ML13120A078
| ML13120A078 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/30/2013 |
| From: | Perkins L T Office of Nuclear Reactor Regulation |
| To: | |
| Beltz, G | |
| References | |
| NUREG-1437, Supp 49 DFC | |
| Download: ML13120A078 (585) | |
Text
{{#Wiki_filter:Generic Environmental Impact Statement for License Renewal of Nuclear Plants
Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Draft Report for Comment Office of Nuclear Reactor Regulation NUREG-1437 Supplement 49
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Generic Environmental Impact Statement for License Renewal of Nuclear Plants
Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Draft Report for Comment
Manuscript Completed: March 2013 Date Published: April 2013
Office of Nuclear Reactor Regulation NUREG-1437 Supplement 49
COMMENTS ON DRAFT REPORT 1 Any interested party may submit comments on this report for consideration by the NRC staff. 2 Comments may be accompanied by additional relevant information or supporting data. Please 3 specify the report number NUREG -1437, Supplement 49, in your comments, and send them b y 4 the end of the comment period specified in the Federal Register notice announcing the 5 availability of this report. 6 Addresses: You may submit comments by any one of the following methods. Please include 7 Docket ID NRC-2011-0166 in the subject line of your comments. Comments submitted in 8 writing or in electronic form will be posted on the NRC website and on the Federal rulemaking 9 website http://www.regulations.gov. 10 Federal Rulemaking Website
- Go to http://www.regulations.gov and search for documents 11 filed under Docket ID NRC-2011-0 166. Address questions about NRC dockets to Carol 12 Gallagher at 301-492-3668 or by e
-mail at Carol.Gallagher@nrc.gov. 13 Mail comments to
- Cindy Bladey, Chief , Rules, Announcements, and Directives Branch 14 (RADB), Division of Administrative Services , Office of Administration , Mail Stop:
15 TWB-05-B01M , U.S. Nuclear Regulatory Commission , Washington, DC 20555 -0001. Faxes 16 may be sent to RADB at 301 -492-3446. 17 For any questions about the material in this report, please contact Leslie Perkins, NRC 18 Environmental Project Manager, a t 1-800-368-5642, extension 2375, or by e -mail at 19 leslie.perkins@nrc.gov Please be aware that any comments that you submit to the NRC will be considered a public 21 record and entered into the Agencywide Documents Access and Management System 22 (ADAMS). Do not provide information you would not want to be publicly available. 23 NUREG-1437, Supplement 49, has been reproduced from the best available copy . iii ABSTRACT 1 This draft supplemental environmental impact statement has been prepared in response to an 2 application submitted by Exelon Generation Company, LLC (Exelon) to renew the operating 3 license for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20 years. 4 This draft supplemental environmental impact statement includes the preliminary analysis that 5 evaluates the environmental impacts of the proposed action and alternatives to the proposed 6 action. Alternatives considered include natural gas combined -cycle (NGCC); supercritical 7 pulverized coal; new nuclear; wind power; purchased power; and not renewing the license (the 8 no action alternative). 9 The U.S. Nuclear Regulatory Commission 's preliminary recommendation is that the adverse 10 environmental impacts of license renewal for LGS are not great enough to deny the option of 11 license renewal for energy planning decisionmakers. This recommendation is based on the 12 following: 13 the analysis and findings in NUREG -1437, Volumes 1 and 2, Generic 14 Environmental Impact Statement for License Renewal of Nuclear Plants; 15 the environmental report submitted by Exelon; 16 consultation with Federal, state, and local agencies; 17 the NRC's environmental review; and 18 consideration of public comments received during the scoping process. 19
v TABLE OF CONTENTS 1 ABSTRACT .............................................................................................................................. iii 2 TABLE OF CONTENTS
............................................................................................................ v 3 FIGURES ..................................................................................................................................
xi 4 TABLES ................................................................................................................................. xiii 5 EXECUTIVE
SUMMARY
.........................................................................................................
xv 6 ABBREVIATIONS AND ACRONYMS
....................................................................................
xxi 7 1.0 PURPOSE AND NEED FOR ACTION
.............................................................................. 1-1 8 1.1. Proposed Federal Action............................................................................................... 1-1 9 1.2. Purpose and Need for the Proposed Federal Action ..................................................... 1-1 10 1.3. Major Environmental Review Milestones ....................................................................... 1-2 11 1.4. Generic Environmental Impact Statement ..................................................................... 1-3 12 1.5. Supplemental Environmental Impact Statement ............................................................ 1-6 13 1.6. Cooperating Agencies ................................................................................................... 1-6 14 1.7. Consultations ................................................................................................................ 1-6 15 1.8. Correspondence ........................................................................................................... 1-7 16 1.9. Status of Compliance .................................................................................................... 1-7 17 1.10. References .................................................................................................................. 1-7 18 2.0 AFFECTED ENVIRONMENT ............................................................................................ 2-1 19 2.1. Facility Description ........................................................................................................ 2-1 20 2.1.1. Reactor and Containment Systems .................................................................. 2-1 21 2.1.2. Radioactive Waste Management ..................................................................... 2-1 22 2.1.3. Nonradiological Waste Management................................................................ 2-7 23 2.1.4. Plant Operation and Maintenance .................................................................... 2-9 24 2.1.5. Power Transmission System ............................................................................ 2-9 25 2.1.6. Cooling and Auxiliary Water Systems ............................................................ 2-16 26 2.1.7. Facility Water Use and Quality ....................................................................... 2-21 27 2.2. Surrounding Environment ........................................................................................... 2-23 28 2.2.1. Land Use ....................................................................................................... 2-24 29 2.2.2. Air Quality and Meteorology ........................................................................... 2-25 30 2.2.3. Geologic Environment .................................................................................... 2-27 31 2.2.4. Surface Water Resources .............................................................................. 2-30 32 2.2.5. Groundwater Resources ................................................................................ 2-34 33 2.2.6. Aquatic Resources ......................................................................................... 2-37 34 2.2.7. Terrestrial Resources ..................................................................................... 2-47 35 2.2.8. Protected Species and Habitats ..................................................................... 2-50 36 2.2.9. Socioeconomics ............................................................................................. 2-65 37 2.2.10. Historic and Archaeological Resources .......................................................... 2-80 38 Table of Contents vi 2.3. Related Federal and State Activities ........................................................................... 2-84 1 2.4. References ................................................................................................................. 2-84 2 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT ..................................................... 3-1 3 3.1. References ................................................................................................................... 3-3 4 4.0 ENVIRONMENTAL IMPACTS OF OPERATION .............................................................. 4-1 5 4.1. Land Use ...................................................................................................................... 4-1 6 4.2. Air Quality ..................................................................................................................... 4-2 7 4.3. Geologic Environment ................................................................................................... 4-2 8 4.3.1. Geology and Soils ............................................................................................ 4-2 9 4.4. Surface Water Resources ............................................................................................. 4-3 10 4.4.1. Generic Surface Water Issues ......................................................................... 4-3 11 4.4.2. Surface Water Use Conflicts ............................................................................ 4-3 12 4.5. Groundwater Resources ............................................................................................... 4-4 13 4.5.1. Generic Groundwater Issues ........................................................................... 4-5 14 4.5.2. Groundwater Use and Quality Conflicts ........................................................... 4-5 15 4.6. Aquatic Resources ........................................................................................................ 4-7 16 4.6.1. Exposure of Aquatic Organisms to Radionuclides ............................................ 4-8 17 4.7. Terrestrial Resources .................................................................................................... 4-8 18 4.7.1. Generic Terrestrial Resources Issues .............................................................. 4-9 19 4.7.2. Effects on Terrestrial Resources (Non
-Cooling System Impacts)
..................... 4-9 20 4.8. Protected Species and Habitats .................................................................................. 4-10 21 4.8.1. Correspondence with Federal and State Agencies......................................... 4-10 22 4.8.2. Aquatic Species and Habitats ........................................................................ 4-11 23 4.8.3. Terrestrial Species and Habitats .................................................................... 4-16 24 4.9. Human Health ............................................................................................................. 4-21 25 4.9.1. Generic Human Health Issues ....................................................................... 4-21 26 4.9.2. Radiological Impacts of Normal Operations ................................................... 4-22 27 4.9.3. Microbiological Organisms ............................................................................. 4-25 28 4.9.4. Electromagnetic Fields
-Acute Effects
.......................................................... 4-26 29 4.9.5. Electromagnetic Fields
-Chronic Effects
....................................................... 4-27 30 4.10. Socioeconomics ........................................................................................................ 4-28 31 4.10.1. Generic Socioeconomic Issues ...................................................................... 4-28 32 4.10.2. Housing ......................................................................................................... 4-29 33 4.10.3. Public Services
-Public Utilities
..................................................................... 4-29 34 4.10.4. Offsite Land Use ............................................................................................ 4-30 35 4.10.5. Public Services
-Transportation
.................................................................... 4-31 36 4.10.6. Historic and Archaeological Resources .......................................................... 4-31 37 4.10.7. Environmental Justice .................................................................................... 4-32 38 4.10.8. Conclusion ..................................................................................................... 4-39 39 4.11. Evaluation of New and Potentially Significant Information ......................................... 4-39 40 Table of Contents vii 4.12. Cumulative Impacts ................................................................................................... 4-41 1 4.12.1. Air Quality ...................................................................................................... 4-42 2 4.12.2. Water Resources ........................................................................................... 4-43 3 4.12.3. Aquatic Resources ......................................................................................... 4-46 4 4.12.4. Terrestrial Resources ..................................................................................... 4-48 5 4.12.5. Human Health ................................................................................................ 4-50 6 4.12.6. Socioeconomics ............................................................................................. 4-51 7 4.12.7. Cultural Resources ........................................................................................ 4-52 8 4.12.8. Summary of Cumulative Impacts ................................................................... 4-52 9 4.13. References ................................................................................................................ 4-54 10 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS ...................................... 5-1 11 5.1. Design-Basis Accidents ................................................................................................ 5-1 12 5.2. Severe Accidents .......................................................................................................... 5-2 13 5.3. Severe Accident Mitigation Alternatives ........................................................................ 5-3 14 5.4. References ................................................................................................................. 5-14 15 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE , 16 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS ...................... 6-1 17 6.1. The Uranium Fuel Cycle ............................................................................................... 6-1 18 6.2. Greenhouse Gas Emissions ......................................................................................... 6-3 19 6.2.1. Existing Studies ............................................................................................... 6-3 20 6.2.2.
Conclusions:
Relative Greenhouse Gas Emissions
......................................... 6-9 21 6.3. References ................................................................................................................. 6-10 22 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ................................................. 7-1 23 7.1. Decommissioning.......................................................................................................... 7-1 24 7.2. References ................................................................................................................... 7-2 25 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES ........................................................ 8-1 26 8.1 Natural Gas Combined
-Cycle Alternative ...................................................................... 8-5 27 8.1.1. Air Quality
........................................................................................................ 8-7 28 8.1.2. Groundwater Resources .................................................................................. 8-8 29 8.1.3. Surface Water Resources ................................................................................ 8-9 30 8.1.4. Aquatic Resources ......................................................................................... 8-10 31 8.1.5. Terrestrial Resources ..................................................................................... 8-11 32 8.1.6. Human Health ................................................................................................ 8-12 33 8.1.7. Land Use ....................................................................................................... 8-12 34 8.1.8. Socioeconomics ............................................................................................. 8-13 35 8.1.9. Transportation ................................................................................................ 8-14 36 8.1.10. Aesthetics ...................................................................................................... 8-14 37 8.1.11. Historic and Archaeological Resources .......................................................... 8-15 38 8.1.12. Environmental Justice .................................................................................... 8-15 39 8.1.13. Waste Management ....................................................................................... 8-16 40 Table of Contents viii 8.2. Supercritical Pulverized Coal
-Fired Alternative
........................................................... 8-17 1 8.2.1. Air Quality ...................................................................................................... 8-18 2 8.2.2. Groundwater Resources ................................................................................ 8-20 3 8.2.3. Surface Water Resources .............................................................................. 8-21 4 8.2.4. Aquatic Resources ......................................................................................... 8-22 5 8.2.5. Terrestrial Resources ..................................................................................... 8-22 6 8.2.6. Human Health ................................................................................................ 8-23 7 8.2.7. Land Use ....................................................................................................... 8-24 8 8.2.8. Socioeconomics ............................................................................................. 8-24 9 8.2.9. Transportation ................................................................................................ 8-25 10 8.2.10. Aesthetics ...................................................................................................... 8-26 11 8.2.11. Historic and Archaeological Resources .......................................................... 8-26 12 8.2.12. Environmental Justice .................................................................................... 8-26 13 8.2.13. Waste Management ....................................................................................... 8-27 14 8.3. New Nuclear ............................................................................................................... 8-28 15 8.3.1. Air Quality ...................................................................................................... 8-29 16 8.3.2. Groundwater Resources ................................................................................ 8-30 17 8.3.3. Surface Water Resources .............................................................................. 8-31 18 8.3.4. Aquatic Resources ......................................................................................... 8-31 19 8.3.5. Terrestrial Resources ..................................................................................... 8-32 20 8.3.6. Human Health ................................................................................................ 8-32 21 8.3.7. Land Use ....................................................................................................... 8-33 22 8.3.8. Socioeconomics ............................................................................................. 8-33 23 8.3.9. Transportation ................................................................................................ 8-34 24 8.3.10. Aesthetics ...................................................................................................... 8-34 25 8.3.11. Historic and Archaeological Resources .......................................................... 8-35 26 8.3.12. Environmental Justice .................................................................................... 8-35 27 8.3.13. Waste Management ....................................................................................... 8-36 28 8.4. Wind Alternative .......................................................................................................... 8-37 29 8.4.1. Air Quality ...................................................................................................... 8-39 30 8.4.2. Groundwater Resources ................................................................................ 8-39 31 8.4.3. Surface Water Resources .............................................................................. 8-40 32 8.4.4. Aquatic Resources ......................................................................................... 8-40 33 8.4.5. Terrestrial Resources ..................................................................................... 8-41 34 8.4.6. Human Health ................................................................................................ 8-41 35 8.4.7. Land Use ....................................................................................................... 8-42 36 8.4.8. Socioeconomics ............................................................................................. 8-43 37 8.4.9. Transportation ................................................................................................ 8-44 38 8.4.10. Aesthetics ...................................................................................................... 8-44 39 8.4.11. Historic and Archaeological Resources .......................................................... 8-44 40 Table of Contents ix 8.4.12. Environmental Justice .................................................................................... 8-45 1 8.4.13. Waste Management ....................................................................................... 8-45 2 8.5. Purchased Power ....................................................................................................... 8-46 3 8.6. Alternatives Considered But Dismissed ...................................................................... 8-49 4 8.6.1. Solar Power ................................................................................................... 8-49 5 8.6.2. Combination Alternative: Wind, Solar, and NGCC ......................................... 8-57 6 8.6.3. Combination Alternative: Wind and Compressed Air Energy Storage ............. 8-65 7 8.6.4. Wood Waste .................................................................................................. 8-74 8 8.6.5. Conventional Hydroelectric Power ................................................................. 8-75 9 8.6.6. Ocean Wave and Current Energy .................................................................. 8-75 10 8.6.7. Geothermal Power ......................................................................................... 8-76 11 8.6.8. Municipal Solid Waste .................................................................................... 8-77 12 8.6.9. Biomass Fuels ............................................................................................... 8-78 13 8.6.10. Oil-Fired Power .............................................................................................. 8-78 14 8.6.11. Delayed Retirement ....................................................................................... 8-78 15 8.6.12. Fuel Cells ....................................................................................................... 8-79 16 8.6.13. Coal-Fired Integrated Gasification Combined
-Cycle ....................................... 8-79 17 8.6.14. Demand-Side Management
........................................................................... 8-80 18 8.7. No-Action Alternative .................................................................................................. 8-81 19 8.7.1. Air Quality ...................................................................................................... 8-81 20 8.7.2. Groundwater Resources ................................................................................ 8-82 21 8.7.3. Surface Water Resources .............................................................................. 8-82 22 8.7.4. Aquatic and Terrestrial Resources ................................................................. 8-82 23 8.7.5. Human Health ................................................................................................ 8-82 24 8.7.6. Land Use ....................................................................................................... 8-82 25 8.7.7. Socioeconomics ............................................................................................. 8-82 26 8.7.8. Transportation ................................................................................................ 8-83 27 8.7.9. Aesthetics ...................................................................................................... 8-83 28 8.7.10. Historic and Archaeological Resources .......................................................... 8-83 29 8.7.11. Environmental Justice .................................................................................... 8-83 30 8.7.12. Waste Management ....................................................................................... 8-83 31 8.8. Alternatives Summary ................................................................................................. 8-84 32 8.9. References ................................................................................................................. 8-86 33
9.0 CONCLUSION
.................................................................................................................. 9-1 34 9.1. Environmental Impacts of License Renewal .................................................................. 9-1 35 9.2. Comparison of Alternatives ........................................................................................... 9-1 36 9.3. Resource Commitments................................................................................................ 9-2 37 9.3.1. Unavoidable Adverse Environmental Impacts .................................................. 9-2 38 9.3.2. Short-Term Versus Long
-Term Productivity
..................................................... 9-2 39 9.3.3. Irreversible and Irretrievable Commitments of Resources ................................ 9-3 40 9.4. Recommendations ........................................................................................................ 9-4 41 Table of Contents x 10.0 LIST OF PREPARERS ................................................................................................. 10-1 1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF 2 THIS SEIS ARE SENT ..................................................................................................
