increase as the price of electricity increases, so that participants are most likely to reduce consumption when electricity is most expensive, which usually (though not always) occurs during times of high demand (this may also occur during certain emergencies). This type of approach usually offsets intermediate and peaking generation rather than baseload generation. Exelon notes, in the ER, that it is unlikely that demand reductions in PJM could be sufficiently increased to replace the LGS baseload capacity (Exelon 2011). The NRC staff determined that this conclusion is reasonable because a considerable amount of demand reduction efforts are currently in place and it is unlikely that additional programs could reduce use by another 2,340 MW(e). 8-80 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 As Exelon noted in its ER, the impacts of DSM at most sites are generally SMALL. The staff has considered energy efficiency or energy conservation in several SEISs (see, e.g., NUREG-1437, Supplements 33, 37, and 38) and in each case has found the impacts to be SMALL, except when conservation or efficiency measures are unlikely to offset socioeconomic impacts of plant shutdown. For LGS, the conservation or efficiency measures may not offset the socioeconomic plant shutdown because the measures could occur across the entire PJM territory, which includes several states. The GEIS also indicates that impacts from energy conservation are likely to be SMALL. The staff notes, however, that some generation owners recently expressed concern that in cases where demand-response programs trigger increased reliance on backup diesel generators, air-quality impacts may occur, particularly in PJM (see, e.g., Beattie 2012). The EPA has provided clean-air waivers for the use of these generators for a limited number of hours throughout the year. Emergency use of these generators is likely to occur during the hottest days of the summer, when impaired air quality often also occurs (Beattie 2012). Some air quality effects from some DSM measures are possible, but they would depend on the specific DSM measures employed. Because it is unlikely that demand reductions in PJM could be sufficiently increased to replace the LGS baseload capacity, the NRC did not consider DSM to be a reasonable alternative. 18 8.7. 19 20 21 22 23 This section examines the environmental effects that occur if NRC takes no action. No action, in this case, means that NRC denies the renewed operating licenses for LGS and the licenses expire at the end of the current license terms, in 2024 and 2029. If the NRC denies the renewed operating licenses, the plant will shut down at or before the end of the current licenses. After shutdown, plant operators will initiate decommissioning in accordance with 10 CFR 50.82. 24 25 26 27 28 29 30 No action does not satisfy the purpose and need for this SEIS, as it neither provides power-generation capacity nor meets the needs currently met by LGS or that the alternatives evaluated in Sections 8.1-8.5 would satisfy. Assuming that a need currently exists for the power generated by LGS, the no-action alternative would require the appropriate energy planning decision-makers (not NRC) to rely on an alternative to replace the capacity of LGS, rely on energy conservation or power purchases to offset parts of the LGS capacity, or rely on some combination of measures to offset and replace the generation provided by the facility. 31 32 33 34 35 36 37 This section addresses only those impacts that arise directly as a result of plant shutdown. The environmental impacts from decommissioning and related activities have already been addressed in several other documents, including the "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," NUREG-0586, Supplement 1 (NRC 2002); the license renewal GEIS, Chapter 7 (NRC 1996); and Chapter 7 of this SEIS. These analyses either directly address or bound the environmental impacts of decommissioning whenever Exelon ceases to operate LGS. 38 39 40 41 42 43 Even with a renewed operating license, LGS will eventually shut down, and the environmental effects we address in this section will occur at that time. Because these effects have not otherwise been addressed in this SEIS, the impacts are addressed in this section. As with decommissioning effects, shutdown effects are expected to be similar whether they occur at the end of the current license or at the end of a renewed license. Table 8-10 provides a summary of the environmental impacts of the no-action alternative. 44 8.7.1. Air Quality 45 46 When the plant stops operating, there will be a reduction in emissions from activities related to plant operation, such as use of diesel generators and employee vehicles. In Chapter 4, the staff No-Action Alternative 8-81 Environmental Impacts of Alternatives 1 2 3 determined that these emissions would have a SMALL impact on air quality during the renewal term; therefore, if emissions decrease, the impact on air quality would also decrease and would be SMALL. 4 8.7.2. Groundwater Resources 5 6 7 Impacts to groundwater resources would decrease, as the plant would withdraw less water than it does during operations. Therefore, shutdown would reduce the impacts to groundwater resources, which would remain SMALL. 8 8.7.3. Surface Water Resources 9 10 11 Impacts to surface water resources would decrease, as the plant would withdraw and discharge less water than it does during operations. Therefore, shutdown would reduce the impacts to surface water resources, which would remain SMALL. 12 8.7.4. Aquatic and Terrestrial Resources 13 14 15 16 Impacts to aquatic ecology would decrease, as the plant would withdraw and discharge less water than it does during operations. Therefore, fewer organisms would be subject to impingement, entrainment, and heat shock. Shutdown would reduce the impacts to aquatic ecology, which would remain SMALL. 17 18 Terrestrial ecology impacts would remain SMALL. No additional land disturbances on or offsite would occur. 19 8.7.5. Human Health 20 21 22 23 24 25 26 27 28 29 30 In Chapter 4 of this SEIS, the staff concluded that the impacts of continued plant operation on human health would be SMALL. After cessation of plant operations, the amounts of radioactive material released to the environment in gaseous and liquid forms, all of which are currently within respective regulatory limits, would be reduced or eliminated. Therefore, the staff concludes that the impact of plant shutdown on human health would also be SMALL. In addition, the potential for a variety of accidents would also be reduced to only those associated specifically with shutdown activities and fuel handling. In Chapter 5 of this SEIS, the staff concluded that impacts of accidents during operation would be SMALL. It follows, therefore, that impacts on human health from a reduced suite of potential accidents after reactor operation ceases would also be SMALL. Therefore, the staff concludes that impacts on human health from the no-action alternative would be SMALL. 31 8.7.6. Land Use 32 33 34 35 Plant shutdown would not affect onsite land use. Plant structures and other facilities would remain in place until decommissioning. Most transmission lines connected to the LGS would remain in service after the plant stops operating. Maintenance of most existing transmission lines would continue as before. Impacts on land use from plant shutdown would be SMALL. 36 8.7.7. Socioeconomics 37 38 39 40 Plant shutdown would have a noticeable impact on socioeconomic conditions in the communities located in the immediate vicinity of LGS. Should LGS shut down, there would be immediate socioeconomic impact from the loss of jobs (some, though not all, of the 820 employees would begin to leave), and tax payments may be reduced. As the majority of 8-82 Environmental Impacts of Alternatives 1 2 3 4 5 6 7 8 9 LGS employees reside in Montgomery, Berks, and Chester Counties, socioeconomic impacts from plant shutdown would be concentrated in these counties, with a corresponding reduction in purchasing activity and tax contributions to the regional economy. Revenue losses from LGS operations would directly affect Montgomery County and other local taxing districts and communities closest to, and most reliant on, the nuclear plant's tax revenue. The impact of the job loss, however, may not be as noticeable given the amount of time required to decontaminate and decommission existing facilities and the proximity of LGS to the Philadelphia metropolitan area. The socioeconomic impacts of plant shutdown (which may not entirely cease until after decommissioning) could, depending on the jurisdiction, range from SMALL to MODERATE. 10 8.7.8. Transportation 11 12 13 14 Traffic volumes on the roads in the vicinity of LGS would be reduced after plant shutdown. Most of the reduction in traffic volume would be associated with the loss of jobs at the nuclear power plant. The number of deliveries to the power plant would be reduced until decommissioning. Transportation impacts would be SMALL as a result of plant shutdown. 15 8.7.9. Aesthetics 16 17 18 Plant structures and other facilities would remain in place until decommissioning. Most sources of operational noise would cease. Therefore, aesthetic impacts of plant closure would be SMALL. 19 8.7.10. Historic and Archaeological Resources 20 21 22 Impacts from the no-action alternative on historic and archaeological resources would be SMALL. A separate environmental review addressing the protection of historic and archaeological resources would be conducted for decommissioning. 23 8.7.11. Environmental Justice 24 25 26 27 28 29 30 Impacts to minority and low-income populations would depend on the number of jobs and the amount of tax revenues lost by communities in the immediate vicinity of the power plant after LGS ceases operations. Closure of LGS would reduce the overall number of jobs (there are currently 820 employed at the facility) and tax revenue for social services attributed to nuclear plant operations. Minority and low-income populations in the vicinity of LGS could experience some socioeconomic effects from plant shutdown, but these effects would not likely be high and adverse. 31 8.7.12. Waste Management 32 33 34 If the no-action alternative were implemented, the generation of high-level waste would stop, and generation of low-level and mixed waste would decrease. Impacts from implementation of the no-action alternative are expected to be SMALL. 8-83 Environmental Impacts of Alternatives Table 8-10. Environmental Impacts of No-Action Alternative 1 No-Action Alternative Continued Operation of LGS Air Quality SMALL SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL SMALL Human Health SMALL SMALL Land Use SMALL SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL SMALL Aesthetics SMALL SMALL Historic and Archaeological SMALL SMALL Waste Management (a) (a) (a) SMALL SMALL As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS 2 8.8. Alternatives Summary 3 4 5 6 7 8 9 In this SEIS, the staff has considered alternative actions to license renewal of LGS, including in-depth evaluations of new generation alternatives (Sections 8.1-8.4), a purchased power alternative (Section 8.5), alternatives that the staff dismissed from detailed evaluation as infeasible or inappropriate (Section 8.6; including in-depth consideration of solar PV generation and two combination alternatives), and the no-action alternative in which the operating license is not renewed (Section 8.7). Impacts of all alternatives considered in detail are summarized in Table 8-11. 10 11 12 13 14 15 16 17 18 19 20 21 22 Based on the above evaluations, the staff concludes that the environmental impacts of renewal of the operating license for LGS would be smaller than those of feasible and commercially viable alternatives studied in this SEIS that satisfy the purpose and need of license renewal (providing 2,340 MWe of baseload power to the grid). Impacts on air quality are less from continued operation of LGS than from any of the alternatives involving fossil fuels, though they are likely to be greater than wind and solar PV alone. Finally, the staff concluded that under the no-action alternative, the act of shutting down LGS on or before its license expiration would have mostly SMALL impacts, although socioeconomic impacts would be SMALL to MODERATE. Depending on how the power lost to the region from reactor shutdown was replaced (decisions outside of the NRC's authority and made instead by Exelon, other power producers, PJM operators, and state or non-NRC Federal authorities), the net environmental impact of the no-action alternative could be greater than continued reactor operation, especially when fossil energy power plants provide replacement generation capacity. 8-84 8BEnvironmental Impacts of Alternatives Table 8-11. Summary of Environmental Impacts of Proposed Action and Alternatives 1 Air Quality Groundwater and Surface Water Resources Aquatic and Terrestrial Resources Human Health Land Use Socioeconomics (including Transportation and Aesthetics) Historic and Archaeological Resources Waste Management Impact Area SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL NGCC at an Alternate Site SMALL to MODERATE SMALL SMALL SMALL SCPC at an Alternate Site MODERATE SMALL SMALL to SMALL to SMALL MODERATE MODERATE SMALL to LARGE SMALL New Nuclear at an Alternate Site SMALL SMALL SMALL to SMALL to SMALL MODERATE MODERATE SMALL to LARGE SMALL Wind Power SMALL SMALL SMALL to MODERATE SMALL MODERATE to LARGE SMALL to LARGE SMALL to LARGE SMALL SMALL to MODERATE SMALL SMALL to SMALL MODERATE SMALL to LARGE SMALL to LARGE SMALL to LARGE SMALL to MODERATE SMALL SMALL SMALL to SMALL MODERATE SMALL to LARGE SMALL to LARGE SMALL to LARGE SMALL Wind, Solar, and NGCC SMALL to (dismissed in Section MODERATE 8.6.2) SMALL SMALL to SMALL to SMALL to SMALL to SMALL MODERATE MODERATE MODERATE MODERATE SMALL Wind and CAES (dismissed in Section 8.6.3) SMALL to MODERATE SMALL SMALL to MODERATE SMALL MODERATE to LARGE SMALL No-Action Alternative SMALL SMALL Alternative License Renewal 8-85 Purchased Power Solar PV (dismissed in Section 8.6.1) (a) SMALL SMALL SMALL to SMALL to SMALL to MODERATE MODERATE MODERATE SMALL SMALL to LARGE SMALL to LARGE SMALL to MODERATE SMALL (a) SMALL MODERATE (a) SMALL (a) SMALL As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS. 8BEnvironmental Impacts of Alternatives 1 8.9. 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Available at (accessed November 2012). 28 29 30 31 [ACAA] American Coal Ash Association. 2010. 2009 Coal Combustion Product (CCP) Production and Use Survey Report. Aurora, CO: ACAA. November 3. Available at (accessed 29 November 2010). 32 33 34 Archer CL, Jacobson MZ. 2007. Supplying baseload power and reducing transmission requirements by interconnecting wind farms. Journal of Applied Meteorology and Climatology 46(11)1701-1717. 35 36 37 Atlantic Wind Connection. Undated. "Right of Way Application--FAQs." Available at (accessed 3 November 2011). 38 39 Beattie J. EPA easing emissions rules for demand response--generators. The Energy Daily. Vol. 40, No. 30 (February 13, 2012). 40 41 42 43 [BLM] Department of the Interior, Bureau of Land Management. 2005. Final Programmatic Environmental Impact Statement on Wind Energy Development on BLM-Administered Lands in the Western United States. Washington, DC: BLM. June. Available at (accessed 17 May 2011). 8-86 8BEnvironmental Impacts of Alternatives 1 2 3 4 [Con Edison] Con Edison and Long Island Power Authority (LIPA). 2009. Joint Con Edison-LIPA Offshore Wind Power Integration Project Feasibility Assessment. March 20, 2009. Available at (accessed 2 December 2011). 5 6 7 [DOE] U.S. Department of Energy (DOE). 2008. 20% Wind Energy by 2030, Increasing Wind Energy's Contribution to U.S. Electricity Supply. DOE/GO-102008-2567. July. Available at (accessed 1 June 2012). 8 9 10 11 [DOE] BLM and Department of Energy (DOE). 2010. Draft Programmatic Environmental Impact Statement for Solar Energy Development in Six Southwestern States. DES 10-59; DOE/EIS 0403. December. Available at (accessed 28 January 2011). 12 13 [DOE] U.S. Department of Energy (DOE). 2012. Wind Powering America. Available at: http://www.windpoweringamerica.gov Accessed November 6, 2012. 14 15 16 17 [DSIRE] Database of State Incentives for Renewables and Efficiency. 2011. Alternative Energy Portfolio Standard. Available at (accessed 7 May 2012). 18 19 20 21 [EIA] U.S. Energy Information Administration. 2010a. Cost and Quality of Fuels for Electric Plants 2009 Edition, Table 15A Destination and Origin of Coal to Electric Plants by State: Total (All Sectors), 2010. Washington, DC: EIA. November. Available at (accessed 11 May 2012). 22 23 24 25 [EIA] U.S. Energy Information Administration. 2010b. Assumptions to the Annual Energy Outlook 2010 with Projections to 2035. Washington, DC: EIA. April 9, 2010. DOE/EIA-0554 (2010). Available at (accessed 7 December 2010). 26 27 28 [EIA] U.S. Energy Information Administration. 2011a. Electric Power Annual with Data for 2009, Summary Statistics for the United States. Washington, DC: EIA. April. Available at (accessed 5 May 2011). 29 30 31 [EIA] U.S. Energy Information Administration. 2011b. Annual Energy Outlook for 2011 with Projections to 2035, Electricity. DOE/EIA 0383(2010). Washington, DC: EIA. April 26. Available at (accessed 5 May 2011). 32 33 34 35 [EIA] U.S. Energy Information Administration. 2011c. Pennsylvania Renewable Energy Profile, 2010. Washington, DC: EIA. March. Available at (accessed 18 May 2012). 36 37 38 [EIA] U.S. Energy Information Administration. 2012. State Electricity Profiles 2010. Washington, DC: EIA. January 27, 2012. Available at (accessed 7 May 2012). 39 40 41 42 [EPA] U.S. Environmental Protection Agency. 1998. Section 1.1, Bituminous and Subbituminous Coal Combustion: Final Section Supplement E. In: Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources: AP 42. 5th ed. Washington, DC: EPA. Available at . 43 44 45 [EPA] U.S. Environmental Protection Agency. 2000a. "Air Pollution Control Technology Fact Sheet, Selective Catalytic Reduction (SCR)." Washington DC: EPA. EPA-452/F-03-032. Available at (accessed 9 November 2010). 8-87 8BEnvironmental Impacts of Alternatives 1 2 [EPA] U.S. Environmental Protection Agency. 2009a. "List of 156 Mandatory Class I Federal Areas." Available at (accessed 7 March 2011). 3 4 [EPA] U.S. Environmental Protection Agency. 2009b. "NOx Trading Programs." April. Available at (accessed 3 March 2011). 5 6 7 8 [EPA] U.S. Environmental Protection Agency. 2010. "Municipal Solid Waste, Electricity from Municipal Solid Waste." Last updated March 17, 2010. Washington, DC: EPA. Available at (accessed 10 December 2010). 9 10 11 12 [EPA] U.S. Environmental Protection Agency. 2011a. Draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2009. Washington, DC: EPA. EPA 430-R-11-005. February 15. Available at (accessed 2 March 2011). 13 14 [EPA] U.S. Environmental Protection Agency. 2011b. "NOx Trading Programs." Available at (accessed 3 March 2011). 15 16 [EPA] U.S. Environmental Protection Agency. 2012a. "New Source Review." Available at (accessed 10 April 2012). 17 18 [EPA] Environmental Protection Agency. 2012b. "Emission Factors & AP42, Compilation of Air Pollutant Emission." Available at (accessed 10 April 2012). 19 20 [EPA] Environmental Protection Agency (EPA). 2012c. "Reducing Air Pollution from Power Plants." Available at (accessed 10 April 2012). 21 22 23 24 25 26 [EPRI and CED] Electric Power Research Institute and Commission for Environmental Cooperation. 2003. Potential Health and Environmental Impacts Associated with the Manufacture and Use of Photovoltaic Cells, Final Report. Report 1000095. November 2003. Prepared by Tetra Tech, Inc., Lafayette: CA for EPRI, Palo Alto: CA and California Energy Commission, Sacramento: CA. Available at (accessed 2 May 2012). 27 28 29 30 31 [ERC] Energy Recovery Council. 2010. The 2010 ERC Directory of Waste-To-Energy Plants. November 12, 2010. Available at (accessed 9 December 2010). Agencywide Documents Access and Management System (ADAMS) Accession No. ML11266A009. 32 33 34 35 [GCRP] Global Change Research Program. 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U.S. Hydropower Resource Assessment for West Virginia. DOE-ID/10430(WV). Idaho Falls: ID. February 1998. Available at (accessed 18 May 2012). 9 10 11 12 [INEEL] Idaho National Engineering and Environmental Laboratory. 1998b. U.S. Hydropower Resource Assessment, Final Report. DOE-ID/10430. Washington, DC. December. Available at (accessed 18 May 2012). 13 14 15 16 [ISEPA] Iowa Stored Energy Park Agency. 2011. "Iowa Stored Energy Park Project Terminated." Press release. July 28, 2011. Available at (accessed 4 November 2011). 17 18 19 20 [MASSDEP and MDPH] Massachusetts Department of Environmental Protection (MassDEP) and Massachusetts Department of Public Health (MDPH). 2012. Wind Turbine Health Impact Study: Report of Independent Expert Panel. Springfield: MA. January 2012. Available at (accessed 2 May 2012). 21 22 23 [MMS] Minerals Management Service. 2006. Technology White Paper on Wave Energy Potential on the U.S. Outer Continental Shelf. 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ADAMS Accession No. ML04069720. 9 10 11 12 [NRC] U.S. Nuclear Regulatory Commission. 2002. Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors. Washington, DC: NRC. NUREG-0586, Supplement 1, Volumes 1 and 2. 13 14 15 16 [NRC] U.S. Nuclear Regulatory Commission. 2011. Information Digest, 2011-2012. Washington, DC: NRC. NUREG-1350, Volume 23. Available at (accessed 7 May 2012). 17 18 19 20 [NREL] National Renewable Energy Laboratory. 2005. Milbrandt A. A Geographic Perspective on the Current Biomass Resource Availability in the United States. Technical Report NREL/TP 560 39181. December. Available at (accessed 17 May 2012). 21 22 23 [NREL] National Renewable Energy Laboratory. 2006. Creating Baseload Wind Power Systems Using Advanced Compressed Air Energy Storage Concepts. NREL/PO-640-40674. October. ADAMS Accession No. ML100151731. 24 25 26 27 28 29 30 [NREL] National Renewable Energy Laboratory. 2010. Solar Insolation Maps, Dynamic Maps, GIS Data and Analysis Tools. Interactive website. Available at (accessed 19 May 2012). [NREL] National Renewable Energy Laboratory. 2011. "Estimates of Windy Land Area and Wind Energy Potential, by State, for Areas >=30% Capacity Factor at 80m." Updated April 13, 2011. Available at (accessed 3 November 2011). 31 32 33 34 35 Office of Innovative Partnerships and Alternate Funding, Highway Division, Oregon Department of Transportation, State of Oregon (OIPP). 2010. Health and Safety Concerns of Photovoltaic Solar Panels. Salem, Oregon. Available at (accessed 2 May 2012). 36 37 38 PJM. Undated. "PJM Demand Response Fact Sheet for End-Use Customers." Available at (accessed 19 May 2012). 39 40 41 PJM. 2010. PJM Manual 21, Rules and Procedures for Determination of Generating Capability. Revision: 09. PJM System Planning Department. Effective Date: May 1, 2010. Available at (accessed 9 November 2011). 42 43 44 PJM. 2012a. Transmission Expansion Advisory Committee. October, 11, 2012. Available at: http://www.pjm.com/~/media/committees-groups/committees/teac/20121011/20121011-reliabilit y-analysis-update.ashx Accessed November 6, 2012. 45 46 PJM. 2012b. Renewable Energy Dashboard. January 4, 2012. Available at: http://www.pjm.com/about-pjm/renewable-dashboard.aspx Accessed November 6, 2012. 8-90 8BEnvironmental Impacts of Alternatives 1 2 3 PJM. 2012c. "Demand Response." Available at (accessed 19 May 2012). 4 5 6 Reuters. 2011. "NYPA Pulls Plug on Great Lakes Offshore Wind Project." September 27, 2011. Available at (accessed 1 November 2011). 7 8 9 10 [Siemens] Siemens Power Generation. 2007. Technical Data: Combined Cycle Power Plant Performance Data. Available at (accessed July 2009). 11 12 13 14 Sovacool B. 2008. Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical Survey. Energy Policy 36 (2008) 2940-2953. Available at (accessed 16 December 2010). 15 16 17 18 Wald ML. "Offshore Wind Is a Bit Closer, Backers Say." Green: A Blog about Energy and the Environment. The New York Times. October 13, 2011. Available at (accessed 2 November 2011). 19 20 21 Wind Powering America. 2011. "Installed Wind Capacity by State." Updated April 29, 2011. Available at (accessed 3 November 2011). 8-91 1 9.0 CONCLUSION 2 3 4 5 6 7 8 9 10 11 12 This draft supplemental environmental impact statement (SEIS) contains the environmental review of Exelon's application for renewed operating licenses for Limerick Generating Station, Units 1 and 2 (LGS), as required by the Code of Federal Regulations (CFR), Part 51 of Title 10 (10 CFR Part 51), the U.S. Nuclear Regulatory Commission's (NRC's) regulations that implement the National Environmental Policy Act (NEPA). This chapter presents conclusions and recommendations from the site-specific environmental review of LGS and summarizes site-specific environmental issues of license renewal that the NRC staff (staff) noted during the review. Section 9.1 summarizes the environmental impacts of license renewal; Section 9.2 presents a comparison of the environmental impacts of license renewal and energy alternatives; Section 9.3 discusses unavoidable impacts of license renewal, energy alternatives, and resource commitments; and Section 9.4 presents conclusions and staff recommendations. 13 9.1. 14 15 16 17 The staff's review of site-specific environmental issues in this SEIS leads to the conclusion that issuing renewed licenses at LGS would have SMALL impacts for the Category 2 issues applicable to license renewal at LGS, as well as environmental justice and chronic effects for electromagnetic fields. 18 19 20 21 22 23 The staff considered mitigation measures for each Category 2 issue, as applicable. For surface water use, current measures to mitigate the environmental impacts of plant operations were found to be adequate. The Delaware River Basin Commission (DRBC) requires LGS to shift to an alternative water source when the flow of the Schuylkill River falls to 560 (15.9 m3/s) to ensure that LGS cooling water withdrawals and associated consumptive use will not reduce flow by more than 12 percent during low-flow periods. 24 25 26 27 28 29 The staff also considered cumulative impacts of past, present, and reasonably foreseeable future actions, regardless of what agency (Federal or non-Federal) or person undertakes them. The staff concluded in Section 4.11 that cumulative impacts of LGS's license renewal would be SMALL for all areas except aquatic ecology and terrestrial ecology. For aquatic ecology, the staff concluded that the cumulative impact would be SMALL to MODERATE. For terrestrial ecology, the cumulative impacts would be MODERATE. 30 9.2. 31 32 In the conclusion to Chapter 8, the staff considered the following alternatives to LGS license renewal: 33 34 35 36 37 38 39 40 41 42 43 Environmental Impacts of License Renewal Comparison of Alternatives ? ? ? ? ? ? natural-gas-fired combined-cycle (NGCC), supercritical pulverized coal, new nuclear, wind power, purchased power, and no-action. The staff concluded that the environmental impacts of renewal of the operating license for LGS would be smaller than those of feasible and commercially viable alternatives. The no-action alternative, the act of shutting down LGS on or before its license expires, would have SMALL environmental impacts in most areas with the exception of socioeconomic impacts which would have SMALL to MODERATE environmental impact. Continued operations would have SMALL 9-1 Conclusion 1 2 environmental impacts in all areas. The staff concluded that continued operation of the existing LGS is the environmentally preferred alternative. 3 9.3. 4 9.3.1. Unavoidable Adverse Environmental Impacts 5 6 7 8 Unavoidable adverse environmental impacts are impacts that would occur after implementation of all workable mitigation measures. Carrying out any of the energy alternatives considered in this SEIS, including the proposed action, would result in some unavoidable adverse environmental impacts. Resource Commitments 9 10 11 12 13 14 15 Minor unavoidable adverse impacts on air quality would occur due to emission and release of various chemical and radiological constituents from power plant operations. Nonradiological emissions resulting from power plant operations are expected to comply with U.S. Environmental Protection Agency (EPA) emissions standards, although the alternative of operating a fossil-fueled power plant in some areas may worsen existing attainment issues. Chemical and radiological emissions would not exceed the National Emission Standards for hazardous air pollutants. 16 17 18 19 20 21 22 23 During nuclear power plant operations, workers and members of the public would face unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be exposed to radiation and chemicals associated with routine plant operations and the handling of nuclear fuel and waste material. Workers would have higher levels of exposure than members of the public, but doses would be administratively controlled and would not exceed standards or administrative control limits. In comparison, the alternatives involving the construction and operation of a non-nuclear power generating facility would also result in unavoidable exposure to hazardous and toxic chemicals to workers and the public. 24 25 26 27 28 29 30 31 The generation of spent nuclear fuel and waste material, including low-level radioactive waste, hazardous waste, and nonhazardous waste would also be unavoidable. In comparison, hazardous and nonhazardous wastes would also be generated at non-nuclear power generating facilities. Wastes generated during plant operations would be collected, stored, and shipped for suitable treatment, recycling, or disposal in accordance with applicable Federal and State regulations. Due to the costs of handling these materials, power plant operators would be expected to carry out all activities and optimize all operations in a way that generates the smallest amount of waste possible. 32 9.3.2. Short-Term Versus Long-Term Productivity 33 34 35 The operation of power generating facilities would result in short-term uses of the environment, as described in Chapters 4, 5, 6, 7, and 8. "Short-term" is the period of time that continued power generating activities take place. 36 37 38 39 40 41 42 43 Power plant operations require short-term use of the environment and commitment of resources and commit certain resources (e.g., land and energy), indefinitely or permanently. Certain short-term resource commitments are substantially greater under most energy alternatives, including license renewal, than under the no-action alternative because of the continued generation of electrical power and the continued use of generating sites and associated infrastructure. During operations, all energy alternatives require similar relationships between local short-term uses of the environment and the maintenance and enhancement of long-term productivity. 9-2 Conclusion 1 2 3 4 5 Air emissions from power plant operations introduce small amounts of radiological and nonradiological constituents to the region around the plant site. Over time, these emissions would result in increased concentrations and exposure, but they are not expected to impact air quality or radiation exposure to the extent that public health and long-term productivity of the environment would be impaired. 6 7 8 9 Continued employment, expenditures, and tax revenues generated during power plant operations directly benefit local, regional, and State economies over the short term. Local governments investing project-generated tax revenues into infrastructure and other required services could enhance economic productivity over the long term. 10 11 12 13 The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous waste, and nonhazardous waste requires an increase in energy and consumes space at treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet waste disposal needs would reduce the long-term productivity of the land. 14 15 16 Power plant facilities are committed to electricity production over the short term. After decommissioning these facilities and restoring the area, the land could be available for other future productive uses. 17 9.3.3. Irreversible and Irretrievable Commitments of Resources 18 19 20 21 22 23 24 25 This section describes the irreversible and irretrievable commitment of resources that have been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit the future options for a resource. An irretrievable commitment refers to the use or consumption of resources that are neither renewable nor recoverable for future use. Irreversible and irretrievable commitment of resources for electrical power generation include the commitment of land, water, energy, raw materials, and other natural and man-made resources required for power plant operations. In general, the commitment of capital, energy, labor, and material resources are also irreversible. 26 27 28 29 The implementation of any of the energy alternatives considered in this SEIS would entail the irreversible and irretrievable commitment of energy, water, chemicals, and in some cases, fossil fuels. These resources would be committed during the license renewal term and over the entire life cycle of the power plant, and they would be unrecoverable. 30 31 32 33 34 Energy expended would be in the form of fuel for equipment, vehicles, and power plant operations and electricity for equipment and facility operations. Electricity and fuel would be purchased from offsite commercial sources. Water would be obtained from existing water supply systems. These resources are readily available, and the amounts required are not expected to deplete available supplies or exceed available system capacities. 9-3 Conclusion 1 9.4. Recommendations 2 3 4 The NRC's preliminary recommendation is that the adverse environmental impacts of license renewal for LGS are not great enough to deny the option of license renewal for energy-planning decisionmakers. This recommendation is based on the following: 5 6 ? the analysis and findings in NUREG-1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, 7 ? the environmental report submitted by Exelon, 8 ? consultation with Federal, state, and local agencies, 9 ? the NRC's environmental review, and 10 ? consideration of public comments received during the scoping process. 9-4 10.0 LIST OF PREPARERS 1 2 3 4 5 Members of the U.S. Nuclear Regulatory Commission's (NRC's) Office of Nuclear Reactor Regulation (NRR) prepared this SEIS with assistance from other NRC organizations and contract support from Pacific Northwest National Laboratory (PNNL). Table 10-1 lists each contributor's name, affiliation, and function or expertise. Table 10-1. List of Preparers 6 Name Affiliation Function or Expertise NRC David Wrona NRR Branch Chief Jeremy Susco NRR Branch Chief Leslie Perkins NRR Project Manager Michelle Moser NRR Aquatic Ecology Briana Balsam NRR Terrestrial Ecology William Rautzen NRR Radiation Protection; Human Health Kevin Folk NRR Hydrology Andrew Stuyvenberg NRR Air Quality & Meteorology; Alternatives Jeffrey Rikhoff NRR Socioeconomics; Environmental Justice; Land Use Emily Larson NRR Historic & Archaeological Resources; Socioeconomic Allison Travers NRR Historic & Archaeological Resources Jerry Dozier NRR Severe Accident Mitigation Alternatives (a) Contractor Eva Hickey PNNL Radiation Protection Ann Miracle PNNL Aquatic Ecology Lance Vail PNNL Hydrology Jim Becker PNNL Terrestrial Ecology Jeremy Rishel PNNL Air Quality & Meteorology Tara O'Neil PNNL Historic & Archaeological Resources David Anderson PNNL Land Use (a) PNNL is operated by Battelle for the U.S. Department of Energy 10-1 1 2 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS SEIS ARE SENT 3 4 Table 11-1. List of Agencies, Organizations, and Persons to Whom Copies of this SEIS Are Sent Name and Title Company and Address EIS Filing Section U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20004 Tom McColloch Office of Federal Programs Advisory Council on Historic Preservation Old Post Office Building, Suite 803 1100 Pennsylvania Avenue, NW Washington, DC 20004 Douglas C. McLearen Chief, Division of Archaeology and Protection Pennsylvania Historical and Museum Commission Bureau for Historic Preservation Commonwealth Keystone Building, 2nd Floor 400 North Street Harrisburg, PA 17120 Jean Cutler Deputy, State Historic Preservation Officer Pennsylvania Historical and Museum Commission Bureau for Historic Preservation Commonwealth Keystone Building, 2nd Floor 400 North Street Harrisburg, PA 17120 Chris Urban Chief, Natural Diversity Section Pennsylvania Fish and Boat Commission Division of Environmental Services Natural Diversity Section 450 Robinson Lane Bellefonte, PA 16823-9620 Olivia Mowery Environmental Planner Division of Environmental Planning and Habitat Protection Bureau of Wildlife Habitat Management Pennsylvania Game Commission 2001 Elmerton Avenue Harrisburg, PA 17110-97-97 Clinton Riley Field Office Supervisor U.S. Fish and Wildlife Service Pennsylvania Field Office 315 South Allen Street, Suite 322 State College, PA 16801 Mark Roberts U.S. Fish and Wildlife Service Pennsylvania Field Office 315 South Allen Street, Suite 322 State College, PA 16801 11-1 List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent Name and Title Company and Address Chris Firestone Pennsylvania Department of Conservation and Natural Resources Bureau of Forestry-Plant Program Forest Advisory Services P.O. Box 8552 Harrisburg, PA 17105-1673 Daniel Morris Acting Regional Administrator National Marine Fisheries Service Northeast Regional Office 55 Great Republic Drive Gloucester, MA 01930-2276 Brice Obermeyer Delaware Tribe Historic Preservation Office 1420 C of E Drive, Suite 190 Emporia, KS 66801 Anthony Gonyea Faithkeeper Onondaga Nation Hemlock Road, 11a Box 319-B Via Nedrow, NY 13120 Sherry White Cultural Preservation Officer Stockbridge-Munsee Band of the Mohican Stockbridge-Munsee Tribal Preservation Office W13447 Camp 14 Road P.O. Box 70 Bowler, WI 54416 Henryetta Ellis Absentee-Shawnee Tribe of Oklahoma 2025 South Gordon Cooper Drive Shawnee, OK 74801 Robin Dushane Cultural Preservation Officer Eastern Shawnee Tribe of Oklahoma P.O. Box 350 Seneca, MO 64865 Tamara Francis Tribal Historic Preservation Officer Tribal Historic Preservation Office Delaware Nation P.O. Box 825 Anadarko, OK 73005 Clint Halftown Heron Clan Representative Cayuga Nation P.O. Box 11 Versailles, NY 14168 Chief Roger Hill Tonawanda Seneca Nation 7027 Meadville Road Basom, NY 14013 Neil Patterson, Jr. Director, Tuscarora Environmental Program Tuscarora Nation 2045 Upper Mountain Road Sanborn, NY 14132 Kim Jumper Tribal Historic Preservation Officer Shawnee Tribe 29 South 69a Highway Miami, OK 74354 11-2 List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent Name and Title Company and Address Arnold Printup Historic Preservation Officer St. Regis Mohawk Tribe 412 State Route 37 Akwesasne, NY 13655 Paul Barton Historic Preservation Officer Seneca-Cayuga Tribe of Oklahoma 23701 South 655 Road Grove, OK 74344 Lana Watt Tribal Historic Preservation Officer Seneca Nation of Indians 90 Ohiyoh Way Salamanca, NY 14779 Corina Burke Tribal Historic Preservation Office Oneida Nation of Wisconsin P.O. Box 365 Oneida, WI 54155-0365 Jesse Bergevin Historian Oneida Indian Nation 1256 Union Street P.O. Box 662 Oneida, NY 13421-0662 Michael P. Gallagher Vice President, License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Nancy L. Ranek Environmental Lead Exelon Generation Company, LLC 200 Exelon Way, KSA-2-E Kennett Square, PA 19348 Chris Wilson Licensing Lead Exelon Generation Company, LLC 200 Exelon Way, KSA-2-E Kennett Square, PA 19348 Environmental Review Section U.S. Environmental Protection Agency Region 3 1650 Arch Street Philadelphia, PA 19103-2029 William Muszynski Branch Manager, Water Resources Management Delaware River Basin Commission P.O. Box 7360 25 State Police Drive West Trenton, NJ 08628-0360 Ken Stoller Project Review Section Chief Delaware River Basin Commission P.O. Box 7360 25 State Police Drive West Trenton, NJ 08628-0360 Steve Walsh Delaware River Basin Commission P.O. Box 7360 25 State Police Drive West Trenton, NJ 08628-0360 Regional Administrator U.S. Nuclear Regulatory Commission Region 1 2100 Renaissance Boulevard Renaissance Park King of Prussia, PA 19406 11-3 List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent Name and Title Company and Address Professor Paul Friesseman Northwestern University 304 Scott Hall Evanston, IL 60208 Michael Stokes Montgomery County Planning Commission P.O. Box 311 Norristown, PA 19404 Thomas Sullivan Montgomery County Department of Public Safety Operation Center 50 Eagleville Road Eagleville, PA 19403 Natural Resources Defense Counsel Natural Resource Defense Counsel 1152 15th Street NW, Suite 300 Washington, DC 20005 Representative Tom Quigley Pennsylvania State Representative Lorraine Ruppe Resident Dr. Fred Winter Resident Dr. Anita Baly Resident Camilla Lange Resident Eric Hamell Resident Steven Furber Resident Charlene Padworny Resident Sylvia Polluck Resident Joe Roberto Resident Richard Kolsch Resident Charles Shank Resident Elizabeth Shank Resident Nancy Leaming Resident Cynthia Gale Resident Jude Shwegel Resident Michael Gale Resident Melissa Atrium Resident Michael Atrium Resident Joan McGone Resident Mary Lou Smith Resident Harold Smith Resident Lisa Moyer Resident Ken Sekellick Resident Debby Penrod Resident Charlie Koeing Resident 11-4 List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent Name and Title Company and Address Joyce Webber Resident Charlotte Derr Resident Dr. Lewis Cuthbert Alliance for Clean Environment Sharon Yohn Resident Michael Smokowicz Resident Barbara Miller Resident Bill Maguire Exelon Generation Company, LLC 11-5 12.0 INDEX 1 23 A 4 5 6 7 accidents, xviii, 4-38, 5-1, 5-2, 5-3, 5-4, 5-5, 5-7, 5-8, 5-9, 5-10, 5-12, 5-13, 5-14, 8-82,A-12, A-27, A-29, A-31, A-32, A-33, B-9 8 Advisory Council on Hispanic 9 Preservation (HCHP), 1-7, 2-83, 2-94, 10 4-31, 4-59, 11-1 11 12 13 14 15 16 17 18 19 20 alternatives, iii, xviii, xix, 1-6, 5-2, 5-3, 5-3, 5-7, 5-13, 6-3, 6-4, 6-5, 8-1, 8-2, 8-3, 8-4, 8-5, 8-8, 8-9, 8-10, 8-12, 8-18, 8-24, 8-28, 8-32, 8-33, 8-37, 8-41, 8-42, 8-43, 8-46, 8-48, 8-49, 8-51, 8-53, 8-56, 8-58, 8-59, 8-60, 8-61, 8-62, 8-63, 8-64, 8-66, 8-68, 8-69, 8-70, 8-71, 8-72, 8-73, 8-77, 8-78, 8-79, 8-81, 8-84, 9-1, 9-2, 9-3, 10-1, A-1, A-7, A-8, A-9, A-22, A-29, A-30, A-31, A-32, A-33, A-42, B-9 21 22 23 24 archaeological resources, xviii, 1-7, 2-80, 2-82, 3-2, 4-28, 4-31, 4-52, 8-3, 8-15, 8-26, 8-35, 8-44, 8-47, 8-54, 8-55, 8-63, 8-72, 8-83, 8-85, 10-1, B-9, D-1 25 B 26 biota, 2-32, 2-37, 2-40, 2-43, 2-45, 4-7, 27 4-13, 4-14, 4-46, 4-47, 4-48,8-11, 8-69, 28 B-2 29 boiling water reactor, 2-1, 3-1, 5-6, A-30, 30 B-7 31 burnup, 2-1, 5-12, 5-13, B-13 32 C 33 chronic effects, 1-3, 4-21, 4-28, 9-1, B-7 34 Clean Air Act (CAA), 2-26, 2-87, 4-43, 35 8-7, 8-18, 8-19, 8-57, 8-66, 8-86, A-10, 36 C-2 37 38 39 40 closed-cycle cooling, xvi, 1-4, 1-6, 2-16, 2-20, 2-21, 2-31, 2-54, 4-8, 4-9, 4-10, 4-13, 4-15, 4-47, 8-3, 8-5, 8-6, 8-11, 8-22, 8-23, 8-28, 8-32, 8-69, 8-80, B-2, B-3, B-4 41 core damage frequency (CDF), A-30 42 Council on Environmental Quality 43 (CEQ), 1-4, 4-55 44 45 46 47 critical habitat, 2-52, 2-57, 2-59, 2-60, 2-61, 2-85, 4-15, 4-19, 8-11, 8-12, 8-22, 8-23, 8-32, 8-40, 8-41, 8-51, 8-59, 8-60, 8-69, C-4 48 D 49 design-basis accident, 4-38, 5-1, B-9 50 51 52 53 54 55 dischargers, 2-2, 2-8, 2-16, 2-20, 2-33, 2-34, 2-45, 4-5, 4-6, 4-8, 4-9, 4-13, 4-14, 4-24, 4-44, 4-45, 4-47, 4-48, 8-10, 8-11, 8-21, 8-22, 8-31, 8-39, 8-59, 8-69, A-33, A-41, A-41, B-1, B-2, B-7, C-3, F-2, F-3, F-4 56 57 58 59 dose, 2-2, 4-8, 4-22, 4-23, 4-24, 4-25, 4-38, 4-40, 4-50, 4-51, 4-53, 5-8, 5-9, 5-12, 5-13, 7-1, 8-35, 9-2, A-18, A-19, A-20, B-7, B-9, B-10, B-11, B-12, B-13 60 E 61 education, 2-67, 2-76, 2-93, 2-95, 2-96, 62 3-2, 4-28, A-23, B-8 63 electromagnetic fields, xviii, 1-3, 4-8, 64 4-21, 4-27, 4-28, 8-52, 9-1, B-6, B-7 65 66 67 68 12-1 endangered and threatened species, 1-7, 1-8, 2-15, 2-50, 2-52, 2-59, 2-85, 2-88. 2-93. 4-10. 4-16. 4-54. 4-58, 8-11, C-4, D-1 Index 1 2 3 4 Endangered Species Act (ESA), 1-7, 1-8, 2-15, 2-50, 2-52, 2-59, 2-85, 2-88, 2-93, 4-10, 4-16, 4-54, 4-58, 8-11, C-4, D-1 5 entrainment, 4-7, 4-13, 8-11, 8-22, 8-31, 6 8-82, B-2, B-3, B-4 7 8 9 10 11 environmental justice (EJ), xviii, 1-3, 1-6, 3-2, 4-28, 4-32, 4-33, 4-38, 4-51, 4-54, 4-55, 8-3, 8-15, 8-26, 8-35, 8-44, 8-48, 8-55, 8-63, 8-72, 8-83, 9-1, 10-1, B-13 12 essential fish habitat (EFH), C-4, D-1 13 F 14 Fish and Wildlife Coordination Act 15 (FWCA), C-4 16 G 17 18 19 20 21 22 23 24 25 Generic Environmental Impact Statement (GEIS), xv, xvi, xvii, xx, 1-3, 1-4, 1-5, 1-6, 1-8,.2-70, 2-71, 3-1, 3-2, 4-1, 4-2, 4-27, 4-28, 4-29, 4-30, 4-33, 4-39, 4-40, 5-1, 5-2, 5-3, 5-4, 5-5, 5-8, 5-14, 6-1, 6-2, 6-3, 7-1, 7-2, 8-1, 8-2, 8-9, 8-12, 8-13, 8-16, 8-23, 8-24, 8-25, 8-33, 8-36, 8-42, 8-45, 8-53, 8-61, 8-70, 8-74, 8-77, 8-78, 8-80, 8-81, A-1, A-5, B-1, B-9 26 greenhouse gases, 6-3, A-34, A-35, 27 A-38, A-39 28 29 30 31 32 33 34 35 36 groundwater, xviii, 1-6, 2-16, 2-21, 2-22, 2-23, 2-35, 2-26, 2-3, 7, 2-55, 2-56, 2-68, 3-1, 4-4, 4-5, 4-6, 4-7, 4-21, 4-23, 4-24, 4-39, 4-40, 4-41, 4-43, 4-45, 4-46, 4-53, 4-55, 8-3, 8-8, 8-9, 8-10, 8-16, 8-20, 8-21, 8-22, 8-27, 8-28, 8-30, 8-31, 8-36, 8-39, 8-45, 8-46, 8-48, 8-50, 8-56, 8-58, 8-65, 8-68, 8-74, 8-81, 8-84, 8-85, A-7, A-12, A-13, A-41, B-4, B-5, B-9, C-1 37 H 38 hazardous waste, 2-7, 2-8, 2-85, 2-86, 39 9-2, 9-3, C-4, C-6 40 heat shock, 4-7, 8-82, B-4 41 high-level waste, xvi, 1-4, 6-1, 6-2, 8-36, 42 8-83, B-9, B-10, B-11, B-12, B-13 43 I 44 Impingement, 4-7, 4-18, 8-11, 8-22, 8-31, 45 8-82, B-2, B-4, 4-7, 4-13 46 Independent spent fuel storage 47 installation, 2-2, 2-70, 4-42, 4-50, 4-53, 48 A-12, F-5 49 L 50 low-level waste, 6-1, 8-36, B-12 51 M 52 Magnuson-Stevenson Fishery 53 Conservation and Management Act 54 (MSA), 1-7, 2-50, C-4 55 Marine Mammal Protectino Act 56 (MMPA), C-4, 57 maximum occupational dose, 4-22, B-7 58 59 60 61 62 63 64 mitigation, xvi, xvii, 1-4, 1-6, 2-15, 2-82, 4-7, 4-9, 4-22, 4-29, 4-40, 4-42, 5-3, 5-5, 5-6, 5-7, 5-9, 5-11, 5-13, 5-13, 5-14, 5-15, 5-16, 5-17, 6-10, 7-1, 7-2, 8-15, 8-26, 8-35, 8-44, 8-47, 8-51, 8-54, 8-60, 8-68, 8-72, 9-1, 9-2, 10-1, A-6, A-12, A-24, A-29, A-30, A-31, A-33 65 mixed waste, 2-7, 6-1, 8-36, 8-83, B-12 66 N 67 68 69 70 12-2 National Environmental Policy Act (NEPA), xii, 1-1, 1-8, 2-92, 4-31, 4-33, 4-55, 4-58, 6=-2, 8-1, 9-1, 8-13, A-43, B-1, B-10, B-11 Index 1 2 3 4 5 National Marine Fisheries Service (NMFS), 1-7, 2-38, 2-40, 2-45, 2-50, 2-51. 2=-52. 2-53. 2-54. 2-84. 2-93. 4=-10. 4-11. 4-12, 4-58, 4-59, 8-11, 8-22, 8-32, 8-40, 8-51, 8-59, 8-60, 8-69, C-4 6 7 8 9 10 11 12 National Pollutant Discharge Elimination System (NPDES), 2-8, 2-16, 2-20, 2-21, 2-31, 2-32, 2-33, 2-36, 2-45, 2-90, 4-13, 4-14, 4-26, 4-47, 8-9, 8-10, 8-20, 8-21, 8-22, 8-30, 8-31, 8-39, 8-40, 8-51, 8-59, 8-68, A-41, A-42, B-2, C-1, C-3, C-5 37 S 38 salinity gradients, 4-3, B-1 39 40 41 42 43 scoping, iii, xv, xvii, xx, 1-2, 1-3, 1-6, 2.95, 4-1, 4-2, 4-3, 4-5, 4-7, 4-8, 4-9, 4-21, 4-22, 4-29, 4-32, 4-41, 5-2, 5-11, 5-12, 5-17, 6-2, 7-2, 9-4, A-1, A-2, A-3, A-6, A-18, A-44, E-2, F-1 44 45 46 47 severe accident mitigation alternative (SAMA), 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 5-10, 5-11, 5-12, 5-13, 5-14, A-6, A-7, A-22, A-27, A-29, A-30, A-31, A-32, A-33 13 nonattainment, 2-26, 2-86, 3-2, 4-42, 14 8-7, 8-18, 8-23, 8-29, 8-38, 8-50, 8-57, 15 8-66, B-6 48 severe accidents, 4-38, 5-1, 5-2, 5-3, 49 5-4, 5-5, 5-7, 5-9, 5-10, 5-13, 5-14, A-12, 50 A-29, A-31, A-32, A-33, B-9 16 O 51 solid waste, xix, 2-2, 2-6, 2-7, 6-1, 6-2, 52 7-2, 8-2, 8-76, 8-77, 8-79, A-10, B-13, 53 C-1, C-4 17 once-through cooling, B-2, B-3, B-4 18 P 19 peak dose, B-10 20 pressurized water reactor, 3-1 21 R 22 radon, 4-23, A-19, B-9 23 Ranny wells, B-5 24 25 26 27 28 29 30 31 reactor, xv, xvi, 1-1, 1-5, 2-1, 2-2, 2-6, 2-9, 2-29, 2-70, 2-84, 3-1, 4-1, 4-6, 4-24, 4-25, 4-26, 4-29, 4-50, 4-51, 4-54, 5-1, 5-2, 5-3, 5-4, 5-5, 5-6, 5-12, 5-14, 6-2, 6-4, 6-10, 7-1, 8-2, 8-6, 8-11, 8-17, 8-23, 8-28, 8-32, 8-41, 8-82, 8-84, A-11, A-12, A-18, A-21, A-23, A-24, A-25, A-26, A-30, A-31, A-42, B-5, B-7, B-9, B-12 32 33 34 35 36 refurbishment, 2-27, 2-80, 3-1, 3-2, 4-2, 4-9, 4-10, 4-11, 4-12, 4-13, 4-15, 4-16, 4-21, 4-25, 4-33, 4-42, 4-43, 4-53, 8-21, 8-31, A-11, B-1, B-2, B-4, B-6, B-7, B-8, B-9 54 55 56 57 58 spent fuel, xvi, 1-4, 2-1, 2-2, 2-70, 4-50, 5-5, 5-6, 6-1, 6-2, 6-10, 8-16, 8-28, 8-36, 8-45, 8-48, 8-56, 8-65, 8-74, 8-84, 8-85, A-12, A-24, A-28, A-29, A-33, A-34, B-9, B-10, B-11, B-12, B-13, F-5 59 State Historic Preservation Office 60 (SHPO), 2-84, 2-94, 4-59, B-9 61 62 63 64 65 66 67 surface water, 2-21, 2-22, 2-31, 2-32, 2-36, 2-60, 2-67, 3-1, 4-2, 4-3, 4-4, 4-5, 4-6, 4-23, 4-38, 4-39, 4-43, 4-44, 4-45, 4-47, 4-48, 4-53, 8-3, 8-9, 8-10, 8-11, 8-21, 8-22, 8-30, 8-31, 8-39, 8-51, 8-59, 8-68, 8-69, 8-81, 9-1, A-10, A-13, A-41, A-42, B-1, B-4, C-1, C-3 68 T 69 70 71 72 73 74 12-3 Transmission lines, 2-15, 2-49, 2-50, 2-51, 2-52, 2-59, 2-82, 2-97, 4-2, 4-10, 4-13, 4-14, 4-15, 4-16, 4-17, 4-18, 4-20, 4-27, 4-28, 4-42, 4-49, 4-52, 4-61, 8-6, 8-28, 8-39, 8-46, 8-47, 8-51, 8-53, 8-55, 8-70, 8-82, B-6, B-9 Index 1 U 2 U.S. Department of Energy (DOE), 4-28, 3 8-3, 8-37, 8-38, 8-75, 8-87, 8-89, 8-90, 4 B-11 5 6 7 8 9 10 11 12 U.S. Environmental Protection Agency (EPA), 1-1, 1-7, 2-7, 2-8, 2-9, 2-24, 2-26, 2-35, 2-36, 2-37, 2-69, 2-70, 2-89, 4-6, 4-25, 4-40, 4-42, 4-45, 4-46, 4-47, 4-50, 4-55, 8-3, 8-7, 8-18, 8-19, 8-23, 8-29, 8-38, 8-50, 8-57, 8-66, 8-67, 8-77, 8-80, 8-86, 8-87, 8-88, 9-2, 11-1, A-13, A-14, B-1, B-11, C-1, C-2, C-3, C-4, C-6, F-5 13 U.S. Fish and Wildlife Service (FWS), 14 2-50, 2-51, 2-52, 2-55, 2-57, 2-59, 2-60, 15 2-61, 2-62, 2-84, 2-90, 2-91, 4-10, 4-11, 16 4-12, 4-17, 4-18, 4-19, 4-57, 8-11, 8-12, 17 8-22, 8-23, 8-32, 8-40, 8-41, 8-51, 8-59, 18 8-60, 8-69, D-1, D-2 19 20 21 22 uranium, 2-1, 2-2, 4-50, 5-12, 6-1, 6-2, 6-4, 6-5, 6-6, 6-7, 6-8, 6-9, 8-5, 8-13, 8-23, 8-24, 8-32, 8-33, 8-42,8-53, 8-61, 8-70, A-34, B-9, B-12, B-13 23 W 24 wastewater, 2-8, 2-21, 2-31, 2-33, 2-36, 25 2-40, 2-45, 4-3, 4-43, 4-44, 4-47, 8-77, 26 A-40, B-2, F-2, F-3 27 Y 28 Yucca Mountain, B-10, B-11, B-13 12-4 1 2 3 APPENDIX A COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, UNITS 1 AND 2, ENVIRONMENTAL REVIEW 1 2 COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, UNITS 1 AND 2, ENVIRONMENTAL REVIEW 3 A.1. Comments Received during Scoping 4 5 6 7 8 9 10 11 12 13 14 15 16 17 The scoping process began on August 26, 2011, with the publication of the U.S. Nuclear Regulatory Commission's (NRC's) notice of intent to conduct scoping in the Federal Register (FR) (75 FR 53498). As part of the scoping process, the NRC held two public meetings at the Sunnybrook Ballroom in Pottstown, PA, September 22, 2011. Approximately 100 members of the public attended the meetings. After the NRC staff presented prepared statements pertaining to the license renewal and the scoping processes, the meetings were opened to members of the public for their comments. Attendees provided oral statements that were recorded and transcribed by a certified court reporter. Transcripts of the entire meeting are available using the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. Transcripts for the afternoon and evening meetings are available in ADAMS under Accession Nos. ML11287A207 and ML11287A211, respectively (NRC 2011a, NRC 2011b). In addition to the comments received during the public meetings, comments were received through the mail and e-mail. 18 19 20 21 22 23 24 Each commenter was given a unique identifier so that every comment could be traced back to its author. Table A-1 identifies the individuals who provided comments applicable to the environmental review and the commenter ID associated with each person's set of comments. The individuals are listed in the order in which they spoke at the public meeting and in random order for the comments received by letter or e--mail. To maintain consistency with the scoping summary report, the unique identifier used in that report for each set of comments is retained in this appendix. 25 26 27 Specific comments were categorized and consolidated by topic. Comments with similar specific objectives were combined to capture the common essential issues raised by participants. Comments fall into one of the following general groups: 28 29 30 31 32 33 34 35 o Specific comments that address environmental issues within the purview of the NRC environmental regulations related to license renewal. These comments address the Category 1 (generic) or Category 2 (site-specific) issues identified in NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GEIS), or issues not addressed in the GEIS. The comments also address alternatives to license renewal and related Federal actions. There are also comments that do not identify new information for the NRC to analyze as part of its environmental review. 36 37 38 39 40 41 o There are comments that address issues that do not to fall within or are specifically excluded from the purview of NRC environmental regulations related to license renewal. These comments typically address issues such as the need for power, emergency preparedness, security, current operational safety issues, and safety issues related to operation during the renewal period. 42 A-1 Appendix A 1 2 3 Table A-1. Individuals Providing Comments during the Scoping Comment Period Commenters are identified below, along with their affiliations and how their comments were submitted. Thomas Neafcy Dr. Anita Baly Tim Fenchel Bill Vogel State Representative 3 Resident 4 Vice President for License Renewal, Exelon 5 Resident 6 Resident 7 Resident 8 Afternoon scoping meeting Ml11287A207 Evening scoping meeting ML11287A211 Afternoon scoping meeting ML11287A207 ML11287A207 Evening scoping meeting ML11287A211 ML11308B354 Afternoon scoping meeting ML11287A207 Evening scoping meeting ML11287A211 ML11287A207 Evening scoping meeting ML11287A211 ML11305A016 Afternoon scoping meeting ML11287A207 Afternoon scoping meeting ML11287A207 Letter Dr. Fred Winter 2 ML11354A392 ML11036A244 ML11036A245 Letter Mike Gallagher Limerick Site Vice President, Exelon ML11287A211 Afternoon scoping meeting Lorraine Ruppe 1 Evening scoping meeting Letter Representative Tom Quigley Alliance for a Clean Environment ML11287A207 Afternoon scoping meeting Bill Maguire ID ADAMS Accession Number Letters Dr. Lewis Cuthbert Affiliation (if stated) Comment source Afternoon scoping meeting Commenter ML11035A010 Schuylkill River Heritage Area 9 Afternoon scoping meeting ML11287A207 Resident 10 Afternoon scoping meeting ML11287A207 A-2 Appendix A Affiliation (if stated) ID Comment source ADAMS Accession Number Tri-County Area Chamber of Commerce 11 Afternoon scoping meeting ML11287A207 Resident 12 Afternoon scoping meeting ML11287A207 John McGowen Jaeco/Gas Breaker/UMAC, Inc. 13 Afternoon scoping meeting ML11287A207 Ted Del Gaizo Resident 14 Afternoon scoping meeting ML11287A207 Tim Phelps Resident 15 Afternoon scoping meeting ML11287A207 Saporito-Associates 16 Evening scoping meeting ML11287A207 Jeff Chomnuk Resident 17 Evening scoping meeting ML11287A207 Daniel Ludwig Resident 18 Evening scoping meeting ML11287A207 19 Evening scoping meeting ML11287A207 Pennsylvania Energy Alliance 20 Evening scoping meeting ML11287A207 Dan Ely Resident 21 Evening scoping meeting ML11287A207 Jay Beckermen Resident 22 Evening scoping meeting ML11287A207 Pottstown Energy Advisory Committee 23 Evening scoping meeting ML11287A207 Energy Justice Network 24 Evening scoping meeting ML11287A207 Camilla Lange 25 E-mail ML11279A107 Eric Hamell 26 E-mail ML11279A108 Steven Furber 27 E-mail ML11279A109 Charlene Padworny 28 Letter ML11279A110 Sylvia Polluck 29 Letter ML11279A111 Joe Roberto 30 E-mail ML11290A106 E-mail ML11279A112 Commenter Eileen Dautrich Billy Albany Thomas Saporito Catherine Allison Jeffrey Norton Jim Der Traci Confer Brice Obermeyer Sherry White Delaware Tribe Historic Preservation Office 31 Letter ML11279A113 Stockbridge-Munsee Tribal Historic Preservation Office 32 Letter ML11279A114 A-3 Appendix A Commenter ID Unknown Comment source ADAMS Accession Number 33 Affiliation (if stated) Letter ML11286A298 Richard Kolsch Resident 34 E-mail ML11286A299 Charles and Elizabeth Shank Resident 35 Letter ML11286A300 Nancy Leaming Resident 36 E-mail ML11290A102 Cynthia Gale Resident 37 E-mail ML11290A103 38 E-mail ML11290A104 Jude Schwegel Michael Gale Resident 39 E-mail ML11290A105 Melissa Antrim Resident 40 E-mail ML11291A155 Michael Antrim Resident 41 E-mail ML11291A156 42 E-mail ML11292A011 43 Letter ML11294A208 Lisa Smoyer 44 E-mail ML11300A011 Unknown 45 Letter ML11300A012 Joan McGone Mary Lou and Harold Smith Resident Lori Molinari Resident 46 Letter ML11305A072 Doris Meyers Resident 47 E-mail ML11305A014 Ken Sekellick Resident 48 E-mail ML11305A015 Onondaga Nation 49 Letter ML11305A006 Debby Penrod Resident 50 E-mail ML11305A007 Charlie Koeing Resident 51 E-mail ML11305A008 Joyce Webber Resident 52 E-mail ML11305A009 Charlotte Derr Resident 53 Letter ML11307A388 Michael Stokes Montgomery County Planning Commission 54 Letter ML11307A387 Montgomery County Department of Public Safety 55 Letter ML11307A386 Natural Resources Defense Council 56 Letter ML11307A456 Sharon Yohn 57 E-mail ML11307A455 Michael Smokowicz 58 E-mail ML11307A454 Anthony Gonyea Thomas Sullivan Barbara Miller Resident 59 Letter ML11311A063 Debra Schneider Resident 60 Letter ML11313A013 A-4 Appendix A 1 2 3 4 To evaluate the comments, the NRC staff gave each comment a unique identification code that categorizes the comment by technical issue and allows each comment or set of comments to be traced back to the commenter and original source (transcript, letter, or e-mail) from which the comments were submitted. 