11-1 3 12.0 INDEX ........................................................................................................................... 12-1 4 APPENDIX A COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 5 UNITS 1 AND 2, ENVIRONMENTAL REVIEW
................................................ A-1 6 APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 7 RENEWAL OF NUCLEAR POWER PLANTS .................................................. B-1 8 APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS ........................ C-1 9 APPENDIX D CONSULTATION CORRESPONDENCE ......................................................... D-1 10 APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE ....... E-1 11 APPENDIX F DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 12 IMPACT ANALYSIS......................................................................................... F-1 13 Table of Contents xi FIGURES 1 Figure 1-1. Environmental Review Process .......................................................................... 1-2 2 Figure 1-2. Environmental Issues Evaluated during License Renewal .................................. 1-5 3 Figure 2-1. Location of LGS, 6
-mile (10-km) vicinity
............................................................. 2-3 4 Figure 2-2. Location of LGS, 50-mile (80-km) region ............................................................ 2-4 5 Figure 2-3. LGS site boundary and facility layout ................................................................. 2-5 6 Figure 2-4. Limerick to Cromby 230
-kV Transmission Line Route
...................................... 2-11 7 Figure 2-5. Cromby to North Wales 230
-kV Transmission Line Route
................................ 2-12 8 Figure 2-6. Cromby to Plymouth Meeting 230
-kV Transmission Line Route
....................... 2-13 9 Figure 2-7. Limerick to Whitpain 500
-kV Transmission Line Route
..................................... 2-14 10 Figure 2-8. Location of Schuylkill Pumphouse and LGS Discharge Structure ..................... 2-17 11 Figure 2-9. LGS Makeup Water Supply System and Alternative Water Sources within 12 the Delaware River Basin ................................................................................. 2-19 13 Figure 4-1. 2010 Census Minority Block Groups within a 50
-mi Radius of the LGS
............ 4-35 14 Figure 4-2. 2010 Census Low
-Income Block Groups within a 50 -mi Radius of LGS
........... 4-37 15
Table of Contents xiii TABLES 1 Table ES-1. Summary of NRC Conclusions Relating to Site -Specific Impacts of 2 License Renewal .............................................................................................. xviii 3 Table 2-1. Annual Fuel Use and Estimated Air Emission Estimates for Significant 4 Sources at LGS ............................................................................................... 2-27 5 Table 2-2. NOAA Trust Resources Observed in LGS -related Aquatic Studies .................. 2-46 6 Table 2-3. Federally and Pennsylvania -Listed Aquatic Species
........................................ 2-52 7 Table 2-4. Federally and Pennsylvania
-listed Terrestrial Species
..................................... 2-58 8 Table 2-5. Pennsylvania
-listed Bird Species in the Action Area
........................................ 2-63 9 Table 2-6. Limerick Generating Station, Employee Residence by County ........................ 2-66 10 Table 2-7. Housing in Berks, Chester, and Montgomery Counties in 2010 ....................... 2-66 11 Table 2-8. Public Water Supply Systems in Berks, Chester, and Montgomery 12 Counties (in million gallons per day [mgd]) ...................................................... 2-68 13 Table 2-9. Major Commuting Routes in the Vicinity of LGS, 2010 Average Annual 14 Daily Traffic Count ........................................................................................... 2-69 15 Table 2-10. Population and Percent Growth in Berks, Chester, and Montgomery 16 Counties from 1970 to 2000 and Projected for 2010
-2050 ............................... 2-71 17 Table 2-11. Demographic Profile of the Population in the Limerick Generating Station 18 Socioeconomic Region of Influence in 2010
.................................................... 2-72 19 Table 2-12. Seasonal Housing in Counties Located within 50 Miles (80 Km) of the 20 Limerick Generating Station(a).......................................................................... 2-73 21 Table 2-13. Migrant Farm Workers and Temporary Farm Labor in Counties Located 22 within 50 Miles (80 Km) of Limerick Generating Station ................................... 2-75 23 Table 2-14. Major Employers by Industry in the LGS ROI in 2010 ...................................... 2-76 24 Table 2-15. Largest Private Sector Employers - Montgomery County
- 2007 .................... 2-77 25 Table 2-16. Estimated Income Information for the Limerick Generating Station Region 26 of Influence in 2010
......................................................................................... 2-77 27 Table 2-17. Limerick Generation Station Tax Distribution, 2006
-2010 ............................... 2-79 28 Table 2-18. Payment as a Percentage of Taxing Authority 2010 Adopted Budget
.............. 2-80 29 Table 3-1. Category 1 Issues Related to Refurbishment .................................................... 3-1 30 Table 3-2. Category 2 Issues Related to Refurbishment .................................................... 3-2 31 Table 4-1. Land Use Issues................................................................................................ 4-1 32 Table 4-2. Air Quality Issues .............................................................................................. 4-2 33 Table 4-3. Surface Water Resources Issues ...................................................................... 4-3 34 Table 4-4. Groundwater Resources Issues ........................................................................ 4-5 35 Table 4-5. Aquatic Resources Issues ................................................................................. 4-7 36 Table of Contents xiv Table 4-6. Terrestrial Resources Issues ............................................................................. 4-8 1 Table 4-7. Protected Species and Habitats Issues ........................................................... 4-10 2 Table 4-8. Human Health Issues ...................................................................................... 4-21 3 Table 4-9. Socioeconomics Issues ................................................................................... 4-28 4 Table 4-10. Summary of Cumulative Impacts on Resource Areas ..................................... 4-53 5 Table 5-1. Issues Related to Postulated Accidents ............................................................. 5-1 6 Table 6-1. Issues Related to the Uranium Fuel Cycle and Waste Management ................. 6-1 7 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal ................................... 6-6 8 Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas ........................ 6-7 9 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 10 Sources ............................................................................................................. 6-8 11 Table 7-1. Issues Related to Decommissioning .................................................................. 7-1 12 Table 8-1. Summary of Alternatives Considered In Depth .................................................. 8-5 13 Table 8-2. Summary of Environmental Impacts of the NGCC Alternative Compared to 14 Continued Operation of the Existing LGS ........................................................ 8-16 15 Table 8-3. Summary of Environmental Impacts of the Supercritical Coal
-Fired 16 Alternative Compared to Continued Operation of LGS
.................................... 8-28 17 Table 8-4. Summary of Environmental Impacts of the New Nuclear Alternative 18 Compared to Continued Operation of the Existing LGS ................................... 8-37 19 Table 8-5. Summary of Environmental Impacts of the Wind Alternative Compared to 20 Continued Operation of the Existing LGS ........................................................ 8-46 21 Table 8-6. Summary of Environmental Impacts of Purchased Power Compared to 22 Continued Operation of the Existing LGS ........................................................ 8-49 23 Table 8-7. Summary of Environmental Impacts of the Solar PV Alternative Compared 24 to Continued Operation of the Existing LGS .................................................... 8-56 25 Table 8-8. Summary of Environmental Impacts of the Combination Alternative 26 Compared to Continued Operation of the Existing LGS ................................... 8-65 27 Table 8-9. Summary of Environmental Impacts of the Wind and CAES Alternative 28 Compared to Continued Operation of the Existing LGS ................................... 8-74 29 Table 8-10. Environmental Impacts of No
-Action Alternative
.............................................. 8-84 30 Table 8-11. Summary of Environmental Impacts of Proposed Action and Alternatives ....... 8-85 31 Table 10-1. List of Preparers ..............................................................................................
10-1 32 Table 11-1. List of Agencies, Organizations, and Persons to Whom Copies of this 33 SEIS Are Sent ................................................................................................. 11-1 34 xv EXECUTIVE
SUMMARY
1 BACKGROUND 2 By letter dated June 22, 2011, Exelon Generation Company, LLC (Exelon) submitted an 3 application to the U.S. Nuclear Regulatory Commission (NRC) to issue renewed operating 4 license s for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20 -year period. 5 Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)), 6 the renewal of a power reactor operating license requires preparation of an environmental 7 impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states 8 that the NRC shall prepare an EIS, which is a supplement to the Commission's NUREG -1437, 9 Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants. 10 Upon acceptance of Exelon's application, the NRC staff began the environmental review 11 process described in 10 CFR Part 51 by publishing a Notice of Intent to prepare a supplemental 12 EIS (SEIS) and conduct scoping. In preparation of this SEIS for LGS, the NRC staff performed 13 the following: 14 conducted public scoping meetings on September 22, 2011, in Pottstown, 15 Pennsylvania, 16 conducted a site audit at the plant on November 7 -10, 2011, 17 reviewed Exelon's environmental report (ER) and compared it to the GEIS, 18 consulted with other agencies, 19 conducted a review of the issues following the guidance set forth in 20 NUREG-1555, Standard Review Plans for Environmental Reviews for 21 Nuclear Power Plants, Supplement 1: Operating License Renewal, and 22 considered public comments received during the scoping process. 23 PROPOSED ACTION 24 Exelon initiated the proposed Federal action -issuing renewed power reactor operating 25 licenses-by submitting an application for license renewal of LGS, for which the existing 26 licenses (NPF -39 and NPF -85) will expire on October 26, 2024, and June 22, 2029, 27 respectively. The NRC's Federal action is the decision whether or not to renew the license for 28 an additional 20 years. 29 PURPOSE AND NEED FOR ACTION 30 The purpose and need for the proposed action (issuance of a renewed license) is to provide an 31 option that allows for power generation capability beyond the term of the current nuclear power 32 plant operating license to meet future system generating needs. Such needs may be 33 determined by other energy -planning decisionmakers, such as state, utility, and, where 34 authorized, Federal (other than NRC). This definition of purpose and need reflects the NRC's 35 recognition that, unless there are findings in the safety review required by the Atomic Energy 36 Act or findings in the National Environmental Policy Act (NEPA) environmental analysis that 37 would lead the NRC to reject a license renewal application, the NRC does not have a role in the 38 Executive Summary xvi energy planning decisions of whether a particular nuclear power plant should continue to 1 operate. 2 If the renewed licenses are issued, the appropriate energy -pla nning decisionmakers, along with 3 Exelon, will ultimately decide if the plant will continue to operate based on factors such as the 4 need for power. If the operating licenses are not renewed, then the facility must be shut down 5 on or before the expiration dates of the current operating licenses, October 26, 2024, and 6 June 22, 2029. 7 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 8 The SEIS evaluates the potential environmental impacts of the proposed action. The 9 environmental impacts from the proposed action are designated as SMALL, MODERATE, or 10 LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following 11 criteria: 12 The environmental impacts associated with the 13 issue is determined to apply either to all plants or, 14 for some issues, to plants having a specific type 15 of cooling system or other specified plant or site 16 characteristics. 17 A single significance level (i.e., SMALL, 18 MODERATE, or LARGE) has been assigned to 19 the impacts, except for collective offsite 20 radiological impacts from the fuel cycle and from 21 high-level waste and spent fuel disposal. 22 Mitigation of adverse impacts associated with the 23 issue is considered in the analysis, and it has 24 been determined that additional plant -specific 25 mitigation measures are likely not to be 26 sufficiently beneficial to warrant implementation. 27 For Category 1 issues, no additional site -specific analysis is 28 required in this draft SEIS unless new and significant information 29 is identified. Chapter 4 of this report presents the process for 30 identifying new and significant information. Site -specific issues (Category
- 2) are those that do 31 not meet one or more of the criteria for Category 1 issues; therefore, an additional site-specific 32 review for these non
-generic issues is required, and the results are documented in the SEIS. 33 Recently, the NRC approved a revision to its environmental protection regulation, 34 10 CFR Part 51, which govern s environmental impact reviews of nuclear power plant operating 35 license renewals. The NRC, through it s rulemaking process, has completed an update and 36 re-evaluation of the potential environmental impacts associated with the renewal of an operating 37 license for a nuclear power reactor for an additional 20 years. A revised GEIS, which updates 38 the 1996 GEIS , provides the technical basis for the revised rule. The revised GEIS specifically 39 supports the revised list of NEPA issues and associated environmental impact findings for 40 license renewal contained in Table B-1 in Appendix B to Subpart A of the revised 41 10 CFR Part 51. The revised rule consolidates similar Category 1 and 2 issues, changes some 42 Category 2 issues into Category 1 issues, and consolidates some of those issues with existing 43 Category 1 issues. The revised rule also adds new Category 1 and 2 issues. 44 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.