5 6 7 8 Comments were placed into one of the technical issue categories, which are based on the topics that will be contained within the staff's supplemental environmental impact statement (SEIS) for Limerick Generating Station (LGS), as outlined by the GEIS. These technical issue categories and their abbreviation codes are presented in Table A-2. Table A-2. Technical Issue Categories Comments were divided into 1 of the 16 categories below, each of which has a unique abbreviation code. 9 10 11 Code Technical issue AL Alternatives Energy Sources AM Air & Meteorology DC Decommissioning GE Geology GW Ground water HA Historical and Archeological HH Human Health LU Land Use LR License Renewal and its Process OL Opposition to License Renewal OS Outside of Scope(a) PA Postulated Accidents and Severe Accident Mitigation Analyses (SAMA) RW Radioactive & Non-Radioactive Waste SE Socioeconomics SR Support of License Renewal SW Surface Water (a) 12 13 14 15 16 Outside of scope are those comments that pertain to issues that are not evaluated during the environmental review of license renewal and include, but are not limited to, issues such as need for power, emergency preparedness, safety, security, terrorism, and spent nuclear fuel storage and disposal. Comments received during scoping applicable to this environmental review are presented in this section, along with the NRC response. They are presented in the order shown in Table A-3. The comments that are outside the scope of the environmental review for LGS are not included here but can be found in the scoping summary report, which can be accessed through ADAMS, Accession No. ML12131A499. A-5 Appendix A 1 Table A-3. Comment Response Location in Order of Resource Area Comment category Page Alternative Energy Sources (AL) A-7 Air & Meteorology (AM) A-10 Decommissioning (DC) A-10 Geology (GE) A-11 Groundwater (GW) A-12 Historical and Archeological (HA) A-13 Human Health (HH) A-14 Land Use (LU) A-20 License Renewal and its Process (LR) A-20 Opposition to License Renewal (OR) A-24 Postulated Accidents and SAMA (PA) A-27 Radioactive & Non-Radioactive Waste (RW) A-33 Socioeconomics (SE) A-34 Support of License Renewal (SR) A-35 Surface Water (SW) A-39 2 A.1.1. Alternative Energy Sources (AL) 3 4 5 Comment: 1-44-AL; We have had 26 years of insults to our environment, and I choose that word purposely, insults to our environment and costly nuclear power. We can replace it with safe, clean, renewable energy before 2029. That is a matter of scientific fact. 6 7 8 9 10 Comment: 4-8-AL; Solar wind, geothermal, ocean thermal, energy conservation and efficiency are now cheaper than nuclear power, along with being truly clean and safe. The Department of Energy 2006 report stated solar alone could provide 55 times our entire nation's energy needs which leads me to a point, there have been numerous studies proving the many dangerous and deadly consequences of nuclear power. 11 12 13 14 15 16 17 18 19 Comment: 5-3-AL; We also reviewed the alternatives if Limerick would not have its license renewed and another source of electric generation would need to be installed either here on site or someplace else to generate the replacement electricity. We concluded that any other means of generating the replacement electricity would have more of an impact on the environment than continued operation of Limerick. For instance, if Limerick could be replaced by a wind generation facility, the wind from [it] would have to occupy between 10 and 40 percent of all the land in the state of Delaware and that would have a huge impact on the land. If a solar facility could replace Limerick, it would need to cover 32 to 50 percent the entire land area of Montgomery County. 20 21 22 Comment: 6-10-AL; Please listen to this advice after years of doing my best for America. Rely on more and truly safe and renewable sources like solar, wind, and geothermal power. A patriotic duty to protect our kids. A-6 Appendix A 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Comment: 16-7-AL; The NRC is required under the law in this review, the environmental review to consider renewable energy sources, alternatives. And that means need. Is there really a need for these two nuclear plants to operate and the answer is no. Simply stated if all the customers who receive power from these nuclear plants were to simply remove their hot water heaters and replace them with on-demand electric water heaters you would reduce the electric base load demand by 50 to 70 percent. You wouldn't need either one of those nuclear power plants to operate. If you take that further and introduce other energy conservation you would actually have the licensee shut down more of their other power plants because of you would need a demand. If you take wind energy which is plentiful up there in Pennsylvania and even the new solar panel which can operate when the sun isn't shining on a cloudy day you could replace even more operating power plants. So these renewable energy sources even with respect to wind energy since you have a common grid throughout the United States you can have wind farms generate power to a common grid point and supplying the power that these nuclear plants are now providing. The NRC's required under the law to consider these alternatives to extending this license. And I would hope that the NRC's final evaluation and review shows a complete and thorough analysis of all these renewable energy sources including installing on demand hot water electric heater and doing an analysis of how many megawatts you're going to take off the grid and based on those evaluations make a licensing determination whether or not this license should be extended. Because 20 years from now all these renewable resources are going to be all that much more advanced and capable of supplying all that much more power than they're currently supplying. 22 23 Comment: 25-5-AL; Other forms of energy can and must be utilized to meet consumption demands. 24 25 Comment: 27-1-AL; I am under the belief that the natural disaster in Japan is enough for Pennsylvania to make a move toward clean energy. 26 27 28 Comment: 28-2-AL; I support more healthy and efficient sources of energy such as Solar and Wind Power. Please stop ignoring the detrimental effects that this power plant is having on our environment, health, and children's health...it's time to move on to betters things for all involved. 29 30 Comment: 29-1-AL; I hope Exelon Energy does not get Renewed. I am sure we could find alternative energy that would not be contaminating the whole area. 31 32 33 34 35 Comment: 35-6-AL; The nuclear process is not an enlightened way to generate electrical energy. This plant needs to transition itself into a more intelligent way of generating energy by actually phasing out and safely shutting down the nuclear plant. By retraining its workers and adopting the safer green technologies, it could truly partner with the local community without putting its workers out of jobs. 36 37 Comment: 37-15-A, 39-16-AL; Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replaced With Safe, Clean, Renewable Energy 38 39 40 41 42 43 Comment: 44-5-AL; We as a society need to wake up and start paying attention to the massive harm power plants can cause to the people, animals, water, air, etc. Why does everyone want to pay attention when it is way too late?? There are safer alternative forms of energy available to our country/communities. We should be working on them and training employees, who currently work for the nuclear power plants, how to work with safer forms of energy to help our country move forward in today's society. 44 45 46 Comment: 44-10-AL; We deserve to live in a community where our air and water isn't being contaminated constantly with hazardous chemicals, radiation, etc., when there are other energy alternatives out there that are being used that are safer for the community. A-7 Appendix A 1 2 3 4 5 Comment: 44-12-AL; Do your job knowing that you are doing what is morally right and safe for humanity and for my children and for the future of generations to come. Please help women have a chance to carry a baby full term without complications due to any possible air and water pollution that may have been caused by allowing more radiation into the environment when there are safer alternatives for energy. 6 7 Comment: 53-2-AL; We need cleaner air and water. We need to decrease radiation. We need clean, safe, renewable energy. 8 9 Comment: 60-3-AL; Do not extend--Plenty of safe alternatives--water--solar--wind-- geothermal. 10 Comment: 60-19-AL; Can replace with clean renewable energy before current license expires. 11 12 13 14 Response: In evaluating alternatives to license renewal, the NRC staff first selects energy technologies or options currently in commercial operation, as well as some technologies not currently in commercial operation but likely to be commercially available by the time the current LGS's operating licenses expire, in 2024 and 2029. 15 16 17 18 19 Second, the NRC staff screens the alternatives to remove those that cannot meet future system needs. Then, the remaining options are screened to remove those whose costs or benefits don't justify inclusion in the range of reasonable alternatives. Any alternatives remaining, then, constitute alternatives to the proposed action that the NRC staff evaluates in depth throughout Chapter 8. 20 21 22 23 The staff will evaluate all reasonable alternatives in Chapter 8 of the SEIS. In this chapter, the NRC staff examines the potential environmental impacts of alternatives to license renewal for LGS, as well as alternatives that may reduce or avoid adverse environmental impacts from license renewal, when and where these alternatives are applicable. 24 25 26 27 In addition to evaluating alternatives to the proposed action, the NRC staff also--when appropriate--examines alternatives that may reduce or avoid environmental impacts of the proposed action; the NRC staff does so to illustrate how such alternatives may mitigate potential impacts of license renewal. 28 29 30 The NRC staff considered 18 alternatives to the proposed action and then narrowed to the five alternatives considered. In addition to the five alternative, the staff considered the no-action alternative (not renewing the operating license). 31 The alternatives evaluated in depth included the following; 32 33 34 35 36 37 38 39 40 41 42 43 44 o o o o o o natural-gas-fired combined-cycle (NGCC) supercritical pulverized coal new nuclear wind power purchased power no action Other alternatives considered, but dismissed, are listed below: o o o o o o solar power combination alternative of wind, solar, and NGCC combination alternative of wind and compressed-air energy storage wood waste conventional hydroelectric power ocean wave and current energy A-8 Appendix A 1 2 3 4 5 6 7 o o o o o o municipal solid waste biofuels oiled-fired power delayed retirement coal-fired integrated gasification combined-cycle demand-side management A.1.2. Air & Meteorology (AM) 8 9 10 Comment: 1 -16-AM; Major air pollution issues under health-based standards of the Clean Air Act, 32 individual sources listed. Drastic, harmful increases permitted in particulate matter known also as PM-10 from the cooling towers, other air pollution increases also permitted. 11 12 13 14 15 16 Comment: 1-22-AM; They are a major air polluter under the Clean Air Act and to say they're not doing it anymore, they just asked for the conditions that would allow an eightfold increase in dangerous air pollution that actually is claimed to kill people, thousands of deaths per year. And they asked for an eightfold increase. As a matter of fact, these are all the air pollution sources and the pollutants they list in their own permit. If you add that to all the radiation emissions there's a broad range of radionuclides. 17 18 19 Comment: 1-32-AM; [M]ajor air pollution under health-based standards of the Clean Air Act. A Title 5 permit being issued to this facility means by definition that they are a major air polluter under the federal Clean Air Act. 20 21 Comment: 37-2-AM, 39-3-AM; Major Air Pollution Under Health Based Standards of the Clean Air Act 22 Comment: 60-8-AM; They want increase emissions--Pollutants 23 24 25 Response: Air pollutant emissions associated with LGS operations are presented in Sections 2.2.2.1 of the SEIS. The NRC's evaluation of LGS's air emissions is presented in Section 4.2 of this SEIS. 26 27 28 Comment: 35-3-AM; Limerick Nuclear's request for re-licensing is ludicrous, considering its aging and inadequate equipment, its increased air pollution by particulate matter, its horrific destruction of Schuylkill river 29 30 31 Response: Aging management of plant systems is evaluated as part of the LRA safety review. The results of the staff's safety review of the LRA for LGS will be documented in the staff's safety evaluation report (SER). 32 33 Air pollutant emissions associated with LGS operations are presented in Sections 2.2.2.1 of the SEIS. The NRC's evaluation of LGS's air emissions is presented in Section 4.2 of this SEIS. 34 35 36 37 Surface water resources at LGS, including the Schuylkill River, and the effects of plant operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied upon by LGS and including the sources of water used to augment low flows in the Schuylkill River. 38 A.1.3. Decommissioning (DC) 39 40 41 Comment: 34-2-DC; A firm closure plan should be approved before license renewal is accepted. This must include what is to be done with the site, where the nuclear waste will be disposed of etc. A-9 Appendix A 1 2 3 4 5 6 7 8 9 10 Response: Decommissioning would occur whether LGS were shut down at the end of its current operating license or at the end of the period of extended operation. Environmental impacts from the activities associated with the decommissioning of any reactor before or at the end of an initial or renewed license are evaluated in the GElS (NUREG-1437) and in NUREG-0586 Generic Environmental Impact Statement for Decommissioning Nuclear Facilities, Supplement 1, "Regarding the Decommissioning of Nuclear Power Reactors," published in 2002. The findings from these two documents are used to support the findings in the SEIS by the use of tiering. Tiering is a process by which agencies eliminate repetitive discussions. The effects of license renewal on the impacts of decommissioning are stated in Chapter 7 of this SEIS. 11 A.1.4. Geology (GE) 12 13 Comment: 1-12- GE; Limerick, in addition, is now third on the earthquake risk list for nuclear plants in the United States. 14 15 Comment: 4-2-GE; [F]our months have passed since the NRC failed to get back to me when I asked how close the Remapo fault line is to the Limerick nuclear reactors? 16 17 18 19 Comment: 4-14-GE; It took five months for the Nuclear Regulatory Commission to answer my question concerning how close the nearest fault line is to Limerick Nuclear Plant. No wonder! Two faults are dangerously close. Chalfont Fault is only 9 miles East. Ramapo Fault is 17 miles Northwest. This is alarming! 20 21 Comment: 30-2-GE; Limerick should NOT be approved for an extension with their permit for the following reasons: 22 23 24 o Limerick is designated as one of the TOP THREE nuclear plants in the country based on it's construction (which is similar to the ones in Japan--and we see how they failed) and the fact that it sits on an earthquake fault line. 25 26 27 28 29 o The NRC JUST a few weeks ago stated that "more information needs to be done and studied" regarding further fortifying nuclear plants regarding earthquakes. Thus, until you folks know exactly what needs to be done, etc.THERE IS NOTHING TO APPROVE as long as Limerick sits in it's current position. 30 31 32 o Do NOT think that earthquakes only happen on the West Coast--as we JUST had a 6+ earthquake less than a month ago. BY ONLY luck was there no damage to the plant, environment or community. 33 Comment: 51-4-GE; Limerick is built on a fault 34 35 Comment: 52-5-GE; It is one of the six most dangerous plants in the country because [of] its proximity to an earthquake fault. 36 Comment: 60-2-GE; Earthquake Fault 37 38 39 40 41 42 43 44 Response: Geologic and seismic conditions were considered in the original design of nuclear power plants and are part of the license bases for operating plants. Seismic conditions are attributes of the geologic environment that are not affected by continued plant operations and refurbishment and are not expected to change appreciably during the license renewal term for all nuclear power plants. Nevertheless, as part of characterizing the environmental baseline (affected environment) and associated resource conditions of LGS and the vicinity, Section 2.2.3 of the SEIS includes a discussion of the current geologic environment, including its seismic setting. Specifically, the section includes a discussion of the Ramapo fault system. A-10 Appendix A 1 2 3 This fault system encompasses the Chalfont fault and other named geologic faults. In addition, the NRC and Exelon considered in Chapter 5 of this SEIS whether increased seismic risk could provide a seriously different picture of severe accidents mitigation at Limerick. 4 5 As noted in the section, the nearest mapped faults to LGS have not been geologically active for more than 140 million years. 6 7 8 9 10 11 12 13 14 15 To the extent that the comments express concern for the seismic design of LGS, the seismic design of structures are beyond the scope of the environmental review. NRC's assessment of seismic hazards for existing nuclear power plants is a separate and distinct process from license renewal reviews. Seismic hazard issues are being addressed by the NRC on an ongoing basis at all licensed nuclear facilities. The NRC requires all licensees to take seismic activity into account to maintain safe operating conditions at all nuclear power plants. When new seismic hazard information becomes available, the NRC evaluates the new data and models to determine if any changes are needed at existing plants, regardless of whether or not a plant has renewed its license or is applying for license renewal. This reactor oversight process, which includes seismic safety, remains separate from license renewal. 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Unrelated to license renewal, the NRC completed the Generic Issues Program Safety/Risk Assessment Stage for Generic Issue (GI) 199 in August 2010, "Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants," which evaluated recent updates to estimates of the seismic hazard in the central and eastern United States. The results of the GI-199 Safety/Risk Assessment indicated that the currently operating nuclear power plants have adequate safety margin for seismic issues. The NRC's assessment indicated that overall seismic risk estimates remain SMALL, and adequate protection is maintained. NRC Information Notice 2010-18 (ADAMS Accession No. ML101970221) was then issued to nuclear power plants and independent spent fuel storage installations (ISFSI). It provided notice of the NRC's intent to follow the appropriate regulatory process to request that operating plants and ISFSIs provide specific information relating to their facilities to enable the NRC staff to complete the Regulatory Assessment, in which candidate backfits would be identified and evaluated. The NRC then developed a draft Generic Letter to request needed data from power reactor licensees. 30 31 32 33 34 35 36 37 38 39 However, following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the NRC established the Near-Term Task Force, as directed by the Commission. The Japan Near-Term Task Force assessment resulted in the issuance of letters requesting information per Title 10 of the Code of Federal Regulations (10 CFR) 50.54(f) letter on March 12, 2012. These letters were issued to all power reactor licensees and holders of construction permits and address GI-199 in its entirety in recommendation 2.1 regarding seismic reevaluations, (ADAMS Accession No ML12056A046). The NRC staff will use this information, as well as information requested in the 10 CFR 50.54(f) letter, to determine if further regulatory action is needed, including issuing orders to modify, suspend, or revoke a license. 40 A.1.5. Groundwater (GW) 41 Comment: 1-34-GW, 37-5-GW, 39-6-GW; Radioactive Groundwater Contamination. 42 43 Comment: 37-4-GW, 39-5-GW; Schuylkill River Depletion and Major Drink Water Contamination 44 45 46 Comment: 45-10-GW; Limerick contaminated groundwater. Radioactive leaks and spills over the years were never cleaned up. More radioactive leaks can be expected in the future through earthquakes, deterioration, and corrosion. Many residential well are very close to Limerick. A-11 Appendix A 1 2 3 4 5 6 7 8 9 Response: This comment deals with groundwater quality issues related to the operation of LGS. Groundwater resources at LGS, and the effects of plant operations on groundwater hydrology and quality, are presented in Sections 2.2.5 and 4.4 of the SEIS. Specifically, Section 2.2.5.1 discusses groundwater users at and in the vicinity of the plant, and Section 2.2.5.2 summarizes the results of the NRC's review of Exelon's Radiological Groundwater Protection Program for LGS, including the placement of site groundwater monitoring wells. As part of this evaluation, the NRC staff specifically reviewed the hydrogeologic investigation prepared for LGS in 2006 and the results of ongoing groundwater quality monitoring. Chapter 2 of this SEIS cites all studies reviewed by the NRC staff. 10 11 12 13 14 15 16 17 18 19 Based on the staff's review, and as presented in Section 4.4.3 of this SEIS, no strontium-90 or gamma-emitting radionuclides have been detected in groundwater or surface water associated with LGS operations or at levels above natural background. While inadvertent releases of liquids containing tritium (a radioactive isotope of hydrogen) have occurred to the ground and subsurface at LGS, levels in groundwater have been less than one-tenth of the EPA established drinking water standard of 20,000 picoCuries per liter. No upward trend in tritium levels has been observed, and Exelon's ongoing Radiological Groundwater Protection Program functions to detect and address potential new sources of groundwater contamination. Further, there are no offsite drinking water wells downgradient of LGS that could be affected by inadvertent releases of radionuclides to groundwater. 20 A.1.6. Historical and Archaeological (HA) 21 22 23 24 Comment: 31-1-HA; Thank you for informing the Delaware Tribe on the proposed construction associated with the above referenced project. Our review indicates that there are no religious or culturally significant sites in the project area. As such, we defer comment to your office as well as to the State Historic Preservation Office and/or the State Archaeologist. 25 26 27 28 29 We wish to continue as a consulting party on this project and look forward to receiving a copy of the cultural resources survey report if one is performed. We also ask that if any human remains are accidentally unearthed during the course of the survey and/or the construction project that you cease development immediately and inform the Delaware Tribe of Indians of the inadvertent discovery. 30 31 32 33 Comment: 49-1-HA; Thank you for providing the Onondaga Nation with information about this project. If any changes are made, I would like to be consulted. I realize that Unit 1 and Unit 2 have licenses that may be renewed in 2024 and 2029 respectively, therefore you may send updates and information until then. 34 35 36 37 38 In the event that during project construction, any archeological resources or remains, including, without limitation, human remains, funerary objects, sacred objects, or objects of cultural patrimony are uncovered, please immediately stop construction and contact me at (315) 952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at (315) 475-2559. 39 40 41 42 43 44 Response: In accordance with 36 CFR 800.8(c), the NRC has elected to coordinate compliance with section 106 of the National Historical Preservation Act with steps it has taken to meet its requirements under the National Environmental Policy Act (NEPA). An overview of consultation activities that occurred during the preparation of this SEIS is given in Section 4.10.6. All consultation parties will receive a copy of the draft SEIS to review and provide comments to the NRC. A-12 Appendix A 1 A.1.7. Human Health (HH) 2 3 Comment: 1-15-HH; Research has confirmed radiation in our children's baby teeth in this community. 4 5 6 Comment: 1-18-HH; Alarming cancer increases that have been well documented in this community repeatedly far higher than national and state averages after Limerick started operating until the late 1990s. 7 8 9 10 11 12 13 14 15 16 Comment: 1-25-HH; The sooner this place closes the better off we'll all be. Even if you look at infant mortality rates we have higher infant mortality rates and neonatal mortality rates far above state averages and even above Philadelphia and Reading, and we've had these for quite awhile. The fact is when babies are the most vulnerable in the womb what else would we expect? And by the way, for those of you who have been saying that ACE data is anecdotal today I have news for you. This infant mortality report for example is state data reported by EPA in 2003. Every cancer statistic that you see back there is based on Pennsylvania Cancer Registry statistics or CDC statistics. So it is not anecdotal, those are the cancer increases, those are the cancer above the national average that have happened here since Limerick started operating. 17 18 19 20 21 Comment: 1-26-HH; We have so many cancers above the national average. Childhood cancer, 92.5 percent higher than the national average. Think about that. We track the cost of one child with cancer diagnosed at six months to two years and up until that time it was $2.2 million. How many more kids have that above the national average? Cost that out and how many other cancers are above the national average? 22 23 Comment: 1-36-H; [D]ocumented alarming cancer increases especially in our children since Limerick started operating 24 25 26 27 28 Comment: 4-6-HH; There has been increased particulate matter in the air and other toxics from Limerick causing increased asthma, heart attacks, and strokes. And to add insult to injury, Limerick was granted a permit to allow an eight-fold increase in air pollution since 2009. Cancer rates in our area have skyrocketed since Limerick has been up and running in the '80s and rates have steadily increased. 29 30 31 32 33 Comment: 4-7-HH; The Toothfairy Project showed high levels of strontium 90, a radionuclide in baby teeth of children nearest to nuke plants. Baby teeth near Limerick plant had the highest levels in the whole United States. This stuff and God knows what else is in our bodies now thanks to a Nuclear Regulatory Commission that to put it nicely is less than enthusiastic about protecting us. 34 35 36 37 38 39 40 41 Comment: 6-1-HH; As a physician practicing radiology for over 50 years, I still have strong concern about cancer sensitivities from harmful radiation exposures, naturally. My medical colleagues share the same concerns because we have seen our cancer rates increase since the Limerick power plant started, especially thyroid cancer. It jumped to 78 percent higher here than the national average. And some of the people I talked to, this is because people are aging more now, getting older, so there are more cancers. But that's not true because in other areas similar to our area in Pottstown, they're not nearly getting the thyroid cancers that we are. This has been well established by the state. 42 43 44 45 46 Comment: 6-2-HH; Having attended a Hiroshima, Japan atom bomb clinic right after World War II, naturally I had a chance to see the worst results of harmful radiation. All those little kids I saw who only lived for a few days, it left me with a very sad memory. Of course, what is happening here will be taking much longer, but it sure is not good. I don't know whether you've heard that some scientists are already predicting that -- I'm sorry to tell you this, but nuclear A-13 Appendix A 1 2 3 energy has the capacity of destroying mankind. It may take about 100 years, but our whole world is exposed to the harmful effects, maybe not so much here in the United States, but the whole world can be affected. 4 5 6 7 Comment: 6-6-HH; According to the National Center of Disease Control, Pennsylvania ranks No. 1 for the highest incidence of Thyroid cancer. This occurred after installation of nuclear power plants in our area as well as in the rest of the State. Medical journals are reporting high rates of cancer near nuclear plants. 8 9 Comment: 6-8-HH; Incidentally, baby teeth studies have revealed Strontium 90 radioactive particles which can affect the child's immune system for more illness. 10 11 12 13 Comment: 19-6-HH; but I hate to tell you I have so many friends and coworkers and people that are only 35, 40, 50 years old, cancer. And why? We have to stop and think. Go home, don't just always, you know, just go watch TV and get on your computer. Stop and think what we're doing to ourselves, our bodies, our children, our grandchildren. 14 15 16 17 18 This is again, this licensing renewal is coming down to human lives, the quality of our lives. Again, why all this cancer? Microwaves and electricity. So I won't go on and on, but I just think us as a group can't just all be just complaining about the power companies, we are the ones using the electricity. That's all I'm saying. Maybe we should cut back and we won't need power plants. 19 20 21 22 23 24 25 26 27 28 Comment: 21-2-HH; Some people don't understand about radiation and I read when the Japanese thing occurred and I heard on the news a radiologist talking about oh, the radiation is such a low amount. It really isn't the low amount of radiation exposure that we get incidentally in standing next to a nuclear power plant. It's three ten-thousandths of a gram of plutonium that is death for you if you breathe that dust particle. It's almost certain death. And the problem becomes you can't have -- and it's not going to be a nuclear bomb. It's going to catch on fire if the fuel pool girders were to fail and you'll have a cloud of a material that in and of itself you might not have radiation exposure to it but that particle when it deposits itself can be an issue much the same as fluoride is what causes thyroid cancer when it's a radioactive fluoride. That's why we're very careful in building a plant with no Teflon and no fluoride components 29 30 31 Comment: 36-1-HH; I am concerned about the effects of our surrounding air and water supply of my children and grandchildren, some of whom are already inflicted with cancer and other diseases. 32 33 Comment: 37-1-HH, 39-2-HH; Radiation into Air and Water From Routine and Accidental Emissions 34 35 Comment: 37-7-HH, 39-8-HH; Alarming cancer increases, especially in children, since Limerick started operating 36 37 38 Comment: 37-14-HH, 39-15-HH; Increased Costs to the Public--More cancers and other costly illnesses, more emergency room visits and hospitalization from massive increases in PM-10 and TDS, treatment of public drinking water, environmental clean-up 39 40 Comment: 25-2-HH; The scientific statistics citing dramatic increase in cancer rates, infant mortality, and Schuylkill River water pollution is disturbing. 41 42 43 Comment: 36-3-HH; I am more concerned about the effects of surrounding air and water supply and the future of my children and grandchildren, some of whom are already inflicted with cancer and other diseases. 44 45 Comment: 40-4-HH; it doesn't take an accident or disaster for Limerick to poison the region's residents with radiation. Radiation from Limerick's routine and accidental emissions alone for A-14 Appendix A 1 2 3 4 the past 26 years is reason enough to deny Exelon's request. It's not credible for NRC to claim continuous radiation levels are safe for me and my family when there is no safe level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility. 5 6 7 8 9 10 11 12 13 NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP cannot be trusted. Exposure to radiation [is] known to cause cancer. It should be obvious to NRC that Limerick played a major role in our tragic, well documented cancer crisis after Limerick started operating in the mid 1980s to late 1990s. Four cancer studies based on PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far higher than national and state averages, especially in children. Our children had the highest levels of Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant released SR-90 into our air and water that got into the milk, vegetation, and food since Limerick started operating. 14 15 16 17 Comment: 40-5-HH; Thyroid cancer increased by 128% from 1985 to 1997--was as side note, with no family history or other obvious risk factors in my life, I was recently treated for thyroid cancer. Since my diagnosis, I have learned of many other locals like me. It's scary to think the choice of where we lived could kill us. 18 19 20 21 22 23 24 25 26 27 28 Comment: 41-3-HH; Exposure to radiation is known to cause cancer. NRC has not done any radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP cannot be trusted--it's ridiculous to think they could monitor themselves. It should be obvious to NRC that Limerick played a major role in our cancer crisis after Limerick started operating mid 1980s to 2000. Four cancer studies based on Pennsylvania Cancer Registry and the CDC showed skyrocketing rates for several cancers much higher than national and state averages, especially children--innocent children. Thyroid cancer increased 128% from 1985 to 1997. I have local friends and family with thyroid cancer and brain cancer--not one, but several. Sadly it is uncommon in other areas of the country. It used to be uncommon here too--prior to Limerick. Would you want to live here? Would you approve a license renewal so close to home? Your job is to safely review the facts. 29 Comment: 42-2-HH; The increased risk of cancer is well founded in the literature also. 30 31 32 33 34 35 36 37 38 39 40 41 Comment: 44-8-HH; The most alarming and compelling thing to me as a taxpayer, homeowner, and mother is the overwhelming and alarming cancer increases to the public after Limerick had started operating. The CDC website showed 92.5% higher than the national average for childhood cancer in six communities close to the Limerick Nuclear Plant which included, Pottstown, West Pottsgrove, Lower Pottsgrove, North Conventry, and Douglas Berks Township from cancers diagnosed from 1995-1999. The Pennsylvannia State Cancer Registry For Montgomery County from 1985-86 to 1996-97 also shows cancer rates skyrocketed in Montgomery County where the Limerick Nuclear Plant is located during the Mid 80's and 90's after they opened. Prostate Cancer increased 132%, Thyroid Cancer increased 128%, Kidney cancer increased 96%, Multiple Myeloma increased 91%, Hodgkin's Disease increase 67%, Non-Hogdin's Lymphoma increased 61%, Breast cancer increased 61%, Pancreas cancer increased 54%, and Leukemia increased 48%. 42 43 44 45 46 47 48 Radiation exposure can cause cancer and other serious disease and disability, at any level of exposure according the National Academy of Sciences and Physicians Responsibility. Permissible radiation levels does not mean that they are safe levels for everyone in the community. Most permissible levels based on the average healthy adult. They are not levels that were based or researched for fetuses, infants, toddlers, and children or pets. Fetuses, infants, children, pets, and the elderly and immuned compromised individuals are at most risk of health problems. There is a broad range of dangerous randionulcides routinely released into air A-15 Appendix A 1 2 3 and water from the Limerick Nuclear Plant as well as any accidental releases. Permissible radiation levels does not mean that they are safe radiation levels, it only means that they are allowed. 4 5 6 7 Comment: 44-9-HH; I have children as well as other loved ones that have or have had allergies, asthma, learning disabilities, speech disabilities, behavioral disabilities, thyroid conditions, cancers, skin disorders and irritation, etc. I know neighbors and other community members that have suffered from the same and more. 8 9 10 11 12 13 Comment: 45-6-HH; But, it doesn't take an accident or disaster for Limerick to poison the region's residents with radiation. Radiation from Limerick routine and accidental emissions alone for the past 26 years is reason enough to deny Exelon's request. It's not credible for NRC to claim continuous radiation levels are safe for me and my family when there is no safe level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility. 14 15 16 17 18 Comment: 45-7-HH; NRC is failing to acknowledge obvious health harms from Limerick's continuous additive, cumulative, and synergistic radiation releases which get into water, food, soil, vegetation, milk, and our bodies. NRC has no idea what health harms some of the region's residents experienced from Limerick Nuclear Plant. NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP cannot by trusted. 19 20 21 22 23 24 25 26 27 Comment: 45-8-HH; Exposure to radiation is known to cause cancer. It should be obvious to the NRC that Limerick played a major role in our tragic, well documented cancer crisis after Limerick started operating in the mid 1980s to the late 1990s. Four cancer studies based on PA Cancer Registry and CDC data showed skyrocketing rate for several cancers for higher than the national and state averages, especially children. Our children had the highest levels of Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant release SR-90 into our air and water that got into the milk, vegetation, and food since Limerick started operating. Thyroid cancer increased by 128% from 1985 to 1997. Other cancers rose dramatically as well. 28 29 30 31 32 33 34 Comment: 46-6-HH; Finally, my concerns regarding the impact of this nuclear power plant on my community are not limited to catastrophic scenarios that might potentially occur. There have been studies published in health journals that show a higher incidence of certain illness-- particular among children--in communities surrounding nuclear plants. While these studies were conducted in a variety of locations, they seem to be consistent with some of the data that Pottstown's local Alliance for a Clean Environment presents on its website regarding increased cancer and leukemia rates-also especially among children-in the greater Pottstown area. 35 Comment: 47-2-HH; I am fully aware of the amount of cancer that is prevalent in this area. 36 37 38 39 40 Comment: 48-2-HH; I moved to Pottstown, Pa., some time ago in perfect health. In 2006, I was diagnosed with prostate cancer. Although, I cannot prove it was a direct cause of the nuclear power plant, I feel that much further, unbiased studies and tests need to be done prior to the relicensing of the Limerick plant by reputable sources not by corporate interests groups that can manipulate the statistics in Exelon's favor. 41 42 43 Wouldn't it be in the best interest of our community and surrounding communities if the higher cancer rate was due the Limerick power plant? This question is a "no brainer." There is plenty of time for testing to be done prior to relicensing. 44 45 Comment: 51-3-HH; Cancer rates are higher than the national average and NRC is going with the status quo. A-16 Appendix A 1 2 Comment: 52-6-HH; The surrounding area has abnormally high cancer rates among adults and children. 3 Comment: 57-3-HH; I also feel its presence has led to [an] increase of cancer in our area. 4 5 6 Comment: 58-1-HH; I feel that there is a lot of people that had not known to report anything because of not knowing who to go to. I don't understand why the hospitals don't give statistical information based on areas? 7 8 9 10 11 Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children's Hospital until she was 5. With several years of chemotherapy she is now 18 and in remission. We had lived on Limerick Center Road for most of our young lives and now with our kids. I don't know what other information you would need but I would be happy to get you whatever you might need. 12 13 Comment: 60-10-HH; High infant mortality rates and neo natal, cancer increase, thyroid cancer rates 70% higher 14 Comment: 60-14-HH; cancer increases, especially children 15 16 17 18 19 20 21 Response: The NRC's mission is to protect the public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. The NRC's regulatory limits for radiological protection are set to protect workers and the public from the harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. Radiation standards reflect extensive scientific study by national and international organizations. The NRC actively participates and monitors the work of these organizations to keep current on the latest trends in radiation protection. 22 23 24 25 Recently, the NRC asked the National Academy of Sciences (NAS) to perform a state-of-the-art study on cancer risk for populations surrounding nuclear power facilities. The NAS study will update the 1990 U.S. National Institutes of Health--NCI report, "Cancer in Populations Living near Nuclear Facilities." 26 27 28 29 30 The study will be carried out in two consecutive phases. A Phase 1 scoping study will identify scientifically sound approaches for carrying out an epidemiological study of cancer risks. This scoping study began on September 1, 2010, and will last for 15 months. The result of this Phase 1 study will be used to inform the design of the cancer risk assessment, which will be carried out in a future Phase 2 study. 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Although radiation can cause cancers at high doses, currently there are no data to unequivocally establish the occurrence of cancer following exposures to low doses, below about 10 rem (0.1 Sv). Radiation protection experts conservatively assume that any amount of radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is higher for larger radiation exposures. Therefore, a linear, no-threshold dose response relationship is used to describe the relationship between radiation dose and detriments such as cancer induction. Simply stated, any increase in dose, no matter how small, is assumed to result in an incremental increase in health risk. This theory is accepted by the NRC as a conservative model for estimating health risks from radiation exposure, recognizing that the model probably over-estimates those risks. Based on this theory, the NRC conservatively establishes limits for radioactive effluents and radiation exposures for workers and members of the public. While the public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC (10 CFR Part 20, "Standards for Protection Against Radiation"), the NRC has imposed additional constraints on nuclear power reactors. Each nuclear power reactor, including LGS, has license conditions that limit the total annual whole body dose to a member of the public outside the facility to 25 mrem (0.25 mSv). In addition, there are license conditions to limit the A-17 Appendix A 1 2 3 dose to a member of the public from radioactive material in gaseous effluents to an annual dose of 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, a dose limit of 3 mrem (0.03 mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ. 4 5 6 7 8 9 10 11 12 13 14 Chapter 4 of this SEIS discusses the Radiological Environmental Monitoring Program (REMP) that LGS uses for environmental monitoring. The purpose of the LGS Radiological REMP is to evaluate the radiological impact that operation may have on the environment. The program is designed to highlight and look at specific consumption pathways for local inhabitants and special interest groups. The LGS radiological environmental monitoring program is made up of three categories based on the exposure pathways to the public. They are as follows: atmospheric, aquatic, and ambient gamma radiation. The atmospheric samples taken around LGS are airborne particulate, airborne iodine, milk, and broad leaf vegetation. Sampling for the LGS REMP program is performed as specified in Appendix I to 10 CFR Part 50, "Domestic licensing of production and utilization facilities," as well as agreements made with the State of Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection. 15 16 17 18 19 20 21 22 23 24 The amount of radioactive material released from nuclear power facilities is well measured, well monitored, and known to be very small. The doses of radiation that are received by members of the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few millirem) that resulting cancers attributed to the radiation have not been observed and would not be expected. To put this in perspective, each person in this country receives a total annual dose of about 300 mrems (3 mSv) from natural sources of radiation (i.e., radon, 200 mrem; cosmic rays, 2 mrem; terrestrial (soil and rocks), 28 mrem; and radiation within our body, 39 mrem) and about 63 mrem (0.63 mSv) from man-made sources (i.e., medical x-rays, 39 mrem; nuclear medicine, 14 mrem; consumer products, 10 mrem; occupational, 0.9 mrem; nuclear fuel cycle, <1 mrem; and fallout, <1 mrem). 25 26 A number of studies have been performed to examine the health effects around nuclear power facilities. The following is a list of some of the studies that have been conducted: 27 28 29 30 31 32 33 o In 1990, at the request of Congress, the National Cancer Institute (NCI) conducted a study of cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities. The study covered the period from 1950-1984 and evaluated the change in mortality rates before and during facility operations. The study concluded there was no evidence that nuclear facilities may be casually linked to excess deaths from leukemia or from other cancers in populations living nearby. 34 35 36 37 38 o Investigators from the University of Pittsburgh found no link between radiation released during the 1979 accident at the Three Mile Island Nuclear Station and cancer deaths among nearby residents. This study followed more than 32,000 people who lived within 5 miles (mi) (8 kilometers (km)) of the facility at the time of the accident. 39 40 41 42 o In January 2001, the Connecticut Academy of Sciences and Engineering issued a report on a study around the Haddam Neck Nuclear Power Plant, in Connecticut, and concluded that exposures to radionuclides were so low as to be negligible and found no meaningful associations to the cancers studied. 43 44 45 46 o In 2001, the American Cancer Society concluded that, although reports about cancer clusters in some communities have raised public concern, studies show that clusters do not occur more often near nuclear plants than they do by chance elsewhere in the population. Likewise, there is no evidence linking A-18 Appendix A 1 2 the isotope strontium-90 with increases in breast cancer, prostate cancer, or childhood cancer rates. 3 4 5 6 7 8 9 o In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there are striking increases in cancer rates in southeastern Florida counties caused by increased radiation exposures from nuclear power plants. However, using the same data to reconstruct the calculations on which the claims were based, Florida officials did not identify unusually high rates of cancers in these counties compared with the rest of the state of Florida and the nation. 10 11 12 o In 2000, the Illinois Public Health Department compared childhood cancer statistics for counties with nuclear power plants to similar counties without nuclear plants and found no statistically significant difference. 13 14 15 16 In summary, there are no studies to date that are accepted by the nation's leading scientific authorities that indicate a causative relationship between radiation dose from nuclear power facilities and cancer in the general public. The amount of radioactive material released from nuclear power facilities is well measured, well monitored, and known to be very small. 17 18 The staff addresses human health impacts of renewing the LGS operating licenses in Chapters 2 and 4 of the draft SEIS. 19 A.1.8. Land Use (LU) 20 21 22 23 24 25 26 27 Comment: 54-5-LU; The county has been working hard to develop an interconnected system of open space and trails along the Schuylkill River and within other natural resource areas of the county. In doing this, the county has provided funding to local municipalities and nonprofit conservation organizations to purchase open space and park land; acquired county land and agriculture easements; and developed trails. The Limerick Generating Station site contains significant land along the Schuylkill River that has been identified as part of the Schuylkill River Greenway in the county plan. The use and management of these lands relative to the county open space and natural areas inventory plans should be evaluated in the relicensing process. 28 29 30 31 32 33 Response: Current onsite and offsite land use conditions in the vicinity of LGS are described in Sections 2.2.1 and 2.2.9.3 of this SEIS. The NRC's evaluation of LGS's impacts on onsite and offsite land use during the license renewal term is presented Section 4.1 of this SEIS. While license renewal is not expected to affect the use and management of LGS lands identified as part of the Schuylkill River Greenway, this information will be evaluated with other potential cumulative effects in Section 4.12.6. 34 A.1.9. License Renewal and its Process (LR) 35 36 Comment: 1-4-LR; Current 40-year operating licenses expire in 2024 and 2029. Why the rush to renew these licenses now? 37 38 39 40 Comment: 1-19-LR; While NRC is required to prepare a supplement to the Limerick Environmental Impact Statement for license renewal, we have little confidence in the process based on NRC's regulatory history. It would be difficult to enumerate a short list, so I'm going to rely on written documents. 41 42 Comment: 4-9-LR; But my big question of the day is why is Exelon applying for an extension 18 years ahead of time? A-19 Appendix A 1 2 3 Comment: 4-13-LR; Exelon is rushing the timeline to reissue a license (18 years ahead of time) to run Limerick Nuclear Plant into the unknown, yet it took more than 5 months for the NRC to get back me concerning an already known survey of fault lines. 4 5 6 7 8 Comment: 8-1-LR; I'm a retired Lutheran pastor and my concern today is with the speed at which this application process is going. I mean it seems to me that to predict what environmental factors will be in place 13 years hence and 18 years hence, posits a kind of omniscience and prescience that we should attribute to Almighty God, but certainly not to any of us human beings. I would favor a slower process. 9 10 11 12 13 14 15 16 Comment: 8-5-LR; As I stated then, I continue to be concerned and puzzled about the very early and pre-mature application of Exelon to extend the licenses of the towers. One [of] those does not come up for renewal until 2024 and the other 2029. I ask the NRC not work on the relicensing for this facility for at least ten years. The wait could only ensure better information. The public can not possibly benefit from a decision to renew the licenses at this time. The best decision will be made based on the best possible information. The NRC does not have the best information this early. Much will happen in the next ten years. I urge NRC to wait and see how any of it affects the prospect of continuing these plants at that later date. 17 18 19 20 21 22 23 What can happen in the next ten years that we can all learn from the relevantly could be anything. It may be better information about how natural disasters are affecting nuclear facilities; we may know more about weather patterns that could cause damage. We will certainly know more about the world situation in terms of advances in terrorist technological capabilities and goals. We will know more about how well nuclear plants in general and the Limerick facility are faring as they continue age. If someone steps forward to fund studies, we will know yet more about cancer rates in the nuclear zones 24 25 26 27 28 29 Comment: 16-4-LR; This particular nuclear plant, these plants, you know, their license is already good till 2024. Why are we here now 12 years ahead of time trying to extend this license? And the only reason is because it's a foot race the NRC's in with Congress and nothing more. This has nothing to do with protecting public health and safety, it's the NRC's zeal to continue to rubber-stamp these license extensions without allowing citizens due process like I already talked about and without doing a cost intense and thorough review. 30 31 32 33 34 Comment: 19-4-LR; He was stating the fact why are we re-licensing them, what, 12 years ahead of time. To me that is absurd. Like maybe a year before or they have to do some studies, two years before. Why do they want us, and I love Thomas's words, rubber-stamp something? Twelve years beforehand to go into what, 2024 for Unit 1 was it and 2029 for Unit 2? Why do they need to push this licensing renewal? You've got to stop and think. 35 36 37 38 Comment: 25-1-LR; First of all, considering the impact of the outcome to many area residents, this forum was not widely publicized for local citizens to be aware of this important matter and offer feedback. Secondly, it does not make sense that Exelon is pursuing renewal for a license that does not expire until 2024. 39 40 41 Comment: 30-1-LR; It is NOT due to expire until 2024--thus, Exelon has nothing to [lose] but getting an extension sooner than later so they can sit back and relax operating for the next 20+ years. 42 43 44 45 46 Comment: 30-13-LR; Since the reactor has until 2024--why the rush, and only one public meeting. I if you have not heard it, you will. There is a major public outrage over this one meeting and not know about it until too late. People want public meetings so that people hear that many are against this plant rather than just submitting comments to the NRC which appears to be rubber stamping license requests--which is not comforting to me and many. A-20 Appendix A 1 2 3 Comment: 3-1-LR; Why is the request so early--The NRC should get a request closer to [the] expiration date. Also, the inspection should [be] done closer to the expiration date. In 2023, not 2013. 4 5 6 7 Comment: 34-1-LR; Why is there rush to renew the license? It is not due until 2024, approval at the earliest should be 2019. This would allow 5 years for the business plan of PECO to either continue or close the plant and make arrangements for additional power to replace the closed plant. 8 9 10 11 12 13 14 15 16 Comment: 41-1-OR; The possible renewal of Limerick Nuclear Plant's license for 20 years past its current 2024 and 2029 expiration dates more than 12 years ahead of time, worries me a great deal. It's hard to understand why something this major would be done so far in advance. It's IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth would this be renewed early? It's lengthy process that could begin earlier, but in no way should something this important be rushed through now. Why not wait until closer to the expiration dates, and then seek approval? I understand this how the original guidelines were set up--but those are long outdated. Approving Limerick Nuclear Plant to be relicensed until 2049 would be jeopardizing the health of millions. Renewing this license could be catastrophic to millions. 17 18 19 Comment: 48-3-LR; Also, why the hurry? Common sense would indicate that Exelon knows something which we are not aware. Why must the license be renewed at this time when they are licensed through 2024 and 2029? 20 Again, Why The Hurry? To relicense now is not the best interest of everyone in our area. 21 22 23 24 25 26 27 Comment: 56-2-LR; Finally, we have grave misgivings regarding the future time-dependence, accuracy, and relevance of the licensee's current ER, as presumptively incorporated in the NRC's planned SEIS for LGS license extension, given that such license extension will not become effective until the current unit operating licenses expire in 2024 (for Unit 1) and 2029 for Unit 2. We submit that any decision to relicense these units must be supported by the most timely NEPA and SAMA analysis obtainable within a reasonable interval (e.g. five years) prior to actual expiration of the existing licenses. 28 29 30 31 32 33 34 35 36 37 38 Intervals of 12 and 17 years are not required for corporate planning purposes and are far too long to credibly sustain the accuracy and relevance of NEPA analyses, or for the NRC to accurately project both the future condition of the plant, the future state of nuclear safety knowledge, trends in local resource use, population, and the affected environment, and the future range of reasonable electricity supply alternatives to LGS license extension. By comparison, major government owned nuclear installations, such as nuclear laboratories and weapon production sites, are required to conduct site-wide NEPA reviews of their operations and facility plans every\five years. Using this federal standard for timeliness, the NRC's NEPA analysis for LGS relicensing should not commence before 2019, for Unit 1, and before 2024 for Unit 2, or should be subjected to mandatory reassessment and supplementation after those dates. 39 Comment: 60-5-LR; 12 years ahead of time--no way to guarantee safety 40 41 Comment 60-13-LR; NRC should not be considering this so far in advance--no way to assure safety--shut it down 42 43 44 45 46 Response: According to NRC regulations, 10 CFR Part 54, "Requirements for renewal of operating licenses for nuclear power plants," a nuclear power plant licensee may apply to the NRC to renew a license as early as 20 years before expiration of the current license. The NRC determined that 20 years of operating experience is sufficient to assess aging and environmental issues at the site. Additionally, 20 years is a reasonable lead period because if A-21 Appendix A 1 2 3 the NRC denies the license renewal application, it takes about 10 years to design and construct major new generating facilities, and long lead time times are required by energy-planning decisionmakers. 4 5 6 7 8 9 Comment: 54-7-LR; As part of the environmental assessment process and the evaluation of the plant safety and long term operational capacity, we think that it is important for the NRC to maintain close communication with the community surrounding the plant. Overall education about the plant and the associated risks presented by its operation should be provided in a variety of ways so that the public is better informed about the plant and the overall evaluation taking place as part of the relicensing. 10 11 12 13 14 15 16 17 Response: The NRC's Office of Public Affairs (OPA) is available to address the public concerns and questions regarding nuclear safety and information regarding about LGS. The office follows news coverage of the agency and responds to media and public inquiries. If members of the public have questions or comments about the NRC, nuclear safety, or related topics, they can contact OPA at OPA.Resource@nrc.gov. For specific questions and concerns regarding Limerick, the public can contact the Region I OPA at OPA1.Resource.@nrc.gov. Additional contact information for OPA can be accessed at http://www.nrc.gov/ about-nrc/organization/opafuncdesc.html 18 19 20 Comment: 1-6-LR; The public was led to believe that Limerick's generators, fuel pools, and miles of underground pipes and cables could operate safely for 40 years and then the facility would close. Is Exelon fearful that the longer they wait the more serious problems may arise? 21 22 23 24 25 26 27 Response: The original licenses for commercial nuclear power plants were granted for 40 year period, which was set by the Atomic Energy Act 1954 and the NRC's regulations. It was imposed for economic and antitrust reasons rather than technical limitations of the plant. According NRC regulations, 10 CFR Part 54, a nuclear power plant licensee may apply to the NRC to renew a license as early as 20 years before expiration of the current license. Part 54 requires the applicant to demonstrate that it can successfully manage aging at the facility during the period of extended operation. 28 29 30 31 32 Comment: 22-1-LR; I'm a resident of Phoenixville. I found out about this meeting because I scan a lot of newspaper websites. I found the notice of the meeting on the West Chester Daily Local website. Didn't find it in the Phoenixville paper, didn't see it in the Philadelphia newspaper, didn't hear about it on any of the local radio stations, didn't hear about it on cable, didn't hear about it on any of the television. 33 34 Comment: 60-20-LR; Should have been more public notice for hearing--Mail notices so people have an opportunity to attend. 35 36 37 38 39 40 Response: The NRC provides notice of the environmental public meetings through the Federal Register, press releases, and local advertisements. The public also can get information about all NRC public meetings at the NRC public Web site, http://www.nrc.gov/public-involve/ public-meetings/index.cfm. The public also can receive public meeting notices and press releases by subscribing to e-mail notices for reactor correspondence for Limerick at http://www.nrc.gov/public-involve/listserver/plants-by-region.html. 41 42 43 44 Comment: 22-3-LR: The slide behind me documents exactly two libraries that the documents are going to go in. Why not in my library in Phoenixville? Why not in Montgomery County and Norristown and all of the other public libraries that are in areas that can be affected by the plume should something happen here? Why are the documents in such a restricted area? 45 46 Response: The NRC contacts the local libraries in the communities surrounding the plant to ask if the agency could send them copies of license renewal applications and other documents A-22 Appendix A 1 2 3 4 5 related to the license renewal review so that they could be accessed by members of the public. However, some libraries have limited shelf space and may not be able to accommodate the NRC. Members of the public also can access the license renewal application and SEIS on the Limerick license renewal Web page on the NRC public Web site. The public can access the site at http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html. 6 7 8 Additionally, the NRC will have hard copies and CDs of the draft SEIS available for the public during the public meeting on the draft SEIS. Members of the public also can contact the NRC to request a hard copy or CD of the SEIS. 9 10 11 12 13 14 15 16 17 Comment: 16-2-LR; And I'd like to correct that statement. He stated that the NRC is extending the original operating license which was granted by the NRC for a 40-year period of time that that initial 40- year license was not based on safety considerations or technical considerations. But that's absolutely not true and there was recently a year-long investigative report done by the Associated Press who interviewed expert nuclear personnel, engineers, safety engineers in the nuclear industry who told them that the 40-year licenses issued by the NRC for 104 nuclear plants in the United States was based on safety and technical--safety technical analysis. So these proceedings, these license extension proceedings like the one we're currently at are a rubber-stamping of these 20-year license extensions. 18 19 20 21 Comment: 16-3-LR; This is in fact a foot race between the Nuclear Regulatory Commission and the United States Congress where Congress wants to stop this process, put a moratorium on the re-licensing until the Fukushima disasters can be fully understood and the enhancement enacted in August for our power plants here. 22 23 24 25 26 27 28 29 30 31 32 33 34 Reponses: As a result of Fukushima, the NRC issued three orders requiring safety enhancements of operating reactors, construction permit holders, and combined license holders. These orders require nuclear power plants to implement safety enhancements related to (1) mitigation strategies to respond to extreme natural events resulting in the loss of power at plants, (2) ways to ensure reliable hardened containment vents, and (3) ways to enhance spent fuel pool instrumentation. The plants are required to promptly begin implementation of the safety enhancements and complete implementation within two refueling outages or by December 31, 2016, whichever comes first. In addition, the NRC issued a request for information asking each licensee to reevaluate the seismic and flooding hazards at the site using present-day methods and information, conduct walkdowns of its facilities to ensure protection against the hazards in its current design basis, and reevaluate emergency communications systems and staffing levels. LGS is required to comply with the NRC orders or revised regulations whether or not the operating licenses are renewed. 35 A.1.10. Opposition to License Renewal (OR) 36 Comment: 1-5-OR; We urge the NRC to say no to Exelon's requested license renewals. 37 38 39 Comment: 1-20-LR; It's long past time for the NRC to summon the courage to do the right thing in our judgment and actually protect the environment and the public, rather than the industry. 40 41 42 43 Comment: 1-21-OR; Based on the compelling body of evidence of environmental harms to date and the enormous increased population in proximity to this facility, Limerick Nuclear Plant must be closed by 2029. There is no amount of energy production that is worth risking the lives of so many people. 44 45 Comment: 1-29-OR; Nuclear Regulatory Commission today and that is very simply that Limerick nuclear power plant must be closed by the NRC, not re-licensed until 2049. A-23 Appendix A 1 2 Comment: 6-5-OR; So please, ask your politicians, reliable politicians to close the Limerick power plant. Let's save America for our kids and descendants 3 4 5 6 Comment: 6-9-OR; We can't control the use of nuclear in the rest of the world, but we can keep the U.S. safer by eliminating nuclear energies. Fortunately, many European allies including Australia have decided to phase out reactors. We should join them [to] reduce human suffering. Also this can reduce our increasing costs of health care. 7 8 Comment: 6-11-OR; Limerick Power Plant is ranked in the top 3 riskiest nuclear power plants in the U.S.A. Limerick Power Plant must be closed not relicensed. 9 10 11 12 Comment: 10-1-OR; If Limerick Unit 1 or 2 fails, all hell breaks loose, no disrespect. That's what a nuclear failure is, hell. It affects everybody in this room, everybody in the community, everybody in the tri-state area, not for a week, but for decades. It's very, very last thing we want to happen. 13 14 15 16 17 18 19 And I think we're putting ourselves in harm's way by taking something that had a lifespan of 40 years and adding another 20 to it. It doesn't make sense. The only way to rationalize it is through our personal fear of being inconvenienced because we lose a very, very good source of power. It's done a great job for us. But like me, you get to a point where your ability to provide a great job is at an end and things start deteriorating. Let's not put ourselves in that position. Let's make an intelligent decision now and allow these two units to expire at their nameplate time. 20 21 Comment: 19-3-OR; So from day one I think power plants never should have been built but now that they are here why would we ever want to re-license. 22 23 24 25 Comment: 25-4-OR; I attend to agree with the fourteen reasons provided by the Alliance For A Clean Environment why Exelon should be denied the renewal license. In my opinion, the long-term negative consequences caused by the Limerick Generating Station far outweigh any possible benefits it may contribute. 26 Comment: 26-1-OR; Please do NOT extend the Limerick licenses! 27 28 29 30 Comment: 27-2-OR; Renewing Limerick's license just as controversies are arising with pushes to move from dependence on Nuclear energy is a bold business strategy by them. I don't think this the right move to make. A long term contract will limit any sort of wiggle room to address future issues that may arise. 31 32 33 I ask that you please consider the future of our great state. I don't think oil or nuclear energy is the way. I truly believe in heart, that in order to protect the health of our population for the future, we must change our ways today. 34 35 36 Comment: 28-1-OR; I object being continuously poisoned by the Limerick Nuclear Plant's radiation and other dangerous toxins. Please do not allow for an extension of the Limerick Nuclear Power Plant's operation license. 37 Comment: 29-2-OR; The Reactor time has served its years and should not be renewed. 38 39 40 41 42 43 44 45 Comment: 30-10-OR; I feel firmly and many in the community feel the exact same way, that there is no reason to approve NOW (especially so far in advance, with no answer on usage on rods nor what needs to be done to prevent a meltdown due to an earthquake, etc.) or Ever since the population will only increase and the facility age further. It is the wrong timing, wrong plant, wrong place, etc. for Limerick. Maybe Exelon can put in as much effort and "energy" to develop solar fields, etc... They would rather beat the hell out of a high efficiency plan at any and all cost to the environment and community. This where the NRC does the right thing and says NO until a year before it expires. A-24 Appendix A 1 2 3 4 5 6 Comment: 35-1-OR; Limerick Nuclear's influence is vast and horrific. This industry is a behemoth that has not been honest with the public about its true impact, forming its own "environmental" partnerships that are pure pronuclear propaganda tools. It's economic contributions are miniscule when compared to its enormous profits, while destroying our quality of life. The nuclear process's devastating environmental effect on our community cannot be understated. 7 8 9 10 11 12 13 Comment: 35-7-OR; Ordinary daily nuclear generation has had devastating community-wide consequences that need to be addressed. Re-licensing should not even be a consideration! The NRC must fully investigate the environmental concerns presented Dr. Lewis and Donna Cuthbert (ACE), Dr. Winter, and each resident who so civilly represented this community's concerns at the September 22, 2011 hearings. The Limerick Nuclear Power Plant should NOT be re-licensed and should, instead, begin to address the pollution issues it has already created as it seriously and carefully shuts down its reactors. 14 15 Comment: 38-1-OR; I'm writing to you to state my opposition to the relicensing of Limerick Generating Station in Limerick Township, Pennsylvania. 16 17 18 19 20 21 22 Comment: 40-1-OR; I attended the recent meeting on the possible renewal of Limerick Nuclear Plant's license for 20 years past its current 2024 and 2029 expiration dates. I strongly believe, as do many of my local friends and family that the Limerick Nuclear Plant must be closed, not relicensed. Approving Limerick Nuclear Plant to be relicensed until 2049 would be jeopardizing the health of thousands and thousands of people in neighboring communities. There is substantial evidence readily available which justifies closing Limerick. Renewing this license could lead to a catastrophic meltdown. 23 24 25 Comment: 40-6-OR; It would be careless, unethical and immoral for NRC to approve Exelon's requested license extensions Limerick Nuclear Power Plant. Limerick Nuclear Power Plant must be closed by 2029. 26 27 28 Comment: 41-4-OR; Just remember, it would be careless, unethical and immoral for NRC to approve Exelon's requested license extensions for Limerick Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. 29 30 Comment: 42-3-OR; Why does the NRC think they can play God with people lives? It is no longer debatable, shut it down before our very lives are jeopardized. 31 32 33 So-called quality life issues addressed as part of public debate, e.g. "the power is always on" seems irrelevant to us when our families are required to evacuate during disaster. Limerick must be closed and NOT relicensed at any cost, specifically the cost of life itself! 34 35 Comment: 43-1-OR; Do NOT renew Limerick licenses. It's too dangerous and too old. Please listen to their neighbors like us. 36 37 38 39 40 41 42 43 44 45 Comment: 44-1-OR; There are so many reasons why you as a group should already know that it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, wildlife in general and the environment for you to refuse/oppose Limerick Power Plant from re-licensing. The problem that always seems to come up at some of the public hearings and sessions where businesses/corporations want to expand and become bigger and run their businesses long past the time that they should truly be allowed in order keep safe, always comes back to the issue of money, offerings, bribes, donations, etc. in the end. When these things occur, people and businesses turn a "blind eye" so to speak to the dangers of allowing a business like the Limerick Power Plant to renew its license again. That is unacceptable. I expect and demand better service from you to help protect myself and my family from harm! A-25 Appendix A 1 2 3 4 5 Comment: 44-4-OR; It is disgusting and heart wrenching to know that officials and organizations are not paying attention to what can happen to the public if Limerick Power Plant continues to operate longer than expected. Ignoring the obvious problems our community is facing and hoping that after they serve their term, it will be someone else problem to deal with is unacceptable. Now is the time. Step up and [do] what is morally right for humanity 6 7 8 9 Comment: 44-11-OR; I expect you to what is morally right now for me, my family, my neighbors, my community, and the pets, wildlife, air, water, and environmental in whole by rejecting, refusing, and opposing Limerick Power Plant from relicensing to run their business longer than originally planned for 2029. 10 11 12 13 14 15 16 Comment: 45-1-OR; I urge NRC to deny Exelon's request to renew Limerick Nuclear Plant's license for 20 years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant must be closed, not relicensed, for many valid reasons. Approval of Limerick Nuclear Plant to be relicensed until 2049 would be reckless and would show blatant disregard for the health and safety of the public. There is more than sufficient evidence of harms and threats to justify closing Limerick. There are too many things beyond NRC's control that could lead to a catastrophic meltdown. 17 18 19 20 Comment: 45-11-OR; It would be both unethical and immoral for NRC to approve Exelon's requested license extensions for Limerick Nuclear Power Plant. All of the unprecedented harms, threats, risks from Limerick Nuclear Plant will increase if NRC approves and additional 20 year Limerick license extension, until 2049. Limerick Nuclear Plant must be closed by 2029. 21 22 23 24 Comment: 46-1-OR; I am writing to express my opposition to the re-licensing of Limerick nuclear power generating station, which is located about 20 miles from my home. There are several reasons why this relicensing in not in the best interests of people living in the surrounding community 25 26 Comment: 48-1-OR; Just a quick note requesting the NRC to NOT allow the relicensing of the Limerick, PA, nuclear plant at this time. 27 28 Comment: 51-1-OR; Please protect our citizens from possible disaster and do not relicense Limerick 29 30 31 Comment: 52-1-OR; As a resident of New Hanover Twp., Montgomery County, PA (less than 5 miles from Exelon's Limerick Nuclear Power Plant), I urge you to vote AGAINST the premature relicensing of that facility. 32 33 34 Comment: 53-1-OR; I implore you to not relicense the Nuclear Power Plant of Limerick when its licenses expires in 2029. If I had my wish, the power plant would be closed years before 2029. 35 36 Comment: 57-1-OR; Just wanted to voice my opinion for a no vote to renew the license for the Limerick power plant. 37 38 39 40 41 Response: These comments are general in nature and express opposition to Exelon, nuclear power, and license renewal of LGS. Portions of these comments that express general opposition to renewing the licenses for LGS provide no new and significant information and have not resulted in any changes to this SEIS. Portions of these comments that address particular technical issues are addressed in the respective technical sections of this appendix. A-26 Appendix A 1 A.1.11. Postulated Accidents & SAMA (PA) 2 3 4 Comment: 1-1-PA; Whether a natural disaster or terrorist attack occurs, by relicensing Limerick, NRC would in effect be playing Russian roulette with the lives of more than eight million people. NRC must close Limerick Nuclear Plant by 2029. 5 6 7 8 Comment: 1-13-PA; With loss of cooling water, Limerick's fuel rods could heat up, self ignite, and burn in an unstoppable fire with catastrophic results. Exelon has not been required to spend the money to guard limerick against terrorists, missiles, or air strike despite repeated requests to do so. 9 10 11 Comment: 1-24-PA; It's not safe, it's a ticking time bomb. And nuclear power, they say it's always on. That's not true either as evidence by shutdowns, some for long periods caused by earthquakes, tornadoes, hurricanes, fires, heat, and drought and more. 12 13 14 15 Comment: 4-1-PA; Increasing floods, droughts, earthquakes, tornados have made us all feel insecure, making nuclear power increasingly risky, especially with the Limerick plant basically in our backyards. Any earthquake that comes through this area could be a possible Fukushima, Chernobyl or Three Mile Island... 16 17 18 Comment: 4-15-PA; The 9-21-11 Mercury article said "whether or not earthquake risk is a factor in the current relicensing request for Limerick remains to be seen". It would be grossly unacceptable for the NRC to ignore Limerick's extreme vulnerability to earthquake damage. 19 20 21 22 Earthquake risk should be on the top of NRC's relicensing concerns for Limerick. Earthquake risks are far greater for Limerick than previously realized--increased by 141%. We now know Limerick is 3rd on nation's earthquake risk list Plus evidence shows earthquakes in the East can be far stronger than Limerick's "design basis" can withstand. 23 24 25 There's a good chance that an earthquake can exceed Limerick's design basis, causing a severe nuclear accident, jeopardizing the health, safety and financial well being of our entire region. 26 27 The Virginia 8-24-11 earthquake caused shaking in PA at Limerick Nuclear Plant. Since January there have been 2 small earthquakes in Philadelphia, only 21 miles from Limerick. 28 29 30 Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to nuclear disaster. It's disquieting that NRC uses a "visual inspection" to determine damage on buried pipes. Problems may not be identified until it's too late. 31 32 33 For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on fires and earthquakes. To save money, Exelon typically concludes Limerick is "safe enough". This is unacceptable! 34 35 36 10-5-11, the Mercury reported a flaw was found in the mechanism to shut down the nuclear plant. The warning was tied to renewed focus on earthquake risk. It's difficult to see how Limerick's design flaws can be fixed, even if Exelon WOULD spend the money. 37 38 There is no proof whatsoever Limerick's design can withstand other threats ranging from hurricanes, tornadoes, floods, or terrorist attacks to an impact from a jet airliner. 39 40 We need precaution before there is a catastrophe. NRC should close Limerick as soon as possible. 41 42 43 Comment: 6-3-PA; Of course, what is happening here will be taking much longer, but it is sure not good news. Besides harmful power plant exposures, we have environmental disasters and a concern about our nearby earthquake fault and others in the eastern U.S., especially one near A-27 Appendix A 1 2 New York City. And then there are the radioactive spent fuel deadly waste material sitting around, supposedly protected. 3 4 Comment: 6-7-A; An earthquake in our area is not too far fetched. And of course, threat of terrorism with vulnerable spent fuel are always a concern. 5 6 7 8 9 10 11 12 Comment: 8-6-PA; One big concern--because of Japan's recent experience and the fact that we had an earthquake in the Limerick plant's territory--is refurbishing the plants so they can withstand earthquakes. It has been widely reported by MSNBC and the AP, using NRC data-- that the Limerick plant has the nation's third highest risk of being damage by an earthquake. When the plant was built, no one thought this area would get earthquakes. Now we do. I understand Congress is now or soon will be considering increasing earthquake preparedness capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would encourage them to do less than they should to make the plant safer. 13 14 15 16 17 18 19 20 21 22 23 Comment: 19-1-A; Now lately with the -- unfortunately it's a reality now that we have hurricanes, more tornadoes, tsunamis throughout the world. And I hate to say it but it is a reality now that we have terrorist attacks and Limerick is definitely one. I don't want to be blowing this out of proportion but it's just something that I know that we've all been concerned about, not wanting to say yes, Limerick, and all the people that built the power plant and the company say oh, there's no impact to the air and the water pollution and so forth. So we've kind of just blinded our, you know, selves to that and let's believe then, okay, let's take a minute. Let's really believe that there is no impact in our clean air, clean water and those type of things and cancer, et cetera. Let's just go into the new reality which is terrorist attacks which would happen. Let's just say for example there was human error there with the spent fuel rods and something happened, or a radiation leak. 24 25 26 27 Comment: 30-10-PA; Let's also mention a fact that Category I Hurricane Irene, which could have been Category 3, just zipped less than 100 miles away from the site a few weeks ago and then Hurricane Lee which decided to travel further east case close to also causing chaos. Limerick is still TOO close to the disaster of Hurricanes as well. 28 29 Comment: 37-11-PA, 39-12-PA; Increased Risked of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disasters 30 31 32 33 34 Comment: 45-2-PA; Limerick is 3rd on the earthquake risk list. It is too dangerous to keep Limerick operating. Earthquakes and other natural disasters are more frequent and stronger. Underground pipes and cables can shake and break, then lead to loss of power, loss of cooling water, and meltdown. Limerick's substandard containment flaw means more radiation would be released. 35 36 Comment: 47-1-PA; Limerick Generating Station is old and I don't think it is strong enough to with stand plane impacts, earthquakes, or tornadoes that occur here. 37 38 39 40 41 42 43 44 45 46 Response: The comments express concern for the potential adverse environmental impacts associated with postulated accidents. The impacts of design basis accidents were evaluated in the GElS and determined to be small for all plants; therefore, it is a Category 1 issue. The GElS evaluated severe accidents for all plants including LGS, and it concluded that the impact was small under Part 51, "Environmental protection regulations for domestic licensing and related regulatory functions." In accordance with 10 CFR 51.53(c)(3)(ii)(L), the license renewal Environmental Reports must provide consideration of alternatives to mitigate severe accidents if the staff has not previous evaluated SAMAs for the applicant's plants in an environmental impact statement or related supplement or in an environmental assessment. The staff has previously performed a site-specific analysis of severe accidents mitigation in the NEPA A-28 Appendix A 1 2 document for LGS. For the license renewal review, the staff must consider whether new and significant information affects the environmental determination in the NRC regulations. 3 4 5 A detailed discussion of postulated accidents, and the staff's considerations of new and significant information related to SAMA, including seismic risk, can be found in Chapter 5 of this SEIS. 6 7 8 9 10 11 12 13 Comment: 56-1-PA; The original SAMA analysis for the Limerick Generating Station (LGS) is a 1989 report that was issued as the result of a ruling by the U.S. Court of Appeals for the Third Circuit, which concluded that the NRC had failed to consider a "reasonable set" of Severe Accident Mitigation Design Alternatives ("SAMDAs"). In 1989, the NRC subsequently adopted this SAMDA analysis and agency staff concluded they had "discovered no substantial changes in the proposed action as previously evaluated in the FES [Final Environmental Statement] that are relevant to environmental concerns nor significant new circumstances or information relevant to environmental concerns and bearing on the licensing of [LGS]". 14 15 16 17 18 19 20 21 As the original LGS SAMDA effort in 1989 was the first mandated effort to focus on SAMAs, the notion that an updated SAMA analysis need not be completed at the license renewal stage (for the exact reactor site that gave birth to the regulatory requirement) we find highly objectionable, particularly in light of the catastrophic nuclear accident that befell similar Boiling Water Reactor (BWR) units in Japan in March, 2011. It has become clear in the 770 years of combined U.S. BWR operational experience since 1989 that domestic and international events provide numerous examples of "new information" and make a strong case for the need to reconsider all that has been learned about newly discovered risks and vulnerabilities of nuclear power plants. 22 23 24 25 26 27 28 29 It has been noted that global core damage events happen at a rate that exceeds NRC's presumptions of what should be considered safe at plants within the U.S., which implies that either the NRC estimates for domestic plants are wrong or that international nuclear plants have a core damage frequency much higher than what the NRC deems safe. Either scenario is troubling and deserves the industry's full attention and effort. Exelon's 1989 effort in response to the Court was, respectfully, less than one would have hoped for in light of the seriousness of the issue. The LGS 1989 SAMDA can in no way claim necessary conservatism with regard to public safety over the total timeframe of a possible sixty year reactor lifetime. 30 31 32 33 34 35 36 37 In contrast to the 1989 SAMDA, relatively recent SAMA analyses conducted in other license renewal applications, such as those for sites at Nine Mile Point, Three Mile Island, and the Joseph M. Farley Nuclear Plant, to name a few, were considerably more thorough and addressed a range of detailed alternatives. Pursuant to regulatory analysis techniques supplied by NRC and aided by an industry-supplied guidance document most modern-day SAMA analyses are designed using a fairly prescriptive set of initial assumptions, baseline calculations, and cost benefit arithmetic recipes that employ the use of sophisticated codes in their evaluation of potential risk and the benefit of removing this risk. 38 39 40 41 42 43 44 45 46 The most common code used is the MELCOR accident consequence code system (MACCS2), which provides a modeling framework for calculating the off-site consequences of a severe accident. This code accepts an advanced set of input parameters, including population density distributions within 50 miles, detailed regional economic data obtained from multiple sources, nuclide release scenarios accounting for reactor core inventory, emergency response and exposure variables, and meteorological data for plume migration pathways. The current state of knowledge regarding the assumptions and understanding of severe accident events has expanded and improved in the intervening twenty-two years since the initial SAMDA analysis for LGS. A-29 Appendix A 1 2 3 4 5 6 While we acknowledge that this analysis was limited by the knowledge available at the time, the limitations and shortcomings of a previous era in no way disqualify the claim that, in light of numerous advances in modeling capabilities, a library of discovered cost-beneficial SAMAs, and the saliency of severe accident risks following the disaster at Fukushima Daiichi, not only is there new and significant information, there are significant volumes of this information acquired since 1989. 7 8 9 10 11 12 In the licensee's current environmental report, the identification and treatment of new and significant information (four items in total) were developed only in the narrow context of how they may affect the dated SAMDA analysis. It should go without saying that this approach does not comprise all of the applicable new and noteworthy severe accident mitigation strategies bearing on the site in question, or serve to remedy gaps and omissions in the original SAMDA analysis. 13 14 15 16 17 The entire set of first-stage envisioned alternatives in the initial SAMDA analysis was no more than fifteen options. The "analysis" in the current environmental report consists of perfunctory, "back-of-the-envelope" calculations in lieu of a proper SAMA analysis. The current operator Exelon referred to these considerations as representing an "abundance of caution." We disagree. 18 19 20 21 22 23 24 25 One of the largest problems with the calculations offered, aside from only focusing on an arbitrarily limited number of alternatives, is that licensee evaluated each item of new information in isolation of the other factors that would also change the cost-benefit conclusion for a particular alternative. The effects of each changed parameter (e.g., population, offsite economic risk, cost per person-rem averted, and seismic hazards) should be evaluated in a comprehensive model that shows the aggregate benefit, as performed in all current day SAMA analyses. Unfortunately, their analysis barely scraped the surface of how this new information should actually be considered in the context of environmental impacts. 26 27 28 29 30 31 32 33 34 35 In comparison, a "reasonable set" of alternatives for another recently relicensed plant included an initial consideration of 128 SAMA candidates developed from previous lists at other plants, NRC documents, and documents related to advanced power reactor designs. After screening this initial set for non-applicable or previously implemented designs as well as combining/dropping common-benefit options, the applicant was still left with a set of forty unique SAMA candidates, for which it was required to enter preliminary cost estimates in a so-called "Phase I Analysis." A total of fifteen SAMA candidates survived this screening to enter more detailed cost consideration in the Phase II analysis, of which none were deemed cost-beneficial. However, in another renewal application, the SAMA analysis found eleven potentially cost-beneficial options from an initial set of thirty-three. 36 37 38 39 40 41 42 In an NRC report discussing insights on SAMAs in connection with plant license renewals, the agency authors list numerous potentially cost-beneficial SAMAs relating to station blackouts, protection and support systems, procedures and training, and external events such as flood, fire, and seismic hazards. The authors note that "averted onsite costs (AOSC) is a critical factor in cost-benefit analyses and tends to make preventative SAMAs more attractive than mitigative SAMAs." This AOSC factor was not considered in either the original SAMDA or the recently submitted environmental report. 43 44 45 46 47 48 Finally, NRDC believes that in addition to a comprehensively updated SAMA analysis, the licensee or agency must conduct a study that, as part of the supplemental environmental impact statement, presents postulated accident scenarios showing the full range and weight of environmental, economic, and health risks posed by these accidents. This type of study should model site-specific severe accidents and illustrate the full consequences of a range of severe accident scenarios so that the public and their policy makers can make informed decisions A-30 Appendix A 1 2 3 4 5 whether to continue plant operations after the existing licenses expire, thereby continuing to run the risk of a severe nuclear accident, invest in additional accident mitigation capabilities, or alternatively, avoid these risks altogether by relying on a portfolio of low carbon electricity generation alternatives that could meet future electricity service needs over the license extension period. 6 7 8 9 10 11 12 13 The SAMA analyses are inadequate in this regard because they only address isolated issues in a cost-benefit analysis that discounts the cumulative impacts on displaced populations, regional economic losses, and environmental cleanup. These types of calculations do not present a clear picture of the potential hazards or costs experienced in the event of a severe accident. Instead they tend to mask the full range of accident consequences that policy makers may wish to avoid. Recently, NRDC produced an analysis, of the type we believe should be included in the Limerick NEPA analysis, to inform ongoing relicensing efforts at the Indian Point nuclear plant site. 14 15 16 17 18 19 20 21 22 In order to illustrate the full extent of a major accident, the NRDC study used the U.S. Department of Defense computer model HPAC (Hazard Prediction and Assessment Capability) to calculate site-specific release radiological source-terms, resulting fallout plumes, and data on the effects on nearby populations. The results were compared to similar modeling of the Fukushima disaster to provide a sense of scale, and to estimate the rough magnitude of financial and economic damages that would be incurred if a severe accident were to occur at Indian Point. This is not a hypothetical issue. Policy makers in several countries, including Germany and Switzerland, have made decisions not to grant nuclear plant license extensions to avoid having to endure the continuing risk of severe nuclear plant accidents. 23 24 25 26 27 28 29 30 31 Regardless of Exelon's own corporate understanding of its legal obligations, NEPA is clear in its well-established mandates and what it requires of the NRC. NEPA requires that federal agencies characterize environmental impacts broadly to include not only ecological effects, such as physical, chemical, radiological and biological effects, but also aesthetic, historic, cultural, economic, and social effects. NEPA requires an agency to consider both the direct effects caused by an action and any indirect effects that are reasonably foreseeable. Effects include direct effects caused by the action and occurring at the same time and place and indirect effects caused by the action, but later in time or farther removed in distance, but still reasonably foreseeable. 32 33 34 35 36 37 38 39 40 41 42 43 Most specifically, NEPA directs that NRC take a "hard look" at the environmental impacts of its proposed action, in this instance the relicensing of two BWR Mark 2 units for an additional 20 years, and compare them to a full range of reasonable alternatives. "What constitutes a 'hard look' cannot be outlined with rule-like precision, but it at least encompasses a thorough investigation into the environmental impacts of an agency's action and a candid acknowledgement of the risks that those impacts entail." Nat'l Audubon Soc. v. Dept of the Navy, 422 F.3d 174, 185 (4th Cir. 2005) (emphasis added). As a stalking horse for the NRC's draft EIS, the applicant's ER does not meet this standard. In taking the "hard look" required by law, the NRC must therefore address the potential environmental impacts of a range of severe accidents--and accident mitigation strategies--especially in light of the new information provided by the Fukushima nuclear disaster on the performance of BWR radiological containment in a prolonged loss-of-coolant, core-damage scenario. 44 45 46 47 48 For the reasons stated above, NRDC urges that NRC direct that a thorough and lawful SAMA analysis be conducted as part of (or supplement to) the required supplemental environmental impact statement, the draft of which is currently scheduled for August 2012 and the final SEIS currently scheduled for February 2013. Additionally, the full cumulative effect of severe accidents must be studied and presented as part of these documents. These analyses must A-31 Appendix A 1 2 3 4 5 6 7 8 9 make every effort to meet the current expectations of what these studies should encompass and use the necessary guidance and tools commonly utilized by the industry and NRC. The NRC's legal obligation to consider new information and determine its nuclear safety significance exists independently of whether a SAMA has or has not been prepared previously: in the event a SAMA has not been prepared, then new and potentially significant nuclear safety information must be included in the initial SAMA; if a previous SAMA exists, then it must be updated to reflect this new information, and the resulting costs and benefits of the full spectrum of reasonable accident mitigation alternatives must be considered as part of the Draft Supplemental Environmental Impact Statement, and issued for public comment. 10 11 12 13 14 15 Response: For license renewal, the NRC discharges its NEPA obligation to consider severe accidents mitigation through 10 CFR 51.539(c)(3)(ii)(L) and Table B-1. In accordance with 10 CFR 51.53(c)(3)(ii)(L), the license renewal ERs must provide consideration of alternatives to mitigate severe accidents if the staff has not previous evaluated SAMAs for the applicants plants in an environmental impact statement or related supplement or in an environmental assessment. LGS is a plant that had a previous SAMA documented in a NEPA document. 16 17 18 19 20 21 22 23 Under NEPA, the NRC must consider whether new and significant information affects environmental determination in the NRC's regulations, including the determination in 10 CFR 51353(c)(3)(ii)(L) and Table B-1, that the agency need not reconsider SAMAs at license renewal if it has already done so in a NEPA document for the plant. New information is significant if it provides a seriously different picture of the impacts of the Federal action under consideration. For SAMAs, new information may be significant if it indicated a given cost-beneficial SAMA would substantially reduce the risk of a severe accident, by reducing the probability, or the consequences of a severe accident. 24 25 The staff's evaluation of new and significant information for SAMAs is addressed in Section 5.3 of this SEIS. 26 A.1.12. Radioactive & Non-Radioactive Waste (RW) 27 28 29 30 Comment: 1-10-RW; This aging plant is an accident waiting to happen. Large volumes, more than 6,000 assemblies weighing more than a thousand tons of highly radioactive waste in the form of spent fuel rods are stored in densely-packed pools, elevated five stories above and outside the reinforced containment structure. 31 32 Comment: 1-11-RW; This plant will produce about two more tons of dangerous spent fuel rods every year that it operates. 33 34 35 Comment: 1-14-RW; Dry cask storage and transport are also very dangerous alternatives. It's time to close Limerick and stop producing such deadly waste for which there is no safe solution. As long as Limerick operates harms to us and our environment will increase. 36 Comment: 1-30-RW; [R]adiation into air and water from routine and accidental emissions 37 38 Comment 1-36-RW; [D]eadly high-level radioactive wastes that are packed in vulnerable fuel pools on this site and they are in fact unprotected. They are above ground and unprotected 39 40 Comment: 6-4-RW; [T]he radioactive spent fuel deadly waste material sitting around, supposedly protected 41 42 Comment: 18-1-RW; One would be what are we going to do with the 20 years of spent rods and how are you going to take care of those. A-32 Appendix A 1 2 3 Comment: 23-3-RW; And then to--I'm sure that the generic plan includes a pretty good discussion of fuel storage long-term and short-term onsite but certainly the site-specific fuel storage considerations. 4 5 6 7 8 Comment: 30-7-RW; The NRC and USA Government still have not decided where to store spent nuclear rods and as we speak each spent rod is sitting in baths on the Limerick site, stacking up--expanding even a greater hazard to the community, environment, etc. So put simply, there absolutely no reason to approve this request for years until the US Government decides how they will handle such rod and such rods and properly stored. 9 10 11 Comment: 34-3-RW; The disposal area must be in operation not some theoretical site like the now defunct Yucca site. The public and our future generation deserves to know what is expected to be done at the site. Radioactive material must not be allowed to remain on the site. 12 13 14 Comment: 35-5-RW; Limerick Nuclear's request for re-licensing is ludicrous, considering its aging and inadequate equipment, its increased air pollution by particular matter, its horrific destruction of the Schuylkill River and dangerous above-ground spent fuel rod storage. 15 16 Comment: 37-8-RW, 39-9-RW; Deadly high level radioactive wastes packed in vulnerable fuel pools on site 17 18 Comment: 52-5-RW; The plant can no longer store its used fuel rods and has asked permission to begin transporting them to another facility. 19 Comment: 60-4-RW; Spent fuel--Storage--Uranium mining--Dirty 20 Comment: 60-11-RW; Nuclear waste--nothing clean 21 Comment: 60-14-RW; Radiation in air and water--Radioactive ground water 22 23 24 Response: Radioactive and non-radioactive waste management is discussed in Section 2.1.2 in this SEIS. The NRC's evaluation of impacts of the uranium fuel cycle and waste management are addressed in Chapter 6 of this SEIS. 25 A.1.13. Socioeconomics (SE) 26 27 28 29 30 Comment: 1-28-SE; Then you take the property taxes. They tried to get zero for their property taxed by the end of the 90s and didn't pay any property taxes until the early 2000s at which time they paid $3 million instead of $17 million they were suppose to pay. So when you think about that no wonder Exelon's willing throw around a couple million in the community. They owe this community a lot more than what they're giving. 31 Comment: 52-3-SE; The area around the facility has exploded with homes and businesses 32 33 34 35 36 37 Response: The property taxes paid by Exelon are presented Section 2.2.9.2 in this SEIS. Section 2.2.9.1 discusses the total number of vacant and occupied housing units in Berks, Chester, and Montgomery counties. Section 2.2.9.6 presents information on the number of businesses in the area. Section 4.9 presents the NRC's evaluation of socioeconomic impacts of continued operation of LGS. In addition, the socioeconomic impacts of not renewing the operating license are discussed in Chapter 8. 38 A.1.14. Support of License Renewal (SR) 39 40 41 Comment: 2-1-SR; Operating Limerick Generating Station safely and reliably is a responsibility that everyone at the power station takes very seriously. We understand our obligation to the community, to the environment, and to each other to operate the plant safely. A-33 Appendix A 1 2 3 A key component of a thriving community like ours is the availability of safe, clean, and reliable electricity. And as we look into the future for the power needs of Pennsylvania and the United States as a whole, we can see the increasing demand for this very important resource. 4 5 6 7 8 9 At the same time, there's a growing concern about greenhouse gases and climate change that is a result of burning fossil fuels. To help meet that growing power demand and to help keep our environment clean, Exelon has applied to the U.S. Nuclear Regulatory Commission for a 20-year extension to the plant's operating license. Limerick's current license for Unit 1 will expire in 2024 and Unit 2 in 2029. With license renewal, Limerick can provide our region with clean power through 2049. 10 11 12 We understand our special obligation to operate the plant safely and reliably and to maintain a close relationship with our neighbors. We pledge to continue that special trust as we operate the plant well into the future. 13 14 15 Comment: 3-1-SR; I'm here today to voice my strong support for the relicensing of the Limerick Generating Station. I wanted to touch on a couple points of why I feel it is important for this facility to be relicensed. 16 17 18 19 First is the amount of electricity that is produced by this facility. One of the things that myself and my colleagues in Harrisburg hear consistently from businesses and the Commonwealth and our citizens is the demand for energy and electricity now and more importantly what that demand is going to be in the future. 20 21 22 23 24 25 26 Right now this facility generates enough electricity for two millions homes and without producing some of the greenhouse gases that we hear so much about that could be produced by coal, natural gas, or oil. And I'm going to put a caveat in there for my good friends out in the western part of the state where coal is a big part of the Pennsylvania economy and I'm suggesting that this be done to the exclusion of coal and nevertheless, some of the technologies that they're developing out there are also important for that industry and important for the Commonwealth of Pennsylvania. 27 28 29 Again, one of the concerns we hear consistently from businesses is how can we come here into Pennsylvania with the infrastructure being what it is which needs to be improved for the transmission of the electricity, but more importantly the generation of that electricity? 30 31 32 Number two, I think is important is the jobs and overall economy. Again, in these tough economic times that we're facing here in the Commonwealth of Pennsylvania and also in this nation, one of the top issues that we hear consistently about is jobs. 33 34 35 36 37 38 And as was mentioned by the site vice president, over 860 people are employed here with an annual payroll of $75 million. The direct impact that is to the Commonwealth of Pennsylvania, of course, is realized through the state income tax and also all of these local municipalities most of them enact an earned income tax which again sustains their townships as well as their respective school districts. To have that taken away I think would have an even more dramatic impact on our local economy. 39 40 41 42 As was mentioned the impact for the local area here, the temporary workers who show up here during the outages and the refueling, there's already been two hotels that have sprung up along the 422 corridor with another one planned right up here at the Sanatoga area. Again, more jobs and more economic growth here for our communities. 43 44 45 46 Thirdly, I want to talk about the communication that I've experienced in the seven years that I've been in office with Exelon and with their Government Affairs people as well as with their site people. I've been on the site three times, twice for a tour and one to make a presentation during an anniversary of the facility. And I have to say that it is a very secure area. I know a lot of A-34 Appendix A 1 2 3 4 5 people are concerned about terrorism attacks or people being on the property. But unless you've actually gone over there and gone through a tour, seeing how things are set up, seeing the armed guards there, seeing the security measures that are in place, I think you come away much more relieved with that. And I'm able to speak to my constituents more affirmatively about the safety and security of the facility. 6 7 8 9 10 11 Any time that there's been the slightest occurrence there, whether it will be a couple times a hunter has wandered onto the property where the authorities were called, the Government Affairs people at Exelon are on the phone to me or with an email right away to let me know what's happening before the word gets out to the media or to the press. So they're always very well prepared in their explanations, not only of things that happen at the plant itself, but also incidents and issues that occur around the country and around the world. 12 13 14 Obviously, what took place in Japan with the incident over there, they were on the phone with me and met with me a few times to explain what took place over there and how the safeguards are being put in place here so that doesn't happen at this facility. 15 16 17 18 19 Comment: 5-1-SR; Because the license Generating Station can be operated safely and reliably, Exelon decided to pursue license renewal for Limerick. Limerick is a very clean energy source which produces no greenhouse gas emissions. Limerick is also good for the economy in that it lowers market prices on electricity for the citizens of Pennsylvania to the tune of $880 million per year. 20 21 22 Comment: 5-4-SR; [W]e operate Limerick safely and we can continue to operate it safely for an additional 20 years. Limerick will provide approximately 2340 megawatts of base-load generation that's not only safe, but it's clean, reliable and economical. 23 24 Continued operation of Limerick will benefit this community, the Commonwealth of Pennsylvania and our nation. 25 26 27 28 29 30 31 Comment: 7-1-SR; As the largest private employer in the region, the Board is thankful for the 860 jobs that Exelon provides, the positive impact of their operation, the vitality of our local community. The community and local economy are enhanced by the needed services provided by the township, which includes the roadway network maintained by our Limerick Township Public Works, public safety provided by the Limerick and Linfield Fire Companies, and our local emergency medical response, our public parks, our recreation facilities and also the police protection that's provided by Limerick's 21 sworn officers. 32 33 34 35 36 37 38 39 40 41 42 43 Because of Limerick Generating Station's location within our borders, the Limerick Township Police Department is the only municipal police department in Pennsylvania with the primary jurisdiction over Tier 1 critical infrastructure. This Board prides itself on the services provided directly both to the residents and the businesses of this community and the township's ability to maintain those current levels of service during these difficult economic downturns. We are thankful for the generosity of the Limerick generating plant and Exelon for being good corporate neighbors and the assistance they provide to the community. Without their financial assistance that impact to provide those services to the community would fall squarely on the backs of the taxpayers. They assist in our fire companies. They have been corporate sponsors of our Limerick Community Days. And we are confident that Limerick generating facility and Exelon will continue that support in the future and be our good corporate neighbor. We also are in support of the relicensing of the Limerick nuclear plant. 44 45 46 47 Comment: 11-1-SR; I'm president of the Tri-County Area Chamber of Commerce. I'm happy to be here today to provide examples of how Limerick Generating Station is a valued community and business partner and echo the statements already shared by several others. They're one of the tri-county area's largest employer, providing professional employment opportunities for A-35 Appendix A 1 2 3 4 5 local residents. Those local residents employed by Limerick Generating Station are supporting the entire tri-county business community. They're purchasing personal goods and services from local small businesses. The annual outage is a tremendous benefit to the local economy and our local businesses. Limerick encourages their outage employees to visit and purchase from tri-county area, local businesses, and small businesses. 6 7 8 In addition to the jobs they provide local residents, they're making a significant investment in our local communities. Municipalities and residents benefit from assistance received from Limerick to start, maintain, expand parks, recreation, and quality of life opportunities. 9 10 11 12 13 Their corporate culture of giving back to the community is practiced by their hundreds of employees. Nonprofit organizations are supported by Limerick Generating Station and the efforts of their employees. Financial donations, as well as volunteer hours and time are donated, enabling our local nonprofits to provide the much needed services that impact those in need throughout the tri-county area. 14 15 16 17 18 19 The Limerick Generating Station is confident in the clean and safe environment they maintain in our community. The community has been invited to experience the generating station firsthand. The chamber hosted a membership breakfast and the site vice president, Bill Maguire provided the keynote presentation. He summarized safety measures and advancements at Limerick and answered questions pertaining to the Limerick plant and its safety in the wake of the tsunami in Japan. 20 21 Comment: 12-1-SR; I don't believe that continued operations of the power plant would have any detrimental effect on public safety in the southeast region. 22 23 24 25 26 27 Comment: 13-1-SR; Today, I would like to say that in all of the years that I've lived in this area, I've never worried at all about the safety of the nuclear power plant. I see it every day. And it bothers me not in the least. I have never seen any credible evidence to suggest that there are safety problems with this plant. In terms of reliability, it is the same. It is running 24/7, 365 days a year and it has been doing so for a quarter of a century and I hope it continues to do so for many more years to come. 28 29 30 As far as its environmental impact, I think it's pretty widely known that nuclear power is one of the cleanest environmental energies that we possess today throughout the world and to dismiss it is I think a foolish notion. 31 32 33 34 The impact of the Limerick plant in our region has been extraordinarily positive. It provides, as we all know and have heard today, lots of jobs, lots of good jobs, tax revenues for schools, local governments and for those who live in the area to enjoy the fruits of public services and it also provides a lot of charitable donations to the community which is very important. 35 36 37 38 I think that to not keep this plant running and not consider a renewal of its license for an extended period would be a tragic mistake for all of us and I would like to end this by saying that the only meltdown that would concern me is the economic one that certainly would happen to this area should this plant not continue to operate. 