Executive Summary xvii The revised rule is expected to be published in 2013; it will become effective 30 days after 1 publication in the Federal Register. Compliance by license renewal applicants will not be 2 required until 1 year from the date of publication (i.e., license renewal environmental reports 3 submitted later than 1 year after publication must be compliant with the new rule) . 4 Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal 5 SEISs, the potential significant impacts described by the revised rule's new Category 2 issues, 6 and to the extent there is any new and significant information, the potential significant impacts 7 described by the revised rule's new Category 1 issues. 8 The NRC staff has reviewed Exelon's established process for identifying and evaluating the 9 significance of any new and significant information on the environmental impacts of license 10 renewal of LGS. Neither Exelon nor the NRC identified information that is both new and 11 significant related to Category 1 issues that would call into question the conclusions in the 12 GEIS. This conclusion is supported by NRC's review of the applicant's ER, other 13 documentation relevant to the applicant's activities, the public scoping process and substantive 14 comments raised, and the findings from the environmental site audit that the NRC staff 15 conducted. Further, the NRC staff did not identify any new issues applicable to LGS that have a 16 significant environmental impact. The NRC staff, therefore, relies upon the conclusions of the 17 GEIS for all Category 1 issues applicable to LGS. 18 Table ES-1 summarizes the Category 2 issues applicable to LGS, if any, as well as the NRC 19 staff's findings related to those issues. If the NRC staff determined that there were no 20 Category 2 issues applicable for a particular resource area, the findings of the GEIS, as 21 documented in Appendix B to Subpart A of 10 CFR Part 51, stand. 22 Executive Summary xviii Table ES-1. Summary of NRC Conclusions Relating to Site -Specific Impacts of 1 License Renewal 2 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 Cummulative Impacts Aquatic resources Terrestrial resources All other resource areas SMALL to MODERATE MODERATE SMALL With respect to environmental justice, the NRC staff has determined that there would be no 3 disproportionately high and adverse impacts to these populations from the continued operati on 4 of Exelon during the license renewal period. Additionally, the NRC staff has determined that no 5 disproportionately high and adverse human health impacts would be expected in special 6 pathway receptor populations in the region as a result of subsistence consumption of water, 7 local food, fish, and wildlife. 8 SEVERE ACCIDENT MITIGATION ALTERNATIVES 9 The NRC staff previously considered Severe Accident Mitigation Alternatives (SAM As) for the 10 applicant's plant in the Final Environmental Statement Related to Operation of Limerick 11 Generating Station, Units 1 and 2, in NUREG-0974, Supplement
- 1. The analysis was based on 12 the licensee's analysis in the updated probabilistic risk assessment. Because the NRC staff 13 previously considered SAMAs for LGS, NRC regulations do not require the NRC staff to 14 reconsider SAMAs for this license renewal proceeding. Nonetheless, the NRC must conside r 15 whether new and significant information impacts this determination in the NRC regulations, as it 16 must for all environmental issues the NRC addresses through a generic determination in its 17 regulations. The NRC staff has not identified any new and significant information regarding the 18 determination in the regulations to not reconsider SAMAs for facilities that have already 19 considered them once.
20 Executive Summary xix ALTERNATIVES 1 The NRC staff considered the environmental impacts associated with alternatives to license 2 renewal. These alternatives include other methods of power generation and not renewing the 3 LGS operating license (the no action alternative). Replacement power options considered were 4 as follows: 5 natural-gas-fired combined-cycle (NGCC), 6 supercritical pulverized coal (SCPC), 7 new nuclear, 8 wind power, and 9 purchased power. 10 The NRC staff initially considered a number of additional alternatives for analysis as alternatives 11 to license renewal of LGS; these were later dismissed because of technical, resource 12 availability, or commercial limitations that currently exist and that the NRC staff believes are 13 likely to continue to exist when the existing LGS license expires. The no action alternative by 14 the NRC staff, and the effects it would have, were also considered. 15 Where possible, the NRC staff evaluated potential environmental impacts for these alternatives 16 located both at the LGS site and at some other unspecified alternate location. Alternatives 17 considered, but dismissed were as follows: 18 solar power, 19 combination alternative of wind, solar, and NGCC, 20 combination alternative of wind and compressed -air energy storage (CAES), 21 wood waste, 22 conventional hydroelectric power, 23 ocean wave and current energy, 24 geothermal power, 25 municipal solid waste (MSW), 26 b io f ue ls, 27 oiled-fired power, 28 delayed retirement, 29 fuel cells , 30 coal-fired integrated gasification combined -cycle (IGCC), and 31 demand-side management (DSM). 32 The NRC staff evaluated each alternative using the same impact areas that were used in 33 evaluating impacts from license renewal. 34 Executive Summary xx RECOMMENDATION 1 The NRC's preliminary recommendation is that the adverse environmental impacts of license 2 renewal for LGS are not great enough to deny the option of license renewal for energy -planning 3 decisionmakers. This recommendation is based on the following: 4 analysis and findings in the GEIS, 5 ER submitted by Exelon, 6 consultation with Federal, state, and local agencies, 7 NRC staff's own independent review, and 8 consideration of public comments received during the scoping process. 9 xxi ABBREVIATIONS AND ACRONYMS 1 °C degree(s) Celsius 2 °F degree(s) Fahrenheit 3 AADT average annual daily traffic 4 ac acre(s) 5 AC alternating current 6 ACHP Advisory Council on Historic Preservation 7 ADAMS Agencywide Documents Access and Management System 8 AEA Atomic Energy Act of 1954 [Also: UK Atomic Energy Authority] 9 AEC U.S. Atomic Energy Commission 10 AEPS alternative energy portfolio standard 11 ALARA as low as is reasonably achievable 12 ANSI American National Standards Institute 13 APE area of potential effect 14 AQCR air quality control region 15 ATWS anticipated transient without scram 16 BHP Bureau of Historic Preservation 17 BMP best management practice 18 BOL Bureau of Laboratories 19 BTU British thermal unit(s) 20 BTU/kWh British thermal unit(s) per kilowatt -hour 21 BTU/lb British thermal unit(s) per pound 22 BWR boiling water reactor 23 CAA Clean Air Act, as amended through 1990 24 CAES compressed air energy storage 25 CCS carbon capture and storage 26 CDF core damage frequency 27 C eq/kWh carbon equivalent per kilowatt -hour 28 CEQ Council on Environmental Quality 29 CFR Code of Federal Regulations 30 cfs cubic feet per second 31 cm centimeter(s) 32 cm/s centimeter(s) per second 33 CO carbon monoxide 34 Abbreviations and Acronyms xxii CO2 carbon dioxide 1 CPI Containment Performance Improvement 2 CRGIS Cultural Resources Geographic Information System 3 CS candidate species 4 CSAPR Cross-State Air Pollution Rule 5 CSP concentrated solar power 6 CT combustion turbine 7 CWA Clean Water Act of 1972 8 dB decibels 9 dBA decibels adjusted 10 DBA design basis accident 11 DC direct current 12 DMR Discharge Monitoring Report 13 DOE U.S. Department of Energy 14 DRBC Delaware River Basin Commission 15 DSEIS draft supplemental environmental impact statement 16 DSM demand-side management 17 DVRPC Delaware Valley Regional Planning Commission 18 DWS drinking water standard 19 EO Executive Order 20 EFH Essential Fish Habitat 21 EIA Energy Information Administration (of DOE) 22 EIS environmental impact statement 23 ELF EMF extremely low -frequency electromagnetic field 24 EMS environmental management system 25 EPA U.S. Environmental Protection Agency 26 EPCRA Emergency Planning and Community Right -to-Know Act of 1986 27 EPRI Electric Power Research Institute 28 EPT Ephemeroptera, Plecoptera, and Trichoptera 29 ER Environmental Report 30 ESA Endangered Species Act of 1973, as amended 31 Exelon Exelon Generation Company, LLC 32 FE Federally endangered 33 FENOC First Energy Nuclear Operating Compa ny 34 FES final environmental statement 35 Abbreviations and Acronyms xxiii fps feet per second 1 FR Federal Register 2 FSAR final safety analysis report 3 FT threatened 4 ft foot (feet) 5 ft3 cubic foot (feet) 6 FW feedwater 7 FWCA Fish and Wildlife Coordination Act 8 FWS U.S. Fish and Wildlife Service 9 g gram(s) 10 gal gallon(s) 11 GE General Electric 12 GEIS Generic Environmental Impact Statement for License Renewal of 13 Nuclear Plants, NUREG-1437 14 GHG greenhouse gas 15 GIC Green-is-Clean 16 gpd gallons per day 17 gpm gallons per minute 18 GW groundwater 19 ha hectare(s) 20 Hg mercury 21 HLSA high-level storage area 22 Hz hertz 23 IAEA International Atomic Energy Agency 24 IEEE Institute of Electrical and Electronics Engineers, Inc. 25 IGCC integrated gasification combined-cycle 26 in. inch(es) 27 IPE Individual Plant Examination 28 IPEEE Individual Plant Examination of External Events 29 ISFSI Independent Spent F uel Storage Installation 30 ISO International Organization for Standardization 31 kg kilogram(s) 32 km kilometer(s) 33 km 2 square kilometer(s) 34 kV kilovolt(s) 35 Abbreviations and Acronyms xxiv kW kilowatt(s) 1 kWh kilowatt-hour(s) 2 L/min liter(s) per minute 3 lb pound(s) 4 LEFM Leading Edge Flow Meter 5 LGS Limerick Generating Station, Units 1 and 2 6 LLMW low-level mixed waste 7 LLRW low-level radioactive waste 8 m meter(s) 9 m/s meter(s) per second 10 m 2 square meter(s) 11 m3 cubic meter(s) 12 m 3/s cubic meters per second 13 mA milliampere(s) 14 MACCS2 MELCOR Accident Consequence Code System 2 15 MAIS macroinvertebrate aggregated index for streams 16 MassDEP Massachusetts Department of Environmental Protection 17 MATS Mercury and Air Toxics Standards 18 MBTA Migratory Bird Treaty Act of 1918 19 MCPC Montgomery County Planning Commission 20 MDPH Massachusetts Department of Public Health 21 MF migratory fishes 22 mg/L milligrams per liter 23 mgd million gallons per day 24 mGy million gallons per year 25 mi mile(s) 26 mi 2 square mile(s) 27 min minute(s) 28 mm millimeter(s) 29 MMI Modified Mercalli Intensity 30 MMPA Marine Mammal Protection Act of 1972 31 mph mile(s) per hour 32 mrad milliradiation absorbed dose 33 mrem milliroentgen equivalent man 34 Abbreviations and Acronyms xxv MSA Magnuson-Stevens Fishery Conservation and Management Act, 1 as amended through 2006 2 MSL mean sea level 3 mSv millisievert 4 MSW municipal solid waste 5 MUR measurement uncertainty recapture 6 MT metric ton(s) 7 MW megawatt(s) 8 MWd megawatt-day(s) 9 MWd/MTU megawatt-day(s) per metric ton of uranium 10 MWe megawatt(s) electrical 11 MWt megawatt(s) thermal 12 NA not applicable 13 NAAQS National Ambient Air Quality Standards 14 NASS National Agricultural Statistics Service 15 NAS National Academy of Sciences 16 NEPA National Environmental Policy Act of 1969 17 NERC North American Electric Reliability Corporation 18 NESC National Electrical Safety Code 19 NETL National Energy Technology Laboratory 20 NGCC natural-gas-fired combined-cycle 21 NHPA National Historic Preservation Act of 1966, as amended 22 NIEHS National Institute of Environmental Health Sciences 23 NMFS National Marine Fisheries Service (of NOAA) 24 NOAA National Oceanic and Atmospheric Administration 25 NO x nitrogen oxide(s) 26 NPDES National Pollutant Discharge Elimination System 27 NPS National Park Service 28 NRC U.S. Nuclear Regulatory Commission 29 NRCS National Resources Conservation Service 30 NRHP National Register of Historic Places 31 NRR Office of Nuclear Reactor Regulation 32 NUREG NRC technical report designation (Nuclear Regulatory 33 Commission) 34 NWS National Weather Service 35 Abbreviations and Acronyms xxvi O 3 ozone 1 OCA Owner-Controlled Area 2 ODCM Offsite Dose Calculation Manual 3 PADEP Pennsylvania Department of Environmental Protection 4 PAH polycyclic aromatic hydrocarbon 5 Pb lead 6 PBAPS Peach Bottom Atomic Power Station 7 PCBs polychlorinated biphenyl 8 pCi/L picocuries per liter 9 PDCNR Pennsylvania Department of Conservation and Natural Resources 10 PE Pennsylvania endangered 11 PECO PECO Energy Company, the energy delivery subsidiary of Exelon 12 Corporation serving retail customers in southeastern Pennsylvania 13 (also used in this report as an acronym for Philadelphia Electric 14 Company or PECO Energy Company, predecessors of Exelon 15 Generation) 16 PFBC Pennsylvania Fish and Boating Commission 17 PGA peak ground acceleration 18 PGC Pennsylvania Game Commission 19 PJM PJM Interconnection, LLC 20 PM particulate matter 21 PM 10 particulate matter 22 PM2.5 23 PNDI Pennsylvania Natural Diversity Inventory 24 PNHP Pennsylvania Natural Heritage Program 25 PNNL Pacific Northwest National Laboratory 26 POST Parliamentary Office of Science and Technology 27 PPC Preparedness, Prevention, and Contingency 28 PR rare 29 PSD Prevention of Significant Deterioration 30 psia pounds per square inch absolute 31 PV photovoltaic 32 PWR pressurized water reactor 33 RCA radiological control area 34 RCRA Resource Conservation and Recovery Act of 1976, as amended 35 REMP radiological environmental monitoring program 36 Abbreviations and Acronyms xxvii REOP Radiological Environmental Operation 1 RERS reactor enclosure recirculation system 2 RGPP Radiological Groundwater Protection Program 3 RKm river kilometer 4 RM river mile 5 RMC RMC-Environmental Services 6 ROI region of influence 7 ROW(s) right(s)-of-way 8 RPS renewable portfolio standard 9 RSP radwaste storage pad 10 RWCU reactor water cleanup 11 SAMA Severe Accident Mitigation Alternative 12 SAMDA Severe Accident Mitigation Design Alternative 13 SAMGs Severe Accident Mitigation Guidelines 14 SAR safety analysis report 15 SCR selective catalytic reduction 16 SCPC supercritical pulverized coal 17 SE state endangered 18 SEIS supplemental environmental impact statement 19 SER safety evaluation report 20 SGTS standby gas treatment system 21 SHPO State Historic Preservation Officer 22 SIP State Implementation Plan 23 SO 2 sulfur dioxide 24 SO x sulfur oxide(s) 25 SPCC Spill Prevention Control and Countermeasure 26 SR State rare 27 SSCs structures, systems, and components 28 SSC species of special concern 29 SSE safe-shutdown earthquake 30 ST state threatened 31 STG steam turbine generator 32 State Commonwealth of Pennsylvania (or other state if specified) 33 Stroud Stroud Water Research Center 34 Sv sievert 35 Abbreviations and Acronyms xxviii SW surface water 1 SWPPP Stormwater Pollution Prevention Plan 2 TLD thermoluminescent dosimeters 3 TMDL total maximum daily upload 4 TMI Three Mile Island 5 tpy ton(s) per year 6 TSF stocked trout 7 TSP total suspended particles 8 TWh terawatt-hour(s) 9 U uranium 10 U.S. United States 11 U.S.C. United States Code 12 UFSAR updated final safety analysis report 13 USACE U.S. Army Corps of Engineers 14 USCB U.S. Census Bureau 15 USDA U.S. Department of Agriculture 16 USGCRP United States Global Change Research Program [or GCRP] 17 USGS U.S. Geological Survey 18 VOC volatile organic compound 19 WEC wave energy conversion 20 WHC Wildlife Habitat Council 21 WWF warm water fishes 22 1-1 1.0 PURPOSE AND NEED FOR ACTION 1 Under the U.S. Nuclear Regulatory Commission's (NRC's) environmental protection regulations 2 in Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51)-which carry out the 3 National Environmental Policy Act (NEPA)-renewal of a new nuclear power plant operating 4 license requires the preparation of an environmental impact statement (EIS). 5 The Atomic Energy Act of 1954 (AEA) originally specified that licenses for commercial power 6 reactors be granted for up to 40 years. The 40 -year licensing period was based on economic 7 and antitrust considerations rather than on technical limitations of the nuclear facility. 