39 40 41 42 43 44 45 46 Comment: 14-1-SR; But I'm here today as a private citizen, as a resident of the area and as a member of the Pennsylvania Energy Alliance to go on record and say I strongly favor license renewal for the Limerick Generating Station. I say that because in my personal experience I know in spite of some of the things you've probably heard here today, nuclear power is safe, reliable, secure and clean. But in addition to that, I would like to go on record, I would like my neighbors to know we are lucky to have the Limerick Generating Station in this area. In the industry, it has a top reputation. It is one of the finest nuclear power plants in America. And Exelon, if not the best, is certainly one of the finest nuclear operators in the world. A-36 Appendix A 1 2 3 4 I have nothing but confidence that Exelon will work together with the NRC, will run through the process and we will come up with the right conclusion here which is license renewal should be granted to the Limerick Generating Station. I think we need to keep Limerick operating as long as we can. 5 6 7 8 Comment: 14-2-SR; And so from my perspective as a citizen, as a business person who worked in this community, I understand the value this is to the region. And for me, I applaud the NRC for what they're doing here. I applaud Exelon for the great work that they're doing there and I encourage the renewal process to take place. 9 10 11 12 13 14 15 16 17 Comment: 17-1-SR; And my comments tonight are more I guess from my perspective as a newly elected official with the generating station. About a year ago I had the opportunity to go down to the generating station and meet with Joe Saffron and the first part of my meeting had to do with looking for some support for the Pottstown Soapbox Derby. Through some conversation while we were standing outside you know Joe [told] me a little bit on what Exelon and the generating station do for the surrounding communities, whether it's supporting our firefighters, police departments and other civic organizations. You know, from a Pottstown perspective they help us with our yearly borough cleanup, our Salvation Army and now the Soapbox Derby. Thank you. 18 19 20 21 22 23 24 25 26 27 28 29 30 And we were standing outside that day, it was pretty nice out, and our conversation led to the power plant itself. We were standing there looking around it's a pretty impressive sight. So I asked him about, you know, possibly having a tour for municipal officials. He said he would look into it and see what he could do. A couple of months later he got a group of about 20 of us and gave us a tour of the plant one evening. And I have to say that from the time we walked through the front gates and past the security as our tour progressed, you know, throughout the plant safety was paramount. Whether you were having explained what the different colors are on the different panels and what they mean to different fail safes, why you walk certain areas certain ways and what lines you had to stand behind, you know, safety was paramount with them. You know, from the environment, I'm looking around and this place is spotless. And I asked why and it's because they can't afford to have dirt or lint or fuzz balls around because of static electricity because it could create issues. So from that aspect I thought it was a good tour and it made me feel good about the safety aspects there. 31 32 33 34 35 36 37 38 39 To finish our tour we ended up in the control room upstairs. And I'd say maybe a dozen or so individuals up there monitoring you know everything going on within the plant and around the plant. And again, explaining the failsafes and why they're double-, triple-checked to eliminate human error. It was just very impressive and as an elected official to go down and take a tour of the plant and understand how it operates. I know when I left I personally know how to issue a concern with the generating station. I know I felt a lot better and a lot safer going home that night. And it was also good to realize, you know, as one of our region's largest employers now that they are willing to give back to the community and keep safety first. So thank you, I just wanted to make those comments. 40 41 42 43 Comment: 20-1-SR; I'm going to be making essentially five points in support of license renewal for Limerick Generating Stations and they are that, number one, nuclear energy lowers electricity prices, it protects our environment against greenhouse gases, it strengthens our local economies and it is safe. 44 45 46 47 48 With regard to my first point in lowering electricity prices the Limerick Generating Station has reduced wholesale energy costs in Pennsylvania by $880 million in 2010 thus lowering electricity prices for all consumers. It operates around the clock thereby stabilizing the nation's electricity distribution system and the electricity marketplace. The average electricity production costs at nuclear plants have actually declined more than 30 percent in the past 10 years due to A-37 Appendix A 1 2 3 various efficiencies. Nuclear power is cheaper to produce than other forms of electricity generation such as coal and natural gas, and helps moderate the price of electricity for consumers. 4 5 6 7 8 9 10 11 12 13 14 15 My next point is that Limerick Generating Station and nuclear plants strengthen our local economies and it is a valuable economic driver for the Commonwealth of Pennsylvania. Limerick Generating Station contributes $113 million annually in direct economic contributions to the Pennsylvania economy through various employee wages and salaries, purchase of goods and services from other Pennsylvania businesses and in property tax payments to the local governments. Limerick Generating Station also contributes generously as we've also heard and in fact in 2010 contributed $600,000 to various community organizations. Limerick has over 800 full-time employees and employs more than 1,000 skilled temporary contract employees during annual refueling outages. A significant percentage of the current nuclear plant workforce will reach retirement age in the next 10 years creating a demand for high-paying jobs in the nuclear industry. Yes, Limerick Generating Station is one of Pennsylvania's most valuable economic and energy assets and the commonwealth should embrace it. 16 17 18 19 20 My third point is that nuclear energy protects our environment from greenhouse gases and reduces the need to generate electricity from fossil fuels. If Limerick Generating Station were retired from service replacing the electricity would require increased natural gas-fired or coal-fired generation. Nuclear energy is the nation's largest source of carbon-free electricity and is critical to our nation's environmental, security and energy goals. 21 22 My next point is that nuclear energy is safe. It's always on, it's stable, it's a reliable source of electricity and the station here at Limerick has been built with multiple redundant safety layers. 23 24 25 26 27 28 And the workforce is committed to best practices and continuous improvement. It is also important for our nation's quest to be energy-independent. According to the Bureau of Labor Statistics it's safer to work at a nuclear plant than in industries such as manufacturing, real estate and finance. And according to the Department of Energy a person receives more radiation exposure flying from Baltimore to Los Angeles than by standing near a nuclear plant 24 hours for a year. 29 30 31 32 On a personal note I've been inside Limerick Generating Station several times. I've also lived within 30 miles with my four boys and wife next to the Limerick Generating Station and also Three Mile Island. I feel safe, secure and comfortable. That is why I'm in support of the re-licensing of the Limerick Generating Station. 33 34 35 Comment: 50-1-SR; I wanted to let you know that I am complete and full supporter of the Limerick Nuclear plant. I am also supportive of the scientific [judgment] and expertise of those such as yourself who have the job of making the decisions. 36 37 38 Response: These comments express support for nuclear power or the license renewal of LGS or both. The comments provide no new and significant information and will not be evaluated further. 39 A.1.15. Surface Water (SW) 40 41 42 43 Comment: 1-17-SW; Dangerous depletion of the Schuylkill River, in and by itself, a singular reason to deny this permit. The Schuylkill is a vital drinking water source for nearly two million people from Pottstown to Philadelphia. It is being depleted and contaminated every day that this plant operates. 44 45 Comment: 1-23-SW; They are destroying the Schuylkill River. There was enough water in the Schuylkill River to sustain this nuclear plant from the very beginning and now we're seeing the A-38 Appendix A 1 2 3 4 5 6 consequences of that and they more and more pollution in it. They want to pump mine water in to supplement the flow for Limerick. It's contaminated and they don't filter it. And they're actually asking for huge, four times Safe Drinking Water standard increase in total dissolved solids which carry a lot of toxic pollutants. So they put radiation into the river 24 hours a day, 365 days a year, and now they're asking for these huge increases and people have the nerve to get up here and say that they have no environmental impacts. 7 8 Comment: 1-32 SW; Schuylkill River depletion and major drinking water contamination. Keep in this is vital drinking water source for nearly 2 million people from here to Philadelphia. 9 10 11 12 13 14 Comment: 4-5-SW; Our drinking and bathing water here is being continuously polluted by Limerick every day, 24/7 for years with radiation and unfiltered toxic contaminated mine water, thanks to the NRC and Exelon. This is disgusting. Most of us have to depend on the water, especially for bathing. Some of us pay extra for water filtration or drink bottled water because we are afraid to drink from the Schuylkill and because it tastes really bad now. Imagine how toxic it would be 18 plus years from now if there was even any wate left. 15 16 17 18 19 20 21 22 Comment: 4-10-SW; So then there's the cost for the pollution they're putting in the river. They're asking for increases in pollution. They want to put more mine water in. They want to increase the total dissolved salts. That's going to cost water treatment systems a lot of money to try to--for extra treatment for that. It can even break down their equipment, some of the stuff that's coming out of the mines. And when you think about it who actually ultimately pays that cost? We do. We pay for increased costs for our water because they're having to do that at the water treatment systems. And it seems to me that if you really take a good look at things Limerick has got to be the major cause for the radiation in Philadelphia's water. 23 24 25 26 Comment: 23-1-SW; Mine water issue, better defining that quality and flow particularly in light of the likely pending changes in stormwater concerns and regulations in the area. Adding that flow to the Schuylkill is going to affect all the municipalities around here who have to deal with stormwater. 27 28 29 Comment: 44-3-SW; There is concern that should be faced regarding the Schuylkill River and the affects it is going to have on the public if it becomes depleted, and/or toxic due to the contaminates going in it. 30 31 32 Comment: 36-2-SW; I am more concerned about the effects of surrounding air and water supply and the future of my children and grandchildren, some of whom are already inflicted with cancer and other diseases. 33 34 35 36 37 38 39 Comment: 45-9-SW; Limerick Nuclear Plant is slowly destroying the vital public drinking water source for almost two million people from Pottstown to Philadelphia. Radioactive and heated wastewater is discharged by Limerick Nuclear Plant into the Schuylkill River 24/7. Limerick's cooling towers are causing significant depletion. To supplement the flow to operate Limerick, Exelon wants to pump more contaminated mine water into the river. No one can credibly assure if drinking water will remain safe even until 2029 when Limerick's original license expires. 40 41 42 43 44 45 46 Comment: 54-4-SW; Since the last impact statement was prepared in 1973, the Schuylkill River has been designated as a state scenic river and as a heritage area for both the state and federal government. Due to these designations and the efforts of non-profit organizations and local government, access to the river has been expanded so that the river has become a recreation and heritage tourism destination. Use of the river in the vicinity of the plant will continue to grow. With the return of American Shad made possible through down stream fish ladders, interest in the river could even grow further in the future. A-39 Appendix A 1 2 3 4 5 6 7 8 9 10 11 12 13 The Limerick Plant withdraws sizeable portions of river water. During low flow periods, additional quantities of water are released into the river from the Wadesville Mine, and Still Creek Reservoir in Schuylkill County to compensate for the water withdrawn at the plant. This process was initially approved by the Delaware River Basin Commission (DRBC), in 2003 and kept active through a series of docket amendments. Future river water use is, dependent upon the ability of this water make up system to operate within various water quality and flow parameters set by DRBC. It is important to evaluate the viability of the use of the river water and water make up system to provide needed water through the expanded plant lifetime. Analysis of this aspect of plant operation needs to account for the water quality impact from the total dissolved solids in the Wadesville water among other parameters. If resumed use of the Delaware water diversion is anticipated, an evaluation of that system is required to ensure that the capacity is available in the conveyance system and that water quality objectives can be met for discharge into the East Branch of the Perkiomen Creek. 14 Comment: 60-9-SW; Dirty polluted mine water 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Response: These comments express concern in part over the health of the Schuylkill River, including river flow and water quality. Surface water resources at LGS, including the Schuylkill River, and the effects of plant operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied upon by LGS and include the sources of water used to augment low flows in the Schuylkill River. Section 2.1.7 further describes the surface water and groundwater sources used to support plant operations, the volumes of water used, and the regulatory conditions and associated regulatory agencies that govern the plant's water uses. With respect to the comments regarding depletion of the Schuylkill River, the NRC's evaluation of LGS's consumptive use of surface water is presented in Section 4.3.2.1 of the SEIS. As described in Section 2.1.7.1 and 4.3.2.1, the Delaware River Basin Commission (DRBC) has imposed consumptive use limits on LGS's surface water withdrawals. During low river flows, the DRBC limits the plant's consumptive withdrawals to no more than 12 percent of river flow to be protective of aquatic life and downstream water users. Under average flow conditions, consumptive water use by LGS amounts to about 3 percent of river flow. 30 31 32 33 34 35 36 37 38 39 With respect to concerns about pollution attributable to operation of LGS, effluent discharges to the Schuylkill River through its discharge structure are regulated by, and subject to, water quality standards set by, the Pennsylvania Department of Environmental Protection (DEP), in conjunction with the DRBC docket issued to Exelon. More precisely, these discharges are regulated through the National Pollutant Discharge Elimination System (NPDES) permitting process as discussed in Section 2.2.4.1. Although the Schuylkill River has historically been affected by a range of activities as described in Section 2.2.4.1 and further in Section 4.11.3 (Cumulative Impacts), the main stem of the Schuylkill River in the vicinity of the LGS currently meets designated water quality standards and uses, including use as a source for public water supply. 40 41 42 43 44 45 46 47 48 49 As required by its operating license, Exelon Generation conducts a Radiological Environmental Monitoring Program (REMP) at LGS to assess the radiological impact, if any, to its employees, the public, and the environment around the plant site. The REMP measures the aquatic, terrestrial, and atmospheric environment for radioactivity, as well as the ambient radiation. The NRC's staff's evaluation of the radiological impacts of LGS operation and its REMP are discussed in Section 4.8 of this SEIS. As part of its evaluation, the NRC staff reviewed Exelon's annual radiological environmental operating reports for 2006-2010 to look for any significant impacts to the environment or any unusual trends in the data. A 5-year period provides a representative data set that covers a broad range of activities that occur at a nuclear power plant. Based on the review of the radiological environmental monitoring data, the staff found A-40 Appendix A 1 2 3 4 5 6 7 8 that there were no unusual and adverse trends, and there was no measurable impact to the offsite environment from LGS operations. Further, the NRC's ongoing Inspection Program periodically inspects Exelon's Radioactive Effluent Monitoring and REMP programs for compliance with the NRC's radiation protection standards in 10 CFR. The NRC's Inspection Program evaluates the data for compliance with radiation protection standards. If the data were to show a noncompliance with requirements, the NRC would take appropriate enforcement action. Additional information for LGS can be found at http://www.nrc.gov/reactors/operating/ ops-experience/tritium/plant-specific-reports/lim1-2.html. 9 10 11 12 13 14 15 16 17 18 19 20 21 Comments 1-23-SW, 4-5-SW, 4-10-SW, 45-9-SW, 54-4-SW, and 60-9-SW specifically raise the issue of the diversion of water from the Wadesville Mine Pool to augment the flow of the Schuylkill River. The use of mine pool water and other diversion sources to augment surface water flows to support LGS operations are described in Sections 2.1.6 and 2.1.7 of the SEIS. These sections also summarize the background and current status surrounding the ongoing water diversion demonstration project that is regulated by the DRBC. The NRC staff's evaluation of the projected impacts on surface water resources of the continued operations of LGS during the license renewal term are presented in Section 4.3 of this SEIS. Regarding use of the Wadesville Mine Pool and other low flow augmentation sources, the DRBC, and not the NRC, is responsible for regulating such activities. Likewise, and as mentioned above, the Pennsylvania DEP through the NPDES permitting process, along with DRBC's docket approval process, are responsible for regulating effluent discharges from LGS and will ultimately decide if revised effluent limits on chemical and thermal discharges are appropriate. 22 23 24 25 26 Comment: 55-6-SW; A note should be added regarding the diversion of Delaware River water to the East Bank of the Perkiomen. Due to the residential build-up along the Perkiomen Creek area, additional consideration should be presented and discussed with the Army Corps of Engineers and the National Weather Service regarding potential flooding impact this may have on the area. 27 28 29 Comment: 35-4-SW; Limerick Nuclear's request for re-licensing is ludicrous, considering its aging and inadequate equipment, its increased air pollution by particular matter, its horrific destruction of the Schuylkill River and dangerous above-ground spent fuel rod storage. 30 31 Response: Aging management of plant systems is evaluated as part of the LRA safety review. The results of the staff's safety review of the LRA for LGS will be documented in the staff's SER. 32 33 Air pollutant emissions associated with LGS operations are presented in Section 2.2.2.1 of the SEIS. The NRC's evaluation of LGS's air emissions is presented in Section 4.2 of this SEIS. 34 35 36 37 Surface water resources at LGS, including the Schuylkill River, and the effects of plant operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied on by LGS and include the sources of water used to augment low flows in the Schuylkill River. 38 39 Comment: 24-1-SW; ...I want to add that I want the NRC to look into potential water depletion issues from shale gas fracking upriver in both rivers. 40 Comment: 60-21-SW; Depleted water due to fracking up river 41 42 43 44 45 46 Response: The contributions of past, present, and reasonably foreseeable future actions or activities in the Delaware River Basin, including hydraulic fracturing (fracking), have been considered in the cumulative impacts analyses of this SEIS as presented in Section 4.11 of the SEIS. With respect to surface water, these impacts are presented in Section 4.11.3. In addition, the environmental impacts of alternatives to the proposed action (i.e., whether to grant a renewed operating license to LGS) are evaluated in depth in Chapter 8 of the SEIS. This A-41 Appendix A 1 2 includes comparative analysis of a natural gas-fired combined-cycle facility as a replacement power source for LGS and considers related effects of hydraulic fracturing to supply natural gas. 3 A.2. References 4 5 10 CFR 2. Code of Federal Regulations, Title 10, Energy, Part 2, "Rules of practice for domestic licensing proceedings and issuance of orders." 6 7 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of production and utilization facilities." 8 9 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental protection regulations for domestic licensing and related regulatory functions." 10 11 10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for renewal of operating licenses for nuclear power plants." 12 13 14 15 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) Accession No. ML11179A104. 16 National Environmental Policy Act of 1969. 42 U.S.C. 4321, et seq. 17 18 19 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, DC, ADAMS Accession Nos. ML040690705 and ML040690738. 20 21 22 23 24 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final Report," NUREG-1437, Volume 1, Addendum 1, Washington, DC, ADAMS Accession No. ML040690720. 25 26 27 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Official Transcript of Proceeding, "Limerick Generating Station License Renewal Public Meeting: Afternoon Session." Adams Accession No ML11287A207 28 29 30 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Official Transcript of Proceeding, "Limerick Generating Station License Renewal Public Meeting: Afternoon Session." Adams Accession No ML11287A211 A-42 1 Comment Letters and Meeting Transcripts 2 3 The following pages contain the comments, identified by commenter designation and comment number, from letters and public scoping meeting transcripts. A-43 Appendix A 31 1 unthinkable proportions . Whether a 2 pr 3 NRc would in effect be placing Russian roulette with 4 the lives of more than eight millio n people . 5 close Limerick Nuclear Plant by 2029 terrorist a tt ack occurs , natura l disaster by relicensing Limerick , I 1-1-PA NRC must 0 There is no way for either NRC or Exelon 6 1-2-0S 7 to ensure 8 r es i dent s 9 fn i l t he s afety of the environment impacted b y th i s plant . snfe No o t. her ent ire fncc i l i t v the I cannot be made It hns or t he notent i nl 10 render t he 11 cen t ur i es 12 at t ack . 13 to region uninhabi table , p o ssibly for the resu lt of an a c cident or t errorist exi st i n any commu n it y i n t h i s co u n try . 1-3-0S as I 1-4-LR I Th i s i s t he highest - ris k f acility that could Current 40 - year operating li censes expire 14 15 n 202 4 and 16 i censes now? 17 2029 we Why 0 urge NKC to to no say renew to t;xe l on s t l1-5-0R I 19 ~ e li eve 20 f'nil es of und erground pipes 21 safely for 40 years and then the f ac ili ty woul d close . 22 Is Exelon fearful that the longer they wait the more Limerick ' s t ha t The public was these requested generators , and fuel cabl es led pools , and 1 1-6-LR could operate I serious problems may arise ? 24 25 renewals . rush 18 23 license the the After only 26 of 4 0 years , of aging and risk have numerous signs b een ide n tified . Corrosion , NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-44 WW'W.nealrgross.com 1-7-0S I Appendix A 32 1 2 !deterioration , of tatigue , materia l , loss cracKing , thinning wi tn fra cture toughness of loss are all 1-7-0S I Cont'd 3 documented i n Exelon ' s own ren ewal application in the 4 agi ng 5 fatigue 6 reactor vessel and coolan t sys tem . management and cracking o f Aging 7 8 sugges t s 9 2029 , 10 section . I nst a nces vital but also equ ipment equipment , aft er that NRC should no t ramp up of equipment include the on ly 26 years just close the pla nt by their oversight 1-8-0S I vig ilance dur i ng the rema i n i ng 1 8 y ears o f the current l i cense . 11 In 12 nplanned 13 ignif i cant probl e ms . 14 u ne 15 imerick 16 ad i oactive 17 nreported 18 nfrastru ct u re , mu ch of it underg round . 19 20 the past few years , shutdowns Li merick h ad numerous t here suggest i ng has are already Th ree occur red i n on e week i n 1-9-0S 20 11. Loss have of already have leaks been contaminati on for There coolant documented . cou l d years and acci dents go already been the two I Serious u ndetected from at and corroding n ear misses at Limerick fro m 1996 to 2001 . This aging p l ant is an acci dent wait i ng to 21 22 happen . Large v o lume s , more 23 weighing more tha n thousand 24 radioactive waste in the form of spent fue l 25 stored in d e nse l y - packed pools , a than 6 , 000 tons assemblies rL-..1....::--:=-:-:-:, 1-10-RW of highly I rods are elevated five stories NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-45 WW'W.nealrgross.com Appendix A 33 1 2 above a nd out side tructure . Th is th e p lant reinforced wi ll produce 1 cont a i nment 1- 10-RW Cont'd about I I two more ,...,.......,....,-::::;-:.,..., 3 4 perat es . fuel ons o f dangerous spent r ods e very year th a t it 1- 11 -RWI LlmerlcK , ln addlt lon , lS now thl rd on the 1 5 ear thqua k e r isk list f o r 6 I Sta t es . Wth i 7 los s nuclea r p la nt s in the of 8 fuel rods could he at up , 9 unstoppable not fire been with cool ing se l f wa t er , igni t e , cata stroph ic 10 has 11 Limerick a g ai nst ter rorists , 12 Dry cask d angerou s to spend and burn in an r es ul ts . t he Exel on miss iles , storage a nd 14 e ry 15 imerick 16 h i ch there is n o safe s o l u t i on . 17 perates 18 or air strikes transpo r t stop har ms to Their 19 produci ng us harmf ul are the s u ch time de adly to also 'f:-J'-:-!-=:-:-:-:o p - 14-RW I close wa ste for As long as Lime r i ck our envi ronme nt e nvi ro nment al conc lusi on of impacts our wil l are 20 unprecedented . 21 invest i ga tion of ro u t i ne radiation releases and review 22 of 23 dangerous water contamination iss u es , 24 thi s 25 Evid e nce permi ts At and It ' s g uard n c rease . and a lte rna t ives . money t o 1-1 3-PA despite re peat ed requests t o d o so . 13 req u i red Li mer i ck ' s 11 - year for ma j or air pollut i o n and a va ri et y of ene rgy is not j ust dir ty , that we ' ve c o m iled p it ' s clear t hat it is i n fact fi lthy . h as a ddress e d a wide NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-46 WW'W.nealrgross.com I Appendix A 34 1 r ange o f topics : r out in e radiat i o n r e l eases into the 2 ai r , 3 Schu ylki ll 4 c on taminatio n , 5 the 6 v egetation , our f is h , our wat er , and milk . radioa c t ive pla nt wastewater Riv e r , in Res e arch 7 radioactive radioact i v e det ec t ed discharges n uclides our has soil , t he groundwater associa t ed o ur c o nfirmed into wi th sediment , radiation in our I our 1-15-HH 8 9 10 lean Air Act , 32 i ndividual s our ces listed . 11 armful 12 nown a l so as PM- 1 0 from t h e cool i ng t owers , o t h er air 13 o llut i o n i ncreases a l s o pe rmi tted . i ncreases 14 p ermitted Da ngero us in in depleti o n a nd by i tself , a Drastic , pa r t i cul ate of t he matter Schuylkill 15 Rive r , 16 this permit . 17 s ou rce for nearly two mi l li o n people from Pottstown t o 18 Philadelphia . 19 eve ry day t hat this p lan t operates . rea s on to deny /+--:-::!-:::~--, It is be ing depleted a nd contami nated d ocume nted 22 h i gher th an n a t ional and state a v e rages a ft er Lime r ick 23 started o p e r a t i ng unti l the l ate 1990s . 24 f i ndings of o u r inv es tig at i o n l ead u s to co nclud e that 25 this in this common community that h ave been wel l is in increases 21 p lant la ng u age r epeated l y far j1 -18-HH The a r ec ipe fo r NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 I p -17-SW The Schuyl kill is a v i tal drinking wat er Alarmi ng ca n cer 20 singul ar W ASHINGTON , D.C. 20005-3701 A-47 WW'W.nealrgross.com I Appendix A 35 1 disaster . While 2 to NRC t he is required Li merick to prepare Environment al a 3 suppleme nt I mpact 4 Statement f or 5 confidence in 6 h i s t ory . It would b e d ifficult t o enumera t e a s hort 7 li st , I ' m goi ng 8 There are cri t ics o f t he NRC o ut t here who h ave d o n e a 9 much better 10 l i st , mo st 11 Associa t ed Pr ess . 12 info r mati o n . 13 14 It ' s long past t ime for the NRC to summon r.-7:::-::::::-=, 1-20-0R t he courage t o d o the right t h i ng in o u r judgment and 15 actua ll y 16 rat h er t han t he i ndus try . 1-1 9-LR so lic e ns e th e job ren ewal , process to t han notabl y b ased o n r el y we a we on have of s ca thing I ' m not have NRC ' s I li t tl e regu la tory writ t e n docume nt s . g e n e r ati ng i ndi c tment su ch by a t he going to re - enu merate that I pro t ect the environment and the publi c , 17 Today , 18 record summary packets of o u r 19 maj or air pol l ution , 20 radioact i ve 21 Limer i c k ' s r ad iati on and o ur e l evated cancers i n thi s 22 community 23 fact , b e replaced with safer sources tod ay . 24 I am going to be submitt ing on the harms gro u ndwater and to the Schuylkil l contamination , how Limerick ' s Based research on Limerick ' s nuclear link s p ower on the compelling body o f River , between can , in evidence 1-21-0R 25 of environment al h a rms to date and t he enormous N~LK.uKU~~ COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-48 WW'W.nealrgross.com I Appendix A 1 i ncr eased p opulat ion in proxi mi ty to this facility , I 1-21-0R Cont'd 2 Limerick Nuclear Plant must be closed by 2029 . 3 There is no amount of energy production tha t 4 worth risking th e l ives of so many people . 5 is very much . 6 (Applause . ) 7 FACILITATOR BARKLEY : 8 MR . MAGUIRE : Thank you 9 Bi l l Magu i re and I Good afternoon . am Generat i ng Thank you , sir . the site St ation . vice And My name is president I h ave at 10 Limerick overa l l 11 responsibility for the safe and r e l iable operation of 12 t he facil i ty . 13 I have been worki ng i n t he nuc l ear power 14 industry for years 15 Limerick Generating 16 continued 17 reactor 18 o rga nizat i o n 19 tha t 25 with a and my Stat i on l icense operator career as an be a to supervisor and was the at t he engineer . licensed in on - shift began the I senior operations senior manager of facili ty f or many years . 20 I have also worked at a few other nuclear 21 stations across 22 Limerick as t h e site vice president 23 was t h e site vice president at the Peach Bottom Atomic 24 Power 25 County . Station in the cou ntry southeastern and before rejoin ing in May of 2010 , Pennsylva nia in York NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-49 I WW'W.nealrgross.com I Appendix A 37 Operat ing Generating Stat i on 2 safely and r e l iabl y is a respon sibility t ha t everyone 3 at 4 u nders t a nd 5 e nvironmen t , 6 safely . 1 t he power Li merick station our t akes obligation a nd to to o urs 8 l ik e 9 reliab l e electricity . the is the p owe r the seriously . co mmuni ty, We to each ot h er to operate t h e A key component 7 very of a of ava ila b i l it y ne eds th riving s afe , t he plant commun i ty cl ean , and And a s we l ook i nt o t he f uture 10 for 11 Sta tes as a whol e , 12 for this v ery important res our ce . At 13 t he of Pennsylvania we can see th e same a nd t he Un ited increas i ng demand 1 2-1-SR I t i me , t here ' s a growi ng 14 concern about gree nhouse gases and climate change that 15 is 16 t hat 17 env i ronment 18 Nuc lea r 19 t o th e p l ant ' s o p erating l icense . 20 l i cense fo r Uni t 21 2029 22 region wi th clean power through 20 49 . a resu l t of growi ng 0 burn ing p ower c l ean , fossi l demand Exe lon f ue ls . a nd has to To help meet he l p appl ied to keep th e our U. S . Reg u latory Commiss ion for a 20 - year extension Limerick ' s cu r rent 1 will e xpire in 202 4 and Un i t 2 in W th l icens e renewal , Li me r ick can provide our i We 23 understand our specia l obligation to 24 operate the plant safe l y and reliably and to ma i ntain 25 a c l ose relationship with o ur neighbors . We p ledge t o NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-50 WW'W.nealrgross.com Appendix A 38 1 ontinue that special 2 ell into the futur e . The 3 as we operate the plant nuclear roughly 20 reactors percent in of the States 5 electricit y . 6 already received approva l 7 Commis sion for a 8 the Peach Bottom Atomic Power St ation in York Count y . More th an 7 0 react ors our United 4 9 nation ' s nationwide h ave from t he Nuclear Regulatory 20 - year license extension including Limerick Generating St ation op e r ates in a t ha t 10 ma nner 11 produces almost 12 conduct s approximately 13 wa t er , fish , soil , cow ' s mi lk , and other food products 14 t o measure for environmental impact . 15 a cha i n of radiation monitors surrounding the plant . 16 preserves In no the environment . g r een house 2005 , 1 700 t he The The gases . t ests plan t plant annually on air , We also ma i nta i n environmental management 17 systems 18 certification 19 International 20 This 21 industry 22 certification . 23 commitmen t 24 ensure continuous improve ment in environmental areas . Limerick at under the is strict for known r eference as for Station ac h ieved criterion of Standardization , ISO 14001 , the a the ISO . common envi ronmental The ISO 1 4 001 certification requ ires a t o excellen ce to prevent pollution and to In 25 Generating Organization certification 2010 , the W ildli f e Habitat Counci l NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 I 2-1-sRI Cont'd 104 provide trust W ASHINGTON , D.C. 20005-3701 A-51 WW'W.nealrgross.com Appendix A 39 1 recogn i zed Limeric k Gener ati ng Station ' s commitme nt t o 2 e nvironmental stewards hi p by awarding us the Wildlife 3 at Work Certi fi cation . This distinction was awarded 4 to St at i o n 5 t owards 6 e n hancemen t s 7 food , 8 l i v i ng o n the p l ant sta ti on ' s l a ndscape . Limerick Generating establishing that water , f or long - term our and ensure to Lime r i ck 10 safely 11 upgrades t o p lant equipment . 12 invest ed more 13 inc l ud i ng insta l lat i on 14 elec tri ca l 15 coo l ing towers . 16 t han $40 milli on i n phys ical 17 t han cab l es , come , f or habita t s anima l c ont i n u es $200 of Exel on habi t a t is wi t h speci es to ope r ate 2001. 18 year s space commitment wildlife provided undist urbed cov er , To 9 for inves t ing S ince 20 1 0 , mil lion i nto new sa f et y new va l ves , In a ddit i o n , and in Exe lon has t he plan t equipment , new re furb ishi ng t he Limerick h as made more securit y upgrades since Our investment i n the fut ure does not stop 19 with equipment . 20 new employees over the last three years , mostly coming 21 f r om o u r 22 workforce of appr oximately 850 peopl e and during our 23 annual maintena nce and refu eling outages , we bring in 24 b etween 1500 and 200 0 temporary workers that provide a 25 b oost to our local economy . native We hav e reg i on hired here . and t ra i ned over 100 We mainta i n Hiring a steady and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-52 WW'W.nealrgross.com Appendix A 40 1 retain i ng top ta lent 2 Generat i ng St atio n . 3 is a Over t h e pas t of the best key priority for Limer i ck 25 years , performing Lime rick has been 4 one 5 generat i n g 6 Du r i ng th a t 7 for 8 r ecogn i zed b y th e i ndustry for our reliable opera ti on . 9 In March 2010 , Lime r i ck completed a success ful r un of stations t ime , con t inuous co nt i n uo u s in most r e liable nuclear the a nd power industry . t he p lant h as set several days operation 11 r epr esented 12 W le hi we do Uni t been boi li ng wat e r re actor i n the Un i t e d States . s econd o ur has 727 the f or and 10 13 days of records l o ngest no t are cont i nuo u s to break on indicator continuous 15 excellent huma n performa nce and equipmen t 16 This run out 14 fo r a re cords , t hat Limer i ck strikes f o r every day . 17 operations set plant . 1 We also take pride in ou r communi ty . of t he reliability investments i n 18 the 19 $600 , 000 20 United Way , fire and ambul ance compan i es , 21 health youth 22 employees serve as vol un teers in the loca l c ommu nities 23 around t h e plant . to and In 20 1 0 , the community Limerick donated more than in contri b u tions organ i zations . And to t he educational many of our 24 In conclusion , Limerick Generating Station 25 looks forward to working with the Nuclear Regu l atory NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-53 WW'W.nealrgross.com Appendix A 41 1 Commi ssion as you r e vi ew 2 appreciate the 3 a ft ernoon . our Tha nk you . o ppor tuni t y license to speak 4 FACILITATOR BARKLEY : 5 FACILITATOR with I yo u this (Applause . ) 6 r e n ewa l . 7 Thanks , Bi ll . BARKLEY : Represen t ative Qui gley . RE P . QUIGLEY : 8 9 State Rep resenta tive 10 146 t h Dist ric t 11 par t y of t ha t 12 here 13 t h i s meeting and t h ank t h em for comi ng o ut 14 t o the p u blic and take c omme nta r y . here o f t he Quigley . wh ich dis trict , t oday t o 15 Tom Good afternoon , my name is lower s o I want b eaut ifu l I represent Pot tsvi ll e t he is a t o we l come t he NRC Sunnybroo k Ba l l room f or to lis t en I 'm h ere today t o voice my stro ng support 3- 1-SR 16 for re l i cens ing 17 Sta tion . 18 I 19 r e li censed . the feel of the Limeri ck Generat i ng I want ed t o to uch o n a coup l e p o i n ts o f why it 20 is i mport ant for this f acil it y to be Firs t is the amo unt of electri city that is 21 produced b y 22 mysel f 23 consisten tly from businesses a nd the Commonwea lth and 24 our 25 n ow and more impo rtan t l y wh a t a nd th i s my faci lity . One o f co lleagu es in the th i ngs Harrisburg that hear ci t i z e ns is the d e mand for ene r g y a nd e l ectricity that dema nd i s going t o NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-54 WW'W.nealrgross.com I Appendix A 42 1 b e in the future . Right now this 2 for two facil it y generates millions homes a nd e nough 3 electricity without 4 producing some o f the greenhouse gases t hat we hear so 3-1-SR 5 much a b o ut 6 gas , or 7 for 8 9 Cont'd t hat cou l d be produ ced by coal , n a tu ral And I ' m go i ng t o put a caveat in the re o il . my good f rie nds ou t s ta t e where coa l a economy a nd I ' m suggest i ng t h at t his be d one of is coal in t he b ig part 10 exc lusi o n 11 t echno l og ies 12 als o i mp o rtant 13 of t he t hey ' r e f or that Aga in , 14 n eve rt heless , the Pennsylvania developing s ome t o t he Co mmonwealth o f Pennsyl v a n i a . t hat a nd wes t ern part o f o ut of t he t here are indust ry and importan t o ne of the c o ncern s for t he we hear 15 c ons istently f rom business e s 16 into 17 it is wh i ch needs to be improved for th e tran s mi ss i on 18 of 19 generation o f t h at e lectricity? Pennsylva n i a the wi t h t he e l ectricity, infrastr uct ure being wh at but Number two , 20 is how can we come he re I more think is impo r t antly the important the is 21 j ob s 22 economic 23 Commonwealt h of Pe nns y lvania and a l so i n t hi s n at i on , 24 one of the top issues that we hear c o n sistently about 25 i s jobs . and overal l t ime s economy . t hat Again , we ' re f a c i ng in t h e se here in tough t he NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-55 WW'W.nealrgross.com Appendix A 43 And 1 as me nt ioned the site v i ce resident , 3 n nual p ayrol l o f $7 5 million . 4 s t o the Co mmonwealth o f Pe nnsylvania , 5 ea l ized th rough the state i ncome t ax and al s o all of 6 h ese 7 arned i n co me t ax wh ich ag a i n sustains t he i r t own shi ps r.3~-~ -S~R~-.~ 1- 8 swell as t h eir respect ive schoo l distr i cts . 9 hat l ocal taken 8 6 0 p eopl e by 2 10 ove r was are e mployed h ere with an munic ip ali t ies away I thi nk The direc t most wou l d of impac t that of cou r se , th em h a ve an e nact is an Cont'd To h ave ~~----~ e v en more ramat i c i mpact on our l o c al e c onomy . As was menti o ned t h e i mpa ct f o r 11 he re , 12 rea 13 u r i ng t he o u t ages a nd t h e r efuel i ng , 14 ee n 15 or r idor with ano t h e r one planned right up here a t t h e 16 ana toga 17 rowth here for o u r commun iti es . 18 Th irdly, t wo t he tempora r y h o tels area . t hat ommuni ca tion tha t 20 h at 21 ove r nment Af f a i r s 22 eople . 23 tou r I ' ve have Ag a i n , 19 work e rs sprung more I wh o t h e l oca l want a nd to up a l ong more talk t he a b o ut one nniversary o f 25 t the I ' v e exp erienced in the seven years peop l e as we l l as with thei r I ' ve b een on the site three times , 24 422 economi c b een in office with Exelon and with a nd h ere there ' s a lready up j obs s how to th e make a faci l ity . is a very secur e area . p resentation And I their s ite twice for during an have to say that I know a l ot of p eople are NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-56 WW'W.nealrgross.com Appendix A 44 1 concerned about terrorism attacks or peopl e b e i ng on 2 the 3 the r e a nd gone through a t o ur , 4 set 5 securi t y meas u res th a t 6 away much more relieved wi th t h a t . 7 speak t o my co nst itue nt s more affirmati vely a bout the 8 safe ty and s ecuri ty o f t he fac i l ity . But property . up , seeing u nl ess y o u ' ve act ua lly t he a rme d gone over seeing h ow things are guards th ere , are i n place , t he I thin k you come And I ' m abl e t o 1 3-1-SR ICont'd 9 Any t i me that 10 occu rrenc e t h e re , whet h e r 11 h u n te r 12 aut hori t ies were cal led , t h e Gove rnment Affa i rs people 13 at 14 r i ght away t o let 15 word 16 they ' re 17 explanati ons , 18 pl ant its e l f , but 19 a r ound t h e country and around the wor ld . has wandered Ex e lon are o n gets o ut it wi l l o nto t he t he pho ne to be en t he s l ig h test be a c o upl e times a pro pert y me where or wi t h an t he e ma i l me k now what ' s happening be f o re t he to th e always media very or wel l to the press . prepared not on ly of t hings tha t in happen So the i r at t he also i ncidents and issues that occur Obviously, 20 t he r e ' s seeing what took p l ace in Japan with 21 the i nci de nt over there , 22 me and 23 pl ace over there and how t he safeguards are bei ng put 24 in place he r e so t h at d oes n ' t happen a t met with me It 25 was a they we r e on t h e p hone with few times to explain what took me n t i oned ear l ier this faci lity. t he dry cask NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-57 WW'W.nealrgross.com I Appendix A 45 1 storage 2 o uts i de in a d r y cask storage fac i lity . 3 proposed 4 h e ld t wo open houses that were very well a tt e nded . 5 wen t to b o t h of th em where t hey h ad peopl e on there t o 6 expl a i n to t he peopl e wh a t 7 wi t h th i s d r y ca sk storage , why it was neces sary . A 8 lot I 9 t h i nk a 10 wh ere of back t he in s p ent fu el 2005 - 2006 , ques ti o ns a nd the are now stored When th at was Gen erati ng exa ctly was a nswers lot of the p e opl e r ods ba c k Station I taking pl ace and f or t h and came away bette r in f ormed Ju st recent ly at a n open house , t he si t e about t ha t proces s . 11 12 VP who just s poke , Bi ll Maguire , came o ut t o give some 13 ini tial comment s 14 in an impromptu q u estion and answe r 15 again 16 q u estions . 17 fee l ing confident in t h e ope nness and the transparency 18 that 19 session . j us t was and wound up spendi n g t he fu ll ho ur pl anted And I q u esti on s , t h ink displ ayed in a l ot of and not tough aga in the people came away that question Another point of that is 20 sessio n for and answer relicensing 21 for t h e overa ll env i ronment h ere i s the go od corpo rate 22 c i tizenship that the Ge n erating Station has e xhibited . 23 As 24 contri b ut i ons that h ave gone on , not only for the host 25 community of Limerick , was mentioned by Bill , some b ut also of t he f or t he charitable surroundi ng NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-58 WW'W.nealrgross.com Appendix A 46 1 areas . I attended 2 t hey p rovided mo n e y t o the Upper Pr oviden ce El eme n tary 3 Schoo l 4 o utside environ me nt al c l assro o m. a nd t he f ew dedication services Li merick On e 5 a of El ement a ry t he l eade rs , t h i ngs and we ta l k an about 7 Committ ee , is th e need f o r our c hildren to be educat e d 8 par t icular l y 9 c onstra i nt s t hat we ' r e d i str i c t s g i ven o p erat i ng t he se b udget unde r , see a corpo ra t e c it izen steppi ng up t o the plate and 12 providi ng t hat f i na nci a l 13 area 14 Montgomery 15 assistance 16 n u c lea r engineer i ng te chno l ogy . Th ey ' ve Co u nt y 17 s u pport , s u pport for an partnere d Co l lege b e i ng well assoc i ate versed wi t h to Again , we hear s o mu c h a bo ut no t good to pa r t i c u l arl y i n t he a l so Co mmu nit y it ' s t he 11 in Commonwe a l t h , bot h scho o l s c ience . the Educat i o n 10 of and and House as p o li tica l s c i ences the for 6 in the I ' m on Sc hool wh ere prov i de degree in our students te chno logy 18 here 19 e ng i nee ri ng a nd 20 s te pping u p to 21 when , 22 wh ere the governme n t might not be able to do that . in f act , things the pla te per h a ps Last , 23 of in that in t he n a t u re . to provid e these 24 opi nion and sa f et y issues . 25 looked a t One o f again , that ass i stance t ough I want to talk abou t So and budge t t i mes overall public the thi ngs t h a t when I ta l k about sa f e t y and the f eeling of NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 I W ASHINGTON , D.C. 20005-3701 A-59 WW'W.nealrgross.com Appendix A 47 1 comfort that p eople 2 peop le who work at that plant live within the t en - mile 3 radius of the 4 when I first was elected in 2004 and I 5 again in 6 empl oyees l ive wi t hin the t en- mi le r adius . f acility? preparation The 7 have here is And I f or how asked this population g r owth 8 t he pas t 9 lines based on the 201 0 Census , many that of the question just asked it hearing and 563 in my District in ten yea rs , we ' re gett i ng ready to r edraw our s o I broke i t d own by 10 t ownsh ip as to ho w much the population has i ncr eased 11 in t ho s e areas : 12 percent; Upper Potts grove b y 29 . 5 ; Royer sford Boro u gh , 13 whe re I li v e , 11 . 9 ; Lower Pottsgrove , 7 ; Pottstown , 2 ; 14 now this is a 15 piece of New Hanover Townsh i p which actua l ly i ncre ased 16 by 54 percent . 17 Limeri ck Township , i ncr easi ng by 33 . 5 l ittle bit skewed , but I have a small When y ou l ook at t h e p u b l ic opini on, and 18 again , we get call s on a lot of d ifferent i ssues and 19 as 20 then , 21 r o l l ed out to th e publ i c , Boyd Gaming had purchased a 22 prope r ty next to our plant was getting ready to apply 23 -- had applied for a lice nse , casino license . 24 t i me , my office had received 2 ca ll s in regard to the 25 dry cask storage pro ject , over 200 calls regarding the I mentioned at the t hat same dry t ime cask sto rage that that issue . issue Back was being At that NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-60 WW'W.nealrgross.com Appendix A 48 1 casino a ppli cati o n . So 2 p eople were more 3 casino b eing in 4 at dry cask s t orage fa cil ity . concerned the a b ou t th e ir n e ighborhoo d time , the it appeared p r osp ect of a t han t h ey were a And lastly, as some o f you h ea rd , there is 5 6 a pro p o sa l right now t o put a hold on Rout e 422 . 7 again , in t h e past six mont hs wi t h t h e 8 Japan , wit h the c urrent 9 t he AP s t o ry t el l ing And inciden ts in earthquak e we had here , with you how these plan t s are al l 10 fa l ling apart , I rece i ved t wo calls regarding t ha t one 11 where they could 12 c ou l d -- what wa s the evacu a t ion plan for t hat , and 13 mor e calls and e mai l s regarding the proposed 422 . So 14 aga i n , i t 15 they ' re mo re co nce rned about the prospec t 16 t ol l 17 p ower p lant i ss u es . get t he KI pil l s , o ne where they appears t hat t he c ons t it uents and t h e 1 46t h , o f paying a t o ride of 422 t ha n t hey are about the nuc lear 18 again , So 19 r e l icens i ng 20 of th i s I for strongly FACILITATOR 23 I mentioned . (App l ause . ) 22 reasons the Th ank y o u . 21 the support Representa tive Quig l e y . The 24 25 first is next Lorr aine BARKLEY : Th ank t hree people I ' d li ke to Ruppe , private citizen ; and you , ca ll , t he NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-61 WW'W.nealrgross.com Appendix A 49 1 next , Michael Gallagher of 2 l ik e to call Dr . Fr ed W nter aft er th at . i MS . RU E'E'E : 3 Exe lon ; and finally , I 'd Hi , my n ame is Lorraine Ruppe . a m spea ki ng h ere t oday t o represent t he ch ild ren 4 I 5 a nd 6 Res i dent s 7 disast ers here i n light o f Fuku shima in March 201 1 and 8 s i nce 9 2011 affec ting our a rea . fut ure gene rations , are the especially in our communi t y . f earfu l ea r thquake a b out and t he p ossibi l it y Hurri ca ne Irene in Climate changes , of August e t c ete ra , 10 are causing disasters everywhere and continuing t o get 11 wors e . Increasing 12 h a ve made f l oods, 13 t orn ado s 14 n u c lear power i ncreas i ng ly risky , 15 Lime rick 16 eart hquake 17 p ossib l e 18 whi ch 19 NRC f ailed t o get bac k to me when I 20 the l ine 21 reactors ? p lant al l bas i cal ly tha t comes Fukushi ma , remi nds me , Remapo us d r ought s , f eel in Ch ernobyl is to mak i ng 4-1 -PA I espec i al l y wit h t he b ackyards . t h is or four mont hs f ault i n secure , ou r through e art hqua kes , area Three Any cou ld Mil e be a I s land h ave p assed since the r.--=--=-:~ 4-2-GE I the asked how c l ose Li me ri c k nuc l ear Maybe I can get an answer today . Ind ian E'oint nuke plant was sketched as a 22 4-3-os 1 23 p ossib l e terrorist target in reference to 24 attac ks . A s uspected t errorist wo rk ed at Limer i ck for 25 y ea r s wi thout t h e i nd ust r y knowing it . 9/11 How s c ary is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-62 WW'W.nealrgross.com Appendix A 50 1 that? 2 The Pacific Ocean by Fukushima . is severely 4-4-0S now 3 i rradiated Ra d iation i mpacts 4 I of Fuk ushima eq ua lled o ver 20 Hiros hima b o mbs whe n I last 5 esearched . Our drinking and b a t hing water her e 6 e i ng 7 4/7 8 on tamina t ed mine water , thanks to the NRC and Exelon . 9 Th is is dis gust ing . continuously for years pollu t ed with radiation Most of u s 10 for by Lime ri c k and unfil t ered have to depend bath i ng . 4-5-SW 1 on t he wa ter , 12 ater filtrat i on o r drink b o ttled water because we are 13 f r aid 14 astes r eal ly bad now . 15 8 plus 16 eft . years 17 the Schuyl k ill has air pay a nd ext ra for because it Imag i n e how toxic it wo uld be f r om n ow if there was Ther e in us t oxic specia l ly f r om the of day , 11 to drink Some e very is bee n 18 matte r a nd 19 causing increased ast h ma , even inc reased ot her t oxics any water particulate from Lime r ick ...,_~.,...,..,......., 4-6-HH 20 heart a ttacks , I and stro ke s . And to a dd i ns ul t to i njury , Lime rick was granted a al low an e i ght - fo l d 21 p ermit 22 p o lluti o n since 2009 . 23 skyrocketed s ince Limerick has b een up and running in 24 t he to inc rease in air Cancer rates i n our area have ' 80s and rates have s t eadi ly increased . I 25 The Tooth fa i ry Pro ject showe d hi g h l evels 114-7-HH NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-63 WW'W.nealrgross.com I Appendix A 51 strontium a radionuclide in baby teetn or 1 or 2 children 3 Limerick p lan t had 4 United States . Th is stuff and God knows what else is 5 in now 6 Commiss ion 7 e nthus i astic about p r otecting us . :!U , nearest to nuke plants . Baby teet h n ear 4-7-HH our bodies t hat 9 nergy highest t ha nks to Solar 8 th e put a it wi nd , conservat i o n to levels the Nuclear nic el y efficien cy less ocea n are whole Cont'd Regulatory is geothermal , and in than t hermal , now ch eaper 10 ha n nuclear power , a lon g with bei ng trul y clean and 11 afe . 12 o l ar a lone c ould provide 55 t i mes o ur en ti re na tion ' s 13 nergy needs 14 ee n numero us 15 eadly ~-:--~:,.......,....,...., 4-8-AL I The Department which of leads Energy me to 2006 a report point, stated there have studies provi ng the many da ngero us and consequences of n u c lear power . There ' s no 16 den ying the mas s i ve devastation it has alre ady cau sed 17 and 18 i nd ustry 19 indifferent 20 wonderful 21 now o r 22 really scares us t h e most . wi l l cont i n ue f as hi on and wi l l u nti l 24 secrecy , 25 under the rug . cau se goes still 2049 The 23 to on as if i ndefinitely, in their but the trance - like , everything is safe and contin ue to b e 18 plus years from for o u r NRC has communi ty . turned into Th is a i s what culture of h iding th e dangers a nd sweeping the p ro bl ems The i nd ustry ' s addiction to mo ney and NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-64 WW'W.nealrgross.com I Appendix A 52 1 p ower has bli nd ed them to moral life and death issues 2 a nd facts set right 3 ~ ig 4 a n extens i o n 18 years ahead o f t ime ? 5 (Applause . ) 6 FACILITATOR BARKLEY : 7 my.-1:--='-::-=---, 1 4-9-LR question of t he day is why is Exelon a pplyi ng for Bu t I Th ank you . Thank you , Lorra ine . M ke ? i MR . GALLAGHER : 8 9 in front of t h eir faces . is Mike Gallagher Renewal a nd Good a f ternoon . I 'm 10 License 11 responsibility 12 Vice for Exelo n . President t he I Limer i ck have of l i cense rene wal a p plicat i on . 13 for t he My name ove ra l l Generat i n g Sta t i on Ex e lon has a great dea l o f experience wi t h 14 l i c e ns e renewa l , as we 15 renewed license s for ou r 16 pl ants 17 J ersey , 18 Illinois . in Pennsyl vania , and have a l read y Peach Bottom and o u r Oyste r Cree k plant o ur Dresden and Just 19 obtained Quad briefly a b o ut Cities myse l f . t he our TMI i n New p l ants I ' ve in been 20 working in the n u c l ear power indu stry for 30 years . 21 was 22 Li merick and I worked a t 23 o ur corporate offices . a licensed operato r Mr . Magu ire , 24 25 senio r Limerick spoke abo ut a nd p l a n t I manager a t two other nuc lear plants and the site vice pres ident for re asons for re n ewi n g the license NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-65 WW'W.nealrgross.com Appendix A 53 I 'd Limerick . like to speak briefly about the 1 for 2 pro cess f or preparing th is l icens e renewal application 3 a nd t he amoun t 4 was put i nto preparing the applic a t ion . of work and engi ne er i ng a n alysis that Because th e license Generat i n g Station can 5 7 purs ue 8 very c l ean e nergy so urce which produces no greenhouse 9 pa s emissi o ns . 10 1~"--::=---, 5-1-SR 6 pe opera t ed sa f ely license n t ha t i t a nd renewal reliably, fo r Exelon decid ed Limerick . to Lime ric k is a Lime r i ck is a lso good f o r the eco nomy l owers market pr i ces on el ect r icity for t he 11 pi ti zens of Pe n ns yl vania to t he tune o f 12 per year . 13 $880 mil l i on So i n 2009 , we annou nced o ur i nt e nt i on t o 14 seek l icense renewal 15 we 16 applicatio n . 17 submitted 18 Commission o n June 22 , 2011 . 19 had ment ioned , 20 p ages . 21 large 22 But t hat on ly represents a small part o f t h e wor k that 23 was done for the engineering analysis to p repare this 24 appl icatio n . sta r t e d t he for Limerick . work Af ter the 25 necessary over appl ication two to to years the It ' s a year , p repa re of work , t he we Nuclear Regu l atory The a ppl i cation , as Lisa when you print it o u t And when you p u t binders . Later t ha t it 's about 2100 it in the binders it ' s three huge amount of in fo r ma t ion . The to tal amount of engineering ana lysis , NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-66 WW'W.nealrgross.com I Appendix A 54 1 i f we printed it a ll out would be about 290 binders of 2 i nfo rmatio n . 3 e ngineering work . 4 work to prepare th e application , we broug h t 5 fro m 6 e ns ure 7 Our total cost t o prepare the applicati o n and get t his 8 applicat io n 9 mi l lion . outside that invested Exe lon it was 12 eview . 13 qu ipment complete , by are t he t wo manho urs of in exp ert s application wi ll NRC to a nd accurat e . be different about pa rts of $3 0 our review and the environmental hist o ry and t he the t he thorough For t he safety rev i ew, in 60 , 000 review t he safet y ook at t h e 14 to revi ewed f:l ppl ica t io n , over Once we co m l eted our engineering p Th ere 10 11 We plan t . we t ook an in - dept h c o ndit i o n of t h e W e did that to safety determi n e 15 ~hether 16 pn t hat eq uipment and to make sure t hat the equ i pment 17 ~i ll 18 19 the necessary maintenance was being performed be able to operate when it ' s n eed ed , not on l y for oday, but 22 Whe n ~as b ui l t , horoughly 23 p roperly, 24 ~ hat 25 for an addit ional years 20 of pperation . 20 21 also you look b ac k at al l t he tested equi p ment to make Limeri c k , was sure it new. doesn ' t mean it won ' t er tai n act i v i ti es ne e d work , It would but like anything e l se equipmen t when it was perform does a g e . but it do es age and t o be do ne to the equipment . NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-67 WW'W.nealrgross.com 5-2-0S I Appendix A 55 1 So we 2 refurbish th e equipment . 