8 The decision to seek a license renewal rests entirely with nuclear power facility owners and, 9 typically, is based on the facility's economic viability and the investment necessary to continue 10 to meet NRC safety and environmental requirements. The NRC makes the decision to grant or 11 deny license renewal based on whether the applicant has demonstrated that the environmental 12 and safety requirements in the agency's regulations can be met during the period of extended 13 operation. 14 1.1. Proposed Federal Action 15 Exelon Generation Company, LLC (Exelon) initialized the proposed Federal action by submitting 16 an application for license renewal of Limerick Generating Station, Units 1 and 2 (LGS), for which 17 the existing licenses (NPF-39 and NPF-85) expire on October 26, 2024, and June 22, 2029. 18 The NRC's Federal action is to decide whether to renew the license for an additional 20 years. 19 1.2. Purpose and Need for the Proposed Federal Action 20 The purpose and need for the proposed action (issuance of a renewed license) is to provide an 21 option that allows for power generation capability beyond the term of a current nuclear power 22 plant operating license to meet future system generating needs, as such needs may be 23 determined by other energy -planning decision makers. This definition of purpose and need 24 reflects the Commission's recognition that, unless there are findings in the safety review 25 required by the Atomic Energy Act or findings in the NEPA environmental analysis that would 26 lead the NRC to reject a license renewal application, the NRC does not have a role in the 27 energy-planning decisions of state regulators and utility officials as to whether a particular 28 nuclear power plant should continue to operate. 29 If the renewed license is issued, state regulatory agencies and Exelon will ultimately decide 30 whether the plant will continue to operate based on factors such as the need for power or other 31 matters within the state's jurisdiction or the purview of the owners. If the operating license is not 32 renewed, then the facility must be shut down on or before the expiration date of the current 33 operating licenses -October 26, 2024, and June 22, 2029. 34 Purpose and Need for Action 1-2 Figure 1-1. Environmental Review Process 1 1.3. Major Environmental Review Milestones 2 Exelon submitted an Environmental Report (ER) (Exelon 2011b) as part of its license renewal 3 application (Exelon 2011a) o n June 22, 2011. After reviewing the application and ER for 4 sufficiency, the staff published a Federal Register Notice of Acceptability and Opportunity for 5 Hearing (76 FR 52992) on August 24, 2011. Then, on August 26, 2011 , the NRC published 6 another notice in the Federal Register (76 FR 53498) on the intent to conduct scoping, thereby 7 beginning the 60-day scoping period. 8 NRC staff reviews application Staff conduct s environmental site audit The NRC issues draft SEIS Company submits an application to the NRC *Scoping Process *Draft SEIS Process The NRC issues final SEIS NRC decision on whether to renew license
- Opportunity for Public Involvement
Purpose and Need for Action 1-3 Two public scoping meetings were held on September 22, 2011, in Pottstown, Pennsylvania 1 (NRC 2011). The comments received during the scoping process are presented in 2 "Environmental Impact Statement, Scoping Process, Summary Report," published in February 3 2013 (NRC 201 3). The scoping process summary report presents NRC responses to 4 comments that the NRC staff considered to be out -of-scope of the environmental license 5 renewal review. The comments considered to be within the scope of the environmental license 6 renewal review and the NRC responses are presented in Appendix A of this supplemental 7 environmental impact statement (SEIS). 8 To independently verify information provided in the ER, NRC staff conducted a site audit at LGS 9 in November 2011. During the site audit, NRC staff met with plant personnel, reviewed specific 10 documentation, toured the facility, and met with interested Federal, state, and local agencies. A 11 summary of that site audit and the attendees is contained in "Summary of Site Audit in Support 12 to the Environmental Review of the License Renewal Application for Limerick Generating 13 Station, Units 1 and 2," published May 21, 2012 (NRC 2012a). 14 Upon completion of the scoping period and site audit, NRC staff compiled its findings in a draft 15 SEIS (Figure 1 -1). This document is made available for public comment for 75 days. During 16 this time, NRC staff will host public meetings and collect public comments. Based on the 17 information gathered, the NRC staff will amend the draft SEIS findings, as necessary, and 18 publish the final SEIS. 19 The NRC has established a license renewal process that can be completed in a reasonable 20 period of time with clear requirements to ensure safe plant operation for up to an additional 21 20 years of plant life. The safety review, which documents its finding in a safety evaluation 22 report, is conducted simultaneously with the environmental review. The findings in both the 23 SEIS and the safety evaluation report are factors in the Commission's decision to either grant or 24 deny the issuance of a renewed license. 25 1.4. Generic Environmental Impact Statement 26 The NRC performed a generic assessment of the environmental impacts associated with 27 license renewal to improve the efficiency of the license renewal process. The Generic 28 Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437 29 (GEIS) documented the results of the NRC staff's systematic approach to evaluate the 30 environmental consequences of renewing the licenses of individual nuclear power plants and 31 operating them for an additional 20 years. NRC staff analyzed in detail and resolved those 32 environmental issues that could be resolved generically in the GEIS. 33 The GEIS establishes 92 separate issues for NRC staff to independently verify. Of these 34 issues, NRC staff determined that 69 are generic to all plants (Category
- 1) while 21 issues do 35 not lend themselves to generic consideration (Category 2). Two other issues remained 36 uncategorized; environmental justice and chronic effects of electromagnetic fields, and must be 37 evaluated on a site
-specific basis. A list of all 92 issues can be found in Appendix B. 38 For each potential environmental issue, the GEIS: 39 (1) describes the activity that affects the environment, 40 (2) identifies the population or resource that is affected, 41 (3) assesses the nature and magnitude of the impact on the affected population 42 or resource, 43 Purpose and Need for Action 1-4 (4) characterizes the significance of the effect for both beneficial and adverse 1 effects, 2 (5) determines if the results of the analysis apply to all plants, and 3 (6) considers whether additional mitigation measures would be warranted for 4 impacts that would have the same significance level for all plants. 5 The NRC's standard of significance for impacts was established using the Council on 6 Environmental Quality (CEQ) terminology for "significant." The NRC established three levels of 7 significance for potential impacts: SMALL, MODERATE, and LARGE, as defined below. 8 SMALL: Environmental effects are not detectable 9 or are so minor that they will neither destabilize nor 10 noticeably alter any important attribute of the 11 resource. 12 MODERATE: Environmental effects are sufficient 13 to alter noticeably, but not to destabilize, important 14 attributes of the resource. 15 LARGE: Environmental effects are clearly 16 noticeable and are sufficient to destabilize important 17 attributes of the resource. 18 The GEIS includes a determination of whether the analysis of the environmental issue could be 19 applied to all plants and whether additional mitigation measures would be warranted (Figure 1-20 2). Issues are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, 21 Category 1 issues are those that meet the following criteria: 22 (1) The environmental impacts associated with the issue have been determined 23 to apply either to all plants or, for some issues, to plants having a specific 24 type of cooling syst em or other specified plant or site characteristics. 25 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been 26 assigned to the impacts (except for collective off -site radiological impacts 27 from the fuel cycle and from high-level waste and spent fuel disposal). 28 (3) Mitigation of adverse impacts associated with the issue has been considered 29 in the analysis, and it has been determined that additional plant -specific 30 mitigation measures are likely not to be sufficiently beneficial to warrant 31 implementation. 32 For generic issues (Category 1), no additional site -specific analysis is required in this SEIS 33 unless new and significant information is identified. The process for identifying new and 34 significant information is presented in Chapter
- 4. Site-specific issues (Category
- 2) are those 35 that do not meet one or more of the criteria of Category 1 issues, and therefore, additional 36 site-specific review for these issues is required. The results of that site
-specific review are 37 documented in the SEIS. 38 Significance indicates the importance of likely environmental impacts and is determined by considering two variables: context and intensity. Context is the geographic, biophysical, and social context in which the effects will occur. Intensity refers to the severity of the impact, in whatever context it occurs . Purpose and Need for Action 1-5 Figure 1-2. Environmental Issues Evaluated during License Renewal 1 The NRC staff initially evaluated 92 issues in the GEIS. Based on the findings of the GEIS, a 2 site-specific analysis is required for 23 of those 92 issues. 3 On December 6, 2012, the Commission affirmed a decision to publish in the Federal Register 4 an amendment that would revise its environmental protection regulation, 10 CFR Part 51, which 5 govern s environmental impact reviews of nuclear power plant operating license renewals 6 (NRC 2012 b). Specifically, t he revised rule will update and re evaluate the potential 7 environmental impacts associated with the renewal of an operating license for a nuclear power 8 reactor for an additional 20 years. A revised GEIS, which updates the 1996 GEIS , provides the 9 technical basis for the revised rule. The revised GEIS specifically supports the revised list of 10 NEPA issues and associated environmental impact findings for license renewal contained in 11 Table B-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and 12 rule reflect lessons learned and knowledge gained during previous license renewal 13 environmental reviews. In addition, public comments received on the draft revised GEIS and 14 rule and during previous license renewal environmental reviews were re examined to validate 15 existing environmental issues and identify new ones. 16 The revised rule identifies 78 environmental impact issues, of which, 17 will require 17 plant-specific analysis. The revised rule consolidates similar Category 1 and 2 issues, changes 18 some Category 2 issues into Category 1 issues, and consolidates some of those issues with 19 existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues. The new 20 Purpose and Need for Action 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. Category 1 issues include geology and soils, exposure of terrestrial organisms to radionuclides, 1 exposure of aquatic organisms to radionuclides, human health impact from chemicals, and 2 physical occupational hazards. Radionuclides released to groundwater, effects on terrestrial 3 resources (non -cooling system impacts), minority and low -income populations 4 (i.e., environmental justice), and cumulative impacts were added as new Category 2 issues. 5 The revised rule is expected to be published in 2013, and it will become effective 30 days after 6 publication in the Federal Register. Compliance by license renewal applicants will not be 7 required until 1 year from the date of publication (i.e., license renewal environmental reports 8 submitted later than 1 year after publication must be compliant with the new rule) . 9 Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal 10 SEISs, the potential significant impacts described by the revised rule's new Category 2 issues 11 and, to the extent there is any new and significant information, the potential significant impacts 12 described by the revised rule's new Category 1 issues. 13 1.5. Supplemental Environmental Impact Statement 14 The SEIS presents an analysis that considers the environmental effects of the continued 15 operation of LGS, alternatives to license renewal, and mitigation measures for minimizing 16 adverse environmental impacts. Chapter 8 contains analysis and comparison of the potential 17 environmental impacts from alternatives while Chapter 9 presents the staff's preliminary 18 recommendation to the Commission on whether or not the environmental impacts of license 19 renewal are so great that preserving the option of license renewal would be unreasonable. The 20 recommendation includes consideration of comments received during the public scoping period. 21 In the preparation of this SEIS for LGS, the staff: 22 reviewed the information provided in Exelon's ER, 23 consulted with other Federal, state, and local agencies, 24 conducted an independent review of the issues during a site audit, and 25 considered the public comments received during the scoping process. 26 New information can be identified from a 27 number of sources, including the applicant, the 28 NRC, other agencies, or public comments. If a 29 new issue is revealed, then it is first analyzed to 30 determine if it is within the scope of the license 31 renewal evaluation. If it is not addressed in the 32 GEIS, then the NRC determines its significance 33 and documents its analysis in the SEIS. 34 1.6. Cooperating Agencies 35 During the scoping process, no Federal, state, or local agencies were identified as cooperating 36 agencies in the preparation of this SEIS. 37 1.7. Consultations 38 The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries 39 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 40 require that Federal agencies consult with applicable state and Federal agencies and groups 41 prior to taking action that may affect endangered species, fisheries, or historic and 42 Purpose and Need for Action 1-7 archaeological resources, respectively. Below are the agencies and groups with whom the 1 NRC consulted; Appendix D to this report includes copies of consultation documents. 2 Advisory Council on Historic Preservation 3 National Marine Fisheries Service 4 U.S. Environmental Protection Agency, Region 3 5 U.S. Fish and Wildlife Service, State College, Pennsylvania 6 Absentee-Shawnee Tribe of Oklahoma 7 Cayuga Nation 8 Delaware Nation 9 Delaware Tribe 10 Eastern Shawnee Tribe of Oklahoma 11 Oneida Indian Nation 12 Oneida Nation of Wisconsin 13 Onondaga Nation 14 Seneca Nation of Indians 15 Seneca-Cayuga Tribe of Oklahoma 16 St. Regis Mohawk Tribe 17 Shawnee Tribe 18 Stockbridge -Munsee Band of the Mohican Nation of Wisconsin 19 Tonawanda Seneca Nation 20 Tuscarora Nation 21 1.8. Correspondence 22 During the course of the environmental review, the NRC staff contacted the Federal, state, 23 regional, local, and tribal agencies listed in Section 1.7, as well as the following: 24 Pennsylvania Fish & Boat Commission 25 Pennsylvania Game Commission 26 Pennsylvania Historical and Museum Commission 27 Pennsylvania Department of Conservation and Natural Resources 28 Appendix E contains a chronological list of all the documents sent and received during the 29 environmental review. 30 A list of persons who received a copy of this SEIS is provided in Chapter
- 11. 31 1.9. Status of Compliance 32 Exelon is responsible for complying with all NRC regulations and other applicable Federal, 33 state, and local requirements. A description of some of the major Federal statutes can be found 34 in Appendix H of the GEIS. Appendix C to this SEIS includes a list of the permits and licenses 35 issued by Federal, state, and local authorities for activities at LGS.
36 1.10. References 37 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 38 Protection Regulations for Domestic Licensing and Related Regulator Activities." 39 76 FR 52992. U.S. Nuclear Regulatory Commission, Washington, DC, "Notice of Acceptance for 40 Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of 41 Facility Operating License Nos. NPF -39 and NPF -85 for an Additional 20 -Year Period, Exelon 42 Purpose and Need for Action 1-8 Generation Company, LLC, Limerick Generating Station." Federal Register 1 76(164):52992 -52994, August 24, 2011. 2 76 FR 53498. U.S. Nuclear Regulatory Commission, Washington, DC, "Exelon Generation 3 Company, LLC; Notice of Intent To Prepare an Environmental Impact Statement and Conduct 4 Scoping Process for Limerick Generating Station, Units 1 and 2." Federal Register 5 76(166):53498 -53500, August 26, 2011. 6 Atomic Energy Act of 1954. 42 U.S.C. §2011, et seq. 7 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531, et seq. 8 [Exelon] Exelon Generation Company, LLC, 2011a. Limerick Generating Station, Units 1 and 9 2-License Renewal Application. June 2011. Agencywide Documents Access and Management 10 System (ADAMS) Accession No. ML11179A101. 11 [Exelon] Exelon Generation Company, LLC, 2011 b. License Renewal Application, Limerick 12 Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating 13 License Renewal Stage. ADAMS Accession No. ML11179A104. 14 Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 15 Sustainable Fisheries Act of 1996. 16 U.S.C 1855, et seq. 16 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321, et seq. 17 National Historic Preservation Act of 1966. 16 U.S.C. §470, et seq. 18 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 19 for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2. Washington, DC. 20 May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 21 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 22 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 -Transportation, Table 9.1, 23 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 24 Report, NUREG -1437, Volume 1, Addendum 1. Washington DC. August 1999. ADAMS 25 Accession No. ML04069720. 26 [NRC] U.S. Nuclear Regulatory Commission. 2011. "Summary of Public Scoping Meetings 27 Conducted on September 22, 2011, Related to the Review of the Limerick Generating Station, 28 Units 1 and 2, License Renewal Application." September 2011. ADAMS Accession 29 No. ML04069720. 30 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Summary of Site Audit Related to the 31 Environmental Review of the License Renewal Application for Limerick Generating Station, 32 Units 1 and 2." May 21, 2012. ADAMS Accession No. ML12124A127. 33 [NRC] U.S. Nuclear Regulatory Commission. 2012 b. Staff Requirements, SECY-12-0063 - 34 Final Rule: Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating 35 Licenses (10 CFR Part 51; RIN 3150 -AI42). December 6, 2012. ADAMS Accession 36 No. ML12341A134. 37 [NRC] U.S. Nuclear Regulatory Commission. 2013. "Environmental Impact Statement, Scoping 38 Process, Summary Report," March 2013. ADAMS Accession No. ML12131A499. 39 2-1 2.0 AFFECTED ENVIRONMENT 1 Limerick Generating Station, Units 1 and 2 (LGS) is located in Limerick Township of 2 Montgomery County, Pennsylvania, 1.7 miles (2.7 kilometers [ km]) southeast of the Borough of 3 Pottstown. The City of Reading is about 19 miles (30.6 km) northwest of the site and the 4 Borough of Phoenixville is about 9.3 miles (15 km) southeast of the site. Other nearby 5 population centers are the Municipality of Norristown, about 11 miles (17.7 km) southeast of the 6 site, and the City of Philadelphia, the city limits of which are about 21 miles (33.8 km) southeast 7 from the site. Figure 2-1 and Figure 2 -2 present the 6 -mile (10-km) and 50 -mile (80-km) 8 vicinity maps, respectively. 9 For the purposes of the evaluation in this supplemental environmental impact statement (SEIS), 10 the "affected environment" is the environment that currently exists at and around LGS. Because 11 existing conditions are at least partially the result of past construction and operation at the plant, 12 the impacts of these past and ongoing actions and how they have shaped the environment are 13 presented here. Section 2.1 of this SEIS describes the facility and its operation, and Section 2.2 14 discusses the surrounding environment. 15 2.1. Facility Description 16 LGS is a two -unit nuclear -powered steam electric generating facility that began commercial 17 operation in February 1986 (Unit 1) and January 1990 (Unit 2). The nuclear reactor for each 18 unit is a General Electric Mark II boiling water reactor (BWR) producing a reactor core rated 19 thermal power of 3,515 megawatts (MWt). The nominal net electrical capacity is 20 1,170 megawatts electric (MWe). Figure 2-3 provides a general site layout of LGS. 21 2.1.1. Reactor and Containment Systems 22 The nuclear reactor system for each Limerick unit includes a single -cycle, forced circulation, 23 General Electric Mark II BWR. The reactor core heats water that is dried by steam separators 24 and dryers located in the upper portion of the reactor vessel. The steam is then directed 25 through four main steam lines to the main turbine where it turns the turbine generator to 26 produce electricity. 27 Fuel enrichment and average peak rod burnup conditions are no more than 5 percent 28 uranium-235 and 62,000 megawatt-days per metric ton of uranium (MWd/MTU), respectively. 29 LGS operates on a 24 -month refueling cycle. 30 The reactor and related systems are enclosed in primary and secondary containment
- s. The 31 primary containment surrounds the reactor vessel and also houses the reactor coolant 32 recirculation pumps and piping loops. The secondary containment is the structure that encloses 33 the reactor's primary containment and spent fuel storage pool areas.
The primary containment 34 is a steel -lined reinforced concrete pressure -suppression system of the over -and-under 35 configuration. The secondary containment system is a reinforced concrete building and is 36 designed to minimize the release of airborne radioactive materials under accident conditions. 37 2.1.2. Radioactive Waste Management 38 The radioactive waste systems collect, treat, and dispose of radioactive and potentially 39 radioactive wastes that are byproducts of LGS operations. The byproducts are activation 40 products associated with nuclear fission, reactor coolant activation, and noncoolant material 41 activation. Release of liquid and gaseous effluents are controlled to meet the limits specified in 42 Purpose and Need for Action 2-2 Title 10, Code of Federal Regulations (CFR) Part 20 and 10 CFR Part 50, Appendix I, through 1 the Radioactive Effluent Controls Program defined in the LGS technical specifications 2 (Exelon 2011 a). Operation procedures for the radioactive waste system ensure that radioactive 3 wastes are safely processed and discharged from the LGS. The systems are designed and 4 operated to ensure that the quantities of radioactive materials released from LGS are as low as 5 is reasonably achievable (ALARA) and within the dose standards set forth in 10 CFR Part 20, 6 "Standards for protection against radiation," and Appendix I to 10 CFR Part 50, "Domestic 7 licensing of production and utilization facilities." The LGS Offsite Dose Calculation Manual 8 (ODCM) contains the methods and parameters used to calculate offsite doses resulting from 9 radioactive effluents. These methods are used to ensure that radioactive material discharges 10 from the LGS meet regulatory dose standards. 11 Radioactive wastes resulting from LGS operations are classified as liquid, gaseous, and solid. 12 The design and operation objectives of the radioactive waste management systems are to limit 13 the release of radioactive effluents from LGS during normal operation and anticipated operation. 14 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 15 as spent fuel. Spent fuel assemblies that are removed from the reactor core are replaced with 16 fresh fuel assemblies during routine refueling outages. Spent nuclear fuel from the reactor is 17 stored on site in a spent fuel pool and an independent spent fuel storage installation (ISFSI) 18 located west of the Turbine Buildings. Under 10 CFR Part 50, LGS has a general license to 19 store spent fuel from both units in pre -approved dry storage casks in accordance with the 20 requirements in 10 CFR Part 72, Subpart K (Exelon 2011 b). 21 2.1.2.1. Radioactive Liquid Waste 22 The liquid waste -management system collects, segregates, stores, and disposes of radioactive 23 liquid waste. The system is designed to reduce radioactive materials in liquid effluents to levels 24 that are ALARA and reduce the volume of waste through recycling. Liquid wastes that 25 accumulate in radwaste drain tanks or in sumps at locations throughout each LGS unit are 26 transferred to collection tanks in the common radwaste enclosure based on the classification of 27 waste: equipment drain, floor drain, chemical drain, or laundry drain waste. The liquid wastes 28 are processed for packaging and offsite shipment, returned to the condensate system, or mixed 29 with cooling -tower blowdown and released from the plant. 30 Wastes from the equipment drains and floor drains are processed through separate precoat 31 filters and mixed resin bed demineralizers. The processed waste is collected in one of two 32 sample tanks. Usually, the water from these tanks is sent to the condensate tank for reuse, but 33 if necessary, it will be treated or discharged into the Schuylkill River with radionuclide 34 concentrations below 10 CFR Part 20 limits. 35 Laboratory wastes, decontamination solutions, and other wastes that may be corrosive are 36 collected and chemically neutralized before being sent to the floor drain system for processing. 37 Waste from decontamination laundry facilities is processed through the laundry filter and then 38 collected in a sample tank. 39 The contamination in the liquid wastes is concentrated in filters and ion exchange resins and 40 then sent to solid waste management for processing. The waste is stored and eventually 41 shipped to a licensed waste disposal facility. The processed liquids are either recycled or 42 discharged from the plant in the cooling -tower blowdown into the Schuylkill River with 43 radionuclide concentrations below 10 CFR Part 20 limits. 44 Purpose and Need for Action 2-3 Figure 2-1. Location of LGS, 6 -mi le (10-km) vicinity 1 Pennsylvania
- Limerick Generating Station E xelon Property Boundary [ ___ County Boundary Major Roads 0 --Minor Roads --+--+ Railroad CJ Waterbody Agricultural Land .. Pasture Land .. Forest Land Developed Land Purpose and Need for Action 2-4 Figure 2-2. Location of LGS, 50
-mi le (80-km) region 1 Pennsylvania
- = Li mited Access -Na1ional Pa rk Service limerick Generating Station -.. --Highway Mih1ary Reserve c:J S tate Boundary Conserva t ion Area County Boundary Urban Area C)waterbody State Park 0 5 10 20 Mi les Purpose and Need for Action 2-5 Figure 2-3. LGS site boundary and facility layout 1 .*'-. / . . . . '* / *, ./ *,.. *.,_ , /' Exclusion Ar ea Boundary (2 , 500 . '* , , , , , ,' .; , "><:;<:; , 'I , . (: ./ ./ ./ *,_ ! *,_ *, *. / ,_. 500 kV Transmission Line 230 kV Transmission Line c=J Exclusion Area Boundary (EAB) 0 550 1.100 2, 200 Fee t -..... __ / .* , . I / I : ..... __ '; ./ ./ LGS Security Barrier i.:::-_-_-.J Exelon Property Boundary Security Fence D Limerick Nuc l ear Pl ant Plant Roads D W aterbody -+--+ Railroad 0 220 44 0 Me t er s 880 ,-
Purpose and Need for Action 2-6 2.1.2.2. Radioactive Gaseous Waste 1 Gaseous waste management system s process and control the release of gaseous radioactive 2 effluents to the atmosphere. Sources of radioactive gases from LGS include condenser 3 offgases, sources from the reactor enclosure, containment systems, and the "hot" maintenance 4 shop. 5 The condenser offgases are the largest source of radioactive gaseous waste. The offgas 6 system collects the noncondensable radioactive gases that are removed by the air ejectors from 7 the main condensers. The release of the offgas is delayed to allow for radioactive decay. T he 8 stream is released to the turbine enclosure vent stack and diluted with air and monitored upon 9 release through the north stack. 10 Other sources of radioactive gases are from the reactor enclosures, the turbine enclosures, and 11 radwaste buildings. Discharge of these gases are planned, monitored, controlled, and 12 discharged through the south stack. 13 The standby gas treatment system (SGTS) and the reactor enclosure recirculation system 14 (RERS) are used to reduce radioactive levels before being discharged into the environment. 15 2.1.2.3. Radioactive Solid Waste 16 The solid waste management system collects, processes, and packages solid radioactive 17 wastes for storage and offsite shipment and permanent disposal. To ensure compliance with 18 applicable regulations in 10 CFR Parts 20, 61, and 71, characterization, classification, 19 processing, waste storage, handling, and transportation are controlled by the LGS Process 20 Control Program. 21 Dry wastes (mostly Class A low -level radioactive wastes [LLRWs]) are collected throughout the 22 plant. Compressible and noncompressible wastes are packaged and temporarily stored until 23 they are sent to Duratech in Tennessee for processing or final disposal. 24 Wet wastes, generally Class A LLRWs, are collected, dewatered, packaged, and stored prior to 25 offsite shipment. Wastes from the reactor water cleanup (RWCU) system floor drains, 26 equipment drains, and fuel pool system usually exceed the criteria for LLRW or low specific 27 activity material and are packaged in containers and stored in the high level storage area 28 (HLSA), which is located in the Radwaste Enclosure. Exelon Generation Company, LLC 29 (Exelon) transports Class A LLRWs to EnergySolutions, LLC, in Clive, Utah, for disposal. 30 LGS has a "Green -is-Clean" (GIC) waste program that collects noncontaminated waste from the 31 radiological control area (RCA) from the different controls streams. This waste is packaged 32 separately and shipped to Duratech in Tennessee for processing and disposal. Any waste sent 33 to Duratech that is found to be contaminated is repackaged and sent to the offsite LLRW facility 34 in Clive, Utah. Exelon 's corporate policy is to minimize the generation of radioactive wastes by 35 following corporate waste minimization procedures. 