3 perform preventive There may be mai nt e n ance . Sometimes we Some equipment is replaced . modifications don e to upgrade the f act , as Bi ll M agui re 4 equipment in the plant and i n 5 has 6 the last couple years a lone t o i mprove a nd modernize 7 the equipment and enhance pl ant operations and safety . stated , Limerick h ad spent over $2 00 millio n in W e 8 a l so t hen revi ewed calcula t ions that 5-2-0S I Cont'd 9 were performed as pa r t 10 plant t ha t 11 operat e 12 calc ulati o ns 13 would 14 Overall , 15 was 16 of the o ri gi na l were d one t o design o f t he years . safely be for 40 e nsure t hat the plant c oul d years . tho se We a n a lyz ed and were able t o confirm t ha t able our to o p erat e con c lusi on safe ly from o u r fo r the plant years . 60 e ng i neer i ng review that Lime rick could operate safely for up to 60 We als o too k a l oo k at the environmental 17 18 impacts of continu ing t o operate Limerick . 19 at all t he impacts of c o nt i nued impact o f the p l a nt on 20 the 21 the envi ronment are sma ll and I use the term s mall i n 22 the sense th a t 23 defines 24 detectabl e or are mino r . environme nt . 25 small We We l ooked Our concl u sion is th a t is i n the reg ul a t ion . as a l so environmenta l revlewed impact s The regu la t ion effects t he on are a l ternatlves not l f NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-68 WW'W.nealrgross.com 115-3-AL I Appendix A 56 1 Limerick wo uld not 2 a nother source o f electr ic generation wou ld n eed to be 3 i n s t alled 4 gene r a t e 5 tha t 6 electricity 7 e n vironmen t than co ntinu e d ope rati on o f Limerick . 8 ins t ance , 9 g enerat ion ei t her the any have here on means would if have faci l ity , or r e newed someplace electr icity . of Limerick license sit e repl acemen t o the r its generating more could t he of wi nd t he an be We by wo u ld occup y bet ween 1 0 a nd 11 t he 12 impact o n t h e l and . 13 Limerick , 14 to concluded impact 10 of Delaware a nd of al l on a t he I Fo r 115-3-AL IICont'd wi nd have to t he ent ire land area o f Mont gome ry Co u nt y . s t ate 4 0 perc ent else replacement rep l ace d f o rm a nd that would t he land i n h ave a h uge If a s ol a r fac ility could re place it woul d n eed t o cover 32 t o 50 percent 15 In conclusion , 16 and 17 add i t i ona l 18 approximately 2340 19 tha t ' s 20 of we ope r ate Li me ric k safe l y economica l . we ca n cont i n u e 20 not o nl y this o perat e y ea r s . safe , it sa f e ly Limer ick megawat ts Cont i n u ed 21 to but of base - l oad it ' s clean , operation community, 22 b enefit 23 Pennsylvania and our nation . 24 t i me for this . will the of for an prov i d e gene ration 5-4-SR re liable Lime ric k Commo nwea lth and will of Thanks for giving me the Th ank you . (Appla u se . ) 25 NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-69 WW'W.nealrgross.com I Appendix A 57 FACILITATOR 1 2 BARKLEY : Tha nk yo u , Mike . Dr . Winter? DR . WINTER : 3 4 letting me speak . 5 c o ns , 6 tha t ' s f or sure . haven ' t 50 We h a v e we? As 7 Good a f ternoon . And it ' s But a I lo t for of pros and hard t o make a decisi o n let me ge t going h ere . pnys lcla n years , h ea rd a Thanks have r aalo.Logy o ver 9 cancer sensitiviti es from h armfu l radiat i o n exposures , medica l s t r ong 10 na t ura l ly . 11 concern s because 12 increase since 13 espec i a l ly thyro id cancer . 14 h i g h er here t h an the nati o nal average . 15 the 16 agi ng 17 cancers . 18 simi l a r 19 getting th e 20 have seen share about b een we l l established by the state . we co l l eagues c o ncern ror 8 My s t i ll praCLlClng o ur the same cancer rat es 6-1 -HH peop le I more t he ta l ked n ow , to , plant started , j umped to 78 p ercent It this getting power And some of is because pe ople are older , so there a re more But that ' s not true because in other areas t o our area i n Pottstown , t hyroid cancers You 21 Li merick wond e r why t hat we some h aven ' t fundrai s ers th ey ' re no t of 22 cancer 23 r es p o ns ibil ity in order to stop this . 24 a l ot o f mone y , but 25 are . ou r This has medical with reacted n early and mo re e nvi ronmen tal d amage . The y ' re making not taking much effort to prevent NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-70 WW'W.nealrgross.com I Appendix A 58 Yes , 1 2 3 t errorism. Bu t we are crea t ing our own form of Now th a t sound s kind of funn y , doesn ' t it? a l lowing any harm ful e nviro nmenta l event s to 4 occu r , we a r e a l lowing o ur own for m of t er r oris m, j ust 5 li k e forei g n people would come in here . Havi ng 6 7 8 9 att end ed a Hi rosh ima , Japan a t om o mb c lini c right a ft er W rld War II , natu ra lly I had o chanc e to adiati o n . s ee t he worst resu lts of harm f ul All tho se lit tle kid s I saw who only lived 10 or a f ew da ys , it left me wi th a v e ry s ad memory . 11 ou rse , 12 I ong er , but it s u re is no t good . what is I 13 h a ppen i ng don ' t know he r e wil l wh e ther be Ofii6-2-HH taking much you ' ve heard tha t 14 orne 15 or ry to 16 apacity of destroyi ng ma n k ind . 17 ears , 18 f fects , maybe not so much here i n t he United Sta te s , 19 ut the whole world can be a f f ected . s c ientis ts te l l are you already pr edict ing t hi s , but nuclea r but ou r whole wo r l d i s 20 that I 'm e ne rgy has t he I t may t a ke about 1 00 exposed to t he ha r mfu l Of course , what is happening h ere wil l b e 21 taking much l o nger , but it is s ure not goo d news . 22 Besides we have 23 environmental disasters and a concern about our nearby 24 earthq uake 25 e specia l ly o ne near New York Cit y . 6-3-PA harmful fault power a nd pla nt ot h ers e xposures , in the easter n U. S ., And the n th ere are NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-71 WW'W.nealrgross.com I Appendix A 59 .------------------, 1 he radioactive 2 itting spent around , f uel deadly supposedly waste mater i al We protect ed . I 1-::1-:--::::--::::-o 6-4-os 1 can ' t 3 control the use of n uclear power in the rest o f 4 world , but can k eep America sa f er and cleaner here . So please , 5 ask your poli ti cians , the reliable 6 p o li ticians t o c l o se t he Limerick power p l ant . 7 save America f o r ou r kids a nd de s cendants . 8 will take my con cerns ser i ous l y . 9 6-5-0R li stening . 10 I h ope you And t hank you FACILITATOR BARKLEY : for (Appla use . ) 11 Let ' s 12 W nt er . i 13 Neaf c y 14 Baly, 15 Okay, thank you , Dr . The next three people I ' d l i k e t o call i s Tom Heritage Fo undat i o n . of a nd 16 Li merick Townsh ip , then Fen c he l MR . Tim NEAFCY : f ollowed of Good t he by Dr . An i t a Schuylki l l Ri ver a f ternoon , t hank you . 17 My name i s Tom Neafcy . 18 Township Board of Supervi sors and I want to thank you 19 for this opportunity to speak at t his forum t o d ay . As 20 the I ' m t he Chairman of Limerick largest priv ate in the 21 region , the Board is thank fu l 22 Exelon provides , 23 operation , 24 community and local economy are enhanced by the needed 25 services provided by t h e township , which includes the the f or empl oyer positive the 8 60 jobs that impact of the vitality of our local community . the i r'r=-L-1= , - F-1 -SR I The NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-72 WW'W.nealrgross.com I Appendix A 60 1 roadway n e twork maintained 2 Public Works , 3 a nd Linfi eld 4 med ica l 5 facili t ies 6 p r ovided by Limerick ' s 2 1 sworn o ffi cers . Fir e Compa n ies , and o ur locat ion al s o 9 Pol ice withi n t he in parks , police ou r recreat i o n prote ct i o n Li mer i c k Generating our Department a nd our l ocal e mergency public Because o f 8 Township public sa f e ty provided by the Li merick response , 7 by our Li merick b orders , t h e is t he Township municipal depart men t 11 jurisd i ct i o n 12 Thi s 13 dir ectly bo t h t o the res i dents and t h e b u sinesses of 14 t h i s c o mmunity and t he t ownship ' s ab il ity to ma i nta i n 15 thos e cur rent l evels of service du r ing t hes e di f ficu lt 16 economi c 17 gen eros ity of the Limerick generating p lant a nd Exe l on 18 for be i ng good corpora te neighbors and the assistance 19 they 20 f i nancia l 21 services to the c ommuni ty would f a l l 22 b acks 23 companies . 24 Li merick Co mmun ity Days . 25 Limerick gen erat ing facili ty and Exelon will con tinue over prides to We t he ass i stance the 1 itself d ownturns . provide of Tier criti ca l on t he are pr i mary lr= -1,.....-s =-___,I 7._ =-R i nfras t ructure ? iCont'sd tha nkf u l i mp act They t he servi ces commu nity . that taxpayers . wi t h pol i ce 10 Board Pennsyl vania Station ' s Limer i ck o nly tha t ' s provi ded f or t he W thout i their provide those to squa r el y on the ass ist in our fire They have b een corporate sponsors of our And we are co nfid ent that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-73 WW'W.nealrgross.com Appendix A 61 1 that support in the f uture and be our good corporate 2 neighbor . 7-1-SR We a ls o are i n support of t h e relicensi n g 3 4 o f the Lime rick nuclear plant . Cont'd I Th a nk you . 5 (Applause . ) 6 FACILITATOR BARKLEY : 7 DR . 8 Bal y . 9 t oda y I 'm a is BALY : a f ternoon . I ' m An ita ret i red Lut heran pastor and my concern wit h is Good Dr . Baly? the speed g o i ng . I at mea n which it this seems to appl i cat i on 10 p rocess me t hat to 11 p redict what environmental fact ors wi ll be i n p la ce 1 3 12 years 13 p mn isci enc e a nd prescience t ha t we shoul d attribu te t o 14 f\l mi ght y 15 ~ e i ng s . 8- 1-LR h en c e a nd God , 16 18 b ut I years hence , certai n l y would favor 17 look around , 18 is 19 b e i ng improved . 20 a b out how 21 needed . 22 good evacuat ion tod ay . 23 p opulation 24 deteriorating . 25 Po tt stown Mercury , a not posits to k i nd a any of s l ower us hu man process . As we we see t h at th e p opulation i n th i s get ting d e nser al l we the And would I suspect time . The l eaves t hat ef f ect an ro ads me wi th e v acuation of area are not conce rns 8-2-os 1 were one st rong l y t h at we couldn ' t p erfo r m a will be In And I a l so suspect that t he increasing fact , just and this the morning ro ads in the t h ey were r eport ing on the hearing NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-74 WW'W.nealrgross.com I Appendix A 62 1 2 3 4 5 6 h at was around held o n here . xecutive Route 4 22 And Barry Director which a 50 percent 7 n crease of th e Del aware 8 ~r i dlock ma i n he ' s River r o ad the Valley population projections anticipate on region a nd if we don ' t 422 , we will have v irtual a l l th e way to t he Berks Count y l ine . Maybe 9 we ' ll improve t h at situation , happen . but 10 it ' s way too early t o k now i f that wi l l 11 s o my plea a nd my c oncern is can we s low th i s down s o 12 t hat we k now , 13 are going t o be c l oser to a time that the dec is ion i s 14 made . i n fact , what t he environmen t a l And i mpacts Tha n k you. 15 (Ap p l ause . ) 16 FACILI TATOR BARKLEY: 17 MR . FENCHEL : and I ' m on Tha n k you . Good afternoon . 18 Tim Fenchel 19 River National a nd State Her i t age Area . 20 49 the staff of 21 country 22 conservatio n , 23 preservation 24 r evi ta l ization 25 Ti m? M name i s y Schuyl k i ll River Valley . congress i o n a l ly- designated and ou r mi ssion educa ti on , a nd touri sm and the Schuylkill We are o ne of Heritage is to Areas use in the r ecr ea t i on , c u ltural and historic as for community economic tools development with the NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-75 118-2-08 1 and he t ol d last wee k ' s IICont'd I increase in th e capacit y ou r Seymour is quot e d , Reg i onal Pla nning Commission , orum audience tha t is WW'W.nealrgross.com Appendix A 63 The Heri t age Area has had t he oppor tun i ty 1 2 for al most 3 Nuclear a nd t h e Limerick Generating Station on several 4 local 5 programs have p r oven t o have a positive impac t 6 local commun i ties , 7 And I wou l d 8 t hose now . and sev en region a l li k e In 9 the ye ars now to pro j ect s residents , to tak e 2 00 5 , a Exelon programs . a nd natural Nuc lea r These on our resources . t o hi g h li ght appro ach ed about 11 g ra nt progr am t h a t 12 cri tica l 13 river has b een d e t rime nt al l y i mpacted by h undreds of 14 years o f 15 our 16 Revolut ion . 17 deforestat i on , 18 space developme nt . wo uld partnering wo rk t o reso urce , h i sto ry But even to more f a rmi ng p r a c tice s , Begi nning in 2006 , 19 Ri ver . pr ima rily as a related on a resto re o ur area ' s t h e Schuylk i l l abu se and n eglec t , natio n ' s t o gethe r us 10 natura l of a nd wit h few moments Exelon possibi li ty pa r t ne r the resu l t of I ndu st r ial recent ly, and Th e due to c o ntinued open a ft er the creat i on of 20 gra nt p r o gram g uid e l ines , 21 necessary account i ng a nd r eport i ng s t ructu r es , 22 b egan 23 River Restorat ion Fund . 24 Area acts as the adminis trator a nd t h e manager of this 25 grant ma king program, ann ual an a dv isory committ ee and a contributions to the Exe l on Schuylkill The Sch uyl kil l River Heritag e redi s tri but i ng Exel on ' s co ntribu tions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-76 WW'W.nealrgross.com Appendix A 64 1 t o local and regiona l 2 organ i z a t i o n s , 3 project s 4 Schuylkill River wate r . 5 agr icu ltu ral remediation , a bandoned mi n e drainage , a nd 6 stormwat er runo ff are supported t hrou g h th is program . and local add ressing 8 mill ion to 9 project s . t he groups , conservat i on g overnment t he To d a t e , 7 waters h ed q u ality agenc i es a nd Projects f or q u ant ity of f ocu s ing on Exelon ha s con t r ibuted over $1 . 2 res tora t i on fund f or wate rs hed - wi de Twen t y -two g rants have been a warded a nd 1 1 10 project s have been 11 made a n i mpact on the water q ualit y and q u antit y of 12 t he Ri v er wh i c h 13 wa t er 14 Penn sylva n i a . Schuyl ki ll f or over 15 c o mpl e t ed . 1 . 75 Th ese is mi llion a project s sou r c e people in of have dr i n ki ng s o u t heastern Ex e lon ' s establ i shment and c on tributi o n t o 16 t he re storati on f u nd has be en a model 17 now a 18 several 19 the i r 20 Phil ad elphia Water Dep art me nt 21 the 22 program 23 The 24 catal y st 25 $600 , 000 f o r area res tora tion . uni qu ely val ued new own pa r tn e rs public/pri v a te p artn ers hip have cont ribu tions De l aware and Estua r y to to e fforts and fund . t he Bot h as made t he and the Part n ers hip for brou ght reg i o n a l made l everage j oi ned h ave s u pport ed con tri butions p rog r a m and is by f u nding waters h ed Exe l on additional have funds to the project s . b een we ll the over NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-77 WW'W.nealrgross.com Appendix A 65 The goal o f 1 the Restoration Fu nd Advisory 2 Commi ttee is to be a bl e t o support a sustainable level 3 o f half a mi l lion d o llars a nnually for th e fund a nd in 4 turn , 5 e ns ure th e futu re hea lth o f th e Sch uyl ki l l Riv er . conservation projects t ha t wil l c on tinue to I n a ddi ti o n t o o ur wo rk o n the res t oration 6 7 f u nd , we have a ssisted Exe lon Nucl ear , 8 Town shi p , 9 beg i n the process o f East Cove ntry and Ch e st er Count y in a p l a nning ef f or t to rest ora tio n a nd preservat i on of 10 t he h ist o r i c Fric ks Locks Vi l lage . 11 Exe l on Nuclear , 12 s i gned an 13 stabil i ze , 14 Ches t er Cou nty ' s oldest b u ildings . 15 to 16 several buildi n gs as stabi l i z ed ru ins . 17 be buil t around 18 donating four 19 es timated $1 mil l ion . spend t he current agreement with mill ion the of t he v il lage , East Coven try Townsh i p to p r o tect severa l of to grou nds ho uses own e r s a nd reh abi litate , $2 . 5 Earl i er t h is year , to Exe lon ha s agreed resto re and t he t he t he exterior of A fen ce wil l corporat i o n towns hip wort h is an 20 In a dditi o n , the corp oration has agreed to 21 c on tinue t o do rout ine ma i nt en ance on the vi l lage and 22 work with the l o c a l h is t or i ca l soc i ety to host g uid e d , 23 historic and edu cation a l tours for t h e p ublic . 24 From ou r perspective , mu ch of the success 25 o f t h i s pa rtners hip can be ass i g ned t o the h ard work , NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-78 WW'W.nealrgross.com Appendix A 66 1 dedicat ion and p erson al commi tment of Exelon sta ff a nd 2 management . 3 pro g rams 4 witnessed 5 wou ld 6 r e licens i ng 7 Gene rat i n g Stat i o n . Bas e d on t he v er y positive c ommunity 9- 1-SR and i nvolvement fir s t l i ke hand as we a h ave experienced organization , regiona l to communicat e a nd c o nt inued our a nd I we support o p era ti on for of t he Lime r i ck Th ank you . 8 (Ap pla use . ) 9 FAC ILITATOR 10 The next t hree 11 Vogel , 12 BARKLEY : people I would Oka y , you . call , Bill s ay that ? fo ll owed by Eileen Dautrich , 13 MS . DAUTRICH : 14 FACILITATOR 15 to is t h at how you Dau trich . BARKLEY: Dautric h . Okay . And then Bi l l Albany . 16 MR . VOGEL : 17 l ive i n 18 l i fe e x pectancy o f 19 increase that 20 Everything has a 21 as people . 22 like t ha n k If I Hi , my na me i s Bill Vo gel . Pho e nixvil le . was Un its 1 and 40 years . 20 ye a rs , li fe a I 2 had an i n i t ial They a re now asking t o f ull o ne expectancy , third machi n ery , increase . as well Demogra ph i cal l y , my l i fe e x pectancy i s 74 . 10-1-LR 1 to get a one third extens i on , like t he 23 Limerick p lant wa nt s , t h at woul d take me to 111 . 24 do you think is going to h appen to me between age 74 , 25 my l i f e span , my n a mepla te capaci ty , and the y ear when .. What ... ""? '"'""'"'"" ~ COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-79 WW'W.nealrgross.com Appendix A 67 111? going I 2 l ifecycle . Mach inery has 3 e ngineer t o t e ll 4 have t hem . 5 6 The to go down hi l l . less compe t e nt . 7 reach It ' s 1 You don ' t them . you that . Just n eed an l ike human b e ings We b ecome less e ff ect ive , less effi cient , signi f i ca nt d i ffere n ce wi l l be con ta inabl e . That ' s is my f a il ure Limer i c k ' s mo st like ly wi ll n o t . 10-1-LR I Cont'd 8 If I drive o ver you wi t h my car beca use I 9 see as well or h ave t h e re fl exes I o nce had , 10 t ragedy for you , 11 The s phere o f t he tragedy is conta inable . 12 Uni t 13 dis respec t . 14 It aff ects 15 community , 16 week , 17 18 And or 2 f ami l y , that ' s a want to h a ppen . 1 you r no l o nge r fai ls , al l Th at ' s what f or me and my hel l a n u c lea r everybody in t hi s If Lime r i ck breaks loo se , f ailur e r oom , famil y . is , no hell . ever ybody in t h e everybody i n the t r i - s t ate a rea , not for a but for decade s . I I t ' s very, very la st thing we think we ' re putting ourselves in 19 harm ' s way by taki ng someth i ng that had a li f espan of 20 40 years and addi ng another 20 to it . 21 sense . 22 p ersonal fear o f b eing inconvenienced b eca u se we l ose 23 a very, 24 job for u s . 25 your abi l ity to provi de a great job is at an end and It doesn ' t make The o n l y way t o rat i ona l i ze i t very g ood so u rce of power . But l i ke me , i s thro ugh our It ' s done a great you get to a point where NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-80 WW'W.nealrgross.com 10-20R I Appendix A 68 1 2 i n that position . 3 n ow 4 n a me pl a t e t ime . Let ' s thi ngs start d eter i o r a ting . and a l low not put ourselves Let ' s make an intellige n t these two u nits to expire decision at the ir you , 110-2-0R I ICont'd I Bill . Th a nk you . 5 (Applause . ) 6 FACILITATOR 7 Thank Ei l een . MS . DAUTRICH : 8 9 BARKLEY : Ei l een Dautrich . Goo d afternoo n . My name is I ' m president o f the Tr i - County Area I 10 f=hamber of Commerce . 11 p rovide examples of how Limerick Ge nerati ng St a tio n is 111-1-SR 12 a valued c ommu n ity a nd b usiness part ner and echo t he 13 statements already s hared by seve ral others . I ' m happy to be here t o day t o ,..,u......,....=-=-..., 14 Th ey ' re empl o ye r , one of provi ding t he tr i-county 15 l arg est 16 p pportunit i es 17 res i dents empl o yed by Limeri ck Generating Sta t i on are 18 s u pporting the e n tire 19 rrh ey ' re 20 local 21 t r e mendou s benef i t 22 ~u s i nesses . 23 employees to v is i t 24 local b us i nesses , and s mal l busi n esses . for l oca l residents . 25 businesses . goods The and annual emplo yment Thos e tri - county bus iness purch asing pers onal s ma ll pro fessio n al area ' s l oca l commun ity . services outage from is a t o the local e conomy and o u r local Limerick en courages t he ir outage and purchase f rom tri - county area , In additio n to t h e jobs t hey provide local NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-81 WW'W.nealrgross.com I Appendix A 69 1 r es ide nts , t h e y ' re maki ng a si g ni fi c a n t 2 our co mmu ni ti e s . 3 b e n e fit loc al f rom i nvestment in Muni cipa l it ies a nd r es idents a s s istance r eceiv e d fr o m Limerick 4 to 1 11-1-SR ICont'd s ta r t , ma i n tain , e xp a nd p a rks , r ec r eat ion , a nd q ua lity 5 o f l i f e o pportuni ti es . The ir c orp o r a te culture o f givi ng back t o 6 7 the commun i ty is p ra ct i ced 8 e mpl o yees . 9 Limerick Generat i ng Station a nd t he effo r ts o f 10 empl o yees . Fi nancial as well as v o l unteer 11 h ou rs time 12 nonprofits 13 impact t hose i n n eed through o ut the tri - c o unt y area . Nonprofi t and to donat i ons , are donated , t he of o ur Generating l o cal is ma i ntain 17 invi t e d 18 f i r s t hand . 19 a nd the sit e vice pr es ident , Bill Magu ir e p r ovid e d t he 20 key note p resent a tio n . 21 and 22 p e rtai ni ng t o th e Limerick p lan t 23 wa k e o f the tsun a mi i n J a p an . to c ommun i ty . exp erien ce The chambe r adv ancemen ts at me mb ers wer e t he t h ey commun ity has The e nvironment been generating sta t i o n ho sted a membership breakfast He s umma ri zed Limeri ck In a d dition , 24 sa f e Stat io n t hat 16 our and their c onf ident in c l e an e nabling much n eeded servi c es Limerick t he hundr e ds 15 25 in their o rganizati o ns are suppo r t ed by provi d e Th e 14 by e n c ou r a ged and s afety meas u res a n s we red q u es t ions and i t s s afet y in t h e after o ur break fa s t , to a tte nd t he Chamb e r info r ma tional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-82 WW'W.nealrgross.com I Appendix A 71 1 see p o licies and procedures that people t al k about a n d 2 t hey ' re put up on a she l f 3 haphazardly with a 4 the policy is n ot addressed . 5 One of and t hey ' r e wink and a t he impressed a t 7 t o po l icy and p r oc edure . 8 9 LGS when I I ' ve been t o vi s i t numerou s exer c ises a t NRC and neve r 11 out 12 as 13 involv i ng 14 SWAT 15 c ond uct 16 was 17 pro cedures 18 throughou t on a I 've t op . s i te fe de ral , teams t o u sed as a devia t e i n f i rs t 2009 , plant, nu merous t he Th e y and go loca l into pilot exerci se law enfo rc e ment the powe r there , in p l ate a l ways come Limerick was se le c t ed comprehen s i v e s t ate , boi l er from i t . some of wh ich were run by t he ope r at i o ns for is t heir sound adherence They don ' t act ua ll y tacti ca l I ' m c o n t inuously seen t hem fail . In f act , f or t he th a t d r i lls a t the p l a nt , 10 nod and deviation from things 6 followed at best and to develop implementation in b l o ck that and dr i l l pol i cies and power plants don ' t bel i eve the cou ntry . 19 One o f the I ' m s o rry , operations 20 that continued 21 have any det r i menta l 22 southeast regi o n . of e f fect the on I power pub l i c p l ant wo uld 1 12-1-SRI safety in the Th a nk you . 23 (Applause . ) 24 FACILITATOR 25 I 'd li k e to call t he BARKLEY : final three Okay , thank speakers wh o you . h ave NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-83 WW'W.nealrgross.com Appendix A 72 1 signed up , Jo hn McGowan , 2 Phillips . Joh n? MR . 3 Ted Del Ga izo , McGOWAN : Thank you and Timothy very much . My 4 n ame i s John McGowan and I am a l i f e - long r es id ent 5 the Delaware Valley . 6 should say th e Limer ick Nu c l ear Power St a t ion has been 7 operat i ng 8 ma nu fact ur i ng companies i n the Ma l vern area and emp l oy 9 a for number of of I have l ived h a lf o f my -- or I ha lf peop l e of in my l ife . t ho se I own faci l it i es three who r ely 10 t remendo usl y on the Limerick Power Ge ne r ating St ati on 11 t o supply safe , 12 operating . re l iable e l ect rica l power t o k eep us Today, I would li ke to say t ha t 13 years t hat I ' ve 14 t he 15 wor r ied a t 16 pl ant . in thi s area , I ' ve never 17 the least . 18 s uggest 19 pl ant . 20 is run ning 24 /7 , 365 days a year and it has been doing 21 so for a quarter o f a cent u ry and I hop e it con tinues 22 to do so f or ma ny more years to come . a ll about the safe ty of t h e n u c lear power I see i t every day . And it bothe rs me not i n I have n ever seen any credi b le evid ence t o lr:- -=--::::-R 13=---1 s ::::-'1 t hat there I n t e rms o f As 23 l ived in all of far are s afety re li a bil ity, as its p roblems it with thi s is the same . environmenta l It impact , I 24 thi nk it ' s pretty widely known that n u clear power is 25 one of the c leanes t environmental energ ies th a t we NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-84 WW'W.nealrgross.com Appendix A 73 1 p ossess t od a y throughout the world and t o d ismi ss it 2 is I t hi nk a foolish n otion . 3 The the Limerick p lant provid es , as we a ll know and have heard t od ay , lots o f 6 j o bs , 7 local governmen ts and for t hose who li ve i n the area 8 to 9 provides e nj oy t he good fru its lo t a jobs , of of tax p os itive . our 5 of ex traordinari l y in r eg i o n l ots b een of 4 10 h as impact r eve n ues publ ic servi ces chari tabl e for It schools , and d o nati o ns it also to t he c o mmuni t y which is ve r y impo rta nt . I 11 think t hat to not keep this plant 12 runn ing a nd not 13 an extended period would be a tragic mis take fo r 14 o f us and I would l i ke t o end t h i s by saying t hat t he 15 o nly meltdown that wo uld 16 o ne 17 this p lant not con t i n u e to opera t e . 18 (Applause . ) 19 FACILITATOR BARKLEY : Ted , go ahead . 20 MR . my con sid er a renewal of its license f o r c o ncern me i s al l the eco nomic that certainly wo uld happen to this area s hould DEL GAIZ O: 21 Ga i zo . 22 Co mmonwea lth o f 23 CEO of 24 Hi , name i s Te d Del I' m a r eg i stered p r o fes s i o nal engi nee r i n the Ext on , Penns ylvania . a Pennsylvan ia . small bus iness My exper i e nce 25 I ' m also president and e ngin eeri n g firm in nearby in nuclear p ower goes back NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-85 WW'W.nealrgross.com 13-1-SE Cont'd Appendix A 74 1 t o the 196 0s where I spent 1 4 years i n Navy submarines 2 a nd 3 nuc l ear power plants during th a t period . I personally operated , But I ' m he r e 4 maintained , a nd refueled t o d ay as a pri v ate c itizen , 5 as 6 Pennsylvan i a En ergy Alli ance t o go o n r ecord and say I 7 s trong l y 8 Gene rat i n g Stat ion . 9 experience a resident of favor I th e area l icense know and as r e newal a for member the of the Limer i ck I say that because i n my personal in spite probably h eard s ome the nuclear t h ings y ou ' ve 11 safe , reliable , secure and c le an. 12 t hat , 13 n e i ghbors 14 Generat i ng Station in t h is area . 15 has a top reputat i o n . 16 p ower pla n ts i n America . And Exe l o n , if not the best , 17 is ce r t a i nly one f i ne st nucl ear operato rs 18 the worl d . 19 t oda y , of 10 I here of know we are lucky t o of is But i n addi tio n t o would l ike t o go o n record , to power I would l ike my have t he Lime r i c k In the i ndu stry , it It i s one of the fi nest nu clear t he I have no thing but in con fide nce t hat Exe l on 20 will wor k together wi th the NRC , wi ll run through the 21 process and we wi l l 22 here which i s license renewal s h ould b e granted to t he 23 Limerick Generating Station . 24 Limerick operating as long as we can . 25 c ome up wi th th e r i ght conc l us ion I think we need to keep In additio n, in sp ite of some other things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-86 WW'W.nealrgross.com Appendix A 76 1 openness in the t h inking process t hat goes into place 2 for renewa l of any nuclea r power plant . And so f rom my p erspective as a citize n , 3 4 as a bus in ess person who h as worked in this community, 114-2-SR 5 I und erstand the value t his is to t h e r egio n . 6 ~e , 7 applaud Exelon fo r 8 there 9 p lace . And f o r I applaud the NRC f or what they ' re do i ng here . and I I the g reat work that t h ey ' re d o ing encourage the renewa l process to take Th ank you . 10 (Applause . ) 11 FACILITATOR BARKLEY : Thank you . With 12 t hat , 13 meeting , have been cal l ed . Is ther e anyon e else who 14 would l i ke to make a short f o l low- up remark or would 15 li ke to sti l l speak at this p o i nt ? I h ave a l l 16 15 people who had signed up f o r this Okay, if not , I ' d li ke to make two points 17 befo re we wrap 18 meeting feedba ck fo r ms whi ch give us feedback on how 19 y ou 20 greatly appreciate yo u filling out one o f those forms 21 for us so tha t we c a n l earn how to improve . 22 another session o f this meeting at 7 o ' clock tonight . 23 think th i s On e , meeting the was NRC do es cond ucted , have so I publ i c would The re is You ' re welcome to speak again to night . And secondly, 24 25 up . wh at I 'd l i ke to say is I facili tate a l ot o f mee tings t h rou ghout t he Nor theast NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-87 WW'W.nealrgross.com I Appendix A 27 1 meeting via c o nference arrangements of the bridge . audio in And this due room to it the wasn ' t p ossible t o do it any other way than a cell pho ne . we ' re go i ng to go to him a nd ask him to make statement f or the period and move from there . first speaker will be Mr . Thomas So a So our Saporito who is a senior consulting associate and he actua l l y l ives in Florida . So as so o n as we can work having him on t he microphone we wil l 1 REGNER : Go ahead . MR . SAPORITO : MS . REGNER : MR . 1 Yes . SAPORI TO : Oka y . Can you hear me oka y? 1 MS . REGNER : 1 MR . Thomas I 'm Associ ates the and senior I 'm environmental review but b efore I know , to comment I ' m very My name consultant l ocated 2 you like right . Florida . that , would All 2 state I As best we can , yes . Yes , go ahead . SAPORI TO : Saporito . Sapr odani 2 Go ahead , Is it my turn t o speak? FACILITATOR BARKLEY : 2 Yes . Mr . Sapori to . 1 1 Are we free to give i t a try? MS . 1 have him make his statement . in on the at with Jupiter , d o that I upset is NRC ' s want to the NRC ' s refusal to honor my enforcement p e tition filed under NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-88 WW'W.nealrgross.com 16-1-0S I Appendix A 28 1 10 CFR pl ant . I 2 . 206 wi t h respect to th e Limerick The NRC denied th a t petit i o n on the basis that would have proceedi n g However , an o pportunity the th rough tha t ' s not to in t erven e judi cial NRC ' s available to on process . me . q uit e c l ear in t he 2 2 06 petit ion . standing as physica l loc ated . and a Un i t e d location pro ceedi n g 1 nuc l ear in in Stat es cit ize n Jupit er Pennsylvania to t hey ha ve a leg a l that I do n ' t 16-1-0SI I Cont'd h ave because of my intervene in a where The NRC s taff is incorrect made I Now , this this plan t is i n their opini on obli g a tio n to honor that 1 enforceme n t pet i ti o n and t o provide a n opport un it y f or 1 me t o address t he Pet it i on Review Bo ard . So I wa nt t o put t hat on the record and I' m asking t he NRC to l ook 1 into that iss ue . W th i 1 respect to this peti t i on the fel low who spoke earlier reca l l his name . environmental from t he NRC , I 1 don ' t 1 hear t hro ugh this communication his name . 2 o n e of his comments was exceptiona l l y incorrect and he mi s i n for med the p ublic . 2 statement . 2 o rigina l It was very h a r d f or me to But anyway , And I ' d l ike to correct that He stated that the NRC is e x tendi ng the operating license which was gr anted by the NRC for a 40 - year period o f time that that initi al 4 02 yea r licen se was no t based on safe ty cons i deratio n s or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-89 WW'W.nealrgross.com 16-2-LR I 1 --r-----' Appendix A 29 1 echnical consid e rati ons . But that ' s abso l u t el y not rue and there was recently a year- long investigative eport 4 done by the Associated 2xpert nuclear perso nnel , Press who int erviewed t-:-::! - 2 - :-:LR 1 6~:- ::::-ol safety engineers Cont'd engineers , ~ n th e nucl ear industry who told t hem that the 40 - year E i censes issued by the 7 h e United States was based on safety and t echni cal afety c 1C techni cal NRC f or 104 n uclear analys is. So these plants in proceed ings , hese l icen se extension proceedings l ike th e one we ' re :::urrent ly a t are a rubber - stampi ng extensions . This the Reg u lato ry 1L bet ween L ' Uni ted 14 t hi s 1" until the Fukush ima disasters can be ful l y understood 1E and 17 ::>lants here . 1c ::>lants , yo u Congress where fact a 20 - year icense St ates in these 11 Nuclear is of foo t Co mmission race a nd Congress wants to t he s t op 16-3-LR process , the 024 . 2C 21 2.c 2 24 2 ." put a enhancement This know , moratorium enacted in nd nothing ::>rotecting ea l to 2xtensi o n s here re - li c e n si ng for our power p lant, nuclear now 1 2 foot ra ce more . continue to years these has and ahead of time And the only reason is the NRC ' s This public health without August particul ar ryi ng to extend this license? a the their license is a lready good till Why are we ::>ecause i t ' s on in with Co ngress nothing safety, rubber- stamp to it ' s these do the with NRC ' s l i cense allowing c i tizens due p rocess like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-90 WW'W.nealrgross.com 16-4-L R I I Appendix A 30 1 I already talked a b out a nd wit h out doing a cost Cont'd i nt e nse and t horough e nvironmental r e v iew . And e nvironmen tal with review pro p er ly consider eactor r esp ec t th e t he vessel . NRC to in my When th ese of to numerous become year s bri tt l e of o ver ope r a t ion fail ed this nuclear :>perat i ng th e ne utrons c ause the me ta l vessel to n u cl ear re actors are i n the reacto r t ime . these NRC ' s t he v iew embri t t lemen t I 16-4-LR And reactor a ft er vessels 16-5-0S I cou l d crack because t hey ' r e so bri tt l e . But t he NRC j oesn ' t NRC does n 't equire properly the analys i s evaluat e l i cen see of t he to that do react or ' s a nd the des t ruc tive metal testing ves se l a nd pr i or to ubbe r - s t ampi ng a 20 - year extens i on t o t h ese l icenses . Twenty years f r om now , o h actually 20 years f rom 2024 whi ch wi l l m e or b e 204 4 this c r iticall y brittle reactor is go i ng to be even and the understand th e dynamics of t ha t c r ack and i t ' s eco v er f rom mag n itude . a l oss of to and t he re act or could coo l a nt acc iden t of that So th a t ' s one p oint . ot h er p oint :>ver there i n Ro ckvi ll e , recently a d o p ted e v a cua t ions . not going g oi ng t o melt down because y ou can ' t The hey NRC ' s They a wan t is the NRC ' s Commi ss i on in the Whit e Fl int Building , new p olicy th ese wit h licensees respect to to u pdate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-91 WW'W.nealrgross.com 16-6-0SI I Appendix their evacuation plans. Now, 1 would hope that the NRC staff has made that requirement to the Limerick licensee so that the people near and around within 15 miles of the nuclear' plant can properly' and timely evacuate the area. Again, the Associated Press's investigation, year--long investigation shows that the populations around these nuclear plants increased tenfold over the years and that the roads and the congestion, you can't timely' evacuate these areas. And the NRC keeps pushing these evacuation plans onto the licensee but the NRC doesn't enforce its regulation or properly review if these plans are even effective. 6-6-OS onfd The NRC is required under the law in this review, the environmental review to consider renewable energy sources, alternatives. And that means need. Is there really a need for these two nuclear plants to operate and the answer is no. Simply stated if all the customers who receive power fronx these nuclear plants were to simply remove their hot water heaters and replace them with on--demand electric water heaters you would reduce the electric base load demand by 50 You wouldn't need either one of those to 70 percent. nuclear power plants to operate. If you take that further' and introduce other' energyi conservation you 6-7-AL NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 A-92 Appendix A 32 1 would actual ly h ave the licensee shut down more their other power p lants because o f demand . of y ou would ne ed a I f you t a k e wind energy which is plentiful up there in which Pennsylvania can operat e and when even t he the sun n ew solar panel isn ' t s hin ing on a cloudy day you could replace even more operating power plants . respec t So th ese renewable e n ergy sou rces even with to wind energy s i nce you have a common grid t hroughout t h e United St ates you can have wind farms 1 g enerat e power t o a common gri d point and supplyi ng 16-7-AL Cont'd t he p ower t hat t hese nuc l ear p lants are now provi ding . The NRC ' s 1 1 required under the law t o co nsider these al t e rna ti ves to extending t his l icens e . hope that a 1 woul d the NRC ' s f i nal eval u ation and revi ew shows complete 1 And I renewable and energy thoro u gh sources ana l ysis including of a ll installing these on- demand hot water electric heater and doing an analysis 1 of how many megawatts 1 grid and based on those evaluations make a licensing 2 determination whether or not extended . Because you ' re 20 going to take off the this years l icense sho u ld be from now al l these 2 renewable r esources are going to be all that much more 2 advanced a nd capable of supplying al l power than they ' re c u rrent ly s upplyi ng . 2 my comments that much more So those are and I would hope that the NRC takes them NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-93 WW'W.nealrgross.com I Appendix A 33 1 seriously and applies them to this li cense renewal . you hear that? They ' re And I hope e verybo dy h eard me . (Applause) MS . REGNER : Ca n clapping . FACILITATOR BARKLEY : I '1 1 h is ca l l b ack Mr . remarks It ' s and awfully Okay, Sapori to later being succinct fo r a wkward t o at and provide this point t hank him in his for remarks . comme nts v ia this avenue . Th e call a re t h ree so I' d Chumnuk , li ke then Cat h e r i ne Allis on . to start Daniel I 'm a member Borough . would And my of Hi , speak this them . and t o Firstly, t h en f i na lly co mments to go d own my name is Jeff Chumnuk Borough a gen erating station . oppo r tuni t y not like S o Je ff , i f you could lead off . from my perspect ive as the I wit h Ludewi g , MR . CHUMNUK : and people actual ly i ndiv i d u a ls who did aft ernoon Jef f firs t Counc il t on i ght with are newly elec t e d Ab out a Pottstown more I g uess o f ficial with y ear ago I had the to the generating stati on and 1 .-:-:::'--:--=:-=-. 17-1 -SR meet with Joe Saffro n and the first part of my meeting h ad to do Pottstown whil e we with S oapb o x were looking Derb y . s t a n di n g for so me Th rou gh supp ort some outsid e you for the conversation know Joe NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-94 WW'W.nealrgross.com I Appendix A 34 1 e nli ght ened me a l ittle b it on what Exelon and the generat i ng stat ion do for t he surroundi ng communities , wh ether it ' s supporting our f i refighters , departme nt s and other civi c o rganizati o ns . fro m a Pottstown p erspective they help p o lice Yo u know , us with our year ly b o r oug h cleanup , o ur Salvatio n Ar my and now t he Soa pbox Derby . Thank you . And we we re standi ng outside that day , i t wa s pret ty nice ou t, 1 and o u r power p lant i tse l f. We were s t anding t here loo king aro und , it' s abo ut , a pretty impressive sight . 1 hi m 1 mun icipal offi c i a l s . you know , pos sib l y hav i ng a got a group o f abo ut 20 o f 1 the plant one even ing . tour the securit y 1 througho ut 2 y ou were on as us and gave us a t o u r And I t he plant having the our h ave t o say t hat to u r p rog r essed , expl ained what pa nels why f a il safes , it th e you you walk t hey from know , W hether di fferent and what of and p ast safety was paramount . d i ffere nt f or look i n t o time we wal ked thr o ug h the fr o nt ga tes 1 asked A cou ple of months la te r he 1 ar e So I He sa i d he wou l d and see what he could d o . the c o nve rs ati on l ed to t he co lo rs mean cer tai n to areas 2 d i fferent 2 certain ways a nd what li nes you had to stand beh ind , you know, 2 safety was paramount with them . from e nvironment , t he I ' m loo king You know , aro und and t his NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-95 WW'W.nealrgross.com 17-1-SR Cont'd I Appendix A 35 1 And I plac e is spotless . t hey can ' t asked wh y and it ' s because af ford to have dirt or lint or fuzz b a lls around b e cause o f static e lectricit y beca u s e i t crea te issues . So f rom that aspect I thought good t o ur and i t could i t wa s a made me feel good abo ut the safety aspect s there . To fin i sh o ur c on t rol r oom upsta i rs . tour we ended up in t he And I ' d say maybe a dozen o r s o i nd i vi d u a l s up there mon i t o ri n g you know everythi ng goi ng o n wit hin t h e p l a n t aga i n , e xpl a i ning t he and around t he p l an t. f a il s a f e s and wh y And t h e y ' re doub l e -, tripl e - chec k ed t o e limi nate h uman err o r . It was j ust v e ry i mpr e ss i v e a nd as an el ect e d offici a l t o go down and t ake a t our of the p l ant and u nderstand how it opera t es . I know wh e n I left I personal ly know how to issue a c onc e rn with the ge nerati ng stat i on . know I that know , fe lt a night . as l ot better and a And one of it was our a l so region ' s I l ot safer go i ng home good to largest rea l ize , you empl o yers now that they are wil l ing to give b ac k to the community and keep s a fety fir st . So t h ank yo u, I just wan ted to mak e those comments . (Applause) FACILITATOR BARKLEY : Thank you , J e ff . Dan iel? NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-96 WW'W.nealrgross.com 1 1-,J?'---s R ,... - 1 =-==--""1 Cont'd Appendix A 36 I ' m Da n Lud ewig . MR . LUDEWIG : 1 Jus t two On e wo uld be what ar e we go i ng t o d o wi t h lr.:':-:--::::-:-:-:"1 18- 1-RW,1 q ues t ions . 1 the 20 y e a r s of spen t t a k: e car e o t those . And s e c o ndl y , l t we d o n t get the lice ns e which I d oub t get el e ctric if r o ds a nd how a r e you g o i ng t o but wha t would -- h ow woul d we t he l icens e we r e c ance l ed ? I don ' t k now who a nswe rs t hi s . FACILITATOR BARKLEY : I 'll as k Li sa to s p ea k . MS . REGNER : Yes , the spen t fuel Limerick is l icens ed f o r a n ind ivi d u al s pe n t fac i li t y . They o ff l oad t he spe n t f ue l . r ods . f u e l pool Once t h e y ' ve c oo led t o a c ert a i n l eve l th e y wil l p ut t ho se in t o dry cas k storage env i r onme n ta l and review Li me rick d o es h a v e Th a t ' s an s to re o ngoi ng , t ho se t hat ' s ons i t e . l o o ked storage f or the it 's o nsi te work at t he p lant t he g ene ri ca ll y . spent and r eactor o v e r s i g ht process a s we l l . tha t at In fuel p art r ods . of the i r So t he res i d e n ts monito r th e s a f e ope r a t ion of those fac ilit i es . The second q uest i o n , whe r e wou ld the power come f rom a l tern ate if Li me ri ck p ower we r e fac il it i es s hut in the d own ? There ar e a r ea . Da v e , you wan t t o g i ve th at a t ry? MR . WRONA: I ' m David Wro n a , a bra nch NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-97 WW'W.nealrgross.com 18-2-0S I Appendix A 38 1 Can everyone hear me i n the back r ow? I am Catherine Al li son and I was born and raised in this area so as far as t he NRC want i ng to know h ow this impacts t he area I wor l d k now it so , Europe , abl e to hear me , et ce t era . jus t also I ' ve very wel l . trave l ed t he So did a n yone r a i se your ha nd . not be You ' re good? Okay . One t on i ght 1 for 1 mo st 1 li ke , wanted t he r e - li censing . years p e ople clean I to sa y is th e NRC is d o ing a scoping basicall y fo r e nviro nment a l p u rpo ses f o r is thing you air , eve ryon e , have bee n k now , 1 c on ce rned abo ut 1 anyth i ng about i t I ' m being tal king c ancer , c le an water a nd W hat I wanted t o say a yo u general abo ut know, which lot t he t he us effects but of i mpact on t h e thi ngs of here , just we are didn ' t al l do even thou gh we were ve r y concerned . Now l at ely wi th the -- u nfo rtunately it ' s 1 a reality now t h at we have h urrica n es , mor e to r nadoes , 1 tsu nami s throughout the worl d . 2 but And I hate to say it it i s a reality now th at we h ave terrorist at t acks and Li meri ck is d efin i t e ly one . I 2 blowing t hi s out of proportio n but it ' s just something 2 that I want to b e know t hat we ' ve all been c oncern ed about , wanting to say yes , 2 don ' t Limerick , and al l not the peop le that bui lt the power p lant and the company say o h , there ' s NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-98 WW'W.nealrgross.com lr-=1..,.-=-:--. 19-1 - PA I Appendix A 39 1 no impact to the ai r f ort h . and th e wat er pollution and So we ' v e kind o f selves to th a t a nd j ust b linded our , let ' s b e l iev e t hen , you know , o k ay , Let ' s r ea l l y b e lieve th a t a k e a mi n ut e . so l et ' s 19-1-PA Cont'd t here i s n o mpact i n ou r clean a i r , c lean wa t er a nd those typ e o f hi ngs and ca n ce r , e t new rea l ity which happen . e rror would human t here wi th or r o m King hese which j u st say f or exa mp le ther e was Let ' s happened , Let ' s j ust go into t he cet era . is the terrorist s p e nt fue l a rad iati on l ea k . of n atural Pruss i a . Talk disast ers and attac ks r ods I a nd s omething j ust d r ove to n i ght abo ut evacuati o n realiti e s hit us . when One a cc i den t, t wo hou r bac ku p , a lmost no exaggerat i on , one housand cars . The re wi ll be no eva cuatio n . want t o be l ike I don 't scare tactics here but li ke I s aid , he weath e r and s o f ort h , na tur al d i sast ers h as r eally 19-2-0S I bee n hi tt i ng th e whole Un i t ed St ates and the wo r l d after the hurricane ately so i t ' s a reality . Ther e h at we was just had . floo d ing Five d ays later there was roads l ased in Pottstown , i n No rth Covent r y , East Coventry . There were , when I t ried to get home f rom work r ight Jn Route 7 2 4 , no e x aggeration again from a l l oads a b o u t 500 cars . t h e back Th ere wi ll b e no evacuat ion and certai n l v hope t hat p eople understand I ' m not trvinq NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-99 WW'W.nealrgross.com I Appendix A 40 1 t o b e scare tactics . I I ' m sure a l ot of see t his . y ou have seen this and been in th ese situations . Aoain ~-:-1~-~2--="""s,....,l 9 o What t his do es to the Cont'd with a l ittle bit of flooding . r oads . All there will be no evacu at ion . So fro m day one I t h i nk power plants never 19-3-0R I they are here why i-"T"--...1 s ho uld h ave b een built but n ow tha t would we gen t leman ever want calle r to just re - license . said , I Thomas , he was very el oq uent . And believe his as o ur name was He was stating the fact why are we re - li c ensi ng t hem, what, 1 2 years ahead of t ime . or To me that is absurd . they h ave Why do they to do s ome want us , rubber - stamp something? Like maybe a year befo re studies , and t wo l ove I years before . Thoma s ' s words , r'-:-:,..._:-:--=-o 19-4-LR I Twe l ve years beforeh and to go into what , 202 4 f o r Unit 1 was it and 2029 for Unit 2? Wh y do they need to push t his You ' ve got t o stop and t hink . about that . I ' m not an licens i ng re newal? Peo p l e , go home , expert l ike think evidently our ca l le r Thomas was b ut again , I ' m concerned a bout human l if e . This is what I have at the top here . a l k ing about human li fe . all this -For the ompanies W t ' s mo r e i mportant , not ha e lectricity that phones a nd everything . fact are that we need for al l I n a wa y we are PECO and bui l d ing We are all these power plants . ou r responsible 19-5-0SI other I cell Exelon myse lf you 1\I~L "? U"U;;);;) COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-100 WW'W.nealrgross.com Appendix A 41 1 Know am gu1 1ty ot a lot ot tn1s but for let s JUSt maybe a solution besides the wi nd and solar power and everythi n g s t op using all t his new techno logy . Yes , 4 you need it good ~ for c ertai n thin gs , but E need s o much electr icity that we are willi n g t o risk 7 our for lives . 1C wa te r jobs and businesses , t hat poll u ted anymor e . c omes it ' s let ' s not overi nd ul ge where we Cancer , dri nk i ng wate r c so me water . Peop l e fr o m natu ral There ' s have to no pay to buy s prings . But yo u ' re us i ng p l astic bot tl es , you c an 't even trust t hat. But 11 this whole world h as kind Let ' s of get just 1 19-5-0S I ICont'd 1 ;; cha nged f rom L ' na t ure , let 14 t ee n agers 1" electri c it y , t hat again it ' s going to cause cancer for lE them . 17 the powe r p l ants ? 1c o u r wonderfu l 1S the 2C usi ng 21 games on the computers . 2.c for hours at a time doing nons ense . 2 electricity 24 electricity? 2 :' c hild ren . you t he on know -- their nature . i nst ead o f cell back to having all th e young t ext i ng , us i ng more phones Everybod y has to stop and think why do we need solar so We real ly don ' t cal l er mentio ned some a l ternatives like power , mu ch wind , but electricity I ' m jus t and again why It coul d be am no t t hat saying stupid we little are video People get on the compute rs where I and again , Thomas , do yo u causing That ' s taking up need cancer old but I ' m no t a ll this in your th at young f1~ -6~-~ " 9~ H~H~1 NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-101 I WW'W.nealrgross.com I Appendix A 42 1 but I h ate c oworkers to y ou I have And why? don ' t to j ust always , ourselves , 40 , a nd years 50 W have to stop and think . e you know , and get on your computer . doi ng so many friends and peop le that are o n l y 35 , old , cancer . h o me , tell Go just go watch TV Stop and think what we ' re o ur bodies , our children , our grandchi l dren . Th i s is aga i n , t h is l i censing renewal is comi ng down t o human lives , the quali t y o f our lives . 1 Again , why all electri ci t y . t his So I cancer? won ' t go on Mi crowaves and on , but I and just 1 t h i nk us a s a group can ' t 1 about the power co mpanies , we are the o nes using t he electrici ty . 1 That ' s al l just all b e just compla i ning I ' m saying . Maybe we should cut back and we won ' t need powe r p lants . Thank you . (App l a use) 1 FACILITATOR 1 Cat h erine . 1 would be 2 the n The Bi ll BARKLEY : Tha nk next three pe ople I ' d Jeffrey Nort o n M g uire a and of then the P. you , l ike to call Energy Al li ance , fi na lly Lorr a ine Ruppe . Mr. Norton? MR . 2 2 J eff rey Nor t o n Penns ylvani a 2 NORTON : and I 'm Good evening . h ere to My name represe n t Energy Al liance which is an is the i ndependent grassroots diverse organization made u p of community NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-102 WW'W.nealrgross.com .-~'f--:::-_:-H:-:-H-:-~I _ 19 6 Cont'd ~r-----~ Appendix A 43 1 leaders a nd org a ni zati o n s who promote nuclear power as a c l ean , p owe r . safe , reliable and af f ord a b le source of I ' m go i ng t o be ma king essentia l l y five p o ints i n s u ppo rt o f l ice ns e renewal for Limer ick Generating Sta t ions and they are that , number o n e , n u clear e nergy lowers e l ec t ricity p r i ces , i t pro t ects our env ironment agains t greenhouse gas e s , it strength ens our l ocal economi es and it is safe . W t h regard t o my fir s t i p o i nt in lowe r ing ele c tri c i t y prices the Limerick Ge n e r ati ng St ati o n has r ed u ced wholesale energy co sts i n Penn s y l v ania by $880 mi ll ion i n 2 010 thus l o wering elec tr i c it y pri c es all c onsume rs . stabi li z i ng It t he for operates aro u nd t h e c l o ck t h e reby n at i o n ' s e l e c tric ity di s t ribut i on system a nd t he electric ity ma rketp l a ce . The ave r age electricity prod uct i on costs at n u c lear p l ant s have actua ll y dec l i ned more than 30 pe rce nt i n the past 1 0 years due to various eff i cie ncies . c heaper to generation produce such as tha n other coa l and Nu c l ear p owe r f orms natur a l of is e l ectrici ty gas , and helps mode r ate t he pr i ce of e l ectri c i t y for cons ume r s . My next Station and po i nt is tha t nucl ear plants Limer i ck Genera t ing strength en our local economies and it is a val u a b le economic dr iver f or the Commonwea lth of Penn syl va ni a . Limeric k Generating NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-103 WW'W.nealrgross.com 20-1-SR I Appendix A 44 1 Station contri butes economic $113 mi l l io n contributions to the a n nua l ly in direct Penn sylv ania economy through v arious e mployee wages and salaries , purchase of goods and services fro m other Pennsylvania businesses and i n property tax payments to the l ocal governme nts . Limer i ck Generat ing Station also contributes generously as we ' v e also heard and i n fa c t 1 t emporary contract employees during a nnual A s i gnifi ca nt 1 o uta ges . 1 n uclear p lant workforce wi ll reach retirement age i n t he next jobs in 1 Generating valuable 1 the nuc lear Stati on is e conomic a demand industry . one and of of the for cu r rent high- paying Yes , Lime r ick Pennsyl van ia ' s energy assets most and the commonwea lth should embrace i t . My 1 2 years cre a ti ng 10 1 percen t age refuel i ng protects our third point environment is from that nuclear greenhouse energy gases and r educes the need to generate e l ectr i c i ty from foss i l 2 fuels . If Limerick Generating Station were ret i red 2 from service replacing the electricity wo ul d require increased natural gas - fired or coal - fired generation . 2 Nuclear energy is the nation ' s largest source of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-104 WW'W.nealrgross.com Appendix A 45 1 carbon- free electricity a nd is critical to our nati o n ' s e nvi ron mental , security and energy goals . My next poi nt safe . It ' s a lwa ys on , is that it ' s n uclear energy is stable , it ' s a r e lia ble source o f electr icity a nd t he s t a tio n here a t Li merick h as been b ui lt wi th multiple redunda nt sa f e ty l ayers . And t he workforce is committed t o b est c on tinuous i mproveme nt . It practice s and is a ls o i m o rtant f or our p nati o n ' s qu est t o be e n ergy- independ e nt . According t o t he Bureau o f Labo r St atis t ics it ' s safer t o work a t n u c lear p l ant than in industries suc h a as ma nu fact u r i ng , rea l estate and fi n ance . And acc ordi ng to r e c e i v es mo re the Department radiati o n of expo sure Energy a fl yi ng p ers on f r om Bal t imore to Los Angeles t ha n by st andi ng near a nuc l ear p lant 24 hours for a year . On a pe r sonal n o te Li merick Generating St a ti o n s evera l I ' ve bee n times . i ns ide I ' ve also lived within 3 0 mi les with my f our boys and wif e next to the Li meric k Generating Station a nd a l so Three Mile Is l and . I fee l s a fe , secu re and comfort a ble . Tha t is why I ' m in suppo rt o f th e re - licensi ng o f the Limerick Generati n g Station . Th ank you very muc h . (App l a us e ) FACILITATOR BARKLEY: Tha nk you . Mr . NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-105 WW'W.nealrgross.com 20-1-SR Cont;'d I Appendix A 54 1 three people I ' ll cal l are Donna Cuthb ert , fo l lowed by Mik e Gallag her and then f ollowed by Dr . Fred Winter . Okay, Don na . MS . CUTHBERT : You k now , some of th ese gent leme n speak t o ni ght l i v i ng i n f antasy land . after I heari ng f eel like I ' m For some b ody t o get up h ere a nd ac tually say t hat th ere ' s n o a dv erse i mpacts f rom Li mer i ck n uclear power u nbe li e v a b l e . 1 I r evi ewi ng pe r mi t s p l ant have is s pent insani t y . t he It las t is yea r s p owe r fro m Li mer i c k nu clea r 11 plan t. They are a ma jor a i r p o l l ut e r under the Clean Air Act 1 a nd to s ay t h ey ' r e not do i ng it anymor e , th e y jus t 1 a sked fo r t he cond i t i ons t h at wou l d all ow an ei g h t fo l d inc rease i n dang e rous air po llut i o n that act ua ll y i s 1 1 cla imed t o ki l l peo ple , thou s a nds of deaths pe r ye a r . And t hey asked f or a n e i ght fo ld i ncrease . As a matter of f act , th e se are a ll the a i r 1 p o l lut i on 1 the i r 2 rad i ation own so urces and permi t . If emiss i ons r ad i o n uclides . the poll utants yo u add there ' s a they that b road to list in all t he range of For some b o d y t o just c l aim that i t ' s 2 onl y tr i ti um going into t he water is insanity . 