36 There is an onsite radwaste storage pad (RSP) for temporary storage of radioactive waste 37 containers. The RSP is located west of the spray pond and has a fenced -in holding area and 38 another area surrounded by a concrete shell. Contaminated reusable equipment is stored here 39 as well as Class A wastes. Higher activity Class B/C wastes are not stored in this area. 40 Since closure of the Barnwell Facility to LGS in 2008, there has been no licensed facility that 41 accepts Class B/C LLRW shipments. Exelon has been temporarily storing the Class B/C 42 wastes in the HLSA. In May 2011, the NRC approved transport and temporary storage of LGS 43 Class B/C wastes at Exelon's Peach Bottom Atomic Power Station (PBAPS). Class B/C LLRW 44 stored at LGS or packaged in the future will be sent to PBAPS to be stored at the LLRW storage 45 Purpose and Need for Action 2-7 facility at that site. The storage capacity for LGS Class B/C wastes at PBAPS is expected to be 1 sufficient through the extended operating license for both LGS units. 2 2.1.2.4. Low-Level Mixed Wastes 3 Low-level mixed waste s (LLMW) are wastes that contain both low -level radioactive waste and 4 RCRA hazardous waste (40 CFR 266.210). LLMW is handled in accordance with Exelon 5 guidance and procedures. There is currently no LLMW stored at LGS. It is rare that LGS 6 generates LLMW; however, if it were necessary to treat and dispose of LLMW during the license 7 renewal period, Exelon would store it on site, in compliance with the 1976 Resource 8 Conservation and Recovery Act (RCRA) storage and treatment conditional exemption. RCRA 9 regulations are administered in the State by the Pennsylvania Department of Environmental 10 Protection (PADEP) (25 Pa. Code 260a). Transportation and disposal of LLMW would also 11 follow RCRA requirements. 12 When necessary, LLMW is shipped off site to Perma-Fix of Florida, which is licensed and 13 permitted to treat a variety of mixed waste, solids, liquids, sludges, and debris. Treated wastes 14 are then sent to EnergySolutions, LLC, disposal facility located near Clive, Utah. LLMW are 15 generated at LGS on occasion. LLMW are wastes that contain both low -level radioactive waste 16 and RCRA hazardous waste (40 CFR 266.210). 17 2.1.3. Nonradiological Waste Management 18 The LGS site generates nonradioactive wastes as part of routine plant maintenance, cleaning 19 activities, and plant operations. RCRA governs the disposal of solid and hazardous waste. 20 RCRA waste regulations are contained in 40 CFR Parts 239-299. In addition, 21 40 CFR Parts 239-259 contain regulations for solid (nonhazardous) waste, and 22 40 CFR Parts 260-279 contain regulations for hazardous waste. RCRA Subtitle C establishes 23 a system for controlling hazardous waste from "cradle to grave," and RCRA Subtitle D 24 encourages States to develop comprehensive plans to manage nonhazardous solid waste and 25 mandates minimum technological standards for municipal solid waste landfills. RCRA 26 regulations are administered in the State by the Pennsylvania Department of Environmental 27 Protection (PADEP) (25 Pa. Code 260a). PADEP further classifies solid waste as either 28 municipal waste (25 P a. Code 271) or residual waste (25 P a. Code 287). 29 2.1.3.1. Nonradioactive Waste Streams 30 LGS generates solid nonradioactive waste, defined by RCRA, as part of routine plant 31 maintenance, cleaning activities, and plant operations. Exelon manages these wastes, 32 including waste minimization, using corporate procedures that meet applicable regulations 33 (Exelon 2011b). RCRA regulations are administered in the state by the PADEP 34 (25 P a. Code Article 260a). 35 EPA classifies certain nonradioactive wastes as hazardous based on characteristics including 36 ignitability, corrosivity, reactivity, or toxicity (hazardous wastes are listed in 40 CFR Part 261). 37 State-level regulators may add wastes to the EPA's list of hazardous wastes. RCRA supplies 38 standards for the treatment, storage, and disposal of hazardous waste for hazardous waste 39 generators (regulations are available in 40 CFR 262). 40 EPA recognizes the following main types of hazardous waste generators based on the quantity 41 of the hazardous waste produced (EPA 2012d): 42 large quantity generators that generate 2,200 pounds (lb) (1,000 kg) per 43 month or more of hazardous waste, more than 2.2 lb (1 kg) per month of 44 Purpose and Need for Action 2-8 acutely hazardous waste, or more than 220 lb (100 kg) per month of acute 1 spill residue or soil, 2 small quantity generators that generate more than 220 lb (100 kg) but less 3 than 2,200 lb (1,000 kg) of hazardous waste per month, and 4 conditionally exempt small quantity generators that generate 220 lb (100 kg) 5 or less per month of hazardous waste, 2.2 lb (1 kg) or less per month of 6 acutely hazardous waste, or less than 220 lb (100 kg) per month of acute spill 7 residue or soil. 8 LGS, based on past and current generation of hazardous waste is classified as a small quantity 9 generator of hazardous waste, according to 40 CFR 262 and given in P a. Code 264a, with 10 hazardous wastes between 220 lb (100 kg) and 2 , 200 lb (1 , 000 kg) per month. The quantities 11 of hazardous waste and nonhazardous wastes are annually reported to PADEP (Exelon 2011 b). 12 The EPA classifies several hazardous wastes as universal wastes; these include batteries, 13 pesticides, mercury -containing items, and fluorescent lamps (25 P a. Code 266b). Exelon has 14 and expects to continue to generate universal waste such as discarded batteries, pesticides, 15 thermostats, and mercury -containing devices. Other wastes that are not classified as 16 hazardous waste but require regulation in Pennsylvania are (1) residual wastes such as 17 discarded solid, liquid, semi -solids from industrial operations, waste treatment system sludges, 18 and laboratory chemicals; (2) infectious waste; (3) regulated asbestos -containing material; and 19 (4) municipal waste. LGS is considered a Large Quantity Generator of universal wastes 20 (greater than 2 , 200 lb [1 , 000 kg] per month) (Exelon 2011b). 21 National Pollutant Discharge Elimination System (NPDES) permits that provide limits and 22 conditions for wastewater discharge are held by Exelon for industrial wastewater discharges 23 and storm water discharges from the LGS site into the Schuylkill River (No. PA0051926) and 24 discharges to the Bradshaw Reservoir to the East Branch Perkiomen Creek (No. PA0052221) 25 (Exelon 2011b). Radioactive liquid waste is addressed in Section 2.1.2.1 of this SEIS. 26 Section 2.2.4.2 gives more information about the LGS NPDES permit and permitted discharges. 27 The Emergency Planning and Community Right -to-Know Act (EPCRA) requires applicable 28 facilities to supply information about hazardous and toxic chemicals to local emergency planning 29 authorities and the EPA (42 USC 11001). On October 17, 2008, the EPA finalized several 30 changes to the Emergency Planning (Section 302), Emergency Release Notification 31 (Section 304), and Hazardous Chemical Reporting (Sections 311 and 312) regulations that were 32 proposed on June 8, 1998 (63 FR 31268). 33 Exelon does not expect its generation rates of nonradiological waste to increase significantly 34 during the extended period of operation (Exelon 2011b). 35 2.1.3.2. Pollution Prevention and Waste Minimization 36 In compliance with PADEP requirements, Exelon has implemented a Preparedness, Prevention 37 and Contingency (PPC) Plan as well as a Spill Prevention Control and Countermeasure (SPCC) 38 Plan compliant with 40 CFR 112, "Oil Pollution Prevention." 39 In support of nonradiological waste -minimization efforts, EPA's Office of Prevention and Toxics 40 has established a clearinghouse that supplies information about waste management and 41 technical and operational approaches to pollution prevention (EPA 2012 a). The EPA 42 clearinghouse can be used as a source for additional opportunities for waste minimization and 43 pollution prevention at LGS, as appropriate. EPA also encourages the use of environmental 44 management systems (EMSs) for organizations to assess and manage the environmental 45 impacts associated with their activities, products, and services in an efficient and co st-effective 46 Purpose and Need for Action 2-9 manner. EPA defines an EMS as "a set of processes and practices that enable an organization 1 to reduce its environmental impacts and increase its operating efficiency." EMSs help 2 organizations fully integrate a wide range of environmental initiatives, establish environmental 3 goals, and create a continuous monitoring process to help meet those goals. The EPA Office of 4 Solid Waste especially advocates the use of EMSs at RCRA -regulated facilities to improve 5 environmental performance, compliance, and pollution prevention (EPA 2012 b). Exelon has 6 implemented an EMS. 7 2.1.4. Plant Operation and Maintenance 8 Various types of maintenance activities are conducted at LGS, including inspection, testing, and 9 surveillance to maintain current licensing basis of the facility and to ensure compliance with 10 environmental and safety requirements. Various programs currently exist at LGS to maintain, 11 inspect, test, and monitor performance of facility equipment. These maintenance activities 12 include inspection requirements for reactor vessel materials, boiler and pressure vessel 13 inservice inspection and testing, a maintenance structures monitoring program, and 14 maintenance of water chemistry. 15 Additional programs include those carried out to meet technical specification surveillance 16 requirements, those implemented in response to NRC generic communications, and various 17 periodic maintenance, testing, and inspection procedures. Certain program activities are 18 performed during operation of the plant, while others are carried out during scheduled refueling 19 outages. Nuclear power plants must periodically discontinue production of electricity for 20 refueling, periodic inservice inspection, and scheduled maintenance. LGS refuels on a 21 24-month interval. 22 2.1.5. Power Transmission System 23 Four 230-kilovolt (kV) lines were constructed specifically to connect LGS Unit 1 to the regional 24 power grid, and one 500 -kV line was constructed to connect LGS Unit 2 to the regional electric 25 grid. Philadelphia Energy Company (PECO), an energy delivery subsidiary of Exelon 26 Corporation, owns and operates these lines. The LGS site also includes two switchyards -one 27 for each reactor unit. The Unit 1 switchyard is a 230 -kV substation, and the Unit 2 switchyard is 28 a 500-kV substation. Unless otherwise noted, the discussion of the power transmission system 29 is adapted from the Environmental Report (ER) (Exelon 2011b) or information gathered at 30 NRC's November 2011 environmental site audit (NRC 2012a). 31 2.1.5.1. Description of the Lines 32 220-60 and 220 -61 Lines 33 These lines extend southeast from the plant to the Cromby Substation in East Pikeland 34 Township, Chester County (see Figure 2-4). The two lines run parallel to the Schuylkill River 35 within two separate pre -existing railroad corridors on opposite sides of the river for about 36 12.9 km (8 miles). The 220-60 line traverses the Montgomery County side of the river, and the 37 220-61 line traverses the Chester County side of the river. The 220-60 line crosses the river 38 into Chester County before terminating at the Cromby Substation in East Pikeland Township, 39 Chester County. The 220-60 corridor is 18.3 m (60 ft) wide for the first 10.1 km (6.3 miles), at 40 which point the line leaves the railroad corridor and joins with an existing 76.2 -m (250-ft)-wide 41 PECO corridor for 1.8 km (1.1 miles). The 220-60 line travels through the 220 -61 corridor once 42 it crosses the river. The 220-61 corridor is 18.3 m (60 ft) wide for the entire length of the 43 corridor. The 220-61 line is within the Schuylkill River National and State Heritage Area and 44 parallels a planned portion of the Schuylkill River Trail. 45 Purpose and Need for Action 2-10 220-62 Line 1 This line spans a total of 25.7 km (16 miles) from the Cromby Substation (the termination point 2 of the 220 -60 and 220-61 lines) to north and then east to the North Wales Substation in Upper 3 Gwynedd Township, Montgomery County (see Figure 2-5). When constructed, the line was 4 routed through an existing PECO transmission line corridor. The corridor varies from 45.7 m 5 (150 ft) to 137.2 m (450 ft) wide and traverses the Evansburg State Park in Skippack Township. 6 220-63 and 220 -64 Lines 7 The 220-63 and 220 -64 lines span a total of 16.1 km (10 miles) and 5.6 km (3.5 miles), 8 respectively, from the Cromby Substation southeast and then south to their respective 9 termination points at Barbadoes Substation in West Norri s to wn Township and Plymouth 10 Meeting Substation in Plymouth Township, Montgomery County (see Figure 2-6). The lines 11 cross the Schuylkill River in five locations and parallel an open portion of the Schuylkill River 12 Trail between Phoenixville Borough and Philadelphia. The lines also traverse the Valley Forge 13 National Park. When constructed, the lines were routed through a combination of existing 14 PECO transmission line corridors and railroad corridors. The corridor width varies from 45.7 m 15 (150 ft) to 137.2 m (450 ft). 16 5031 Line 17 This line spans a total of 27.4 km (17 miles) from the Limerick 500 -kV substation east to the 18 Whitpain Su bstation in Whitpain Township, Montgomery County (see Figure 2-7). The line 19 crosses the Schuylkill River in Limerick Township and Evansburg State Park in Skippack 20 Township. When constructed, the line was routed along an existing transmission line corridor 21 associated with a 500 -kV line originating from Peach Bottom Atomic Power Station in Delta, 22 Pennsylvania. The line also merges with the 220 -62 line corridor for about 4.8 km (3 miles). 23 The corridor width varies from 91.4 m (300 ft) to 137.2 m (450 ft). 24 Purpose and Need for Action 2-11 Figure 2-4. Limerick to Cromby 230-kV Transmission Line Route 1 Source: Exelon 2011b EAST COVENTRY Limerick 230 kV (Exelon Generation) EAST VINCENT ':;..0 !!!!!!!!!!!!!!!!! 0 iii'5 iiiiiiiiiiii c: Mi les 1 in= 1 mi les Le aend 230 kV V oltage (;l i Mun i cipal Boundary ,..., Umerick-Cromby 220-00 Line
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- Substation (PO WERm ap 2009) 0 U.S. Highway
- Slate Parks (DCNR 2009) 0 State Road Exelon. NAO 1983 State Protection
- lambe rt Confoc ma l Co n ic Unear Un it Foot US Purpose and Need for Action 2-15 2.1.5.2. Transmission Line Corridor Vegetation Maintenance 1 The majority of the transmission line 2 corridors associated with LGS lines 3 traverse suburban areas and agricultural 4 lands. PECO follows an integrated 5 vegetation management program that 6 combines manual, mechanical, biological, 7 and chemical control techniques to 8 maintain proper clearance from 9 transmission lines and structures.