2 unbelievable what they exp ect people It ' s to b elieve . I encourage everybod y to go back to the table we have 2 a nd take a good look at that Schu yl kil l Ri ver board . NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-106 WW'W.nealrgross.com 1-22-AM I Appendix A 55 1 Th e y are d estro y i ng t h e Schuyl kill Ri ver . never enou gh water in th e thi s n uclear we ' re p lan t seeing th e Schuyl kill River to susta in fr o m th e very beginni n g consequences of more and more p ol l ut i on in i t . water in t o suppl e ment c o ntami nated t he f or Wa t er i n c re ase standa rd wh i ch carry a rad i a ti o n year , a l ot o f int o the t hey a nd now put They wa nt to pump mine f ilte r huge , f ou r in t oxi c r i ver that a nd fl ow f or Li meri ck . and they d on ' t act u ally asking The r e was it . And I t' s t hey ' re t i mes Safe Dr i nki ng t o tal diss ol ved p o l l ut a nt s . 24 1-23-SW ho u r s a s o lids So t hey put day, 365 da y s a and now t h ey ' re aski ng f o r these h u ge i ncr eases and people h a v e t h e nerve t o get up he r e and say that t hey h ave no e n v iro nme nt al i mpact s . enough of .l t hi s deception at the Frankly I ' ve had expense of pub l ic T The facts s h ow, when we looked at Ex elon ' s thi ng f o r env i ronme n t al h a rms they say t h ey wer e clean ene r gy . The il thy . facts s how Limerick It ' s not s afe , n uc l ear power , isn ' t c le an , it i t ' s a ticki n g time bomb . they say i t ' s a l ways on . is And Th at ' s not 1-c--:!-:--:~ 1-24-PA I ru e eit her as p eriod s evi d enced by shutdowns , ca u sed by eart h quakes , -Fi res , h ea t always on and in dro u ght Japa n . So and t ornadoes , mo r e . when some you It t ake fo r long h urricanes , clearl y al l of isn ' t this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-107 WW'W.nealrgross.com I Appendix A 56 1 toge ther p o llute and o ur you look at environment all with the ways radiation that and they all the other toxics , every day Limerick operates o ur children face more risk . And that ' s what i t ' s all about . It ' s about the health of o ur region . The o ff place all we ' ll sooner t h is be . if Even closes you the bett er at i nfant l oo k mor t al ity rates we have higher in f ant mortal i ty rat es and neonata l mo r t a l i t y rates far above s t ate averages and even above Phi ladelph i a and Reading , and we ' ve had t hese for qu i te awhi le . t he The fact most vulnerable i n expe c t ? is when babies are t he womb what And by t he way , fo r e l se would we those of you who have bee n sayi ng t h at ACE data is anecdotal news for you . This infa nt t oda y I morta l i ty report example is state data reported by EPA in 2003 . have for Every cancer stati s t ic that you see back there is based on Pennsylva n ia statistics . cancer So increases , nat i onal Registry Cancer average it is s tatistics not anecdotal , those are the have that Limerick started operating . or CDC those are the cancer h a ppened above here the s i nce That is a fact . So it ' s not anecdotal and t h e fact of the matter is I thought this was about the environment but apparently it ' s abo ut money . So I decided that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-108 WW'W.nealrgross.com r-:1--'- ':c5::-_-:-H:-:-H.,-,I 2 Appendix A 57 1 b etween the around a sessio ns l it t le e nv i ronmen t a l it ' s I was go i ng I cou l d bit . impacts o f so b a d . it . cha nge ta lk t h ings abo ut t he th is place f or a whole week And I ' ve got al l o ffic e to prov e to Let ' s t h e d ocumen t s t a lk a b o ut , i n our l et ' s t ake a mi nute now t ho u gh a nd we ' re go i ng to talk a b ou t cost . What i s thi s p la ce act ua lly cost ing us? just t h i n k abou t c ance r f or ex a mp le . a bout c an ce r unt i l We dia g no sed t ha t Chi ld hood c a nce r , h i g he r than t he na t i o na l th a t . time k i ds h a v e tha t tr a c k at it t he cost s ix mo nths of to av er age . one Thi nk child with t wo years was $ 2 . 2 mi ll ion . a bove the nat ion a l Let ' s We h ave s o many c a n ce r s above t he n ati o nal a v e r a g e . 92 . 5 perc ent t he a nd 1-26-HH I up How many mo re ave r a ge? Co s t that o ut and how ma n y o t h er c a n c ers a r e a bove the na tiona l average ? Yo u d o t h e ma t h . How hea r them Limerick . t al k abo u t th e a bo ut how Fig ur e t h a t o u t . custome rs g reat the t hat pa id costs are I for We pa id f or Limeri c k from 1 98 5 t o 2 010 i n 1-.L......--::-~ 1-21-os 1 o u r electri c b i lls . And i n f act the e l ectric that was s uppos ed to b e too cheap t o me t e r t u r n e d o ut t o be 55 p ercent above the nation a l average by 1 997 . So that ' s h ow c h eap Limerick electric is . The n t r i e d to get you ta ke the property t axes . They zero f or th ei r p roperty t a x es by t he e nd NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-109 WW'W.nealrgross.com 1-28-SE I Appendix A 58 1 of the the ' 90s a nd d i dn ' t ea rly 2000s at pa y any p r opert y which time taxes until they paid $3 million 1-:-'=~':="1 1-28-SE I i n s t ead of th e $17 million th ey were supposed to pay . Con'W So when wi ll ing you to think th row communi t y . about a r o und They owe this that a no wonder coupl e Exelon ' s mi l li o n community a in t he l ot mor e than what t hev ' re aivina o u t . (Applause) MS . RUPPE : So t hen t here ' s t he pol luti on t he y ' re put t i ng i n t h e ask i ng f o r disso lved sa l ts . systems a l ot They want river . Th e y ' re They want i ncrea ses i n p o lluti o n . mor e mi n e water i n . t he cost f o r t o put t o i ncr ease the t o t a l Tha t ' s go i n g t o c o st wa te r t reatment mo ney of can to even f or I e qu i pment , some o f the stuff that ' s comi ng o ut o f t he ultimately whe n pays you that th i n k abo ut cost? increased cos ts f or ou r to do that at see ms break down ext ra .....,_......,,.......,,..,...,..,., 4- 10-SW their f or And It try trea tment mi n es . t hat . to We it do . who We a c tually pay for wa t er be cause t he y ' re having the wat er treatment to me that if you s ystems . And it rea ll y take a good l ook a t thi ngs Limer ick has g ot to be the ma j or cause for t he radiation i n Ph ilad elphi a ' s water . So a l l h as u n p recede nted i n all taken as a whole t hi s place e nv ironme nt al h arms . The re is no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-110 WW'W.nealrgross.com Appendix A 59 1 Anybody t h at doesn ' t question a b out that . c o me look at the permits with me exactly what ' s going on . and believe it I 'll show you I i nvi te a n yb o d y to d o that . And t he one t h i ng t hat ' s really impo r tant is that NRC a nd the nuclear i ndus try are claiming that 4-11-08 1 age is no i ssue wh i le at t he same t ime t hey admit that s o me part s are t o o b ig and too expensive t o replace . I f ra nk ly am real ly conce rned abou t the 1 nu clear e nfo rceme n t, It 's i ndu str y wi t h n e g l ig e n ce h a p pened right NRC accommodat i ng wea kened a nd regul atio ns , lax unsubsta ntiated d e n ial s . h ere e v en wi th t h eir fire sa fe t y 1 r egulat ions t hat are -- we ' re o n wea ke ned fire safet y 1 reg ulat ion s eve n though we know eve ntually lead to a meltdown . 1 know my time ' s u p . BARKLEY : Thank yo u, Do nna . Mik e? MR . 1 name ' s license Mike GALLAGHER : Gallagher r enewal 2 r esponsibil i ty 2 application . f or f or Okay, and I 'm Exe lon . t he good evening . vice I have Lime rick presid ent the l i cense My of overa l l renewal Exelo n has a great d ea l of experience in l i cense r enewa l . 2 can (Ap p l a use) FACILITATOR 2 t ha t Th ank you. 1 1 I t ha t We ' ve obtained re n ewed lic e n ses for the Peach Bottom and TMI p l ants i n Pennsylvania , a l so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-111 WW'W.nealrgross.com 4-12-081 Appendix A 68 FACILITATOR 1 BARKLEY : i n spect ion ongoing at t h a t the North Ann a facil ity . earthq ua k e b eyond its We poi nt have an right now regardi ng So yes , i t d id experience an ori g i nal des i g n . So f ar i n spect ions have revea l ed no -- mi ni mal da mage . t he I 've o nl y heard of one p i ece o f equipme nt that exper i e n ced even vi s i bl e a n a l ysis , signs of problems . But t he overa ll this is continu i ng a nd t he l i cen see h as t o have p e rmiss i o n fro m us t o r es t a rt a f ter a n e x t e nsi ve 1 i nspec t ion . MR . ELY : 1 l i cens e r e n ewa l 1 eng i neeri ng My conc e rn i s t ha t t hi s ha stened proc ess reas ons. I a r eas in 1 plant and t her e we re cont i n ual 1 pro v i d ed, whether mon i tori n g of it inapprop r iate work ed d i f f e r e nt t he the is in constru c t ion was condi t i on a v a r iet y of t ha t devi at i on s in- storage of t he for th a t of power were mai nt ena nce compone nts that 1 were us ed to the act ua l constru cti on of th a t p lant . 1 cou l d cite you several exampl es . I What I wou ld l ike to as k of the pub lic is 2 tha t the people that had worked a t take a look at this t hat nuclea r power 2 p lant l icensing renewal and 2 understand t hat they need to review those fail u res and those devi ations that were provided to go a head wi t h 2 the construct i o n of t hat p l a nt with non - con for ma nces NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-112 WW'W.nealrgross.com 21-1-0S I Appendix A 69 1 that were reviewed , b u t we understand and other anomalies . the eval uati on pools . There a r e know today about of what earthquakes or We need to have enough ti me to make on The fue l not reviewed in ligh t those deviati ons . The cooling pool girders t h at are placed there . rebar concrete reinforced supports where a q uality engineer , he was supposed to be accepting t he very highes t grad e o f concr e t e t o be placed i n a 36- hour pour there and he didn ' t 1 cofferdam wa s pay attention . bei ng bui lt down i n t he And t he river and up come s this sand mi x wit h a very low st rengt h and get s 1 p umped up i n t o those fuel pool 1 t he e ng i n ee r mi stake , sa i d well , b oy, but it ' 1 1 be okay . 1 t ake a 1 t hat they ' re g i rders in a l ayer a nd t hat was a t err i ble We need to go back and look at all of tho se mis t akes and make sure not writt en off because a la yer structure under load cau sed by an earthquake , 1 an issue . 1 of 2 that when we see them i n the fue l in a that ' s It might not be a n issue for the strength pool girders t o suppor t those f u e l Japan and they catch pools fire b ecause t hey ' r e ex tremely hot and you need to address 2 that . I was o n that p o ur b u t 2 that made t h at error , that we r e made . 2 I wasn ' t but t h ere ' s And I don ' t the engineer a number of e rro rs see or und erstand that the NRC or th e review or the licensing application is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-113 WW'W.nealrgross.com 21 - 1-0S Cont'd I Appendix A 70 1 t aking a look a t those failures and those errors a nd addressing them in light o f the k nowledge that we have 21-1-0S I Cont'd t oday . Some radiation and I and I oh, the people don ' t understand about read whe n t h e Japa n ese thing occurred heard on the news a radiation is s uch radiologist t alking about a low amount . It rea lly isn ' t th e l ow amount o f rad i ation exposure that we get i n c i dentall y plant . in It ' s standing three next to a nuc lea r t en-t h ou sandt h s of power gram a of pluton i um that is death f or you if you breathe that dust p artic le . It ' s almost certain death . problem becomes you can ' t t o be a nuc lear bo mb. have -- and it ' s And t he not go i ng It' s go i ng to ca t ch on fire if the f uel pool girders were to fa i l and you ' ll have a cloud of a material that in and of itself you might not have radiation exposure to it but that particle when it deposits i tself can be an issue much the same as f l uoride i s what causes thyroid cancer when it ' s a radioactive fluoride . in b ui ld i ng a That ' s why we ' re very careful pl ant wi th no Tefl o n and no f l uor ide components . So we need to pay attention to some of that engineering and I ' m not certain that that ' s being done . I ' d like t o see an agency or for somebody t o NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-114 WW'W.nealrgross.com 21 -2-HH I Appendix A 71 1 contact me if th ey know a b o ut a variet y o f di ff erent flaws that they saw during the construction . email a ddress is asqc hair@ hoo . com. ya Yes , And my I wil l be the chair o f t h e Philadelphia section of the Ame ri can Society f or Quality comi n g up and I ' ve been past chair i n t he past s o yes , I ' m very quality- orient ed a nd I ' d apprec i ate any f eedback f rom people that have issues wit h t hat const r uct i o n . Th ank you . (Ap p lause) FACILITATOR 1 Da n . Okay . Th ank you , Jim Beckerman? MR . BECKERMAN : 1 1 BARKLEY: Jay Beckerman . I 'm a Good even i ng . resi den t of My name is Pho eni xvi l l e . I found out a b o ut this meeting because I s can a l ot of 1 news paper webs ites . 1 on t he West Chester Daily Loca l we bsite . it in the I fo u nd t he not i ce of the meeting Phoenixvi ll e pape r , d i dn ' t Di d n ' t see it f i nd ~~~~ 22- 1-LR I i n the 1 Philadelph i a newsp aper , didn ' t hear about it on any of 1 the 2 cabl e , di dn ' t loca l radio sta t i ons , hear about i t didn ' t hear a b out it on o n any of t h e te levision . Once a month , what i s i t the f irst Tuesday 2 about 2 : 00 I 2 should happen hear the siren th at we all hear . in terms of people gett ing What notice is everybody who ' s wit hi n t h e pl ume a re a should something 2 happen at Li mer i ck shoul d fi nd out about th is meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-115 WW'W.nealrgross.com Appendix A 72 1 and I seriously doubt that th at actually h appened . thi nk it was pure accide nt t h a t I f o und it . I Some thing as serious as license renewa l s h ould get th e same kind of o utreach that occu rs when s hould whi c h is to mail out of t he possibly affected Limerick does what it every year o r t wo t o all homes t he n o tifi cat i o ns of how do y ou eva cuate . maps and 22-2- LR I t he I f you ' re go ing t o renew a plant which happens once every 20 years I don ' t 1 u nderstand why t h e NRC d o esn 't requi re the same k i nd of o ut rea c h p ub l ic notifi ca ti on so peop l e get a chance to come to o ne - time 1 t h i nk that 1 re- licen si ng procedure and I meet ings li ke t h is . I i s a bas i c f l aw i n t he NRC ' s l i censi ng a nd th i n k i t should address t hat . The slide behind me document s exactly t wo 1 1 l i braries that the docume nts are goi ng to go i n . not in my l i brary in Pho e n ixville? Why Why n ot in 1 Montgomery County and No rris t own and a ll of the other 1 public 2 affected by the libraries that plume are in a reas that can should something happe n be here ? Why are the doc u me n ts i n s u c h a r estr i cted a r ea? I 'd 2 2 b een researching , o rgani zat i o n . 2 like I to switch didn ' t e ven Glad t o find it . a l ittle bit . I ' ve know about t h is ACE I ' ve b een researching o n my own information about nuclear power plants and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-116 WW'W.nealrgross.com 22-3-LR I Appendix A 73 1 their risks f o r quite awhile . thi s An organization I b ook across publ i s hed Risk s . The organization is c a lled t he I n stit ute for En ergy and Environment a l well - resea rched book . t it led ran I t ' s a n a maz ingly Research . I r ead it but you should . Ins u r moun t a ble d o ubt very many peop le h ave This organization is a t l east as int erested i n a l ternat ive e nergy s ources as it is in h avi ng pu t the e f fort in to d oc ument what are t he problems with nuclea r p ower engineer i ng - wise . The man who ' s n u clear head sci enti st , of a this is is a g uy named Arj u n M akhi j ani . n u c lear s c ie nt ist . t hi s o rgan iza t i o n a PhD These are f irst-class resear chers , PhD- l evel c onsump ti o n . He ' s So stuff I ' 11 be wri t ten glad to for make po pular mo re detai l about t he book avai l able to anybody who wants to know. A few q ues tions I have , o ne t hat I' ve been thi nk i ng abo u t for a l ong peop le here are awa r e t ime . I wo nder how many of somet hing ca l l ed Anderson Nu clea r Indust ries Indemn ity Ac t . a b out that ? p ause . act? The title alone t he Who knows give sho uld Price you some Why do we need a n ucl ear i ndust r ies i ndemn i ty W t ha cei l i ng of d oes a it do ? few What it does h undred mil l i o n is it pu ts dollars on a the l i a b ility that nu clear power plant owners h ave f or the d amage t he i r p lan ts wo uld ca us e . It 's basically a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-117 WW'W.nealrgross.com 22-4-0S I Appendix A 74 1 s cne me , u1ey pay ln LO c e i l i ng was set a a poo.L . v ery unrealistic in terms o f long Tile prou.Lem lS time ago . It ' s Li laL tot a lly risk in just the value of 22-4-0S th e I Cont'd h ouses i n a r eas that are covered by a p lant When area th is plant that percent its of was plume what th e plan n ed wou l d t he populatio n cover p opulati o n probably i s now . t h i nk a va l id environment al concern . in which t h i s pl a nt in- migrat i o n , reas ons . t erms o f populat ion Part of a va l i d been rout es , the wasn ' t Th at 20 i s I The environment for al l discussed of sor t s of ton i ght in would you be able t o I 22-5-0S get The roads haven ' t the p o pulat i on h as . e nvironmenta l in cha n ged be c ause were there an accide nt . changed very mu ch , i s h as i ncrease that ' s evacua tio n people out operat es lik e this . That I thi nk c o ncern t hat surely o u g h t t o be addressed . The l i a bility is Anderson Act . d oes q u estion not pa y let ' s Th e fact market for the l iabi l i t i es . I jus t ask about go back rates for ins urance This congress i ona l i ndu stry did n ' t to the is t hat the n uclea r b ack in th e 1960s el i mi n ates t h at need . insurance the to money Price indus try cover i t a ct f r om way 22-6-0S Back the n t he have the research to put a pri ce on what shou ld the L imericks of the world have t o pay for a liability p o licy . I t hink th ere ' s plenty NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-118 WW'W.nealrgross.com I Appendix A 1 ~-------------------- 5 I 7~ o f insurance ind us try experience now . So my quest i on would b e if n uclear plants are so safe why do we n eed ~ -=.....,=-"'=""q 2~2- 6-o s Cont'd I the Pr ice Anderson Act ? (Applause) MR . BECKERMAN : switch subjects aga in . I and I h eard s omethi ng I He said t hat I l is t e n ed , l is t ened to Mr . really didn ' t Gallagher e xpect t o hear . th eir studi es said t hat t his pla nt now safe to run for 60 years . advanced I ' m going t o not ice to the is Th at s ounds t o me like publ i c t hat t his is n ' t t he first renewal t h e y ' re go i ng t o ask for o n t h i s plant. Mr . Ga l l aghe r , are you goi ng to ask f or another one 20 years from n ow? FACILITATOR BARKLEY : lic e nsee at this point in We have n ' t t ime as k f or had any s omething beyond th at . MR . statement . BECKERMAN: Yo u to make t he Mr . Ga l lagher did . FACILITATOR BARKLEY : going di d n ' t have him add r ess I t h is know and I ' m not fr om the I audi e nce . would Thi s i s a meeting wi th us . MR . BECKERMAN: And l ik e to finally address an issue t h at the speake r o n t h e cell phone b rought up . He concrete life t ime o v er t he tal ked a bo u t so f ar embr i ttleme n t of the of nuclear NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-119 WW'W.nealrgross.com 22-7-0S I Appendix A 76 1 r eacto r c ontai nment e nv ironmenta l That ' s vesse l . d on ' t I matt er . an know i f in t ern al it ' s q uite i n t h e scop e o f what th e NRC plans t o ta l k a bo ut or pl a n s t o l ook a t , at a l l b ut some thing t ha t is an NRC requireme n t For i n s t ance , if you wa n t I ha v e not 22-7-0S I Con'td r ead about f or d estructive t es ting . t o k now wha t li k e on th e i n s ide you p ut a borehol e a tree l ooks i n it and y ou p u l l a co re sample o u t a nd you f i nd out wha t t h a t tree look s 1 li ke on th e k now wha t pou red is for ins i d e. t he a If q ua li t y r o ad -- I of an t he used 1 nd t h en you t ake a look a t n yt h i ng a b o u t 1 1 ~on e for was Fl o r i da t h e y b o re o u t a sample it . W t ha I haven 't heard gen e ral iza ti ons is has an ybody a n y des tructi ve eve n b oreho l e ha s th ere b e e n 1 onc r e t e , 1 he r e . lvi re , t he all of in r e ba r The stu f f on c r e t e . t est i ng of these fact and a n y de t e rior ati on of t h e an yth ing e l se t hat went that ' s b u r i ed i n the concret e , t h ose thi n gs that are buried in in t he the I f y o u h a v e n ' t bothe r ed t o ope n t h at stu ff s i nce the plant was b ui lt h ow o n earth do yo u know 2 ~p 2 lvhat cond i tion equirement 2 wo r k t hat to on tai nment v es s e ls a nd t heir s u pport pouri ngs t o f i nd put 2 e xc ep t c on cret e to Departme nt o f Tra ns p o r t at i o n 1 eng i neer wa n ts it 's to d o some in? Shoul dn ' t d est ruct i ve , that open t h e be a bottom es t i ng , go all the way t h ro ugh and make s u r e wha t you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-120 WW'W.nealrgross.com 22-8-0S I Appendix A 77 1 thi nk is that there it is what ' s be should t he re l ast i n to and f or in the condit i on another or 20 40 22-a-osl Cont'd years? go t o So t hese are q u es t ions into . Overall I it ' s tha nk been a th ank you f o r 1 much the opport u nity . occur I would li s t en ing . by l i ke to s ee at a bigger venue wi t h more An example wou l d be , as I ' ve di s cussed wi th Ms . Regner is it? FACILITATOR BARKLEY : MR . 1 1 f or and people who have ques ti ons and a mee ting li ke th i s notice . very li ke t he NRC very i n forma ti ve presentat i o n b o t h t he proponent s I y ou that I ' d c or rect. centra l 1 It 1 s 1 t hat ' s Th e to ri ght not cent e r o f BECKERMAN : I Phil ade l phia where the off hard to T h is get 1 FACILITATOR have h er i s for not It ' s this h ard mu ch name be mo re p lant t o is . get t o, in t he mo re Thank you v ery muc h . (Appl a us e) 1 area to . the popu lati on . didn ' t y es . Expo Cent er wo uld p lume 422 . Regner , 2 Mr . Cu thb er t? Aga i n , BARKLEY : Okay , thank you . fol l owing Mr . Cuthbert ' s re marks i t ' l l b e J i m De rr t o wrap u p the even i ng . DR . 2 2 Dr . Lewis Al l i ance 2 thi s CU THBERT : Cuthbert . for a Good I ' m the Cl ean eve ni ng . president Environmen t . e v eni ng are going to di f f er And My of my fro m this name is ACE , the comment s afternoon NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-121 WW'W.nealrgross.com Appendix A 78 1 b ecause t h e y ' re go ing t o b e focusing o n as a g eneral t o pi c docume n ted asserti o ns , We ' ve e vid e nce . heard a lot ass umpt ions and c l aims throughout many of which would be v ery d i fficul t i n o ur exp eri ence . of the day t o s ubs t an ti a t e Based o n a n 1 1 - y ear inves tig at i o n conduct ed by t he Al l iance f or a Cl ean Enviro nment we have f o rmed a conclus i o n that we are pre senting t o the Nuclear Re g ul a t ory Commi ssi o n today and t hat is very simply that Limerick nuclear power closed by t he NRC, no t t hat ' s 1 s u bs tant ia l based on a plant re - l i censed unti l b o dy of 20 4 9 . t erms of d o cument ed e nvironmental harms , 1 ris k s have in fact g o t t en into be And evidenc e 1 that must in threats and ou r ai r , o ur water , our s o il , our f ood , o ur mi l k and o ur children . 1 Th e evi de nce is no t re fu table . So 1 I ' ll be presenting remarks t o n ight wh at I ' m calling a as pa r t my list o f sho r t of 14 1 r easons why the NRC may feel 1 a d equate 2 g o i ng to categor i ze each of them v e ry br ie fly without any j ustifi cation furt he r d en y d escri p ti o n or free t o wi t h mor e than this permit . an a l ys i s . The And I 'm evi d ence 2 comes f rom a variet y of permits , o f ficial records and 2 r e p o r ts , and Exelon ' s own re n ewal a pplicati on whi c h is s i za bl e by th e ir o wn admission and i n o ur experience 2 i n taking a look at it . NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-122 WW'W.nealrgross.com j-,-J~=-=,., 1-29-0R I Appendix A 79 The 14 i tems a ny o f whic h i n our j udgment 1 sho uld b e adequate a nd sufficient t o d eny thi s permit enewa l i nc lude , n umber "ater fr o m rou t in e rad i ation 1, into air and accid ental e mi ssions . a nd 1-30-RW I 1-31-AM I Number 2 , major a i r pol lu tion und er heal t h - based stand ard s of the Cl ea n Air Act . thi s fa c i l i t y A Tit le 5 permit b e i ng issued t o means by d e f initio n maj or air po l lut er under th e Numbe r Schuyl kill 3, that federa l Ri v e r they ar e a Clean Air Act . dep l e t ion a nd ma jor I 1-32-SW d r i nk i ng water c o nt a minatio n . Ke ep i n mind this is a vi t a l for drinki ng people from h ere radi o act i v e radlatl o n wa te r s o u rce to 2 mil l i on Phil ade lphia . Nu mber c o nt ami n ati on . gro u ndwat er repor tl ng n early Number level s lncreased Japa n disast e r . 4 a ramatlCallY 1-34-RW after t he Fukushima Number children since Limerick started operating . I 6, documen t ed a la rmi ng cancer increases e s peciall y i n our deadly h i g h - level I s , 1-33-GW 1-35-HH I Number 7 , radi oactive wastes t hat are packed 1-36-RW I in v u l nerabl e fuel pools on t his si t e a nd t he y are in unprotected . fact unprotected . and mult ipl e leaks fro m The y Numbe r l ax 8, viola t ions . cor rod ing , are a bo ve fire Numb e r ground sa f e t y 9, d eteriorating and r egul a tions accidents e quipme n t 1-37-0S and p lus 1-38-0S mil es o f b uried pipes and cab les . shu tdowns h ave al ready occurred a t Many prob l ems and t hi s fac i l ity in NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-123 WW'W.nealrgross.com I I Appendix A 80 1 its first 26 years of operation . They are a matter of 1 r':-1-: 8-: -3:-::--0::-::8~1 Cont'd record . more Number 10 , freq ue nt increased risk of meltdowns from and stronger earthquakes and other 1-39-o8 1 nat u ral disasters such as tornadoes and fl oods , not t o mention mechanical failures . Number 11 , threats from unguarded terrorist attacks with p lanes and missiles and a new threat , cyber attacks . Fue l pool are 1-40-081 vul nerable to at t ack . Number 12, one that I thi nk probably should jump to the head of t he list for t he NRC bas ed o n a lot of comments from a l o t o f o t her ana l y s ts and elected officia l s , the need f or an updated evacuation pla n and i ncreased EPZ , is seri o us ly observatio ns evacuation Several a 10- mile radius . o utdated . fatally in people the f lawed . eve n t spoke popu l ati on in this is It of by worst that to t his area has many There a This p lan expert ' s wi ll case o bviously needed and comprehens i ve , detailed evenin g . The increased more th an 180 th e y and no scenari o . percent si nce 1980 to 2010 , U. S . Census da ta . are be 1-41-08 1 shou ld be acco mmodate Updates reasonable , al l of the demographics fr om 1 985 to today and from today unti l as far o ut as th e NRC is willing to license this facility . I Number 13 , i ncreased cost to t h e public . 1-42-08 NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 W ASHINGTON , D.C. 20005-3701 A-124 WW'W.nealrgross.com 1 Appendix A 81 1 W ' v e heard a littl e bit a b o ut thi s t h i s e v e ning , more e cancers , mo r e mo r e i l l n esses , h o spit al iz a t ion r ese a r ch on wha t does to human mo r e eme rg e n c y fr o m i n c r eas e d pa r t icula t e ma t t e r b eings . And PM- 1 0 . One case t her e that a re Donn a million f o r a c h ildhood c a n cer case . And n u mbe r 1 W e 14 , h ave had 2 6 years o f and choose I 1 enviro n me n t 1 it wit h t h at a f ew oth e r Th e c o sts a re $2 . 2 You d o t he math . the last i tem o n my list . i nsults to o ur enviro n me n t, wo rd c l ea n , 1 11-42-0S PM- 10 IICont'd ment i one d , p urpo se l y , insul ts a nd c o s t l y n uclear power . sa f e , Ma ssive i n t e rms o f thi ngs that c o ntribute t o tho s e vis i t s . astro no mi c a l . r o om v isits , re n ewable to 1-43-AL We ca n replace e n ergy b e f ore 2 029 . That is a matter o f s c i e n ti f i c fact . It is a 1 1 thr eats and commun i ty 1 1 2 ris ks wi l l sc i e n ti fic certain ty that h a rms , to o ur increase conti n uo u sly and to d a ily o ur unti l Limerick ' s c u r r e nt operating li c enses exp ire in 2 029 . It would be both u n e t h i c a l NRC to the caval i e r l y most a pprov e r i go rous hi s t ory 2 opp o r tuni t y b efore y o u t h a t neve r of thi s r ev i ew 2 2 e n vi ro nment a g ency . are affo rde d . and i r re spon sib l e fo r t he a l i c e n se and re n e wa l j u sti fi cation NRC , you ha v e without in a the rar e most peop l e and a g enc i e s I t ' s ca l led a d o - over , a chan ce t o c or rect a l itany of mi stakes and errors associ a ted NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-125 I o u r 'r-""T""----' WW'W.nealrgross.com I Appendix A 82 1 with t hi s f aci lity and wi th your agen c y s i n ce 1985 . Twent ieth cent ury techn o l ogy a nd infrastructure are no longer sufficient ly reliable for a n y o f yo u t o assure us t h at t here is nothing t o which t o b e con cerned . is no longer addi t i onal evi dence an of a l ong wit h what I ca te gori es t h at you ' ll r eading and did review, Ex elon ' s no thi ng We ' ll research comp l iment 1 a nd about De n ial of d ocument e d evidence o pt ion . packet s tonigh t fear sub mit ting d o cume nt ation my comments earl i er be be me ltdown whi c h f or will The t oday . get ti ng and ma jor a dditiona l thr eats , eva cuati on 1 pla n s , inacc u rat e a nd un substan ti ated c lai ms 1 and a cri t i cism o f the NRC ' s o vers i g ht t rac k record i n t h i s c ommu n i ty . 1 Th ank y o u very mu ch and please accept thi s for review . (Appl a us e) 1 FACILI TATOR BARKLEY: 1 will . Th an k you . MR . 1 2 wou ld add und e rst and ing i s t h a nk yo u , I I t ho u ght I s ure my Mr . De r r ? DERR : some Okay, Good co mments t hat t h is eve ning . just is to make e ss ent ially the NRC ' s 2 opportuni ty of liste ni ng f or things specifically to be 2 i n clud ed in the environme n tal site review of the rel i censi ng . 2 And j ust a few thing s whi c h are question marks that l ots o f f ol ks in t he community I think will NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-126 WW'W.nealrgross.com Appendix A 83 1 b e interested in . Most o f these have b een touched on . Mine q u ality and wat er issue , b etter d efining fl ow particul arly i n light o f that t he likely pending c h anges in stormwater concerns and regulations 23- 1-8VV i n t h e area . Ad ding th at f low t o t h e Schuylkil l goi ng t o a f fect I is a ll t he mun i c ipal it ies around h ere who have t o d eal with sto r mwa t er . The needs to be emergency p l a nni n g ser i o usly l oo ked is an area whi ch a t. Hard Hopefull y and t ha t ' s soft 1 23-2-08 i nfras t ru c tu re whi c h is part on t hat . s ome t hi ng I of t he o ngoing o perat ional require men t s for pe riodic revi ew and u pdate si nce obvi o usly t his is not a stat i c environment we l i ve i n . And then t o -- I ' m sur e changed on a n o ngoi ng bas i s . hat the gener i c pla n Th at h as t o be i ncl ude s a pretty good 23-3-o8 1 ::li scussion ::ms i t e of but fuel c e rta i n ly the onsiderat i ons . Mr . Ely o f anything sto rage constructio n site- spec i fic shor t - te rm f u el storage And I want t o seco nd the comments by review o f that l ong - te rm a nd was record s done record . of non - con f ormances and is part And basical l y of the that ' s i n i tial those are the things t hat we ' re going to be looking f or a b etter understa ndi ng o f . Thank you . (Applause) FACILITATOR BARKLEY : I did h ave o ne l ast NEAL R. GROSS COURT REPORTERS AND TRA NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON , D.C. 20005-3701 A-127 WW'W.nealrgross.com 23-4-08 1 Appendix A 84 1 req ues t for she ' l l an indi vid ual o nly b e to s p eak . MS . CONFER : Thank you . Hi , my n a me is Traci Con f er . I ' m with Energy Justice Netwo rk . e nergy whi c h we do n o t to p ro mis es two minu tes so we ' ll have h er u p and then we ' ll wrap up the meet i ng . li ke Sh e put our name We s upport believe n u c l ear is . behind a l l of I clean would Buzz Cu thbe r t ' s o mments and I wan t to add t hat I want t h e NRC t o look nt o potenti a l 1 from s h ale gas 24- 1-SW I water depleti on issues rac ki ng upriver i n both r i vers . would be very prudent t o put a I als o thi n k t hat it lot of att ention on 24-2-0S I 1 t errori st attacks o n t he f u e l poo ls . 1 pri ma ry c omment s . And tho se are my Th ank you f o r yo ur time . (Ap p lause) FACILI TATOR 1 1 BARKLEY : Okay , t han k you . W h t hat I'd like t o have Lisa Regner come up f o r it a mi nute and give clos ing remarks . MS . REGNER : 1 1 thank 2 t on i ght out of the good ness of her heart . She do es not g e t sta nding 2 our senior I j us t wanted t o real quickly pa id for this . Jo , i nspector who would you mi nd came out up? (Applause ) 2 M . S 2 res id e n t REGNER : Than k you . Th is is one of the NRC inspectors wh o works at the plant d a y in and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 A-128 WW'W.nealrgross.com Appendix A Mendiola, Doris From: Sent: To: Subject: Camilla Lange [camillange@verizon.net] Monday, September 26, 2011 2:20 AM Regner, Lisa NRC Public Meeting Feedback .g)/le/cfbJ// %rJ<_J3f-1 g-- (j) Dear Ms. Regner: I attended the NRC Limerick Generating Station License Renewal public meeting at Sunnybrook Ballroom on 9/22/11 . I listened attentively to comments from all 15 speakers at the evening session and took into account all the pro and con arguments presented. Despite all the reassurances from Exelon representatives about the safety and efficacy of the generating station's nuclear power, I have serious reservations and concerns about these issues. First of all, considering the impact of the outcome to the many area residents, this forum was not widely publicized for local citizens to be aware of this important matter and offer feedback. Secondly, it does not make sense that Exelon is pursuing renewal for a license that does not expire until 2024. This action seem ve remature. I will briefly summarize my chief concerns. consum 1on eman s. _ _ 25 5 ts Thank you for arranging the public meetings to discuss this serious matter. I trust you will take my AI into consideration and urge Exelon to provide other such forums with widespread notification beforehand so that more interested citizens can participate. Sincerely, Camilla Lange 616 W. Schuylkill Road Apt. 164 Pottstown, PA 19465 camilla nge@verizon. net :=1 ' :oJ ! I . ? ?--? .~ ---.. :l 0 ~){F s = :V c ,v. "' ?. J ) ~ " ? ' :. -?? c~ 9 0 ?- .. q -- f" ~ < rn (/) .,!::: /T'l:;d-f-o3 ~ =oX/f~ ~e~ A-129 Appendix A Mendiola, Doris From: Sent: To: Subj ect: Eric Hamell [stripey7@yahoo.com] Wednesday, September 21 , 2011 7:38AM Regner, Lisa Limerick Follow Up Flag: Flag Status: Follow up Flagged Please do NOT extend the Limerick licenses! 126-1-0R Eric Hamel! Philadelphia, PA I <6'jd&/~/f /ZF/f. 6-9?-J f" C0 . ... e ?? - JJ .-.l .-,I -" --;TI ! CJ .., o?I o .) 1- r i? o: .. -.;??: : c- :?-:.:: 9 0 ....::. . - ' - j .?._ ~ < rn (/) ..!:: ?-,;L.z::-:Os ~ /9,!).r-7-o 3 ~ = ;;(.i!}~ 0-t*-) A-130 Appendix A Mendiola, Doris From: Sent: To: Subject: steve furber [ctevewrx@yahoo.com] Tuesday, September 20, 2011 4:17 PM Regner, Lisa Limerack Renewal Follow Up Flag: Flag Status: Follow up Flagged ij&~;~ /,/ ')t??.5:3~ yr/ @ Kenewmg Ltmencl<'s license JUSt as controversies are ansmg w1th pushes to move trom dependence on Nuclear ~7_::2? 1 energy is a bold business strategy by them. I don't think this is the right move to make. A long term contract ~ will limit any sort of wiggle room to address future issues that may arise. ? I ask that you please consider the future of our great state. I don't think oil or nuclear energy is the way. I truly believe in heart, that in order to protect the health of our population for the future, we must change our ways today. Sincerely, Steven Furber JJ ~ il: -... r?t -;??n ~- CJ ~-/{!-~ s = :_1:1 c: r;-q o> :..g ??..) o- (r) .. ~? :."??. .:'1; ' '-~ ~,; 9 a ~ \ hl c: --i ~ (/) .!::: /7 o H-o 6 ~ =C;zfi}~(!-He~ A-131 Appendix A Page I of I R LES .:.J ;/ iECTIVES U ~~?-; :..-..~C:H PUBLIC SUBMISSION: ~-:~ 71 c; a= ll7 ~;-?.~.---1\ 'i As of: September 27, 2011 Received: September 22, 2011 Status: Pending_Post Tracking No. 80f27eee Comments Due: October 28, 2011 Submission Type: Web 0 Docket: NRC-2011-0166 ,-,, - , ? ? I .. ,!Notice of Receipt and Availability of Application for Renewal of Limerick Generating Station, Units I and 2 Facility Operating License Comment On: NRC-2011-0166-0003 Exelon Generation Company, LLC; Notice of Intent to Prepare an Environmental Impact Statement and Conduct the Scoping Process for Limerick Generating Station, Units 1 and 2 Document: NRC-2011-0166-DRAFT-0002 Comment on FR Doc # 2011-21921 ,2)::u,J:V /f Submitter Information 7C.r/L6-5 7-:JF:' 0 Name: Charlene Padwomy Address: Ill 7 Oakdale Dr Pottstown, pennsyvania, 19464-2782 General Comment Thanks so much, Charlene Padworny _?-;/{'_.;::: _})5 =- ,&.!::>~'--1 -c:? 3 ~;;//)~f-At.r2.:z.) https :1/fdms.erulemaking.net/fdms-web-agencyIcomponent/contentstrearner?objectld=0900006480f27ee... 09/27/20 II A-132 Appendix A ?) ;rt ,:;) .. -?, :?o,) c:.- ~U.S.NRC ...-- .......... Unired Scares Nucle..... Literaturefte(:9p.d sear6h. wcf~9.in&col0red 'maPli. , ' ' .,. ? ;;" o? ., ?' ? } ; -o Pictures ofthe!$'iie . ? ? . ? ? ? ? ?o?? ? ? .?. ? . ???, . ...... Any rep,ort~ ?.fh.~ ?~,tate. Htstoric PreseFVation .Office m~y ,haVe~:: . _ _Has the,site;been prev~{)usJy disturbed ? . .. . ? ? ?, \ Review fee !I!:USt-be?included with letter <">Jj' . If site has beeirpreviously disturbed please explain what the us. ~~s :ari~C~hen it was e . . ,... . .??- . ..., dtsturbed. :. ? ,, .? . _ , '? ,.. :? ,. : Other colll11fel)ts..or information needed - ------~-~--~~~--- ~-~~;::~~ : . ?1 . . ~ After reviewi!lg..your?ietter we fmd that: .).~. "t.,. .~il . : . .: :~~ "No P..f.Gp~ies!' -meTribe concurs with a Federal agen<;Y'S ~di~ ~t there are 132-1-HA no National R~&ist~r cli~~ble or listed properties within the f,ederidi:?m~~rtlfking's area of potential effe~t or APE.3q.CFR ,800.4 (d) (1) '? ? o .. . ? ..., _y I :.:; i 1. : ? "No Ef.l~ct" his~oric.or :prehistoric.properties arc::_ pj-esentbut th.e,$.e4eral underta~ing ~~l:f,!t~~~'~o effect on the Natio11al Rc::gi~ter ~1igi,91:C or\i$:te.~,pr~~erties as defined ll:l-,$~d?800, 1 ?6(t.) ? .. ? ? .?.: . ? -. . ,r?o. i' . '. "' '.'? ___''Nd Adverse Effect" ref~,~. written opinioris pp:>~ded to a Federai''a gency as to whether or notlthe Tribe agrees with (or believes-that-there should be) a Federal agency finding that its:Federal undertaking would have ~'No Adverse Effect" 36 CFR 800.5(b) 6ovs .z: IJe-f;~ ~~ tf7~.e.2i = rJ11-1-t!J/3 A-137 - ~ -~.r])S ~ =/3-l)t--1-0 3 =-c/ 1]~&-~1?__-2-) Appendix A U.S. NUCLEAR REGULATORY COMMISSION ,--~~;~~~~-.. ]. '??? NRC Meeting Date: .. - 09/22/2011 . _....!,._.:,_ ,_ ..... .. ...- . .....:-- . I ~L---~?-??- . -- 1? p~~,uc MEETING FEEDBACK ?M~eiing - Li~-eric~ G;~~~rating Station License Renewal Overview and Environmental Title: Scoping Comments Public Meeting - ?- ?-?? ? -- -. .... . _ _ _ _ _ _ ____ _ _ _ _ _ _ _ __ ? - - ......_ _ _ _ __ _ _ __ In order to better serve tile public, we need to hear from the meeting participants. Please take a few minutes to fill out this feedback form and return it to NRC. How did you hear about this ~eetinq? 1. [ l LJ NRC Mailing List D Other NRC Web Page [ ] RadiofTY No Somewhat r'Piease explain below) X!?_ 2. Were you able to find supporting information prior to the meeting? I i 3. Did the meeting achieve its stated purpose? - [~ 4. Has ttiis meeting helped you wiih your understanding of the to_ ic? ? p [J 0 5. Were the meeting starting time, duration, and location reasonably _ G()nvenient? --.k, _ ,-_,- _ ,_ .?.. ; ~?-t.: ... : .. Were you given sufficient opportunity to ask questions or express your views? [] [J [] [_] [J i -] 7. .; o? .,,??" ~ ~.- 6. 1.1 [i6 Are you satisfied O>Jerall with the N_Ry staff who participated inthe meeting? - '.. - -~ ~ ' ?, - _ '-- Continue Comments on the reverse. r.:> OPTIONAL Organization Name Telephone No. - E-Mail <'-~~~-{-- ______ _ ----- Q --~c,:> - C -~ -- - Check here if you would like s - --- - .------ -- -------- - ----- .... -- - ... --... memberofNRCstafftocontactyou Expires: 0813112012 OMS NO. 3150-0197 Public Prote:tion Notification: If a means used to impose an information collection does not display e curr$nlly v&lid OMS control number. the NRC rNlY not conduct 0t sPQr,sor. and a person i!. nol required to tespond 10. the information colledion. Please fold on the dotted lines with Business Reply side out, tape the bottom, and mail back to the NRC. A-138 Appendix A tr . . .. Mendiola, Doris FW: Response from "Comment on NRC Documents" Subject: y-pc., )4!J1/ -----Original Message----From: Richard Kolsch !mailto:Rklsch@aol.coml 7'~ Sent: Thursday, September 22, 2011 5:44PM To: INFOCOLLECTS Resource Subject: Response from "Comment on NRC Documents" @ /'/ /.,!( ~3~/'0 =o :_-, ?' il / (} l '") -- :......_ .--n CJ -, (.'..: ?- o ~ "J ; N r I Richard Kelsch (Rklsch@aol.com) on Thursday, September 22, 2011 at 17:44:25 ;-n - ?1 -,.-, Below is the result of your feedback form. It was submitted by :r.J c: ,-- ?:-, ' ~~ :.::, 2;~ L:-~ '9 -I < rn ..r::: (/) N Document_Title: License Renewal Limerick PA Comments: Comments on Limerick Power Plant License Renewal Limerick, PA September 22, 2011 1. Why is there a rush to renew the license? It is not due 34-1 until 2024, approval at the earliest should be 2019. This would allow 5 years for the business plan of PECO to -LR either continue or close the plant and make arrangements for additional power to replace the closed plant. 34-2-DCI 2. A firm closure plan should be approved before license renewa 1 is accepted. This plan must include what is to be done with the site, where the nuclear waste will be disposed of etc. The site like the now defunct Yucca site. The public and our future RW generation deserves to know what is expected to be done at the site. Radioactive material must not be allowed to remain on the site. 3. The government should conduct a survey of various illness in the vicinity of the nuclear plant prior to an 34-4-HH renewal of a license. If this would indicate a danger living near the plant then the license should not be renewed. 4. Developers are required to fund traffic improvements to an area to allow an area to be developed, this 1 should apply to Limerick. The evacuation plan now will not work. When the plant 1 34-5-0S was started there was no traffic out here, now it is grid lock. Limerick should fund new roads and bridge to alleviate traffic ?ams in order to have an orderly evacuation. I 5. The plant is vulnerable to terrorist attacks. An airport is located next to the facility. A plane could be flown into the reactor building or the emergency power supply for the water circulation system at the same time terrorist could cut all outside power to the plant this would cause a meltdown and render the entire area around and downwind of the area uninhabitable for hundreds ofyears. ;J A organization: None ,? 2J 5 -Q" address1 : 1694 Kepler Rd. 6 .:=- ,!&ZJ.)..t-.?! 3 ~ ;::: ;/- /]7J--T ~,()~ address2: ? c) ,-1/S f ; f ? / l h / / 'l~ ~ p-7) J--t _. L) I :3 A-139 c~,e;<__) Appendix A f/c9~I 6UJI I 7'~ r-,.e .:5-a? ~7 September 24, 20 I I 2461 E. High St.,tJnit F-lB Pottstown PA 19464 0) USNRC Mailstop: TWB-05-BOI M Washington DC 20555 USNRC Lisa Regner: We wish to add our comments to the NRC record. We attended one of the NRC hearings concerning Limerick's Environmental Impact (9/22/ 11 at 2:00 p.m.) and were appalled that local business and community leaders avoided voicing concerns about Limerick's environmental impact, mentioning its economic influence, instead. That doesn't mean that those speakers had no concerns. The NRC would be remiss to consider a "thank you for money and jobs" as part of its evaluation of community-wide nuclear safety issues connected with Limerick's re-licensing request. . . . . . be addressed. Re-licensing should not even be a consideration! The NRC must fully investigate the r::-::-:::-:::c=-, environmental concerns presented Dr. Lewis and Donna Cuthbert (ACE), Dr. Winter, and each resident 1 35-7 -OR who so civilly represented this community's concerns at the September 22, 20 II hearings. The Limerick Nuclear Power Plant should NOT be re-licensed and should, instead, begin to address the pollution issues i has already created as it seriously and carefully shuts down its reactors. Sin~erely, ~ll'rd~tfl~ Charles and Elizabeth Shank (610-323-6715) . .. = ..; : .. .. ~ ?<(. ~ . o ,~ o 1?: o. : o: - o : :r o :o . o ?.:n "???? ? ??PtfV.---:JJs- ?/JJJH-0 3 . ?o ??: ~:~,'X:/5~ (!-u~_z) A-140 Appendix A "7] ?;l Mendiola, Doris From: Sent: To: Subject: naturalcat@comcast. net Wednesday, October 12, 2011 5:26 PM Regner, Lisa NRC 10 DOCKET 2011-0166 ----' 1-! .. .-- :?n CJ ~ ?~ .:;::1 c:: r.... !-;? : o...) - C.F ; w ~ -? I ; l~';~ ~~. ':9 9 < ,,, Vl (/) vJ '? jc:;.-& /4? I I %r~03-f7f' G) 6v>>Sr. IJe ;!;~ ~~~ ?-/(_.J:~s:::. /7-2:;.1'--7'-CJ 3 ~ -==-~ /J~&r~) ~~ --===pf) ;..,'-c/13 A-141 Appendix A ... . -o ~~~~// 7't rJ<:. sa.t/-7' r? Mendiola, Doris From: Sent: To: Cc: Subject: :..:~~ TJ ?- ? , ~ rTI Cynthia Gale [cgale@barbergale.com] Wednesday, October 12, 2011 4 :31 PM :l Regner, Lisa Michael Gale DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERJOD..::::::. I . \..?.) 1 _ (/) . : J :-- ~ ..... . . .? .. ,_ _ "':9 CJ Vl w Dear Ms. Regner, On behalf of my family, friends, and neighbors, please do not relicense the Limerick Nuclear Power Plant. We work in Pottstown, live in Elverson, and our young daughter goes to school in Kimberton. All these locations are in harm's way of Limerick. Every day when I drop our child off at school I have a view of the Limerick towers when I travel on Route 724. I pray everyday that nothing happens when our daughter is at school. We no longer feel safe or even drink our tap water, do you? Limerick Nuclear Plant's License Expires In 2029 - Exelon Wants To Run It Until 2049 Threats and Harms, Already Unacceptable After 26 Years, Are Increasing! Since 1985. Unprecedented Environmental Harms. Threats. and Risks From Limerick Include: I 1. Radiation Into Air and Water From Routine and Accidental Emissions 137 -1-RW 2. Major Air Pollution Under Health Based Standards of the Clean Air Act 137 -2-AM 3. Schuylkill River Depletion and Major Drinking Water Contamination 4. Radioactive Groundwater Contaminationl37-5-GWI 5. Radiation Reporting Levels Increased Dramatically After Japan Disasteri37-6-0S I 6. Alarming Cancer Increases, Especially In Children, Since Limerick Started Operatinq37-7-HHI 7. Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On Site 1 37-8-RW 1 8. Lax Fire Safety Regulations i37-9-0S I 9. Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles of Buried Pipes and Cable 10. 11 . Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaste 37- 11 -PA Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacksl37 -12-0S I 12. Need for an Updated Evacuation Plan and Increased EP~37- 13-0S I 37 -3-SW; 37-4-GW 13. Increased Costs to the Public- More Cancers and Other Costly Illnesses, More Emergency Room Visits 37-14-HH I and Hospitalizations from Massive Increases in PM-10 and TDS, Treatment of Public Drinking Water, 1 Environmental Clean-Up 14. Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replaced::-::--:-:--, r:;::;;.;;; 37-15-AL I With Safe, Clean, Renewable Energy. 1 List Compiled By The Alliance For A Clean Environment- September 2011 5v..vs-'- If-e-n~~~ 17~= IT:vH-t::?/3 ~-XJ:;-?Js = /7-Z>N - .?3 ~==-x .!f~0~R...z) A-142 Appendix A 8jc7(p /?>> 1/ :n .Tl %r;e~3~ ,..-1 ..., (.' ?~ ? /'&r/(_JUfi Via email: Lisa.Regner@NRC.gov U.S. NRC Ms. Lisa Regner Mailstop TWB-05-801 M Washington, D.C. 20555 Reference: ._ , 0 Request for Denial of Limerick License Renewal - NRC I. D. Docket 2011-Q166 Dear Ms. Regner: attended the recent meeting on the possible renewal of LimencK Nuclear Plant's license for 20 years past 1ts currerif 024 and 2029 expiration dates. I strongly believe, as do many of my local friends and family, that the Limerick Nuclear Plant must be closed, not relicensed. Approving Limerick Nuclear Plant to be relicensed until 2049 would be jeopardizing he health of thousands and thousands of people in neighboring communities. There is substantial evidence readilv 140-1-0R vailable which justifies closing Limerick. Renewing this license could lead to a catastrophic meltdown. I Limerick was built to last 40 years. The older any facility gets, the more liKely breakdowns and equipment failure will occur. When it's a nuclear power plant, meltdown could result from corroding, deteriorating, and aging pipes, cables, and equipment - honestly, a number of things. Miles of deteriorating underground buried pipes and cables are a major concern - how and how often are these inspected? Signs of mechanical damage and breakdown already exist three unplanned shutdowns June 2011 , preceded by many others since 2007, one with loss of cooling water. While some parts can be replaced, by the nuclear industry's own admission, some equipment is too big and expensive to replace. Limerick is showing signs of stress and no one knows just how bad this will be by the time the current license is up. To add 20 more years to that, without having a clue as to what the condition will be, would be beyond careless. _ _ 140 2 08 I Over eight million people live within 50 miles of Limerick Nuclear Plant. Safe evacuation is not possible, even within the seriously flawed and inadequate current 10-mile evacuation plan. Until Limerick closes, NRC should expand the evacuation plan (to 50 miles) and be sure there are enough shelters and supplies available to accommodate the ov,.,_~ 87-~:--o e r~ million people within that radius. Exelon should pay for the supplies. 40-3-0S It doesn't take an accident or disaster for Limerick to poison the region's residents w1th ra 1alion. a 1 1on rom a Limerick's routine and accidental emissions alone for the past 26 years is reason enough to deny Exelon's request. It's not credible for NRC to claim continuous radiation levels are safe for me and my family when there is no safe level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility. NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP cannot be trusted. Exposure to radiation is known to cause cancer. It should be obvious to NRC that Limerick played a major role in our tragic, well documented cancer crisis after LimericK started operating in the mid 198.0s to the late 1990s. Four cancer studies based on PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far higher than national and state averages, especially in children. Our ch ildren had the highest levels of Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant released SR-90 into our '"'4:-:0:-_-:-4-:-H-:+-.H,.., air and water that got into the milk, vegetation, and food since Limerick started operating. ' -dJ.3 ~ A-146 Appendix A . hyroid cancer increased by 128% from 1985 to 1997 - was a side note, with no family history or other obvious risk actors in my life, I was recently treated for thyroid cancer. Since my diagnosis, I have learned of many other locals like 40-5-HH e. It's sea to think the choice of where we live could kill us. It would be careless, unethical ? and immoral for NRC to approve Exelon's requested Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. Sincerely, Melissa Antrim 1008 Reading Ave Boyertown, PA 19512 The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer. A-147 Appendix A ' g).u)~l/ ...... ./t r .;t c; -:3-"'-'7 f' Mendiola, Doris (ii) J(j J:J "' ' 9 e!. ----------~-------------------------------------------------~~~) .~~~------~~,------- f~ r p From: Michael Antrim [antrim89@gmail.com] Sen.?t: T0 Subject: Friday, October 14,2011 2:35PM ~~~ Limerick- NRC I. D. Docket 2011-0166 -1 -::::::: D ?~~-l~? ::;?. ~ iTi Reference: ~ Request for Denial of Limerick License Renewal - NRC I.D. Docket 2011-01-66 Dear Ms. Regner: ~he possible renewal of Limerick Nuclear Plant's license for 20 years past its current 2024 and 2029 expiration dates more than 12 years ahead of time, worries me a great deal. It's hard to understand why something this major would be ~one so far in advance. It's IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth ~ould this be renewed so early? It's a lengthy process that could begin earlier, but in no way should something this mportant be rushed through now. Why not wait until closer to the expiration dates, and then seek approval? I ~nderstand this is how the original guidelines were set up - but those are long outdated. Approving Limerick Nuclear Plant to be relicensed until 2049 would be jeopardizing the health of millions. Renewing this license could be catastroohic o millions. Someone has to speak up; someone has to step up. 1 41-1-LR Earthquakes and other natural disasters are more frequent and stronger than ever before. Limerick is 3rd on the earthquake risk list. Underground pipes and cables can shake and break, which would lead to loss of power, loss of cooling water, and meltdown. Limerick's substandard containment flaw means more radiation would be released. It is simply too dangerous to keep limerick operating. Would you want to live within miles of this potential catastrophic disaster? Add the enormous population growth that this area has seen over the past 10 years - with little to no road improvements - and attempting to evacuate the area during a disaster would be futile . It would be virtually impossible to get out of harms way. 1 1-2-0S 4 The older any facility gets, the more likely breakdowns and equipment failure will occur. Limerick was built to last 40 years. Limerick is showing signs of stress and no one knows just how bad this will be by the time the current license is up. To add 20 more years to that, without possibly knowing what the condition will be, would be careless. No one can predict what the condition of Limerick will be in 2024 or 2029. Over eight million people live within 50 miles of Limerick Nuclear Plant. Safe evacuation is not an ootion. Plain and simole . That's a scarv thouaht for those of us who live here!! hey could monitor themselves. It should be obvious to NRC that Limerick played a major role in our cancer crisis after Limerick started operating in the mid 1980s to 2000. Four cancer studies based on Pennsylvania Cancer Registry and the CDC showed skyrocketing rates for several cancers much higher than national and state averages, especially in children - innocent children. Thyroid cancer increased by 128% from 1985 to 1997. I have local friends and family with thyroid cancer and brain ancer- not one, but several. Sadly, it's no longer uncommon in this area to have a personal link to ancer. However, it IS uncommon in other areas of the country. It used to be uncommon here too prior to Limerick. Would YOU want to live here? Would YOU approve a license renewal so close to home? Your job is to safely review the facts. Don't like the money of these corporations ~~~-!----. acts. Thank you for your time today. Just remember, it would be careless, unethical and immoral for NRC to approve ' requested license extensions for Limerick Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. 41-4-0R . Sincerely, SUVSI o ? ~*:J)S-= /'-- lfe-//~~&..4::. 8D/-/-c3 ~-=~ 4~ c~~;;j ~ = A~-P./3 A-148 I I Appendix A Mendiola, Doris From: Sent: To: Subject: Dear Ms. Regner: joanmcglone@comcast.net Sunday,October16, 201110:11 PM Regner, Lisa Limerick License Renewal re: Limerick License Renewal- NRC I.D. Docket 2011-0166 I am opposed to the license renewal of the Limerick nuclear plant which was designed to safely . 1(2-1operate for 30 yrs. and should now be safely ,1>hut down. Statistics regarding nuclear accidents at OS similar aging structures are well documented. Those two towers are ticking timebombs and the NK~ knows this and needs to shut them down. Following the Japanese nuclear disaster our Limerick nuclear plant hit the statistical at risk list aaain. The increased risk of cancer is well-founded in the H literature also. Why does the NRC think they can play God with people's lives? It is no longer debatable, shut it down before our very lives are jeopardized!!! I ~ So-called quality of life issues addressed as part of public debate, e.g. "the power is always on"I42-3-0R I seems irrelevant to us when our families are required to evacuate during a disaster. Limerick must be closed and NOT relicensed at any cost, specifically the cost of life itself! Sincerely, Joan McGlone Resident of Royersford borough JJ -n \ r--l ~~ C:> c-> -i .) -(l -....J .-' --;:) ---- i?-n I~ :::3.: -!'? UJ :-:tJ :!~"': ?~~~ 0 --1 < rn (f) 00 A-149 :::0 c:: r ?- rr1 Appendix A ... .. ..... o? .l.?....:. o . /J.TAile . ;t;;;.;;~;;f~ ~rn ~1' -r w ?3 .-{) s - 13 6 1 ~'~ 1/t-I~J ;J e ,;2. o s- s- s j, o olllo 1 o lo j, 1 j, j, ,j, j00 0 11 ,j I o J 1~ 1 jl i ~ \~~ ~ }~ '-) ~ ''1:> ~ ~~ - r;i J H I( ?~ ~ - l1 -..> <:. ~ ~ ~ ~ ~?"" 1 ~~ "-5 ~ ~ ~ ' ~ ~ ~ I43-1-0R \ A-150 ????. ... .:. _...~ ...........;"..:_ . Appendix A Mendiola, Doris Subject: Attachments: FW: *Limerick License Renewal-NRC I. D. Docket 2011-0166 Limerick.odt -----Original Message----From: Angelbosley To: Lisa.Regner Cc: AngeiBosley Sent: Sun, Oct 23, 2011 12:48 pm Subject: *Limerick License Renewal-NRC I. D. Docket 2011-0166 Lisa Regner: Hello, I am attaching a letter to you regarding Limerick Power Plant trying to Re-license until 2049. Please read it. Thank you for your time and attention. Sincerely, Lisa Smoyer 1027 Farmington Ave. Pottstown PA 19464 484-945-0246 ~t)o~-i?// Ji ~;{ 63~ 9f" 6 ~-. -~ :::0 c r? ::D IT1 l........ l .- o,) - ) ;-.) .i -: ?--:::;;: --. ?-\l ?::J ~-;{J::Ds == --l u~ r---:-.:: ... J? .. ? .r::: ~ '9 V1 co /h.tY'-o 3 ~:; X/f~ (/-A-1/{L) A-151 Appendix A Sunday, October 23, 2011 Lisa Regner, License Renewal Mail stop TWB-05-BO I M Washington DC 20555 Lisa.Regner@NRC.gov *Limerick License Renewal-NRC l.D. Docket 2011-0166 Dear NRC/Lisa Regner: I was unable to attend the public hearing at the time that is occurred. I would like to voice my concern to all of you through this letter. There are so many reasons why you as a group should already know that it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, wildlife in general and the environment for you to refuse/oppose Limerick Power Plant from re-licensing. The problem that always seems to come up at some of these public hearings and sessions where businesses/corporations want to expand and become bigger and run their businesses long past the time that they should truly be allowed in order to keep people safe, always comes back to the issue of money, offerings, bribes, donations, etc. in the end. When these things occur, people and businesses tum a "blind eye" so to speak to the dangers of allowing a business like the Limerick Power Plant to renew its license again. That is unacceptable! I expect and demand better service from you tn h Pln protect myself and my family from harm! 1 44-1-0R There is no "independent" testing being done at Limerick. The results of testmg are provtded by thetr own company, who has a vested interest in the outcome of those results, so how could you ever believe that they would be honest about the results? Seriously?? 1 44-2-0S I I There is concern that should be faced regarding the Schuylkill Rtver and the atlects it ts gomg to have 44-3on the public if it becomes depleted and/or toxic due to the contaminates going in it. It is disgusting and heart wrenchmg to know that ofilctals and orgamzatwns are not paymg attentwn to what can happen to the public if Limerick Power Plant continues to operate longer then expected. Ignoring the obvious problems our community is facing and hoping that after they serve their term, it will be someone else s problem to deal with is unacceptable. Now is the time. Step up and do what is morally right for humanity. 144-4-0RI sw We as a society need to wake up and start paying attention to the massive harm power plants can cause to the people, animals, water, air, etc. Why does everyone want to pay attention when it is way too late?? There are safer alternative forms of energy available to our country/communities. We should be working on them and training employees, who currently work for the nuclear power plants how to work with safer forms of energy to help our country move forward in today's society. 144-5-A L I Haven't we already seen some of the damage that a terrorist attack can cause for our country and for ~ others? Do you really need to risk more possible attacks on a power plant that is not fully equipped for 44-6 hat kind of attack or for some other natural disasters that can occur. This plant is not prepared for -PA !tacks with planes missiles and other threats such as a cyber attack. There should also be a concern .--or accidents and leaks from corroding and deteriorating equipment at the site from over the years 144-7-0 S A-152 I Appendix A (Page 2 of3) which could cause parts of it to be shut down for periods of time, as well as the miles of buried pipes 44-7and cables. There are many concerns that should be fully looked at and considered, and just with OS minimal thought to them, it shouldn't take a "rocket scientists" so to speak to figure out that it is not in Cont'd the best interest of the public or environment to allow them tore-license. he most alarming and compelling thing to me as a taxpayer, homeowner, and mother is the verwhelming and alarming cancer increases to the public after Limerick had started operating. The DC website showed a 92.5% higher than the national average for childhood cancer in six ommunities close to the Limerick Nuclear Plant which included, Pottstown, West Pottsgrove, Lower ottsgrove, Upper Pottsgrove, North Coventry, and Douglass Berks Township from cancers diagnosed om 1995-1999. The Pennsylvania State Cancer Registry For Montgomery County- from 1985-86 to 996-97 also shows cancer rates skyrocketed in Montgomery County where the Limerick Nuclear Plant s located during the Mid 80's to 90's after they opened. Prostate Cancer increased 132%, Thyroid ancer increased 128%, Kidney cancer increased 96%, Multiple Myeloma increased 91%, Hodgkin's isease increased 67%, Non-Hodgkin's Lymphoma increased 61 %,Breast cancer increased 61%, ancreas cancer increased 54%, and Leukemia increased 48%. adiation exposure can cause cancer and other serious disease and disability, at any level of exposure ccording to the National Academy of Sciences and Physicians for Social Responsibility. Permissible adiation levels does not mean that they are safe levels for everyone in the community. Most ermissible levels are based on the average healthy adult. They are not levels that were based or esearched for fetuses, infants, toddlers and children or pets. Fetuses, infants, children, pets and the lderly and immuned compromised individuals are at most risk of health problems. There is a broad ange of dangerous radionuclides routinely released into our air and water from the Limerick Nuclear lant as well as any accidental releases. Permissible radiation levels does not mean that they are safe adiation levels it onl means that the are allowed. I have children as well as other loved ones that have or have had allergies, asthma, learning disabilitie:i,H_H__,_..J speech disabilities, behavioral disabilities, thyroid conditions, cancers, skin disorders and irritation, etc. I expect you to do what is morally right now for me, my family, my neighbors, my community, and the 44-11- 1 pets, wildlife, air, water, and environment in whole by rejecting, refusing and opposing Limerick Power OR Plant from re-licensing to? run their business longer then originally planned for 2029. Don't tum a "blind eve" now. Do vour iob knowin!l: that vou are doing what is morallv ri!l:ht and safe for humanitv and for my children and for the future of generations to come. Please help women have a chance to carry a baby full term without complications due to any possible air and water pollution that may have been caused by allowing more radiation into the environment when there are safer alternatives for 1 44-12-AL energy. I A-153 Appendix A (Page 3 of 3) One person/individual can make a huge difference in the life of others whether or not you realize it. It can have a domino effect on others. Please step up and be that one person that we truly need right now to do what is right. Why does it have to take someone to be personally affected by a situation or to have a loved one suffer or die to step forward and do something? Please don't wait. Now is the time. Please be courageous enough to stand up and fight for what is right for this community and for humanity in a whole, no matter how hard or long the task may seem, it will be worth it in the end!!! I appreciate your time and attention in this matter. Thank you. Sincerely, Lisa Smoyer- Upper Pottsgrove Resident 1027 Farmington Ave. Pottstown PA 19464 CC: Friends, Family and some community members A-154 Appendix A .JJ -n -, I o. .. ) ~-.., October 8, 2011 C?j:J- tjZEJij c U.S. NRC Ms. Lisa Regner Mailstop TWB-05-801 M Washington, D.C. 20555 1cpf7(.:5 3./j9'f' Lisa.Regner@NRC.gov Subject: 8 I --n ; > r -.J c n-: cr t."J -< '" -"'= ?---.... ;] CJ i>? w I :::J r-? .::> '--J ~~:-?; .. ~ -; -=.~: ???.. . . ._ ~-;-s~~ :r: ,~! C') =:; .c? ri9 (/) Deny Limerick License Renewal - NRC I.D. Docket 2011-G166 Dear Ms. Regner: I urge NRC to deny Exelon's request to renew Limerick Nuclear Planfs license for 20 years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant must be closed, 45-1-0R I not relicensed, for many valid reasons. Approval for Limerick Nuclear Plant to be relicensed 1 until 2049 would be reckless and would show blatant disregard for the health and safety of the public. There is more than sufficient evidence of harms and threats to justify closing Limerick. There are too many things beyond NRC's control that could lead to a catastrophic meltdown. Limerick is 3rd on the earthquake risk list. It is too dangerous to keep Limerick operating. Earthquakes and other natural disasters are more frequent and stronger. Underground pipes and cables can shake and break, then lead to loss of power, loss of cooling water, and meltdown. Limerick's substandard containment flaw means more radiation would bA ]45-2-PA released. l Everything has a hfe expectancy. Umenck's was 40 years. The older any facility gets, the more likely mechanical breakdowns and equipment failure will occur. When it's a nuclear plant, meltdown could result from corroding, deteriorating, and aging pipes, cables, and 1-:4-=5,....-3=--=o:-:S~I equipment. Miles of difficult to inspect corroding, deteriorating underground buried pipes and cables are a major concern. Signs of mechanical damage and breakdown already exist - three unplanned shutdowns June 2011 , preceded by many others since 2007. one with loss of cooling water. While some parts can be replaced, by the nuclear industry's own admission, some eauioment is too bia and exoensive to reolace. errons s ave ma e ' c ear ey 1n en o a ac nuc ear p an s. xe on as re us o pay to guard Limerick against a 9/11 type terrorist attack with a plane or missile, even though the most deadly targets (Limerick's fuel pools) are vulnerable to such attacks. Limerick is a similar design to nuclear plants in Japan that are melting down and exploding. NRC's own report from 2000 shows people 500 miles away could be impacted by an accident or attack on .-:'::,.......,.--=:::-o such fuel pools. Deadly radioactive spent fuel rods are jam packed into Limerick's vulnerable 45-4-0S fuel pools five stories high. Cyber attacks, now declared an act of war, could wipe out systems that could lead to meltdown. Hackers have penetrated the Pentagon and other well guarded s stems. Exelon's new lan for c ber attacks ives us little comfort. No NRC policy, review, or report can make Limerick failsafe from a catastrophic meltdown. Over ei ht million eo le live within 50 miles of Limerick Nuclear Plant. Safe ~-/0-:l>S-= /9-L>JY-0.3 ~-x.Q~(-->~.:<--) A-159 Appendix A Mendiola, Doris From: Sent: To: Subject: quteasz@comcast. net Thursday, October 27, 2011 3:03 PM Regner, Lisa Limerick Nuclear Plant Relicensing Hello Ms. Re ner: Just a quick note requesting the NRC to NOT allow the relicensing of the Limerick, Pa ' ~,---, r.-:-.-':nuclear plant at this time. 48-1-0R move o o sown, a., some 1me ago 1n pe ec ea . , w w1 prostate cancer. Although, I cannot prove it was a direct cause of the nuclear power plant, I feel that much further, unbiased studies and tests need to be done prior to the relicensing of the Limerick plant by reputable sources not by corporate interests groups that can manipulate the statistics in Exelon's favor. Wouldn't it be in the best interest of our community and surrounding communities if the higher cancer rate was due to the Limerick power plant???? This question is a "no ..-:::--:::--:-:-:'-:--, brainer". There is plenty of time for testing to be done prior to the relicensing. so, w y e urry ... hich we are not aware. hy must the license be renewed at this time when they are licensed through 2024 and 029???? 48 3 gain, WHY THE HURRY??? - -LR o relicense now is not in the best interest of everyone in our area. Prior to the construction of the Limerick power plant, everyone in our surrounding area was told that our electricity would be one of the lowest in the U.S. THIS WAS A BOLD FACE LIE!!!! IT IS ONE OF THE HIGHEST IN THE U.S.!!! r:-:::-~~ 48-4 -0S Excelon lied to us then and the will distort the facts now. PLEASE DO NOT BE IN A HURRY TO RELICENSE LIMERICK WITHOUT COMPLETE AND HONEST TESTING BY AN IMPARTIAL COMPANY. There is plenty of time after the test results. Thank you for reading my e-mail. I hope God guides your agency into making the correct decision. Ken Sekellick 661 N. Price St. Pottstown, PA. 19464 guteasz@comcast.net A-160 Appendix A "' " II r.-'\ . "11 . .. T 6 l)ev';~~~- = /}2;) H - ,::/ 3 ~ =-Xtfj~{~~,z:) 7~ e.2;-=::ft ]),v-o/3 _ A-161 I Appendix A ~ r~Z(} I/ ttr/(33-l Y>~ @ Anthony Gonyea Onondaga Nation Hemlock Rd. Box 3198 via Nedrow, NY 13120 .. JJ --, Oct. 15, 2011 I I .-) :i David J Wrona US Nuclear Regulatory Commission Washington, DC 20555-0001 ~~ ....._ i"l .:=J RE: . -, ~ :::1 c.. :.? I .oo "! (,/"'; ~~ ... ' ) ~~ ;3 - 'r: ') ~ ?::r: i () ~ n, ~ 1...11 (/) V1 Project ID: Limerick Generating Station Limerick Township of Montgomery County, PA Dear Mr. Wrona, Thank you for providing the Onondaga Nation with information about this project. If anything changes are made, I would like to be consulted. I realize that Unit 1 and Unit 2 have licenses that may be renewed in 2024 and 2029 respectively, therefore you may send updates and information until then. [49-1-HA In the event that during project construction, any archeological resources or remains, including, without limitation, human remains, funerary objects, sacred objects, or objects of cultural patrimony are uncovered, please Immediately stop construction and contact me at (315)952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at (315)475-2559. If you have any comments or questions about this matter, please do not hesitate to let me know. Thank you for your help. Sl~~ Anthony Gonyea A Faithkeeper for the Onondaga Nation Onondaga Nation Historic Preservation Office Section 106 Representative ~/{_J-:ZYS;: Q]) /7'-?/3 ~ ==- y: IJ~ re:0 A-162 I Appendix A q/c?-&/~/1 From: Sent: To: Subject: ,., %!7i S3-f-/~ Mendiola, Doris ...) --? Deb Penrod (deb24532@comcast.net] Thursday, October 27, 2011 8:06 PM Regner, Lisa greetings from a SUPPORTER of Limerick nuclear plant 0) VI N Hi, wanted to let you know that I am a complete and full supporter of the Limerick Nuclear plant I am lso supportive of the scientific judgement and expertise of those such as yourself who have the ?ob f making the decisions. f-= 5,-;:-0--:::1~-:-S~R;:::-, (I saw your name in an article in the Mercury where the writer was requesting that objections be sent to you. I thought I would take advantage of the contact information to state a contrary position .) I grew up in coal-mining country, and never saw a stream or a creek with clear water uncontaminated by acid mine runoff until I was in my late teens. Opponents to nuclear power have usually never lived near coal truck entrances to mines and coal plants, and have probably never lost family members to mine cave-ins or black lung. Risks should be minimized as much as possible, but the world will always have something that someone objects to. Unscientific or fear-based objections to nuclear power are unproductive and do not advance safe or reasonably priced power. I work in the pharmaceutical industry (I was first educated as a pharmacist, and then as an attorney; I now help to get new vaccines approved, and to help increase vaccination rates). The parallel I see is with the group of people who see disaster in every prescription drug product, and complain about everything the FDA approves or does. Nothing is ever 'safe' enough for them. Please renew Limerick, using the best scientific information and risklbenfit analysis available to ou. Thank you. Debby Penrod 215 Amanda Smith Drive PO Box 516 Pottstown, PA 19464 ~7&!:;>5 = ~~ A-163 /JD-0'- t?J 3 d7 15~ c~?..2-) Appendix A Mendiola, Doris From: Sent: To: Subject: DocKoenig@aol.com Thursday, October 27, 2011 8:49 PM Regner, Lisa Fwd: Nuclear Limerick g;/c?c:, ;~ ~ :/&r/G03~:1~ From: DocKoenig@aol.com To: LisaRegner@nrc.gov Sent: 10/27/2011 7:36:13 P.M. Eastern Daylight Time Subj: Nuclear Limerick Hello Lisa Limerick should not .be licensed. or relicensed at this t ime. doing it because the plant has issues that they are trying to hide. The evacuation pia '5-::-1 0 S is a joke because we would not get out of our driveways. It would not have worked 10 1 --::-1-::-::-:::-11 years ago and certainly with the population growth it would be much 1 -2-0S 51 JJ "-;-] ) -~ -~, ;::J -::;. Tl 6utV.5.Z: l}eY;~~~ ; :n c: ' ,.-?? r ," ) u: :, ~..~- ' -I ..) C.J ~ ..~5 ~~- rj?~: .. L. ~:? V1 N ~-;1{1---.))S .= /J"))H-c!J3 ~, /15~ (!-1--!.E'-.:Z..) /1~~/-;jJ,;<.t-CJ/.3 A-164 r-. c: _, < JTl (/) I Appendix A Mendiola, Doris ? John & Joyce Webber [jbwebberpc@comcast.net) Friday, October 28, 2011 2:41 PM Regner, Lisa Exlon Limerick Relicensing From: Sent: To: Subject: As a resident of New Hanover Twp., Montgomery County, PA (less than 5 miles from Exelon's Limerick Nuclear Power Plant), I urge you to vote AGAINST the premature relicensing of that facility. 52-1-0R 5/C?~J~// ;;2.r _,tC S.3 -1- / ([" p1 ,.., "o""d tfie foo,hty fi., e>ploded wrtfi fiom" '"d ""''"o~"1 52-3-SE I Tfie 0 2) It has now gone far beyond its limitations. (4) The roads to any safe place are overwhelmed with congestion with normal traffic. (5)The plant can n longer store its used fuel rods and has asked permission to begin transporting them to another facil ity. r:5!-:::2,--4-:---::0~S~ (5) It is one of the six most dangerous plants in the country because of its proximity to an earthquake fault. 1152-6-HHI j6) The surround ing area has abnormally high cancer rates among adults and chrldren. For all these reasons and many others too numerous to mention, it would be a truly disastrous mistake to extend Exelon's Limerick license for 20 years beyond the current licenses that do no expire until 2024 & 2029! Please consider the thousands and thousands of people who would be lost to an accident that could be prevented. Sincerely, Joyce B. Webber 2338 Holly Drive Gilbertsville, PA 19525 610-326-2584 : :JJ "il ) --:?i -;:;: ?::....._ - ro i . I 0 5o,vs-.z: /?eY;&-r ~~ ~ r- ' ,- t- u: -, _, ,..., ' o -J CJ ~ _::?~~.: . -'~ ~:-:- ,...., VI C) -" "' ;~:::~ (fJ ~-A.__.Ifl5 ::= /7:V-"7-?J3 ~ =-;ttfl~ (?-/-f.e-9 'l~&2;:::=: /7-bf-f-??/3 A-165 Appendix A G'/J4-/~// ~rt~G Mendiola, Doris From: Sent: To: Subject: :::CI S3/j9e' c: o- r ?- AG"" - -: Anita Baly [ajbaly@yahoo.com] Friday, October 28, 2011 3:06 PM Regner, Lisa Limeriok Plom Reli"'"""' -?? \~ ,:,... ? ,-..) V1 w Dear Lisa, It was good to meet you at the September 22, 20 II hearing the NRC held at Sunnybrook. As I stated then, I continue to be concerned and puzzled about the very early and pre-mature application of Exelon to extend the licenses of the towers. One of those towers does not come up for renewal until 2024 and the other 2029. I ask the NRC not to work on the relicensing question for this facility for at least ten years. Th~ wait could only ensure better information. The public cannot possibly benefit from a decision to renew the licenses at this time. The best decision will be made based on the best possible information. The NRC does no have that best information this early. Much will happen in the next ten years. I urge the NRC to wait and see r::-:::-:L=--> how any of it affects the prospect of continuing these plants at that later date. 18-5-LR 1 What can happen in the next ten years that we can all learn from relevantly could be anything. It may be better information about how natural disasters are affecting nuclear facilities; we may know more about weather patterns that could cause damage. We will certainly know more about the world situation in terms of advances in terrorist technological capabilities and goals. We will know more about how well nuclear plants in general and the Limerick facility are faring as they continue to age. If someone steps forward to fund studies, we will know yet more about cancer rates in the nuclear zone. (We do know something about that now: Joseph Mangano and others have done studies already that I assume he has provided to you, and I urge you to consider ? carefully.) One big concern--because of Japan's recent experience and the fact that we had an earthquake here in the Limerick plant's territory--is refurbishing the plants so they can withstand earthquakes. It has been widely reported--by MSNBC and the AP, using NRC data--that the Limerick plant has the nation's third highest risk of being damaged by an earthquake. When the plant was built, no one thought this area would get earthquakes. Now we do. I understand that Congress is now or soon will be considering increasing earthquake preparedness capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would encourage them to do less than thev should to make the nlants safer. 18-6-PA 1 There can be no good reasons for relicensing now. Please wait as long as possible to do that. Better information helps everyone who wants an outcome that is right and socially beneficial--not just profitable for Exelon. Thank you for your consideration. Anita Baly ,E~_2).5 =/32).~7-23 ~'iA~(?~e~) A-166 Appendix A bP/:71. _ _ ChaL'"/L&. _~c__ __ __ ___ ___ __ __ ___ ___ ,-_ _ . _ ____ ___ --~7-'s=-.-~s---:ed~~-Aa q~-------- ___ ________ _____ ____ _,___________ B_-Iftr~?.?-a______ ___ eA__ ~9Z:@.~---- _______ - - - - -- - - - - - - - - - - - - -?- _ _ __ ______ _ ____ ____ . . _ _ ___ __ ______.. --?-- __ ____ __ - ------? ----------?- ._ _ _z-_ m;::JJd!e :;,ou _ _/.ltrc? ..re.(/c-_~ _ e _fhe- _;{/vc/ea,.-. (D ,;?S R.we-::: .7?~-?:. _tJ:,t! ~1_/f? :~.: V1 :::J - Chief, Rules Announcements, and Directives Branch Mail Stop: TWB-05-B01M US Nuclear Regulatory Commission Washington, DC 205550001 r--: il ' ; October 25, 2011 ;.;IJ r== -Tl (/) . fT l V1 Environmental Scoping Comments Limerick Nuclear Generating Station Division of License Renewal NRC-2011-0166 Dear NRC Staff: We have examined thep~Qposed reli~ensing. review information presented by NRC staff at the Public Hearing held in _ Pottstown on September 22 and the information posted on th~ web .site. operated ?by the NRC. We feel that .it is vital that any decision regarding the relicensirig of the Limerick Nuclear Power Station reflect careful consideration of all relevant public health and safety, security, and environmental issues that pertain to nuclear power generation in general and the unique conditions at the nuclear power generating station situated in Limerick Township. It is our understanding that an Environmental Impact Statement will be developed which addresses relevant environmental impacts pertaining to socioeconomics, environmental justice, and noise; cultural resources, archeology, and geological science; atmospheric science, .air-quality; hydrological sciences; transportation and land use; radiation protection; nuclear safety, fuel cycle, waste, and accident analysis; construction, operation, refurbishment,, and decommissioning; regulatory compliance; aquatic ecology; and water quality. Further it is our understanding that a detailed safety review will be conducted to review design assumptions; assess aging management of safety systems; and determine if new monitoring and inspections are needed during the expanded licensing period. While we implo~e the NRC to do a full review of both environmental and public safety issues pei:'tainin'g to the plant- particularly addressing radioactivity exposures during normat operation of the power station and_during various types of unusual events and disasters- we additionally feel that the impact review preceding any relicensing decision should also address specific issues .pertaining to the plant based upon it's conformity to the Montgomery Co~nty Comprehensive Plan ?and overall county development poli~ies. Below we have itemizeci is,sues with respect to land use change and growth around the 'power plan,t, 't ransportation and evacuation capacity, Schuylkill River; and county trruls that feel warrant consideration in the environmental impact study. we 5o~Gr IJ?//~~~? ?--/(J2)S ~ ~~~ /J?)H-?J13 A-168 ::=. 7 /9-:~H-?J 3 /!11~ (2/-//(..1L) Appendix A -- NRC Staff -2- .J October 25, 2011 Land Use Change and Growth around the Power Plant: Since the original plant was constructed,, the population in. the surrounding communities has grown dramatically. LimeriCk Township and nearby Upper ? ? Providence Township have been two of the most rapidly growing communities in the?? county. This gro~ largely fueled by access to US Route? 422 Expressway and ' available land with suitable infrastructure, has dramatically chan'ged the character of the area surrounding the Limerick Power Sta:ticin. In the ?past few years, the ?" ? Philadelphia Premium Outlet Mall, a 600,000 square foot retail facility, and the adjoining Costco shoppi,ng center opened along US Route 422 about one mile north of the..Limerick Power ~h.tti:<,>rJ. proper.cy.: ?The. land adjoining those facilities is being? ? consideredfor various types of retail and residential. uses. ? At' one time, ?a large gamblirig casino had been pr6posed this location as well. Other lands in Lower Pottsgrove Township near the Liinerick Power Station have also been proposed for similar types of uses. ? .. ? m 54-2-0S I While the county planniri:g commission has tried to promote lowerdensities of growth in proximity to the Limerick Plant, the local communities and the marketplace favor this location for significant development due to its proximity to the US Route 422 interchange at Township Line/ Evergreen Road. The growth that has taken place in the area around the power plant, and in particular the growth taking place ?in the area immediately adjoining the. plant and the primary access to it; as well as th:e projected growth in the future, could complieate e~adJ.ation plans and-the movement of ? appropriate emergenc)irespi:irtse personnel-to the?plantin the event ofa disaster. Certainly this access could be even more critical in the event cif-a natural disaster when other roads to the plant niay be?iinpassable. The environmental assessment review needs to analyze this 'groWth in the vicinity of the powe?r plant to evaluate what impact it would have on plant operations and whether or not safe evacuation can take place from the newly developed areas. ? ? ? ? ?? ~ransoortation and Evacuation Caoacitv: ?? ' ? ifhe growth in the whole US Route 422 Corridor has raised numerous proposals for xpanding the vehicle capacity of the 422 expressway. Current peak commuting raffic tie ups on portions of the expressway serve as evidence that it may have ?nadequate capacity to continue to serve as a safe evacuation corridor for the region. lfhe county transportation plan recognizes the need for various road improvements fuong the US 422 ,Corridor 1;o address current and future traffic demands. The first !Priority projects in the plan include ?interchange improvements?at the Township Line !Road/ Evergreen Road intersection which is also the primary access route to the 1 54-3-os l !Plant; needed widening and reconstruction of the highway east of the power station !between Route 29 and US Route 202 in King of Prussia, reconstruction? of US Route ~22 in the vicinity of Pottstown, and the reconstruction and widening of the Route 422 !Bridge across the Schuylkill River at Betzwood. A passenger train line is also !Proposed as a first priority in the transportation' plan to provide service through the jwestem portion of the county into Norristown. The proposed route for this train line is he existing Norfolk Southern raillirie that goes through the Limerick Power Station !Property. O,ther improvements including the wi&ning and expansion of US Route422 rom Pottsto&n tO Route 29 and additionhl interchange improvements at Township !Line/ Evergreen' Road 'are' proposed as seccindaiy priorities iri 't lie CO'\lnty plan. In . !addition ?t o these itn.pr9veinents', several othei-? localired improvements mat may impact !evacuation feasibility a:te'prbposed irt'the' county plan . o: ' . ' . ' ' ' . . A-169 Appendix A ..... ,.. _, NRC Staff October 25, 2011 -3- Due to tundmg limitatiOns m Pennsylvania, these proJects are not likely to move forward at this time ..The envir.o nmental impact review should consider the capacity of the roadway facilities to service the Limerick }'lant as well as provide sufficient 54-3-0S evacuation .?o f the area in the eVent of a disaster? Possible mitigation strategies 'to be . Cont'd considen!d in the environmental assessment review cotlld include the role of Exelon in funding .tp.~ ?imp~~t~t road imj)r~vements needed in t~is area to ensure safe evacuation and access to the, planf ln any type of disaster. . .; . SchuylklllRlver;,... , . . ,,,_,. :: o :c-,: '? ' .... . , ...?? .o; . ' ?? , . . . .. . Since the last i_ pacistaternenJ ,was prep.~~d ~J.i:l 973, the .S~hl.!ylkill'Ri\ler hiu=i been ? m designated as a state scenic river anci'as a ,hefitiige,aiea 'for.b()th the state and federi:U government. D:ue to these.designations .and the efforts.ofnon-? profit organizations and local govert:lment, acce~s tc) the river has been expanded so that the river has become a recreation and heritage tourism destination. Use of the river in the vicinity of the plant will continue to grow. With the return of American Shad made possible ~~:~~e~h down stream fis~ ladders, interes~ iJ1 th~ rive,~: ~_quld e':'en grow further in the 1 _ _ 54 4 8W The .Limerick P.lant withdraws sizeable portions of river water. During low flow periods, additional.quantities of water are released into the river from the Wadesville Mine. and Still Creek Reservoir in Schuylkill County to compensate for the water ? withdrai.vn at the plant . . Thi~ process was. initially approved .by the.Delawar~ River . Basin .Commission (DRBG)jn ~003 and kept.~yi:ive. th,rough, ?;;;_series o?f docket amendments. Future river - ater use is dependent upon the .ability of this water make w up system to op~rcate~thi~~ario~.~ wat~]; qualitY. and flow,parameters set by DRBC.? It is important.to evaluate. th~ \~iability_ ofth.e tlSe of the river water and water make up system to provide needed water through the expanded plant lifetime . Analysis of this aspect of plant operation needs to account for the water quality impact from the total dissolved solids in the Wadesville water among other pai-'a meters. If resumed use of the Delaware water diversion is anticipated, an evaluation of that system is required tc ensure that the capacity is available in the conveyance system and that water qucility objectives can be met for discharge .into the East Branch of the Perkiomen Creek. . Countv Trails and Open Space: The county has been working hard to develop an interconnected system of open space and trails along the;! .Schuylkill. River and within other natural re.s ource areas of the county. In doing this, the county has provided funding to local muniCipalities and ? non-profit conservation organizations to purchase open space and park land; acquirec county land and agriculture easements; and developed trails. The Limerick Generating Station site contains significant land along the Schuylkill River that has been identified as part of the Schuylkill River Greenway in the county plan. The use 1 54-5-LU and management of these lands relative to the county open spac:e and natural areas inventory plans should be evaluated in the relicensing process. . . ? The Mo~tgo~ery County Op~ri Space Pia~ pr~poses a tra,il along the ~iver thrm,;,gh the power plant property .. ,This trail .isprqposed the Schuylkill East Trail, which would be developed as \.Inpave,dtrail. be~ee~ Mo.ti~ Clare and Pottstown. Essentially the proposed route,w:ould .foJlow.an old road,.WayJ:>etween t}1e 'river and Norfolk Southern rail line, through 'the. ~i~.eri~~.P9.~~r St{ltiqn..si~e....J'hgugh ~:ucha trail route.wi:iuld ? appear to raise significant safetY coQ~~m~?.ctu~ ?ii:s prop_o.~~C;l ':p~qximity to ? th~ j:>ower -~ as A-170 I I 1 Appendix A NRC Staff October 25, 2011 -4- station, appropriate elements could be de~igned into any trail system to limit its threat to plant's security. We have found that trails can enhance the overall security of an 54-6-0S area since they concentrate users along a defined corridor. Furthermore, trails can provide emergency access routes that could be used during different disaster events to Cont'd evacuate people and provide access for emergency response. This trail and the m:amigemen~ ?~(undeveloped portions of the Limerick Power Station site should be considered iri 'the environmental assessment. I ,- . Community Outreach and Education: As part of the environmental assessment process and the evaluation of the plant safety and long term operational capacity, we think that it is important for the NRC to ma1ntaill.close communication with the community surrounding the plant. Overall 54-7-LR education about the plant and the associated risks presented by its operation should be provided in a variety of ways so that the public is better informed about the plant and the overall evaluation taking place as part of the relicensing. If you have any questions, please contact me. Also, we offer our assistance in providing local information that may be helpful to your review. _i. ~I o o Sincerely,. ? ?' . . . ! . ? ? ? "'!? -, :? ... . . o' . . o : . . ; . o ~l? '? . . ~ ~ ; .' Michael M. Stokes Assistant Director mstokes.@montcopa.org . .; '?? ' . (610) 278-3729 c. Thomas Sullivan, Public Safety DepaJ1:!nent A-171 ., ' I Appendix A COUNTY OF MONTGOMERY Commissioners Montgomery County Department of Public Safety Operations Center 50 Eagleville Road JAMES R. MATTHEWS CHAIRMAN JOSEPH M. HOEFFEL BRUCE L. CASTOR, Jr Eagleville, PA 19403 (610)631-6500 FAX (610)631-6536 THOMAS M. SULLIVAN DEPARTMENT DIRECTOR www.dps.montcopaorg October 25, 2011 Olief, Rules Announcements, and Directives Branch Mail Stop: 1WB-05-B01M US Nuclear Regulatory O>lnmission Washington, DC 205550001 Re: Environmental Scoping Comments Limerick Nuclear Generating Station Division of License Renewal NRG2011-0166 o/c7~/2VI/ ) .. ?! ~?)(..69-?7~ . ..y~ ? (R) - -j-!j c; Dear NRC Staff: The Montgomery County Department of Public Safety would like to offer the following comments regarding the NRC relicensing review information presented at the Public Hearing held in Pottstown on September 22, 2011. o o [The NRC should provide a full review of environmental and public safety issues pertaining to the plant. t is understood that emergency responders providing services to the power plant understand the ~azards associated with daily operations of the plant. However, in light of events in Japan and recent ~eismic activity in this area, the NRC should clarify the risks associated with plant operations in times of 1 55-1-0S ~usual activity, outage operations, and during times of natural I man- made events that may pose a risk o the plant in terms that the public will understand in an attempt to quell public concern. rw concur that the NRC require Exelon to conform to the Montgomery County Comprehensive Plan e o not only ensure cooperation in the community, but also in the region. Additionally, it is also ~uggested that Exelon be included in pending roadway infrastructure improvements projects as both a take holder and possible source of funding. I 1 55-2-0SI o It is important to note that the 10 - mile Emergency Planning Zone (EPZ) is the second largest in population in the nation. As a result of recent development and type of development in the area of LGS, it is important to review the Evacuation Tlllle Estimate Study (ETE) on a more timely basis and account for the transient population present in the hotels that have accompanied this development. 155-3-os l Additionally, funding should be supplied for either Exelon staff or County staff to act as a transient planning and outreach specialist to assist these transient population locations with emergency planning. o It should be noted that the Evacuation Time Estimate is currently being updated. Required highway and roadway infrastructure upgrades should be included as a part of and also as a result of any changes r=:~~~ noted in the updated ETE. Special attention for improvement should be given to the local, county and 155-4-0S state roads used for evacuation that feed the larger highways, as many of these roadways are no longer ..__ ___, suitable for the amount of traffic that an EPZ evacuation could produce. I ~-;1{.2.- JJs -:::: J9 !Y-7-2J .3 ~ =X ;f ~ 0-H;:<;z.j A-172 Appendix A o -2- o October 25, 2011 The NRC should consider requiring Exelon to enhance planning for day to day emergency situations that require a response from local emergency services. Often times, Fire and EMS access is delayed due 1 55-5-0S to screening of vehicles and personnel This can cause delay in patient care to potentially life threatening illnesses. I o o While recreation utilization is of importance and a major mission within this county, homeland security 5 :_ must be of a concern with any open access within the vicinity of LGS. However, we concur that with 1-:::-:5=---=7--,1 support of local law enforcement and a commitment from LGS to control and monitor access, trail OS ~ughput may be accomplished. o In an attempt to promote and increase community outreach, the NRC should consider requiring Exelon to reopen the LGS Information Visitor Center. As a result of the incident in Fukushima, Japan, the Montgomery County Department of Public Safety has a received a higher than normal volume of '==--=--=-=-> inquiries concerning nuclear power generation from the public. The LGS Information Center, although 55-8-0S dated, could be upgraded to provide this service to the community to raise awareness and promote education of the nuclear power industry. This center could also be incotporated as an educational stop on the County Trail system. I If you have any questions please feel free to contact me. Vuy To: letters Sent: Mon, Oct 24, 2011 9:09 pm \ ?? ,, Ms. Regner, l - ::.::"1 ' ~ o. ! ~~~ .. 'I r r?, 0 -H N Cl < rn (f) 0) Letter to Editor I I Exelon is rushing the timeline to reissue a license(18 years ahead of time) to run Limerick Nuclear Plant into the unknown, yet it took more than 5 months for the NRC to get back to me concerning an already known survey of fault lines. 1 4-13-LR 1 I It took five months for the Nuclear Regulatory Commission to answer my question concerning how close the nearest fault line is to Limerick Nuclear Plant. No wonder! Two faults are dangerously close. Chalfont Fault is only 9 miles East. _ _GE 1 14 4 Ramapo Fault is 17 miles Northwest. This is alarming! 1 I The 9-21-11 Mercurv article said" whether or not earthauake risk is a factor in the current relicensina reauest for Limerick remains to be seen". It would be grossly unacceptable tor the NRC to ignore Limerick's extreme vulnerability to earthquake damage.. Earthquake risk should be on the top of of NRC's relicensing concerns for Limerick. Earthquake risks are far greater for t Limerick than previously realized-increased by 141 %. We now know Limerick is 3rd on nation's earthquake risk lis,_~-=-:-:,.----, .Plus,evidence shows earthquakes in the East can be far stronger than Limerick's " design basis" can withstand. 1 4-15-P A 1 There's a good chance that an earthquake can exceed Limerick's design basis, causing a severe nuclear accident, jeopardizing the health, safety and financial well being of our entire region. The Virginia 8-24-11 earthquake caused shaking in PA at Limerick Nuclear Plant .Since January there have been 2 small earthquakes in Philadelphia, only 21 miles from Limerick. Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to nuclear disaster. It's disquieting that NRC uses a "visual inspection" to determine damage on buried pipes. Problems may not be identified unt it's too late. For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on fires and earthquakes. To save money, Exelon typically concludes Limerick is "safe enough". This is unacceptable! 10-5-11, the Mercury reported a flaw was found in the mechanism to shut down the nuclear plant. T he warning was tied t renewed focus on earthquake risk. It's difficult to see how Limerick's design flaws can be fixed, even if Exelon WOULD spend the money. There is no proof whatsoever Limerick's design can withstand other threats ranging from hurricanes, tornadoes, floods, o terrorist attacks to an impact from a jet airliner. We need precaution before there is a catastrophe. NRC should close Limerick as soon as possible. .?R --:?;;6 =- 13'JJH- o 3 c;2LL = ~ 8~(/_H/f-2-) A-181 Appendix A Mendiola, Doris From: Sent: To: Subject: sunbeamsky [sunbeamsky@aol.com) Monday, October 31, 2011 2:28 PM Regner, Lisa power plant renewal q-J;;-~J~ /j '/d,P/L o-'8 /) 1~ 0 :JJ - il ~-) .> ~ ~"7:! ~:..:i ..._:-:;: .;-l ?- ..__ :?TI i___j ; . .::.::?.... ?-:_ , :.::.: ~ N 0 ~-/l?7?xs ===-ftJJd'-7- z; 3 ~;; 7-:6~ {P-1~~ A-182 Appendix A Mendiola, Doris Smokowicz, April (Aprii.Smokowicz@graphicpkg.com) Wednesday, November 02, 2011 8:49AM Regner, Lisa msworkdog@verizon.net Pottstown Mercury article 10/27/11 From: Sent: To: Cc: Subject: Good Morning I know this is late according to your article, but I wanted to still send you some information. I feel that there is a lot of people that had not known to report anything because of not know ing who to go to. I don't understand why the hospitals don' t give statistical information based on areas? 158-1-HH I Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children' s Hospital until she was 5. With several years of chemotherapy she is now 18 and in remission. We had lived on Limerick Center Road for most of our young lives and now with our kids. I don' t know w hat other information you would need but I would be happy to get you w hatever you might need. qj&t)~// :JJ ;- j 7 ){so~7~ ~r (R) . ~ --. J -?? -- I ?-il 0 :n c: r?-- ??- n-; cr L:.1 -~ ; ~.-:. ~,) , .. ~ t< 'f? .1::: ~~z:>s.:::/5l..D.A.../-,!>_3 5ovsr /Sef/1~~~ ...... r. ???: r~ 0 i =:_i < rn en ~ ~;f;![~r!-'-"AA) ~~-::;../.}:!J~ ---b/3 A-183 Appendix A I 50 us; fie fi& 4/We? A-184 Appendix A ....... , ?~ . ~U.S.NRC Uni ted Stares Nuc:lc;n ReguLuor.y Commh;siol'l Proucting People and the Environment LIMERICK GENERATING STATION Environmental Scoping Comments Division of License Renewal N RC-2011-0166 Written Comment Form Must be received on or before October 28, 2011 .? Please print clearly. "\ie\r _ SfJwi' c\?( cr; Name Title: C\JC z.ef\ ? 1 Organization: 2 Tkio Address: City:fJv H- M cO...... er; (f.l'\.1t-rcL-? L7t~+e s of <{(' c;- IJ']/J-otifl- tJ 1/ Y [ # /"1 State: I It r 5-h Zip Code: . /'1I# 0-- Comment Forms may be maileq to: . Chief, Rules, Announcements, an9 Directiv?94~:aAEiR-:-~~~.....l:~::..,.....,.....:.___:L....=._:__:.....!::===LJ Mail Stop: TWB-05-B01M U.S. Nuclear Regulatory Commissio Washington, DC 20555-0001 A-185 Appendix A {)u t'"'- /1?<..1;- +v iA e. :J-, Comment(Cont/hlued): Ct>~e/fuL ~ j, _,_ ,JMfec-/-;/17 (IH_/If41' ~ 1/b><- }o ' ~ {Pop /f.::; 7 A-186 Ill ff/???B ?- 1 2 3 APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS 1 2 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS 3 4 5 6 7 8 The table in this appendix summarizes the National Environmental Policy Act (NEPA) issues for license renewal of nuclear power plants identified in Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51. Data supporting this table are contained in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Throughout this supplemental environmental impact statement (SEIS), "generic" issues are also referred to as Category 1 issues, and "site-specific" issues are also referred to as Category 2 issues. 9 Table B-1. Summary of Issues and Findings Issue Impacts of refurbishment on surface water quality Type of Issue Findings Surface Water Quality, Hydrology, and Use Generic SMALL. Impacts are expected to be negligible during refurbishment because best management practices are expected to be employed to control soil erosion and spills. Impacts of refurbishment on surface water use Generic SMALL. Water use during refurbishment will not increase appreciably or will be reduced during plant outage. Altered current patterns at intake and discharge structures Generic SMALL. Altered current patterns have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Altered salinity gradients Generic SMALL. Salinity gradients have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Altered thermal stratification of lakes Generic SMALL. Generally, lake stratification has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term. Temperature effects on sediment transport capacity Generic SMALL. These effects have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Scouring caused by discharged cooling water Generic SMALL. Scouring has not been found to be a problem at most operating nuclear power plants and has caused only localized effects at a few plants. It is not expected to be a problem during the license renewal term. Eutrophication Generic SMALL. Eutrophication has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term. B-1 Appendix B Issue Discharge of chlorine or other biocides Type of Issue Generic Findings SMALL. Effects are not a concern among regulatory and resource agencies, and are not expected to be a problem during the license renewal term. Discharge of sanitary wastes and minor chemical spills Generic SMALL. Effects are readily controlled through National Pollutant Discharge Elimination System (NPDES) permit and periodic modifications, if needed, and are not expected to be a problem during the license renewal term. Discharge of other metals in wastewater Generic SMALL. These discharges have not been found to be a problem at operating nuclear power plants with cooling-tower-based heat dissipation systems and have been satisfactorily mitigated at other plants. They are not expected to be a problem during the license renewal term. Water use conflicts (plants with oncethrough cooling systems) Generic SMALL. These conflicts have not been found to be a problem at operating nuclear power plants with once-through heat dissipation systems. Water use conflicts (plants with cooling ponds or cooling towers using makeup water from a small river with low flow) Site-specific Refurbishment SMALL OR MODERATE. The issue has been a concern at nuclear power plants with cooling ponds and at plants with cooling towers. Impacts on in-stream and riparian communities near these plants could be of moderate significance in some situations. See ? 51.53(c)(3)(ii)(A). Aquatic Ecology (all plants) Generic SMALL. During plant shutdown and refurbishment there will be negligible effects on aquatic biota because of a reduction of entrainment and impingement of organisms or a reduced release of chemicals. Accumulation of contaminants in sediments or biota Generic SMALL. Accumulation of contaminants has been a concern at a few nuclear power plants but has been satisfactorily mitigated by replacing copper alloy condenser tubes with those of another metal. It is not expected to be a problem during the license renewal term. Entrainment of phytoplankton and zooplankton Generic SMALL. Entrainment of phytoplankton and zooplankton has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term. Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at operating nuclear plants with once-through cooling systems, has not endangered fish populations, or been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds, and is not expected to be a problem during the license renewal term. B-2 Appendix B Issue Thermal plume barrier to migrating fish Type of Issue Generic Findings SMALL. Thermal plumes have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Distribution of aquatic organisms Generic SMALL. Thermal discharge may have localized effects but is not expected to affect the larger geographical distribution of aquatic organisms. Premature emergence of aquatic insects Generic SMALL. Premature emergence has been found to be a localized effect at some operating nuclear power plants but has not been a problem and is not expected to be a problem during the license renewal term. Gas supersaturation (gas bubble disease) Generic SMALL. Gas supersaturation was a concern at a small number of operating nuclear power plants with once-through cooling systems but has been satisfactorily mitigated. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term. Low dissolved oxygen in the discharge Generic SMALL. Low dissolved oxygen has been a concern at one nuclear power plant with a once-through cooling system but has been effectively mitigated. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term. Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses Generic SMALL. These types of losses have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Stimulation of nuisance organisms (e.g., shipworms) Generic SMALL. Stimulation of nuisance organisms has been satisfactorily mitigated at the single nuclear power plant with a once-through cooling system where previously it was a problem. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term. Aquatic Ecology (for plants with once-through and cooling pond heat dissipation systems) Entrainment of fish and Site-specific SMALL, MODERATE, OR LARGE. The impacts of shellfish in early life entrainment are small at many plants but may be moderate stages or even large at a few plants with once-through and cooling-pond cooling systems. Further, ongoing efforts in the vicinity of these plants to restore fish populations may increase the numbers of fish susceptible to intake effects during the license renewal period, such that entrainment studies conducted in support of the original license may no longer be valid. See ? 51.53(c)(3)(ii)(B). Impingement of fish and shellfish Site-specific SMALL, MODERATE, OR LARGE. The impacts of impingement are small at many plants but may be moderate or even large at a few plants with once-through and cooling-pond cooling systems. See ? 51.53(c)(3)(ii)(B). B-3 Appendix B Issue Heat shock Type of Issue Site-specific Findings SMALL, MODERATE, OR LARGE. Because of continuing concerns about heat shock and the possible need to modify thermal discharges in response to changing environmental conditions, the impacts may be of moderate or large significance at some plants. See ? 51.53(c)(3)(ii)(B). Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems) Entrainment of fish and Generic SMALL. Entrainment of fish has not been found to be a shellfish in early life problem at operating nuclear power plants with this type of stages cooling system and is not expected to be a problem during the license renewal term. Impingement of fish and shellfish Generic SMALL. The impacts of impingement have not been found to be a problem at operating nuclear power plants with this type of cooling system and are not expected to be a problem during the license renewal term. Heat shock Generic SMALL. Heat shock has not been found to be a problem at operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term. Impacts of refurbishment on groundwater use and quality Generic SMALL. Extensive dewatering during the original construction on some sites will not be repeated during refurbishment on any sites. Any plant wastes produced during refurbishment will be handled in the same manner as in current operating practices and are not expected to be a problem during the license renewal term. Groundwater use conflicts (potable and service water; plants that use <100 gallons per minute [gpm]) Generic SMALL. Plants using less than 100 gpm are not expected to cause any groundwater use conflicts. Groundwater use conflicts (potable and service water, and dewatering plants that use >100 gpm) Site-specific SMALL, MODERATE, OR LARGE. Plants that use more than 100 gpm may cause groundwater use conflicts with nearby groundwater users. See ? 51.53(c)(3)(ii)(C). Groundwater use conflicts (plants using cooling towers withdrawing makeup water from a small river) Site-specific SMALL, MODERATE, OR LARGE. Water use conflicts may result from surface water withdrawals from small water bodies during low flow conditions which may affect aquifer recharge, especially if other groundwater or upstream surface water users come on line before the time of license renewal. See ? 51.53(c)(3)(ii)(A). Groundwater use conflicts (Ranney wells) Site-specific SMALL, MODERATE, OR LARGE. Ranney wells can result in potential groundwater depression beyond the site boundary. Impacts of large groundwater withdrawal for cooling tower makeup at nuclear power plants using Ranney wells must be evaluated at the time of application for license renewal. See ? 51.53(c)(3)(ii)(C). B-4 Appendix B Issue Groundwater quality degradation (Ranney wells) Type of Issue Generic Findings SMALL. Groundwater quality at river sites may be degraded by induced infiltration of poor-quality river water into an aquifer that supplies large quantities of reactor cooling water. However, the lower quality infiltrating water would not preclude the current uses of groundwater and is not expected to be a problem during the license renewal term. Groundwater quality degradation (saltwater intrusion) Generic SMALL. Nuclear power plants do not contribute significantly to saltwater intrusion. Groundwater quality degradation (cooling ponds in salt marshes) Generic SMALL. Sites with closed-cycle cooling ponds may degrade groundwater quality. Because water in salt marshes is brackish, this is not a concern for plants located in salt marshes. Groundwater quality degradation (cooling ponds at inland sites) Refurbishment impacts Site-specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle cooling ponds may degrade groundwater quality. For plants located inland, the quality of the groundwater in the vicinity of the ponds must be shown to be adequate to allow continuation of current uses. See ? 51.53(c)(3)(ii)(D). Terrestrial Ecology Site-specific SMALL, MODERATE, OR LARGE. Refurbishment impacts are insignificant if no loss of important plant and animal habitat occurs. However, it cannot be known whether important plant and animal communities may be affected until the specific proposal is presented with the license renewal application. See ? 51.53(c)(3)(ii)(E). Cooling tower impacts on crops and ornamental vegetation Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Cooling tower impacts on native plants Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Bird collisions with cooling towers Generic SMALL. These collisions have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Cooling pond impacts on terrestrial resources Generic SMALL. Impacts of cooling ponds on terrestrial ecological resources are considered to be of small significance at all sites. Power line right-of-way management (cutting and herbicide application) Generic SMALL. The impacts of right-of-way maintenance on wildlife are expected to be of small significance at all sites. Bird collisions with power lines Generic SMALL. Impacts are expected to be of small significance at all sites. B-5 Appendix B Issue Impacts of electromagnetic fields on flora and fauna Type of Issue Generic Floodplains and wetland on power line right-ofway Generic Threatened or endangered species Air quality during refurbishment (nonattainment and maintenance areas) Findings SMALL. No significant impacts of electromagnetic fields on terrestrial flora and fauna have been identified. Such effects are not expected to be a problem during the license renewal term. SMALL. Periodic vegetation control is necessary in forested wetlands underneath power lines and can be achieved with minimal damage to the wetland. No significant impact is expected at any nuclear power plant during the license renewal term. Threatened or Endangered Species Site-specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are not expected to adversely affect threatened or endangered species. However, consultation with appropriate agencies would be needed at the time of license renewal to determine whether threatened or endangered species are present and whether they would be adversely affected. See ? 51.53(c)(3)(ii)(E). Air Quality Site-specific SMALL, MODERATE, OR LARGE. Air quality impacts from plant refurbishment associated with license renewal are expected to be small. However, vehicle exhaust emissions could be cause for concern at locations in or near nonattainment or maintenance areas. The significance of the potential impact cannot be determined without considering the compliance status of each site and the numbers of workers expected to be employed during the outage. See ? 