PECO 10 maintains vegetation on a 5-year cycle, 11 and the degree and type of clearance varies by line voltage and the type, growth rate, and 12 branching characteristics of trees and vegetation. PECO contracts with Asplundh Tree Expert 13 Company to perform the majority of maintenance work, and the Davey Resources Group, part 14 of the Davey Tree Expert Company, oversees quality assurance. 15 Workers follow the current American National Standards Institute (ANSI) guideline document, 16 A300 Standards for Tree Care Operations, which contains requirements and recommendations 17 for tree care practices, including pruning, lightning protection, and integrated vegetation 18 management. These standards describe a wire -border zone management approach in which 19 the wire zone (the section of the corridor directly under the wires and extending outward about 20 10 ft [3 m]) is managed to promote low -growing plant communities dominated by grasses, 21 herbs, and small shrubs (Miller 2007). The border zone (the remainder of the corridor on either 22 side of the lines) is managed to promote small shrubs and lower growing trees (Miller 2007). 23 PECO has also followed the North American Electric Reliability (NERC) FAC -003, Vegetation 24 Management, since 2003. This guidance document recommends that all transmission line 25 owners have a specific vegetation maintenance plan that addresses vegetation inspections, 26 clearances, qualifications of workers, and environmental impact mitigation. 27 2.1.5.3. PECO's Environmental Stewardship and Partnerships with State and Local Agencies 28 As part of its environmental stewardship effort, PECO maintains a program to protect birds and 29 comply with applicable Federal and state bird regulatio ns, and that promotes native vegetation, 30 maintains an environmental management certification, and partners with Federal and state 31 agencies for specific mitigation or restoration projects. 32 PECO's avian management program provides guidance to workers on how to deal with bird 33 nests or dead birds when encountered during field operations and how it complies with 34 applicable Federal and state bird regulations, including the Migratory Bird Treaty Act, the 35 Endangered Species Act, and the Bald and Golden Eagle Protection Act. 36 As part of its maintenance procedures, PECO favors native warm season grass mixtures and 37 native flower mixtures that include species such as little blue stem (Schizachyrium scoparium), 38 big blue stem (Andropogon gerardi), Indian grass (Sorghastrum nutans), goldenrod 39 (Solidago spp.), milkweed (Asclepias spp.), and aster (Aster spp.). 40 PECO maintains an International Organization for Standardization (ISO) 14001 certification, 41 which provides a framework for environmental management systems to help companies 42 manage the environmental impact of their activities and demonstrate sound environmental 43 management (ISO 2009). 44 When the National Park Service (NPS) acquired an additional 65 acres (ac) (26 hectares[ha ]) 45 parcel of land for the Valley Forge National Park that coincided with the 220 -63 and 220 -64 46 Transmission line corridors (or right -of-ways) are strips of land used to construct, operate, maintain, and repair transmission line facilities. The transmission line is usually centered in the corridor. The width of a corridor depends on the voltage of the line and the height of the structures. Transmission
line corridors typically must be clear of tall -growing trees and structures that could interfere with a power line. Purpose and Need for Action 2-16 corridor, PECO partnered with NPS to restore the acquired land to a native warm season grass 1 community. PECO provided both contractors and equipment for this effort (Exelon 2011b). 2 2.1.6. Cooling and Auxiliary Water Systems 3 LGS uses a cooling tower -based heat dissipation system that normally withdraws from and 4 discharges cooling water to the Schuylkill River. In summary, the majority of the makeup water 5 withdrawn is to provide cooling water for the LGS steam turbine condensers. As water 6 evaporates in the cooling towers to dissipate heat to the atmosphere, cooling water is lost and 7 must be replaced. Additionally, to control the chemistry of the circulating water in the cooling 8 system, a portion of the cooling water is continuously discharged (i.e., blowdown). A much 9 smaller portion of the makeup water is used to remove heat from auxiliary equipment during 10 normal operation. A clay -lined spray pond located north of the cooling towers provides 11 emergency cooling but has an insignificant interface with the environment. Four groundwater 12 wells are also located on the LGS site to support LGS operations. Unless otherwise cited for 13 clarity, the NRC drew information about LGS's cooling and auxiliary water systems from 14 Exelon's ER (Exelon 2011b) and responses to NRC's request for additional information 15 (Exelon 2012 b). NRC staff also toured these systems and facilities during the environmental 16 site audit (NRC 2012). 17 Individual LGS systems that interact with the environment are summarized below and focus on 18 facilities owned and operated by Exelon. 19 Makeup Water Supply System. The LGS makeup water supply system is comprised of the 20 individual water sources, facilities, systems, and components used for supplying makeup water 21 to LGS plant systems. These include the cooling water system, including the circulating water 22 systems for each LGS unit, and other plant systems. In total, LGS operates its makeup water 23 supply system and uses its makeup sources in accordance with Delaware River Basin 24 Commission (DRBC) approvals (Docket No. D-69-210, as revised) (DRBC 2004). A discussion 25 of these makeup sources and associated facilities and their attributes follows. 26 2.1.6.1. Schuylkill River Source 27 The Schuylkill River is the primary source of makeup water for LGS (see Figure 2-8). Water is 28 withdrawn from the river via the Schuylkill Pumphouse located on the eastern bank of the river 29 on the LGS site. River water enters the pumphouse through eight trash rack (bar screen) 30 panels with sufficient bar spacing to allow aquatic life to pass. A floating trash dock with skirt 31 located in front of the trash rack functions to divert river debris and some aquatic life before 32 reaching the trash racks. Intake water then passes through four travelling screens prior to the 33 intake bays. The screens have 0.25 -in. (0.64-cm) mesh openings designed to limit water 34 approaching the screens to a velocity of 0.75 fps (0.23 m/s). A backwash system operates 35 automatically to clean the traveling screens of debris to maintain adequate pump wet -well 36 levels. Screen backwash water is returned to the river via a Pennsylvania NPDES permitted 37 outfall (no. 011). Leaves and debris removed from the traveling screens are collected in a 38 dumpster and transported off site for disposal (Exelon 2012b). The facility has three pumps for 39 cooling water makeup and two pumps for blowdown (nonconsumptive) water makeup use. The 40 three cooling water pumps each have a rated capacity of 11,300 gpm (25.2 cfs or 0.71 m 3/s), 41 and the two blowdown makeup pumps are each rated at 4,000 gpm (8.9 cfs or 0.25 m 3/s). 42 These pumps are usable in any combination to meet the total plant makeup demand (for 43 consumptive and nonconsumptive use) of up to 56.2 million gallons per day (mgd) (212,700 m 3). 44 From the pumphouse, a 36-in. (91-cm) pipeline conveys water to the cooling tower basins. Two 45 smaller lines supply water to (1) a raw water clarifier in the process water treatment system and 46 (2) the spray pond. 47 Purpose and Need for Action 2-17 Figure 2-8. Location of Schuylkill Pumphouse and LGS Discharge Structure 1 Source: Exelon 2011a 0 75 150 300 1 inch; 1 50 feel Exelon. NAO 1983 :Stole Plano SOoAh Lambert ConfamaJ ConiC Linear Un it: Foot US Purpose and Need for Action 2-18 Seasonal low flows in the Schuylkill River and specific conditions and limitation s imposed by the 1 DRBC require that alternative makeup water sources be used by LGS either directly or to 2 augment flow in the Schuylkill River. In point, source augmentation averaging 35 mgd 3 (132,500 m 3) or 24,300 gpm (54.1 cfs or 1.5 m 3/s) is required about 6 months per year 4 (Exelon 2012 d). Pursuant to DRBC rules and regulations, dockets are used to place limits and 5 conditions on individual projects, such as LGS, that use water within the Delaware River Basin. 6 DRBC Docket No. D-69-210 CP, as revised, prescribes the low -flow conditions that trigger the 7 requirement for LGS to use alternative water sources for consumptive use. Depending on 8 conditions, a combination of the DRBC -approved alternative water sources (as depicted in 9 Figure 2-9) are used to supply consumptive use makeup water to LGS, although LGS may 10 withdraw water from the Schuylkill River for nonconsumptive use without restriction. Perkiomen 11 Creek is the first supplemental water source to be considered when withdrawals from the 12 Schuylkill River are restricted because of low flow. 13 2.1.6.2. Perkiomen Creek Source 14 LGS must also withdraw water from Perkiomen Creek when the flow in the Schuylkill begins to 15 drop below 560 cfs (15.9 m 3/s) for two -unit operation (as measured at the U.S. Geological 16 Survey [USGS] maintained Pottstown, Pennsylvania, gage station), if instream flow conditions in 17 Perkiomen Creek allow. Water is withdrawn via Exelon's Perkiomen Pumphouse (auxiliary 18 intake pumphouse), which is located just inland from the west bank of Perkiomen Creek. Water 19 is withdrawn from the creek through a set of 15 submerged, stationary "wedge-wire" screen 20 intakes on the middle of the streambed. Each screen is sized at 24 -in. (61-cm) by 72-in. 21 (183-cm), with a slot size of 0.08 in. (0.2 cm). The screens provide an average through -slot 22 velocity of 0.4 fps (0.12 m/s). An air burst backwash system automatically functions to remove 23 accumulated debris (Exelon 201 2b). Three intake pumps, including a spare, rated at 24 14,600 gpm (33 cfs pr 0.92 m 3/s) are sized to supply the consumptive cooling demands for both 25 LGS units. A small auxiliary pump operates as needed to maintain the facility's water storage 26 tank when the intake system is not active. Water is conveyed by an underground pipeline 27 approximately 8 miles (13 km) to a storage tank located at the LGS site. 28 2.1.6.3. Delaware River Augmentation Source 29 The natural flow in Perkiomen Creek is not always adequate for LGS's consumptive makeup 30 water needs. This situation arises when the natural flow of Perkiomen Creek falls below 210 cfs 31 (5.9 m 3/s) for two -unit operation, as measured at the USGS -maintained Graterford, 32 Pennsylvania, gage station. Therefore, Exelon has established a system to transfer water for 33 flow augmentation purposes from the Delaware River to East Branch Perkiomen Creek and, 34 ultimately, Perkiomen Creek. This diversion of water originates at the Point Pleasant Pumping 35 Station on the Delaware River, located about 30 miles (48 km) northeast of the LGS 36 (see Figure 2-9). The pumping station is owned by a municipal water purveyor and not Exelon. 37 The Point Pleasant Pumping Station withdraws from a deep water, mid -channel intake in the 38 Delaware River. The intake structure consists of two rows of fixed cylindrical wedge -wire 39 screens, with each row comprised of 12 screens. Each screen measures 40 -in. (102-cm) in 40 diameter and 80 -in. (203-cm) of total screened length. Screens have a slot size of 0.08 in. 41 (0.2 cm). At the maximum pumping rate of 95 mgd (360,000 m 3), the average intake velocity is 42 0.35 fps (0.11 m/s). Maintenance of the intake screens includes high -pressure spray washing 43 and scrubbing by divers four times a year, with return of organic debris to the Delaware River 44 (Exelon 2012b). 45 Purpose and Need for Action 2-19 Figure 2-9. LGS Makeup Water Supply System and Alternative Water Sources within the 1 Delaware River Basin 2 Source: Modified from Exelon 2011a Once withdrawn at Point Pleasant, water is conveyed through a series of pumping stations, to 3 the Bradshaw Reservoir, and then via transmission mains to East Branch Perkiomen Creek. At 4 the outset, water is transferred as necessary to the Bradshaw Reservoir to maintain adequate 5 reservoir operational volume and reserve storage. Located on a 43 -ac (17-ha) site and 6 approximately 27 miles (44 km) northwest of LGS, both the reservoir and associated Bradshaw 7 Pumphouse are owned and operated by Exelon. According to Exelon personnel, the reservoir 8 is maintained at an operating level of 17 to 21 ft (5.2 to 6.4 m), and the reservoir can be pumped 9 Purpose and Need for Action 2-20 down as far as 8 ft (2.4 m) before suction is lost. From the Bradshaw Reservoir, water is 1 pumped about 6 miles (10 km) by pipeline routed along a natural gas pipeline right-of-way to 2 East Branch Perkiomen Creek. Located about midway along the pipeline routing, Exelon also 3 owns and operates the Bedminster Water Processing (Treatment) Facility that is used to 4 seasonally disinfect the water before it is discharged into the East Branch Perkiomen Creek in 5 accordance with NPDES Permit PA0052221. 6 In the event drought conditions on the Delaware River threaten the ability to transfer water to 7 East Branch Perkiomen Creek, Exelon also has an agreement in place as one of the seve n 8 utility owners of the Merrill Creek Reservoir in northwestern New Jersey to release water to the 9 Delaware for flow augmentation purposes. This could be exercised in the event of a 10 DRBC-declared drought emergency. A separate DRBC docket governs operation of the 11 reservoir. 12 2.1.6.4. Wadesville Mine Pool and Still Creek Reservoir Augmentation Sources 13 LGS also uses two additional upstream water sources, the Wadesville Mine Pool and Merrill 14 Creek Reservoir, to directly augment Schuylkill River flow (see Figure 2-9). As a demonstration 15 project, DRBC approved the use of these sources in 2002 to compensate for the withdrawal of 16 cooling water from the Schuylkill River and to evaluate the feasibility of continuing withdrawals 17 from the river even under low flow conditions. Flow augmentation with these sources began in 18 2003 and has included DRBC oversight. The Wadesville Mine Pool is located approximately 19 70 miles (112 km) northwest of LGS in Pennsylvania's anthracite coal region. The mine pool is 20 comprised of an extensive complex of flooded underground mine workings some 700 ft (210 m) 21 deep, storing an estimated 3.6 billion gal (13.6 billion m 3) of water. The mine pool is unique, as 22 compared to other coal workings that contribute to acid mine drainage, in that the water 23 percolating through the workings has a neutral pH (NAI and URS 2011). Additionally, releases 24 from the Still Creek Reservoir, located northeast of the Wadesville Mine Pool, are included in 25 the demonstration project. DRBC previously approved this reservoir for emergency releases 26 under a contract between Exelon and its owner and operator to augment low flows in the 27 Schuylkill River when the Delaware River diversion system is unavailable (see Section 2.1.7.1). 28 Circulating Water System. The LGS circulating water system is a closed -cycle cooling system 29 that removes heat from the condenser and transfers it to the atmosphere through evaporation 30 using hyperbolic natural -draft cooling towers. The plant's twin cooling towers rise more than 31 500 ft (152 m) above the ground. The circulating water system uses water from the LGS 32 makeup water system to replenish the water lost from evaporation, drift, and blowdown. For 33 each LGS unit, the circulating water system consists of one cooling tower, three main 34 condensers, four 25 -percent-capacity circulating water pumps, and associated piping, valves, 35 controls, and instrumentation. 36 Blowdown Discharge System. Operation of LGS's closed -cycle cooling system results in 37 evaporative water losses of approximately 75 percent from the plant's twin cooling towers. T o 38 control the chemistry of the water in the cooling system due to the buildup of total dissolved 39 solids, a portion of the water must be continuously discharged. Each cooling tower basin has a 40 blowdown line that combines into a single, 36 -in. (32-cm) line that discharges through a 41 submerged, multi-port diffuser pipe into the Schuylkill River at a point about 700 ft (210 m) 42 downstream from the Schuylkill Pumphouse (see Figure 2-8). The diffuser is encased in a 43 concrete channel stabilization structure on the east side of the river. The discharge structure 44 consists of a 28 -in. (71-cm) pipe with a total of 283 nozzles installed on 6 -in. (15-cm) centers; 45 nozzles have a 1.25 -in. (3.2-cm) diameter opening. As shown in Figure 2-8, the diffuser does 46 not use the entire channel width. 47 Purpose and Need for Action 2-21 Plant Service Water System. The plant service water system functions continuously to supply 1 water for service -water cooling (e.g., removal of heat rejected from auxiliary equipment), 2 emergency service water, residual heat removal service water, and the clarified water system. 3 Generally, these are small and normally nonconsumptive uses of water. 4 Each LGS unit has a nonsafety -related single -loop cooling system for normal operations that 5 uses three 50 -percent capacity pumps operating, with one pump on standby status. These 6 loops take water from each unit's cooling tower basin. These pumps circulate cooling water 7 from the cooling tower basins through various heat exchangers and then back to the cooling 8 towers. This service water system may at times also support decay heat removal during a 9 refueling outage. 