51.53(c)(3)(ii)(F). Air quality effects of transmission lines Generic Onsite land use Generic Power line right-of-way Generic Radiation exposures to the public during refurbishment Generic Occupational radiation exposures during refurbishment Generic SMALL. Production of ozone and oxides of nitrogen is insignificant and does not contribute measurably to ambient levels of these gases. Land Use SMALL. Projected onsite land use changes required during refurbishment and the renewal period would be a small fraction of any nuclear power plant site and would involve land that is controlled by the applicant. SMALL. Ongoing use of power line rights-of-way would continue with no change in restrictions. The effects of these restrictions are of small significance. Human Health SMALL. During refurbishment, the gaseous effluents would result in doses that are similar to those from current operation. Applicable regulatory dose limits to the public are not expected to be exceeded. SMALL. Occupational doses from refurbishment are expected to be within the range of annual average collective doses experienced for pressurized-water reactors and boiling-water reactors. Occupational mortality risk from all causes, including radiation, is in the mid-range for industrial settings. B-6 Appendix B Issue Microbiological organisms (occupational health) Type of Issue Generic Microbiological organisms (public health)(plants using lakes or canals, or cooling towers or cooling ponds that discharge to a small river) Site-specific Noise Findings SMALL. Occupational health impacts are expected to be controlled by the continued application of accepted industrial hygiene practices to minimize worker exposures. SMALL, MODERATE, OR LARGE. These organisms are not expected to be a problem at most operating plants, except possibly at plants using cooling ponds, lakes, or canals that discharge to small rivers. Without site-specific data, it is not possible to predict the effects generically. See ? 51.53(c)(3)(ii)(G). Generic SMALL. Noise has not been found to be a problem at operating plants and is not expected to be a problem at any plant during the license renewal term. Electromagnetic fields - acute effects (electric shock) Site-specific SMALL, MODERATE, OR LARGE. Electric shock resulting from direct access to energized conductors or from induced charges in metallic structures has not been found to be a problem at most operating plants and generally is not expected to be a problem during the license renewal term. However, site-specific review is required to determine the significance of the electric shock potential at the site. See ? 51.53(c)(3)(ii)(H). Electromagnetic fields - chronic effects Uncategorized UNCERTAIN. Biological and physical studies of 60-Hz electromagnetic fields have not found consistent evidence linking harmful effects with field exposures. However, research is continuing in this area and a consensus scientific view has not been reached. Radiation exposures to public (license renewal term) Generic Occupational radiation exposures (license renewal term) Generic Housing impacts Public services: public safety, social services, and tourism and recreation SMALL. Radiation doses to the public will continue at current levels associated with normal operations. SMALL. Projected maximum occupational doses during the license renewal term are within the range of doses experienced during normal operations and normal maintenance outages, and would be well below regulatory limits. Socioeconomic Impacts Site-specific SMALL, MODERATE, OR LARGE. Housing impacts are expected to be of small significance at plants located in a medium or high population area and not in an area where growth control measures, that limit housing development, are in effect. Moderate or large housing impacts of the workforce, associated with refurbishment, may be associated with plants located in sparsely populated areas or in areas with growth control measures that limit housing development. See ? 51.53(c)(3)(ii)(I). Generic SMALL. Impacts to public safety, social services, and tourism and recreation are expected to be of small significance at all sites. B-7 Appendix B Issue Public services: public utilities Public services: education (refurbishment) Public services: education (license renewal term) Type of Issue Site-specific Findings SMALL OR MODERATE. An increased problem with water shortages at some sites may lead to impacts of moderate significance on public water supply availability. See ? 51.53(c)(3)(ii)(I). Site-specific SMALL, MODERATE, OR LARGE. Most sites would experience impacts of small significance but larger impacts are possible depending on site- and project-specific factors. See ? 51.53(c)(3)(ii)(I). Generic SMALL. Only impacts of small significance are expected Offsite land use (refurbishment) Site-specific SMALL OR MODERATE. Impacts may be of moderate significance at plants in low population areas. See ? 51.53(c)(3)(ii)(I). Offsite land use (license renewal term) Site-specific SMALL, MODERATE, OR LARGE. Significant changes in land use may be associated with population and tax revenue changes resulting from license renewal. See ? 51.53(c)(3)(ii)(I). Public services: transportation Site-specific SMALL, MODERATE, OR LARGE. Transportation impacts (level of service) of highway traffic generated during plant refurbishment and during the term of the renewed license are generally expected to be of small significance. However, the increase in traffic associated with the additional workers and the local road and traffic control conditions may lead to impacts of moderate or large significance at some sites. See ? 51.53(c)(3)(ii)(J). Type of Issue Site-specific Findings SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are expected to have no more than small adverse impacts on historic and archaeological resources. However, the National Historic Preservation Act requires the Federal agency to consult with the State Historic Preservation Officer to determine whether there are properties present that require protection. See ? 51.53(c)(3)(ii)(K). Issue Historic and archaeological resources Aesthetic impacts (refurbishment) Generic SMALL. No significant impacts are expected during refurbishment. Aesthetic impacts (license renewal term) Generic SMALL. No significant impacts are expected during the license renewal term. Aesthetic impacts of transmission lines (license renewal term) Generic SMALL. No significant impacts are expected during the license renewal term. Design-basis accidents Generic Postulated Accidents SMALL. The NRC staff has concluded that the environmental impacts of design-basis accidents are of small significance for all plants. B-8 Appendix B Issue Severe accidents Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high-level waste) Type of Issue Site-specific Findings SMALL. The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives. See ? 51.53(c)(3)(ii)(L). Uranium Fuel Cycle and Waste Management Generic SMALL. Offsite impacts of the uranium fuel cycle have been considered by the Commission in Table S-3 of this part. Based on information in the GEIS, impacts on individuals from radioactive gaseous and liquid releases, including radon-222 and technetium-99, are small. Offsite radiological impacts (collective effects) Generic Issue Offsite radiological impacts (collective effects) Type of Issue Generic [continued from previous page] The 100-year environmental dose commitment to the U.S. population from the fuel cycle, high-level waste, and spent fuel disposal is calculated to be about 14,800 person rem, or 12 cancer fatalities, for each additional 20-year power reactor operating term. Much of this, especially the contribution of radon releases from mines and tailing piles, consists of tiny doses summed over large populations. This same dose calculation can theoretically be extended to include many tiny doses over additional thousands of years, as well as doses outside the United States. The result of such a calculation would be thousands of cancer fatalities from the fuel cycle, but this result assumes that even tiny doses have some statistical adverse health effects which will not ever be mitigated (for example no cancer cure in the next thousand years), and that these doses projected over thousands of years are meaningful. However, these assumptions are questionable. In particular, science cannot rule out the possibility that there will be no cancer fatalities from these tiny doses. For perspective, the doses are very Findings small fractions of regulatory limits, and even smaller fractions of natural background exposure to the same populations. Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the collective effects of the fuel cycle, this issue is considered Category 1 (Generic). B-9 Appendix B Issue Offsite radiological impacts (spent fuel and high-level waste disposal) Type of Issue Generic Findings For the high-level waste and spent fuel disposal component of the fuel cycle, there are no current regulatory limits for offsite releases of radionuclides for the current candidate repository site. However, if it is assumed that limits are developed along the lines of the 1995 National Academy of Sciences (NAS) report, "Technical Bases for Yucca Mountain Standards," and that in accordance with the Commission's Waste Confidence Decision, 10 CFR 51.23, a repository can and likely will be developed at some site which will comply with such limits, peak doses to virtually all individuals will be 100 milliroentgen equivalent man (millirem) per year or less. However, while the Commission has reasonable confidence that these assumptions will prove correct, there is considerable uncertainty since the limits are yet to be developed, no repository application has been completed or reviewed, and uncertainty is inherent in the models used to evaluate possible pathways to the human environment. The NAS report indicated that 100 millirem per year should be considered as a starting point for limits for individual doses, but notes that some measure of consensus exists among national and international bodies that the limits should be a fraction of the 100 millirem per year. The lifetime individual risk from -3 100 millirem annual dose limit is about 3x10 . Estimating cumulative doses to populations over thousands of years is more problematic. The likelihood and consequences of events that could seriously compromise the integrity of a deep geologic repository were evaluated by the Department of Energy in the "Final Environmental Impact Statement: Management of Commercially Generated Radioactive Waste," October 1980. The evaluation estimated the 70-year whole-body dose commitment to the maximum individual and to the regional population resulting from several modes of breaching a reference repository in the year of closure, after 1,000 years, after 100,000 years, and after 100,000,000 years. Subsequently, the NRC and other Federal agencies have expended considerable effort to develop models for the design and for the licensing of a high-level waste repository, B-10 Appendix B Issue Offsite radiological impacts (spent fuel and high-level waste disposal) Type of Issue Generic [continued from the previous page] Nonradiological impacts of the uranium fuel cycle Generic Findings especially for the candidate repository at Yucca Mountain. More meaningful estimates of doses to the population may be possible in the future as more is understood about the performance of the proposed Yucca Mountain repository. Such estimates would involve great uncertainty, especially with respect to cumulative population doses over thousands of years. The standard proposed by the NAS is a limit on maximum individual dose. The relationship of potential new regulatory requirements, based on the NAS report, and cumulative population impacts has not been determined, although the report articulates the view that protection of individuals will adequately protect the population for a repository at Yucca Mountain. However, the Environmental Protection Agency's (EPA) generic repository standards in 40 CFR Part 191 generally provide an indication of the order of magnitude of cumulative risk to the population that could result from the licensing of a Yucca Mountain repository, assuming the ultimate standards will be within the range of standards now under consideration. The standards in 40 CFR Part 191 protect the population by imposing the amount of radioactive material released over 10,000 years. The cumulative release limits are based on the EPA's population impact goal of 1,000 premature cancer deaths worldwide for a 100,000 metric ton (MTHM) repository. Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the impacts of spent fuel and high-level waste disposal, this issue is considered in Category 1 (Generic). SMALL. The nonradiological impacts of the uranium fuel cycle resulting from the renewal of an operating license for any plant are found to be small. B-11 Appendix B Issue Low-level waste storage and disposal Type of Issue Generic Findings SMALL. The comprehensive regulatory controls that are in place and the low public doses being achieved at reactors ensure that the radiological impacts to the environment will remain small during the term of a renewed license. The maximum additional onsite land that may be required for low-level waste storage during the term of a renewed license and associated impacts will be small. Nonradiological impacts on air and water will be negligible. The radiological and nonradiological environmental impacts of long-term disposal of low-level waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient low-level waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements. Mixed waste storage and disposal Generic SMALL. The comprehensive regulatory controls and the facilities and procedures that are in place ensure proper handling and storage, as well as negligible doses and exposure to toxic materials for the public and the environment at all plants. License renewal will not increase the small, continuing risk to human health and the environment posed by mixed waste at all plants. The radiological and nonradiological environmental impacts of long-term disposal of mixed waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient mixed waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements. Onsite spent fuel Generic SMALL. The expected increase in the volume of spent fuel from an additional 20 years of operation can be safely accommodated on site with small environmental effects through dry or pool storage at all plants if a permanent repository or monitored retrievable storage is not available. Nonradiological waste Generic SMALL. No changes to generating systems are anticipated for license renewal. Facilities and procedures are in place to ensure continued proper handling and disposal at all plants. Transportation Generic SMALL. The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with average burnup for the peak rod to current levels approved by the NRC up to 62,000 megawatt days per metric ton uranium (MWd/MTU) and the cumulative impacts of transporting high-level waste to a single repository, such as Yucca Mountain, Nevada are found to be consistent with the impact values contained in 10 CFR 51.52(c), Summary Table S-4, "Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor." If fuel enrichment or burnup conditions are not met, the applicant must submit an assessment of the implications for the environmental impact values reported in ? 51.52. B-12 Appendix B Issue Type of Issue Findings Decommissioning SMALL. Doses to the public will be well below applicable regulatory standards regardless of which decommissioning method is used. Occupational doses would increase no more than 1 man-rem caused by the buildup of long-lived radionuclides during the license renewal term. Radiation doses Generic Waste management Generic SMALL. Decommissioning at the end of a 20-year license renewal period would generate no more solid wastes than at the end of the current license term. No increase in the quantities of Class C or greater than Class C wastes would be expected. Air quality Generic Water quality Generic SMALL. Air quality impacts of decommissioning are expected to be negligible either at the end of the current operating term or at the end of the license renewal term. SMALL. The potential for significant water quality impacts from erosion or spills is no greater whether decommissioning occurs after a 20-year license renewal period or after the original 40-year operation period, and measures are readily available to avoid such impacts. Ecological resources Generic SMALL. Decommissioning after either the initial operating period or after a 20-year license renewal period is not expected to have any direct ecological impacts. Socioeconomic impacts Generic SMALL. Decommissioning would have some short-term socioeconomic impacts. The impacts would not be increased by delaying decommissioning until the end of a 20-year license renewal period, but they might be decreased by population and economic growth. Environmental justice Environmental Justice Uncategorized NONE. The need for and the content of an analysis of environmental justice will be addressed in plant-specific reviews. Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 B-13 APPENDIX APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 1 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 2 3 4 5 6 7 8 The Atomic Energy Act of 1954, as amended (42 USC ? 2011 et seq.), authorizes the U.S. Nuclear Regulatory Commission (NRC) to enter into agreement with any state to assume regulatory authority for certain activities (see 42 USC ? 2012 et seq.). For example, through the Agreement State Program, Pennsylvania assumed regulatory responsibility over certain byproduct, source, and quantities of special nuclear materials not sufficient to form a critical mass. The Bureau of Radiation Protection, Pennsylvania Department of Environmental Protection, administers the Pennsylvania State Agreement Program. 9 10 11 12 In addition to carrying out some Federal programs, state legislatures develop their own laws. State statutes supplement, as well as implement, Federal laws for protection of air, water quality, and groundwater. State legislation may address solid waste management programs, locally rare and endangered species, and historic and cultural resources. 13 14 15 16 17 18 19 20 21 The Clean Water Act (33 USC ? 1251 et seq., herein referred to as CWA) allows for primary enforcement and administration through state agencies, given that the state program is at least as stringent as the Federal program. The state program must conform to the CWA and to the delegation of authority for the Federal National Pollutant Discharge Elimination System (NPDES) program from the U.S. Environmental Protection Agency (EPA) to the state. The primary mechanism to control water pollution is the requirement for direct dischargers to obtain an NPDES permit, or in the case of states where the authority has been delegated from the EPA, a State Pollutant Discharge Elimination System permit, under the CWA. In Pennsylvania, the Pennsylvania Department of Environmental Protection issues and enforces NPDES permits. 22 23 24 25 One important difference between Federal regulations and certain state regulations is the definition of waters that the state regulates. Certain state regulations may include underground waters, whereas the CWA only regulates surface waters. The Delaware River Basin Commission regulates the Groundwater Protection Area in Southeastern Pennsylvania. 26 C.1. Federal and State Environmental Requirements 27 28 Limerick Generating Station, Units 1 and 2 (LGS) is subject to Federal and state requirements for its environmental program. 29 30 31 32 Table C-1 lists the principle Federal and state environmental regulations and laws applicable to the review of the environmental resources that could be affected by this project that may affect license renewal applications for nuclear power plants. See Table C-2 of this supplemental environmental impact statement for LGS's compliance status with these requirements. C-1 Appendix C Table C-1. Federal and State Environmental Requirements 1 Law/regulation Requirements Current operating license and license renewal Atomic Energy Act (42 This Act is the fundamental U.S. law on both the civilian and the military U.S.C. ? 2011 et seq.) uses of nuclear materials. On the civilian side, it provides for both the development and the regulation of the uses of nuclear materials and facilities in the United States. The Act requires that civilian uses of nuclear materials and facilities be licensed, and it empowers the NRC to establish by rule or order, and to enforce, such standards to govern these uses as "the Commission may deem necessary or desirable in order to protect health and safety and minimize danger to life or property." 10 CFR Part 51. Title 10 "Environmental Protection Regulations for Domestic Licensing and Code of Federal Related Regulatory Functions." This part contains environmental Regulations (10 CFR) Part protection regulations applicable to the NRC's domestic licensing and 51, Energy related regulatory functions. 10 CFR Part 54 "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." This part focuses on managing adverse effects of aging rather than noting all aging mechanisms. The rule is intended to ensure that important systems, structures, and components will maintain their intended function during the period of extended operation. 10 CFR Part 50 "Domestic Licensing of Production and Utilization Facilities." Regulations that the NRC issues under the Atomic Energy Act of 1954, as amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242), provide for the licensing of production and utilization facilities. This part also gives notice to all persons who knowingly supply--to any licensee, applicant, contractor, or subcontractor-- components, equipment, materials, or other goods or services that relate to a licensee's or applicant's activities subject to this part, that they may be individually subject to NRC enforcement action for violation of ? 50.5. Air quality protection Clean Air Act (CAA) (42 USC ? 7401 et seq.) The Clean Air Act (CAA) is a comprehensive Federal law that regulates air emissions. Among other things, this law authorizes EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and public welfare and to regulate emissions of hazardous air pollutants. EPA has promulgated NAAQS for six criteria pollutants: sulfur dioxide, nitrogen dioxide, carbon monoxide (CO), ozone, lead, and particulate matter. All areas of the United States must maintain ambient levels of these pollutants below the ceilings established by the NAAQS. Pennsylvania Air Pollution Control Act (P.L. 2119) The Pennsylvania Air Pollution Control Act establishes procedures for the protection of health and public safety during emergency conditions, creating a stationary air contamination source permit system and providing additional remedies for abating air pollution. Land use resources protection Coastal Zone Management The Coastal Zone Management Act (CZMA) was established to preserve, Act (16 USC ? 1451 et seq.) protect, develop and where possible, restore or enhance, the resources of the Nation's coastal zone. Water resources protection Clean Water Act (CWA) The Clean Water Act (CWA) establishes the basic structure for regulating (33 USC ? 1251 et seq.) discharges of pollutants into the waters of the United States and regulating and the NPDES quality standards for surface waters. (40 CFR 122) C-2 Appendix C Law/regulation Wild and Scenic River Act (16 USC ? 1271 et seq.) Requirements The Wild and Scenic River Act created the National Wild and Scenic Rivers System, which was established to protect the environmental values of free flowing streams from degradation by affecting activities, including water resources projects. Safe Drinking Water Act (42 USC ? 300f et seq.) The Safe Drinking Water Act (SDWA) is the principal Federal law that ensures safe drinking water for the public. Under the SDWA, EPA is required to set standards for drinking water quality and oversees all states, localities, and water suppliers that implement these standards. Pennsylvania Code, Title 25, Environmental Protection, Part I, Department of Environmental Protection, Chapter 92a, National Pollutant Discharge Elimination System Permitting, Monitoring, and Compliance (25 Pa Code 92a). The regulatory provisions contained in this Pennsylvania code implement the NPDES Program by the Pennsylvania Department of Environmental Protection under the Federal Act. Pennsylvania Code, Title 25, Environmental Protection, Part 1, Department of Environmental Protection Chapter 93, Water Quality Standards (25 Pa Code 93) This code sets forth water quality standards for surface waters in the State of Pennsylvania, including wetlands. These standards are based upon water uses that are to be protected and will be considered by the Pennsylvania Department of Environmental Protection in implementing its authority under the Clean Streams Law and other statutes that authorize protection of surface water quality. Pennsylvania Code, Title 25, Environmental Protection, Part V, Delaware River Basin Commission, Chapter 901, General Provisions (20 Pa Code 901) This code incorporates by reference among other things Parts 401, "Rules of Practice and Procedures," "Basin Regulations; Water Code and Administrative Manual Part III Water Quality Regulations," and 430, "Ground Water Protection Area: Pennsylvania," of 18 CFR containing regulations on conservation of power and water resources. Pennsylvania's Clean Streams Law (35 P.S. Section 691.1 et seq.) The Clean Streams Law provides additional remedies for abating pollution of waters; regulates discharges of sewage and industrial wastes; regulates the operation of mines; and regulates the impact of mining upon water quality, supply, and quantity. The law places responsibilities on landowners and land occupiers, and maintains primary jurisdiction over surface coal mining in Pennsylvania. Pennsylvania Safe Drinking The Pennsylvania Safe Drinking Water Act protects the public health and Water Act (P.L. 206, No. 43 safety by assuring that public water systems provide a safe and adequate and 25 PA Code 109) supply of water for human consumption by establishing drinking water quality standards, permit requirements, and design and construction standards. Waste management and pollution prevention Resource Conservation and RCRA gives EPA authority to control hazardous waste. Before a material Recovery Act (RCRA) can be classified as a hazardous waste, it first must be a solid waste as (42 USC ? 6901 et seq.) defined under the Resource Conservation and Recovery Act (RCRA). Hazardous waste is classified under Subtitle C of the RCRA. Parts 261, "Identification and Listing of Hazardous Waste," and 262, "Standards Applicable to Generators of Hazardous Waste," of 40 CFR contain all applicable generators of hazardous waste regulations. C-3 Appendix C Law/regulation Pollution Prevention Act (42 USC ? 13101 et seq.) Protected species Endangered Species Act (ESA) (16 USC ? 1531 et seq.) Requirements The Pollution Prevention Act formally established a national policy to prevent or reduce pollution at its source whenever feasible. The Act supplies funds for state and local pollution prevention programs through a grant program to promote the use of pollution prevention techniques by business. The Endangered Species Act (ESA) forbids any government agency, corporation, or citizen from taking (e.g., harming or killing) endangered animals without an Endangered Species Permit. The ESA also requires Federal agencies to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service if any Federal action may adversely affect any listed species or designated critical habitat. Magnuson-Stevens Fishery Conservation and Management Act (MSA) (P.L. 94-265), as amended through January 12, 2007 The Magnuson-Stevens Fishery Conservation and Management Act (MSA) includes requirements for Federal agencies to consider the impact of Federal actions on essential fish habitat and to consult with the National Marine Fisheries Service if any activities may adversely affect essential fish habitat. Marine Mammal Protection Act (MMPA) (16 USC ? 1361 et seq.) The Marine Mammal Protection Act (MMPA) prohibits the take of marine mammals in U.S. waters or by U.S. citizens on the high seas without an MMPA Take Permit issued by the National Marine Fisheries Service. MMPA also prohibits importation of marine mammals and marine mammal products into the United States. Fish and Wildlife Coordination Act (16 USC ? 661 et seq.) To minimize adverse impacts of proposed actions on fish and wildlife resources and habitat, the Fish and Wildlife Coordination Act requires that Federal agencies consult Government agencies regarding activities that affect, control, or modify waters of any stream or bodies of water. It also requires that justifiable means and measures be used in modifying plans to protect fish and wildlife in these waters. Pennsylvania Code, Title 58, Recreation, Part II, Fish and Boat Commission, Chapter 75, Endangered Species (58 PA Code 75) This code provides a lists of endangered, threatened, and candidate species in the State of Pennsylvania. The code prohibits the catching, taking, killing, possessing, importing or exporting from the State of Pennsylvania, selling, or offering to sale or purchase of any species listed without a special permit from Executive Director of the Pennsylvania Fish and Boat Commission. Historic preservation National Historic Preservation Act (NHPA) (16 USC ? 470 et seq.) The National Historic Preservation Act (NHPA) directs Federal agencies to consider the impact of their actions on historic properties. To comply with NHPA, Federal agencies must consult with State Historic Preservation Officers and, when applicable, tribal historic preservations officers. NHPA also encourages state and local preservation societies. 1 C.2. Operating Permits and Other Requirements 2 3 Table C-2 lists the permits and licenses issued by Federal, state, and local authorities for activities at LGS. C-4 Appendix C Table C-2. Licenses and Permits 1 Permit Number Dates Responsible Agency Operating license NPF-39 Issued: 08/8/1985 NRC Expires: 10/26/2024 Operating license NPF-85 Issued: 08/25/1989 NRC Expires: 06/22/2029 NPDES Permit PA0051926 Issued: 03/31/2006 Pennsylvania Expires: 03/31/2011 Department of Environmental Protection (administratively (PADEP) continued) NPDES Permit PA0052221 Issued: 07/1/2009 PADEP Expires: 06/30/2014 Submission of project for Delaware River Basin Commission (DRBC) approval and determination as to whether project impairs or conflicts with the DRBC comprehensive plan D-69-210 CP Submission of project for DRBC approval and determination as to whether project impairs or conflicts with the DRBC comprehensive plan D-69-52 CP Submission of project for DRBC approval and determination as to whether project impairs or conflicts with the DRBC comprehensive plan D-77-110 CP Submission of project for DRBC approval and determination as to whether project impairs or conflicts with the DRBC comprehensive plan D-65-76 CP Title V Operating Permit Issued: 11/7/1975 TVOP-46-00038 DRBC (Rev. 12- 11/02/2004) Expires: No expiration date indicated Issued: 02/18/1981 DRBC Expires: No expiration date indicated Issued: 10/24/1984 DRBC Expires: No expiration date indicated Issued: 12/18/1981 DRBC Expires: No expiration date indicated Issued: 12/07/2009 PADEP Expires: 12/07/2014 Approval of design modifications, operation, and maintenance of Bradshaw Reservoir Dam D09-181A Issued: 12/30/1986 Expires: 12/30/2036 C-5 PADEP Appendix C Permit Number Dates Responsible Agency Maintenance Dredging Permit 19616 Issued: 07/16/1976 PADEP Maintenance Dredging Permit 19615 General Permit No. 11 for Maintenance Dredging 044610317 Permit to operate a public water system or a substantially modified facility 4696508 Permit to operate a public water system or a substantially modified facility 4606501 Permit to operate a public water system or a substantially modified facility 4609503 Expires: No date listed on permit Issued: 07/16/1976 PADEP Expires: No date listed on permit Issued: 12/07/2010 PADEP Expires: No expiration date indicated Issued: 03/25/1997 PADEP Expires: No date listed on permit Issued: 06/30/2006 PADEP Expires: No date listed on permit Issued: 11/20/2009 PADEP Expires: No date listed on permit Notification of regulated PAD000797951 waste activity to obtain an EPA identification number for hazardous waste Issued: 01/01/2001 Certificate of registration/permit to operate storage tanks None Issued: 02/04/2011 Hazardous Materials Certificate of Registration 070810 750 001SU Issued: 06/09/2010 Fire Marshall approval for storage and handling of flammable and combustible liquid 172,943 Issued: 02/25/1972 Fire Marshall approval for storage and handling of flammable and combustible liquid 186,609 Fire Marshall approval for storage and handling of flammable and combustible liquid 186,610 EPA Expires: N/A PADEP Expires: Renewed Annually U.S. Department of Expires: 06/30/2013 Transportation Expires: No date listed on approval Issued: 08/15/1977 Expires: No date listed on approval Issued: 08/15/1977 Expires: No date listed on approval C-6 Pennsylvania Department of Labor and Industry, Boiler Section Pennsylvania Department of Labor and Industry, Boiler Section Pennsylvania Department of Labor and Industry, Boiler Section Appendix C Permit Number Dates Responsible Agency Fire Marshall approval for storage and handling of flammable and combustible liquid 187,162 Issued: 11/17/1977 Expires: No date listed on approval Pennsylvania Department of Labor and Industry, Boiler Section Environmental laboratory certificate of accreditation under PA Code 252 PA Lab ID No. 460128, Cert. 003 Issued: 08/31/2010 PADEP Permit to operate encroachment E 09-77A Issued: 02/12/1988 Approval for disposal of licensed material generated by licensee's activities N/A Expires: Renewed Annually PADEP Expires: 02/11/2038 Issued: 07/10/1996 (NRC) NRC and PADEP Issued: 03/23/1998 (PADEP) Expires: No date listed on approvals Source: Exelon 2011 1 C.3. Reference 2 3 4 5 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) Accession No. ML11179A104. C-7 APPENDIX CONSULTATION CORRESPONDENCE 1 CONSULTATION CORRESPONDENCE 2 D.1. 3 4 5 6 7 8 The Endangered Species Act of 1973, as amended; the Magnuson Stevens Fisheries Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 (NHPA) require that Federal agencies consult with applicable State and Federal agencies and groups before taking action that may affect threatened or endangered species, essential fish habitat, or historic and archaeological resources, respectively. This appendix contains consultation documentation. 9 10 11 Background Table D-1 lists the consultation documents sent between the U.S. Nuclear Regulatory Commission (NRC) and other agencies. The NRC staff is required to consult with these agencies based on the requirements of the statutes listed above. Table D-1. Consultation Correspondence 12 Author Recipient M. Roberts, U.S. Fish and Wildlife Service (USFWS) Date of Letter/email September 8, 2011 ML11258A248 Wrona, D., NRC O. Braun, Pennsylvania Game Commission September 8, 2011 ML11234A065 Wrona, D., NRC C. Urbarn, Pennsylvania Fish & Boat Commission September 8, 2011 ML11234A024 Wrona, D., NRC H. Ellis, Absentee-Shawnee Tribe of Oklahoma September 13, 2011 ML112340045 Wrona, D., NRC B. Obermeyer, Delaware Tribe September 13, 2011 ML112340045 Wrona, D., NRC R. Dushane, Cultural Resource Officer, Eastern Shawnee Tribe of Oklahoma September 13, 2011 ML112340045 Wrona, D., NRC C. Halftown, Heron Clan Representative, Cayuga Nation September 13, 2011 ML112340045 Wrona, D., NRC T. Francis, Tribal Historic Preservation Office, Delaware Nation September 13, 2011 ML112340045 Wrona, D., NRC R. Hill, Tonawanda Seneca Nation September 13, 2011 ML112340045 Wrona, D., NRC N. Patterson, Tuscarora Nation September 13, 2011 ML112340045 Wrona, D., NRC J. Bergevin, Oneida Indian Nation September 13, 2011 ML112340045 Wrona, D., NRC C. Burke, Oneida Nation of Wisconsin September 13, 2011 ML112340045 Wrona, D., NRC T. Gonyea, Onondaga Nation September 13, 2011 ML112340045 Wrona, D., NRC L. Watt, Seneca Nation of Indians September 13, 2011 ML112340045 Wrona, D., NRC D-1 Appendix D Author Recipient Date of Letter/email Wrona, D., NRC P. Barton, Seneca-Cayuga Tribe of Oklahoma September 13, 2011 ML112340045 Wrona, D., NRC S. White, Stockbridge-Munsee Band of the Mohican Nation of Wisconsin September 13, 2011 ML112340045 Wrona, D., NRC A. Printup, St. Regis Mohawk Tribe September 13, 2011 ML112340045 Wrona, D., NRC K. Jumper, Shawnee Tribe September 13, 2011 ML112340045 Wrona, D., NRC J. Cutler, Pennsylvania Historic and Museum Commission September 15, 2011 ML11221A265 Wrona, D., NRC C. Firestone, Pennsylvania Department of Conservation & Natural Resources September 16, 2011 ML11230B346 Wrona, D., NRC T. McCulloch, Advisory Council on Historical Preservation September 16, 2011 ML11245A083 D. Wrona, NRC September 23, 2011 ML11279A113 Obermeyer, B., Delaware Tribe Historic Preservation Office White, S., Stockbridge-Munsee Tribal Historic Preservation Office D. Wrona, NRC September 28, 2011 ML11279A114 Urban, C., Pennsylvania Fish & Boat Commission D. Wrona, NRC October 5, 2011 ML11291A077 Gonyea, A., Onondaga Nation D. Wrona, NRC October 15, 2011 ML11305A006 McLearn, D., Pennsylvania Historical & Museum Commission, Bureau for Historic Preservation D. Wrona, NRC October 26, 2011 ML11307A383 Mowery, O., Pennsylvania Game Commission D. Wrona, NRC November 17, 2011 ML11339A042 Riley, C., USFWS D. Wrona, NRC November 22, 2011 ML11339A043 Susco, J., NRC D. Morris, National Marine Fisheries Service May 30, 2012 ML12138A347 Colligan, M., National Marine Fisheries Service J. Susco, NRC June 27, 2012 ML12226A163 D-2 1 APPENDIX 2 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 1 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 2 3 4 5 6 7 8 9 10 11 This appendix contains a chronological listing of correspondence between the U.S. Nuclear Regulatory Commission (NRC) and external parties as part of its environmental review for Limerick Generating Station, Units 1 and 2 (LGS). All documents, with the exception of those containing proprietary information, are available electronically from the NRC's Public Electronic Reading Room found on the Internet at the following Web address: http://www.nrc.gov/readingrm.html. From this site, the public can gain access to the NRC's Agencywide Documents Access and Management System (ADAMS), which provides text and image files of NRC's public documents in ADAMS. The ADAMS accession number for each document is included in the following list. To locate a reference in ADAMS, click on the "Simple Search" tab at the top of the web page, and enter the ADAMS accession number in the search box. 12 E.1. 13 14 Table E-1 lists the environmental review correspondence in date order beginning with the request by Exelon to renew the operating license for LGS. Environmental Review Correspondence Table E-1. Environmental Review Correspondence 15 Date Correspondence Description ADAMS No. June 22, 2011 Letter from Exelon forwarding the LGS license renewal application and request to renew operating licenses for additional 20 years ML11179A096 June 30, 2011 NRC press release announcing the availability of license renewal application for LGS ML11181A084 July 13, 2011 Letter to Exelon, "Receipt and Availability of the License Renewal Application for the Limerick Generating Station, Units 1 and 2" ML11180A040 July 26, 2011 Federal Register Notice of Receipt and Availability of Application for Renewal of Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20-Year Period (76 FR 44624) ML11180A178 August 12, 2011 Letter to Exelon, "Determination of Acceptability and Sufficiency for Docketing, Proposed Review Schedule, and Opportunity for a Hearing Regarding the Application from Exelon Generating Station Company, LLC for Renewal of the Operating Licenses for Limerick Generating Station, Units 1 and 2" ML11206A206 August 17, 2011 Letter to Exelon, "Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process for License Renewal for the Limerick Generating Station, Units 1 and 2" ML111213A206 August 24, 2011 Federal Register Notice of Acceptance for Docketing of the ML11206A206 Application and Notice for Opportunity for Hearing Regarding the Renewal of Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20 Years Period, Exelon Generation Company , LLC, Limerick Generating Station (76 FR 52992) August 26, 2011 Federal Register Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping Process for Limerick Generating Station, Units 1 and 2 (76 FR 53498) E-1 ML11214A048 Date Correspondence Description ADAMS No. September 7, 2011 NRC press release announcing the LGS license renewal environmental scoping meeting ML11250A162 September 8, 2011 Letter to Mr. Mark Roberts, U.S. Fish and Wildlife Service ML11258A248 September 8, 2011 Letter to Ms. Olivia Braun, Environmental Planner, Pennsylvania ML11234A650 Game Commission September 8, 2011 Letter to Mr. Chris Urban, Pennsylvania Fish and Boat Commission ML11234A024 September 13, 2011 Letter to Henryetta Ellis, Absentee-Shawnee Tribe of Oklahoma ML112340045 September 13, 2011 Letter to Clint Halftown, Heron Clan Representative, Cayuga Nation ML112340045 September 13, 2011 Letter to Ms. Tamara Francis, Tribal Historic Preservation Office, ML112340045 Delaware Nation September 13, 2011 Letter to Dr. Brice Obermeyer, Delaware Tribe ML112340045 September 13, 2011 Letter to Ms. Robin Dushane, Cultural Resource Officer, Eastern Shawnee Tribe of Oklahoma ML112340045 September 13, 2011 Letter to Chief Rogers Hill, Tonawanda Seneca Nation ML112340045 September 13, 2011 Letter to Mr. Neil Patterson, Director, Tuscarora Nation ML112340045 September 13, 2011 Letter to Ms. Kim Jumper, Tribal Historic Officer, Shawnee Tribe ML112340045 September 13, 2011 Letter to Mr. Arnold Printup, Historic Preservation Officer, St. Regis Mohawk Tribe ML112340045 September 13, 2011 Letter to Ms. Sherry White, Cultural Preservation Officer, Stockbridge-Munsee Band of the Mohican Nation of Wisconsin ML112340045 September 13, 2011 Letter to Mr. Paul Barton, Historic Preservation Officer Seneca-Cayuga Tribe of Oklahoma ML112340045 September 13, 2011 Letter to Ms. Lane Watt, Tribal Historic Preservation Office Seneca Nation of Indians ML112340045 September 13, 2011 Letter to Mr. Tony Gonyea, Faithkeeper, Onondaga Nation ML112340045 September 13, 2011 Letter to Ms. Corina Burke, Tribal Historic Preservation Office Oneida Nation of Wisconsin ML112340045 September 13, 2011 Letter to Mr. Jesse Bergevin, Historian, Oneida Indian Nation ML112340045 September 15, 2011 Letter to Ms. Jean Cutler, Deputy State Historic Preservation Officer, Pennsylvania Historical and Museum Commission ML11221A265 September 16, 2011 Letter to Mr. Chris Firestone, Pennsylvania Department of Conservation & Natural Resources ML11230B346 September 16, 2011 Letter to Mr. Tom McCulloch, Advisory Council on Historic Preservation ML11245A083 September 23, 2011 Letter from Dr. Brice Obermeyer, Delaware Tribe Historic Preservation Office ML11279A113 September 28, 2011 Letter from Ms. Sherry White, Tribal Historic Preservation Officer, Stockbridge-Munsee Tribal Historic Preservation Office ML11279A114 E-2 Appendix E Date Correspondence Description ADAMS No. October 5, 2011 Letter from Mr. Chris Urban, Pennsylvania Fish and Boat Commission ML11291A077 October 15, 2011 Letter from Mr. Anthony Gonyea, Onondaga Nation ML11305A006 October 26, 2011 Letter from Mr. Douglas McLearen, Pennsylvania Historical and Museum Commission ML11307A383 November 17, 2011 Letter from Ms. Olivia Mowery, Pennsylvania Game Commission ML11339A042 November 22, 2011 Letter from Mr. Clinton Riley, U.S. Fish and Wildlife Service ML11339A043 February 24, 2012 Letter to Exelon, "Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application Environmental Review" ML12041A443 March 27, 2012 Letter from Exelon, "Limerick Generating Station, Units 1 and ML12088A366 2-Response to NRC Request for Additional Information, Dated February 28, 2012, Related to the License Renewal Application" April 11, 2012 Memorandum, "Summary of Telephone Conference Call on February 23, 2012, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Request for Additional Information Pertaining to the Limerick Generating Station License Renewal Application" ML12083A211 May 21, 2012 Summary of Site Audit Related to the Environmental Review of the License Renewal Application for Limerick Generating Station, Units 1 and 2 ML12124A127 May 30, 2012 Letter to Mr. Daniel Morris, National Marine Fisheries Service ML12138A347 June 27, 2012 Letter from Ms. Mary Colligan, National Marine Fisheries Service ML12226A163 E-3 1 APPENDIX 2 DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 3 IMPACT ANALYSIS 1 2 DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE IMPACTS ANALYSIS 3 F.1. Description of Projects Considered 4 5 6 7 8 9 10 11 12 13 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described in Sections 4.1-4.9, are combined with other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. The U.S. Nuclear Regulatory Commission (NRC) staff (staff) used the information in the environmental report (ER); responses to requests for additional information (RAIs); information from other Federal, State, and local agencies; scoping comments; and information gathered during the visits to the Limerick Generating Station, Units 1 and 2 (LGS) site to identify other past, present, and reasonably foreseeable actions. Other actions and projects that were identified during this review, and considered in the staff's independent analysis of the potential cumulative effects, are described in Table F-1. 14 Table F-1. Projects and Actions Considered in the Cumulative Impacts Analysis Project Name Summary of Project Location Status Moser Generating 60 MW, 3 unit oil-fired peaking plant Station Oil Plant Lower Operational (Exelon Pottstown Corp. 2012); (Exelon Township, 2011) approximately 2 miles (mi) west (W) of LGs Linfield Energy Center 616 MW, 3 unit natural gas plant 3 mi northwest Air-quality permitted (NW) of LGS in 2002, but project "withdrawn" and not constructed (EJN); (Enviro 2002) Schuylkill Generating Station 196 MW, 3 unit oil power plant 29 mi NW of LGS Cromby Generation Station 2 unit fossil fuel power plant located on the Schuylkill River 8 mi south (S) Both units were of LGS retired from service in 2011 (Exelon Corp. 2012) Titus Coal Plant 261 MW, 5 unit coal power plant 18 mi NW of LGS Ontelaunee Energy Center Gas Plant 728 MW, 3 unit gas power plant 23 mi northeast Operational (GEO (NE) of LGS 2012b) Montenay Montgomery LP Waste Plant 32 MW, 1 unit waste power plant 17 mi southeast Operational (GEO (SE) of LGS 2012c) Grays Ferry 193 MW, 2 unit gas power plant Cogeneration Gas Plant F-1 29 mi SE of LGS Operational (Exelon Corp. 2012) Operational (GEO 2012a) Operational (GEO 2012d) Appendix F Project Name Summary of Project Location Chester Generating Station Oil Plant 56 MW, 3 unit oil power plant 20 mi Operational (GEO southwest (SW) 2012e) of LGS Philadelphia Refinery Waste Plant 30 MW, 3 unit waste power plant 30 mi SE of LGS Operational (GEO 2012f) Delaware Generating Station Oil Plant 392 MW, 4 unit oil power plant 30 mi SE of LGS Operational (GEO 2012g) Eddystone 1,589 MW, 8 unit coal power plant Generation Station Coal Plant 20 mi SE of LGS Operational (GEO 2012h) Florida Power & 836 MW, 4 unit gas power plant Light Energy Marcus Hook Gas Plant 30 mi SE of LGS Operational (GEO 2012i) Chester Operational Coal Plant 67 MW, 1 unit coal power plant 29 mi SE of LGS Operational (GEO 2012j) Royersford Borough Sewage/wastewater treatment plant that discharges 54 millions of gallons per day (mgd) to the Schuylkill River 4 mi SE of LGS Operational (EPA 2012a) Spring City Borough Sewage/wastewater treatment plant that discharges .345 mgd to the Schuylkill River 7 mi SE of LGS Operational (EPA 2012a) Limerick Township Municipal Authority Sewage/wastewater treatment plant that 3 mi SE of LGS Operational (EPA discharges 1.7 mgd to the Schuylkill River 2012a) East Vincent Municipal Authority Sewage/wastewater treatment plant that discharges .5 mgd to the Schuylkill River North Coventry Municipal Authority Sewage/wastewater treatment plant that 2 mi W of LGS Operational (EPA discharges 1.5 mgd to the Schuylkill River 2012a) 4 mi S of LGS Status Operational (EPA 2012a) Phoenixville Sewage/wastewater treatment plant that Borough Sewage discharges 4 mgd to the Schuylkill River Treatment Plant 9 mi SE of LGS Operational (EPA 2012a) Lower Frederick Sewage/wastewater treatment plant that Township Sewage discharges .2 mgd to the Perkiomen Treatment Plant Creek 7 mi NE of LGS Operational (EPA 2012a) F-2 Appendix F Project Name Summary of Project Location Schwenksville Sewage/wastewater treatment plant that Borough Authority discharges .3 mgd to the Perkiomen Sewage Creek Treatment Plant Pottstown Water Treatment Plant Status 7 mi NE of LGS Operational (EPA 2012a) Sewage/wastewater treatment plant 2 mi W of LGS Operational (EPA withdraws up to 5 mgd from the Schuylkill 2012b) River Pennsylvania Sewage/wastewater treatment plant that American Water discharges .111 mgd to the Schuylkill Company, Shady River Lane Water Treatment Plant 2 mi S of LGS Operational (EPA 2012a) JBS Souderton Inc., Industrial Waste Water Treatment Plant 15 mi NE of LGS Operational (DRBC 2011) Sewage/wastewater treatment plant that discharges .832 mgd to the Skippack Creek at River Mile 92.47 - 32.3 - 3.0 - 12.8 (Delaware River - Schuylkill River - Perkiomen Creek - Skippack Creek) Warwick Drainage Public wastewater collection, treatment, 8 mi NW of Company and disposal that discharges .0135 mgd to LGS the French Creek (Schuylkill River Tributary) Operational (EPA 2012a) Doehler-Jarvis Limited Partnership Aluminum die casting 5 mi W of LGS Operational (EPA 2012a) Sun Co., Inc. Major gas service station 3 mi NE of LGS Operational (EPA 2012a) Pottstown Trap Quarry Sanatoga Quarry 3,650 feet NW, Operational (Exelon directly 2011) adjacent to Schuylkill River and contiguous with the LGS plant site property Uniform Tubes, Inc. Steel parts manufacturing 6 mi SE of LGS Operational (EPA 2012a) Plotts Oil Co. Heating oil distribution 4 mi SE of LGS Operational (EPA 2012a) Specialty Chemical Systems Inorganic chemical production 4 mi SE of LGS Operational (EPA 2012a) Spring City Electric Manufacturing Company Iron foundry discharges 4 mi SE of LGS Operational (EPA 2012a) Unitech Services Group, Inc. Industrial launderer 3 mi SE of LGS Operational (EPA 2012a) F-3 Appendix F Project Name Summary of Project Location Smurfit-Stone Container Paper packaging 9 mi SE of LGS Operational (EPA 2012a) Wyeth Pharmaceuticals Biotechnology research and development 8 mi SE of LGS Operational (EPA 2012a) GlaxoSmithKline Pharmaceutical manufacturing 7 mi SE of LGS Operational (EPA 2012a) Evansburg State Park 3,349 acre state park in south-central Montgomery County between Norristown and Collegeville 10 mi east of LGS Operational (DCNR 2012a) Fort Washington State Park 493 acre state park in Springfield and Whitemarsh Townships, Montgomery County 20 mi SE of LGS Operational (DCNR 2012b) Norristown Farm Park 690 acre park in East Norriton and West Norriton Townships and the Borough of Norristown 14 mi SE of LGS Operational (DCNR 2012c) Marsh Creek State Park 1,727 acre state park in Chester County 11 mi SW of LGS Operational (DCNR 2012d) Pickering Creek Preserve 25 acre park in Schuylkill Township 13 mi SE of LGS Operational Valley Forge National Park 3,500 acre national historic park 11 mi SE of LGS Operational French Creek State Park 7,730 acre state park in North Coventry and Warwick Townships in Chester County and Robeson and Union Townships in Berks County 10 mi W of LGS Operational (DCNR 2012e) Ridley Creek State Park 2,606 acres of Delaware County woodlands and meadows 25 mi SE of LGS Operational (DCNR 2012f) At LGS Operational (Exelon 2011) Independent The ISFSI provides dry storage for spent Spent Fuel fuel at the LGS site Storage Installation (ISFSI) Recticon/Allied Steel Corp. Comprehensive Environmental Response, 1 mi S of LGS Compensation, and Liability Act (CERCLA) site Occidental Occidental Chemical Corporation is Chemical remediating under the oversight of EPA Corporation Remediation Site (Formerly Firestone Tire and Rubber Manufacturing Facility) F-4 2.5 mi W of LGS Status CERCLA site (EPA) Superfund site (Exelon 2011) Appendix F 1 F.2. References 2 3 4 5 6 [DRBC] Delaware River Basin Commission. 2012. DOCKET NO. D-1996-021-4, JBS Souderton, Inc., Industrial Wastewater Treatment Plant, Franconia Township, Montgomery County, Pennsylvania. Available at (accessed 7 July 2012). 7 8 [EJN] Energy Justice Network. Linfield Energy Center. Available at (accessed 11 July 2012). 9 10 11 12 [Enviro] Enviro.blr.com. 2002. Environmental Compliance News. "DEP Issues Air Plan Approval to Florida Power and Light for Its Linfield Energy Center Project." April 10, 2002. Available at (accessed 11 July 2012). 13 14 15 16 [EPA] U.S. Environmental Protection Agency. 2012a. Envirofacts. Air Facility System (AFS). Available at (accessed 11 July 2012). 17 18 19 [EPA] U.S. Environmental Protection Agency. 2012a. Envirofacts, Permit Compliance System (PCS) and Integrated Compliance Information System (ICIS) databases. Available at (accessed 11 July 2012). 20 21 22 23 24 [EPA] U.S. Environmental Protection Agency. 2012b. Envirofacts. Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS). Available at (accessed 11 July 2012) 25 26 [Exelon Corp] Exelon Corporation. 2012. Energy Diversity for Pennsylvania. Available at (accessed 11 July 2012). 27 28 29 30 [Exelon] Exelon Generation Company, LLC. 2011. Applicant's Environmental Report -Operating License Renewal Stage, Limerick Generating Station, Units 1 and 2, Docket Numbers 50-352 and 50-353, License Numbers NPF-39 and NPF-85. Exelon Generation Company, LLC. Agencywide Documents Access and Management Systems Accession No. ML11179A104. 31 32 33 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012a. Available at (accessed 8 August 2012). 34 35 36 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012b. Available at (accessed 8 August 2012). 37 38 39 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012c. Available at (accessed 8 August 2012). 40 41 42 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012d. Available at (accessed 8 August 2012). F-5 Appendix F 1 2 3 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012e. Available at (accessed 8 August 2012). 4 5 6 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012f. Available at (accessed 8 August 2012). 7 8 [GEO] Global Energy Observatory. 2012a. Available at (accessed 11 July 2012). 9 10 [GEO] Global Energy Observatory. 2012b. Available at (accessed 11 July 2012). 11 12 [GEO] Global Energy Observatory. 2012c. Available at (accessed 11 July 2012). 13 14 [GEO] Global Energy Observatory. 2012d. Available at (accessed 11 July 2012). 15 16 [GEO] Global Energy Observatory. 2012e. Available at (accessed 11 July 2012). 17 18 [GEO] Global Energy Observatory. 2012f. Available at (accessed 11 July 2012). 19 20 [GEO] Global Energy Observatory. 2012g. Available at (accessed 11 July 2012). 21 22 [GEO] Global Energy Observatory. 2012h. Available at (accessed 11 July 2012). 23 24 [GEO] Global Energy Observatory. 2012i. Available at (accessed 11 July 2012). 25 26 [GEO] Global Energy Observatory. 2012j. Available at (accessed 11 July 2012). F-6 U.S. NUCLEAR REGULATORY COMMISSION NRC FORM 335 (12-2010) NRCMD 3.7 1. REPORT NUMBER (Assigned by NRC, Add Vol., Supp., Rev., and Addendum Numbers, if any .) BIBLIOGRAPHIC DATA SHEET NUREG-1437, Supplement 49 (See instructions on the reverse) 2. TITLE AND SUBTITLE Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Draft Report 3. DATE REPORT PUBLISHED r-?::~; I ;~~---- 4. FIN OR GRANT NUMBER 5. AUTHOR(S) See Chapter 10 6. TYPE OF REPORT Technical 7. PERIOD COVERED (Inclusive Dates) 8. PERFORMING ORGANIZATION ?NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor, provide name and mailing address.) Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-001 9. SPONSORING ORGANIZATION- NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division , Office or Region, U.S. Nuclear Regulatory Commission, and mailing address.) Same os above 10. SUPPLEMENTARY NOTES Docket Nos. 50-352, 50-353 11. ABSTRACT (200 words or less) This draft supplemental environmental impact statement has been prepared in response to an application submitted by Exelon Generation Company, LLC (Exelon) to renew the operating license for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20 years. This draft supplemental environmental impact statement includes the preliminary analysis that evaluates the environmental impacts of the proposed action and alternatives to the proposed action. Alternatives considered include natural gas combined-cycle (NGCC); supercritical pulverized coal; new nuclear; wind power; purchased power; and not renewing the license (the no action alternative). The U.S. Nuclear Regulatory Commission's preliminary recommendation is that the adverse environmental impacts oflicense renewal for LGS are not great enough to deny the option of license renewal for energy planning decisionmakers. This recommendation is based on the following: o the analysis and findings in NUREG 1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants; o the environmental report submitted by Exelon; o consultation with Federal, state, and local agencies; o the NRC's environmental review; and o consideration of public comments received during the scoping process 12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) Limerick Generating Station, Units 1 and 2 Limerick Exelon Generation Company, LLC Exelon Supplemental to the Generic Environmental Impact Statement, SEIS Generic Environmental Impact Statement, GElS National Environmental Policy Act, NEP A License Renewal NUREG- 1437, Supplement 49 NRC FORM 335 (12-201 0) 13. AVAILABILITY STATEMENT unlimited 14. SECURITY CLASSIFICATION (This Page) unclassified (This Report) unclassified 15. NUMBER OF PAGES 16. PRICE Printed on recycled paper Federal Recycling Program UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555-0001 -------------------OFFICIAL BUSINESS NUREG-1437 Supplement 49 Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Limerick Generating Station, Units 1 and 2 April 2013