10 An emergency service water system exists to supply cooling water to emergency equipment in 11 the event of the loss of normal cooling. The system consists of two independent cooling loops 12 and associated pumps. The pumps circulate water through the LGS spray pond located north 13 of the LGS cooling powers for cooling through spray nozzles or winter bypass lines. Another 14 safety-related system, the residual heat removal system, is also routed through the spray pond. 15 The two loops of this system supply cooling water to each of the two heat exchangers that serve 16 each LGS unit. 17 Clarified river water for component lubrication and as makeup to the demineralized water 18 system is supplied by the clarified water system. This system uses water from the cooling water 19 intake system. 20 Groundwater Supply System. Potable water and fire emergency water for LGS are provided by 21 two separate wells. Two additional wells supply nonpotable water intermittently to the Limerick 22 Training Center and the Limerick Energy Information Center, respectively. 23 2.1.7. Facility Water Use and Quality 24 As discussed above, LGS Units 1 and 2 use a closed -cycle cooling system that primarily relies 25 upon the Schuylkill River for its makeup water supply and, secondarily, Perkiomen Creek (see 26 Section 2.1.6). Water losses from the plant's cooling towers because of evaporation and drift 27 average about 75 percent. As this water must be continually replaced, such a high consumptive 28 use can conflict with the needs of other downstream users and with aquatic life, especially on 29 smaller rivers (Exelon 2011b). 30 However, Exelon has developed an extensive surface water diversion system to supplement 31 LGS's consumptive cooling water needs and to manage (augment) low river flows, as also 32 described in Section 2.1.6. The Schuylkill River is also the makeup water source for replacing 33 water discharged as blowdown from the cooling towers, which is necessary to control the quality 34 of the recirculating cooling water. This use is considered to be nonconsumptive in nature. 35 Nevertheless, all surface water withdrawals by LGS are regulated by the DRBC. Cooling tower 36 blowdown, in addition to other plant wastewaters, is ultimately discharged back to the Schuylkill 37 River via a submerged discharge structure. This is LGS's main outfall (no. 001), which is 38 regulated under its Pennsylvania NPDES permit (No. PA0051926), in addition to DRBC docket 39 provisions (Exelon 2011b). 40 Exelon also operates two primary groundwater supply wells in the main plant area to meet the 41 potable needs of plant personnel and to supply fire emergency water, respectively. Two 42 additional wells, one at the Limerick Training Center and another at Limerick Energy Information 43 Center, supply water for sanitary needs in restrooms (Exelon 2011b). 44 Exelon is annually required to report water use data for LGS to the PADEP in accordance with 45 the Pennsylvania Water Resources Planning Act pursuant to 25 P a. Code 110 (Exelon 2011 b). 46 Purpose and Need for Action 2-22 NRC staff reviewed the last 5 years of Exelon's Act 220 Water Withdrawal and Use Reports 1 submitted to the PADEP. 2 A description of surface water resources at LGS and vicinity is provided in Section 2.2.4, and a 3 description of the groundwater resources is presented in Section 2.2.5. The following sections 4 further describe the water use from these resources. 5 2.1.7.1. Surface Water Use 6 Makeup water demands for LGS Units 1 and 2 nominally total 56.2 mgd or 39,000 gpm (87 cfs 7 or 2.5 m 3/s). For full operations, this includes 42 MGD or 29,200 gpm (65 cfs or 1.8 m 3/s) for 8 consumptive cooling water use and 14.2 mgd or 9,860 gpm (22 cfs or 0.6 m 3/s) for 9 nonconsumptive use (Exelon 2011b). As previously discussed, LGS water usage is governed 10 by the DRBC docket approval and demonstration project that restricts surface water withdrawals 11 from the Schuylkill River for consumptive use to protect water quality and quantity. These 12 restrictions are triggered, requiring Exelon to switch to alternative water sources, when either 13 the flow of the river falls below 560 cfs (15.9 m 3/s) for two-unit operation, or 530 cfs (15 m 3/s) for 14 one-unit operation. This is adjusted based on upstream releases from DRBC -approved projects 15 (DRBC 2004, Exelon 2011a). 16 In addition, PADEP requires that water users submit water use information annually, in support 17 of its State Water Plan. Accordingly, Exelon reports LGS water usage to PADEP. The State 18 Water Plan serves as a functional planning tool to establish vision, goals, and recommendations 19 for meeting the challenges of sustainable water use over a 15-year planning horizon. 20 Since initiating the water supply diversion project in 2003, Exelon has sought to demonstrate 21 that makeup water demands could be obtained from the Schuylkill River over a much wider 22 range of conditions without deleterious effects. This included a major modification to the 23 demonstration project that was approved in 2005 which, for the first time, allowed for 24 withdrawals from the Schuylkill River for consumptive use when ambient water temperature was 25 at or above 59
ºF (15 ºC). Previously, DRBC prohibited withdrawals for consumptive use 26 makeup at or above that temperate and required LGS to rely upon the Perkiomen Pumphouse 27 (Exelon 2011b). In summary, the objectives of the demonstration project include:
(1) gaining 28 an understanding of increased reliance on the Schuylkill River, (2) evaluating the effects of 29 permanently lifting the 59
ºF (15 ºC) temperature restriction, (3) evaluating the effects of using 30 the Wadesville Mine Pool and Still Creek Reservoir as low flow augmentation sources, 31 (4) evaluating the effects of reducing water diversions from the Delaware River, and 32 (5) evaluating the effects on public water supplies (Exelon 2012 d). Based on the results of the 33 demonstration project, Exelon submitted an application to the DRBC in September 2007 to 34 make the provisions of the demonstration project permanent to support LGS operations and to 35 consolidate all of DRBC's docket approvals for surface water withdrawal, discharge, and 36 groundwater usage into a single comprehensive docket (Exelon 2011a, DRBC 2011a). 37 In May 2011, the DRBC passed a resolution approving Exelon's request to increase LGS's peak 38 daily surface water withdrawals from 56.2 mgd or 39,000 gpm (87 cfs or 2.5 m 3/s) to 58.2 mgd 39 or 40,420 gpm (90 cfs or 2.6 m 3/s). This request was made to increase consumptive use 40 withdrawals by 2 mgd or 1,390 gpm (3.1 cfs or 0.09 m 3/s) to provide operational flexibility to 41 counter conditions of high air temperature combined with low relative humidity that had caused 42 LGS to approach its maximum daily withdrawal limit in 2010 (DRBC 2011b). In 43 December 2011, the DRBC extended the terms of docket Revision 12 for LGS, including the 44 demonstration project for another year to enable it to complete work on Exelon's docket revision 45 and to hold a public hearing. As such, the terms of the current DRBC docket approval 46 (DRBC 2004), as amended, and demonstration project remain in effect through 47 December 31, 2012 or until the DRBC approves a revised docket (DRBC 2011a). 48 Purpose and Need for Action 2-23 Exelon officials met with DRBC officials on the status of the consolidated docket in 1 February 2012 (Exelon 2012a). In June 2012, DRBC issued a draft consolidated docket for 2 review and comment and held a hearing on August 28, 2012.
3 2.1.7.2. Groundwater Use 4 Groundwater is withdrawn at LGS through two onsite wells to support LGS operations, with two 5 additional wells supporting secondary uses (see Section 2.1.7). 6 Well 1 (the "Alley" Well) supplies potable water to LGS personnel. Well 3 (the "Batch Plant" 7 Well) provides backup water supply to a fire water storage tank. Both wells were constructed as 8 open boreholes in the Brunswick Formation with completion depths of 310 ft (94 m) and 585 ft 9 (178 m) and pump capacities of 50 gpm (189 L/min) and 65 gpm (246 L/min), respectively. 10 Both wells had their pumps replaced in 2004. Well 1 is located just east of the Unit 2 buildings 11 and southeast of the Unit 2 cooling tower, while well 3 is located about 500 ft (150 m) east of the 12 Unit 2 cooling tower (CRA 2006, Exelon 2011a). As a potable supply well for the plant, Well 1 is 13 operated by Exelon under a public water supply permit from the PADEP. Before distribution, 14 the water is treated by disinfection, for corrosion control for lead and copper, and by filtration to 15 reduce arsenic levels (Exelon 2011b). 16 Two additional active groundwater wells (i.e., the Training Center and Energy Information 17 Center wells) are located on the LGS plant site but outside the main plant complex. These wells 18 are seldom operated and only to provide sanitary water for restrooms at the referenced facilities 19 (Exelon 2011b). The Training Center well is 5 60 ft (170 m) in depth and the Information Center 20 well is 1 23 ft (37.5 m) in depth, based on Pennsylvania well records (Exelon 2011a, 21 PA DCNR 2012). 22 LGS's wells are located in the Southeastern Pennsylvania Ground Water Protected Area 23 designated by the DRBC. Specifically, LGS is located in the Schuylkill -Sprogels Run Subbasin 24 designated by the DRBC and for which basin -wide groundwater withdrawal limits have been set 25 due to stress on the bedrock aquifer system (DRBC 1999, Exelon 2011a). Groundwater users 26 in subbasins designated by the DRBC as stressed and withdrawing 10,000 gallons per day 27 (gpd) (38,000 L/day) or more during any 30 -day period are required to obtain a protected area 28 permit from the DRBC or have docket approval for such withdrawals (DRBC 1999 , 29 18 CFR 430). The draft docket issued by the DRBC (see Section 2.1.7.1) proposes 30 groundwater production limits for LGS. 31 Based on data from 2001 through 2010, LGS's total groundwater production from its primary 32 production wells has ranged from 14.3 to 21.1 gpm (54.1 to 79.9 L/min) or 20,600 to 33 30,300 gpd, and averaged 17.9 gpm (67.8 L/min) or 25,800 gpd (Exelon 2011a, 2012 b). While 34 not subject to reporting under PADEP regulations, the two LGS secondary wells produce less 35 than 4 gpm (13.9 L/min) combined (Exelon 2011b). 36 2.2. Surrounding Environment 37 The LGS plant site comprises a total of 645 ac (261.0 ha), including 491 ac (198.7 ha) in 38 Montgomery County and 154 ac (62.3 ha) in Chester County. The LGS site is located along the 39 Schuylkill River, which flows in a southeasterly direction to its confluence with the Delaware 40 River. The Schuylkill River passes through the LGS plant site and separates its western 41 portion, which is located in Chester County, from its eastern portion, which is located in 42 Montgomery County. 43 The LGS is located about 1.7 miles (2.7 km) southeast of the Borough of Pottstown, the nearest 44 population center. Other nearby population centers are the City of Reading located 19 miles 45 Purpose and Need for Action 2-24 (30.6 km) northwest of the site, the Borough of Phoenixville located about 9.3 mi(15 km) 1 southeast of the site, the Municipality of Norristown about 11 miles (17.7 km) southeast of the 2 site, and the city limits of Philadelphia, which are about 21 miles (33.8 km) southeast of the site. 3 2.2.1. Land Use 4 The site is surrounded by gently rolling countryside and farmland, with several valleys 5 containing tributary drainages of the Schuylkill River. The vicinity of the site has experienced 6 suburban growth as local farmland has been converted to several new residential subdivisions 7 since the LGS units came online in 1986 and 1990. Figure 2-1 illustrates the principal land 8 uses in the vicinity of the LGS, out to 6 miles (10 km). 9 Exelon owns both the primary LGS site and several offsite support facilities, including the 10 Perkiomen Pumphouse, the Perkiomen Pumphouse -to-LGS pipeline, Bradshaw Reservoir and 11 Pumphouse, and the Bedminster Water Processing (Treatment) Facility. Additional offsite 12 facilities and components of the LGS makeup water system having contractual agreements with 13 Exelon, but which are neither owned nor controlled by Exelon, including the following: 14 Wadesville Mine Pool, Pumphouse, and discharge channel, 15 Still Creek Reservoir, 16 Point Pleasant Pumping Station and combined water transmission main to 17 the Bradshaw Reservoir, and 18 Pottstown Gage Station, the Graterford Gage Station, and the Bucks Road 19 Gage Station. 20 Exelon jointly owns and operates the Merrill Creek Reservoir near Phillisburg, New Jersey, with 21 six other utilities. The reservoir stores water for release when required to mitigate consumptive 22 use at designated electric generating facilities, including LGS, in the event of low -flow conditions 23 in the Delaware River. 24 The major transportation routes located within 6 miles (10 km) of the site include 25 U.S. Highway 422 (US-422), an east -west highway passing about 1.5 miles (2.4 km) north of 26 the site; Pennsylvania Route 100 (PA-100), a north -south highway passing about 4 miles 27 (6.4 km) west of the site in Chester County; and PA -724, a southeast -northwest highway 28 passing about 1 mile (1.6 km) southwest of the site. The single plant entrance/exit can only be 29 accessed by Evergreen Road, either directly from the Sanatoga exit of US -422 or indirectly from 30 the Limerick Linfield exit of US -422 by several local roads. Figure 2-2 illustrates prominent 31 features of the LGS region, out to 50 miles (80 km). 32 All activities on the LGS site are under the control of Exelon. The immediate area surrounding 33 LGS is enclosed by a security barrier shown in Figure 2-3. Access to LGS is through a security 34 gate by a three-lane road, Evergreen Road, north of the plant. A Conrail rail line (formerly 35 Reading Company) traverses the LGS site along the eastern side of the Schuylkill River. The 36 rail line includes two tracks and a rail spur serving LGS. Another Conrail rail line (formerly Penn 37 Central Railroad) runs along the western side of the Schuylkill River, traversing the Chester 38 County portion of the LGS site. 39 Notable manmade features within a 6 -mi le (10-km) radius of LGS (see Figure 2-1) include the 40 Pottstown-Limerick regional airport roughly 1.5 miles (2.5 km) northeast, the Philadelphia 41 Premium Outlets shopping mall roughly 1 mile (1.6 km) northeast, and the Occidental Chemical 42 Corporation/Firestone Tire EPA superfund site roughly 1.5 miles (2.4 km) west of the LGS site. 43 Purpose and Need for Action 2-25 Nearby communities include Pottstown, approximately 1.7 miles (2.7 km) northwest; 1 Royersford, 3.8 miles (6.1 km) southeast; Phoenixville, 7.6 miles (12.2 km) southeast; and 2 Philadelphia, 29 miles (46 km) southeast of the LGS site. 3 2.2.2. Air Quality and Meteorology 4 The LGS site is located within the Schuylkill River valley of the Piedmont Plateau in 5 southeastern Pennsylvania. LGS maintains two meteorological towers that are in close 6 proximity to the site. The primary tower (Tower
- 1) is located approximately at site grade and is 7 76.2 m (250 ft) above mean sea level (MSL) (Exelon 2011 b). The secondary tower (Tower
- 2) is 8 located closer to the Schuylkill River and is at an elevation of 36.9 m (121 ft) above mean sea 9 level. The meteorological towers are instrumented at three levels and take measurements of 10 wind direction, wind speed, and temperature. Additional measurements, including wind 11 direction fluctuations, relative humidity, pressure, and precipitation, are made at Tower
- 1. 12 The region surrounding the LGS site is characterized by a humid, continental climate that is 13 moderated by the presence of the Appalachian Mountains to the west and the Atlantic Ocean to 14 the east (NCDC 2012a). Periods of extreme heat or cold are generally short
-lived. The 15 summer months of June through September are warm and humid, and at times the area is 16 engulfed in maritime air from the western Atlantic (NCDC 2012 b). The winter months of 17 December through February are characterized by frequent periods of warming and cooling from 18 mid-latitude, low -pressure systems and associated fronts passing through the area; minimum 19 temperatures during this time are usually below freezing, but temperatures below zero are rarely 20 observed (NCDC 2012 c). 21 The staff obtained climatological information with 30 -year averages (19812010) for the 22 Allentown and Philadelphia, Pennsylvania, first-order National Weather Service (NWS) stations. 23 Both stations are approximately 30 miles from the LGS site and can be used to characterize the 24 region's climate because of their nearby location, comparable elevation, and long period of 25 record. Regionally, the prevailing wind direction is from the southwest during most of the year, 26 except during the winter months, when it is generally from the west -northwest 27 (NCDC 2012b, 2012c). During stable atmospheric conditions, low -level winds at the LGS site 28 may be channeled in the same general direction as the Schuylkill River Valley, which is oriented 29 in the north -northwest to south -southeast direction (Exelon 2012 c). Mean annual wind speeds 30 average around 8 to 9 mph (3.5 to 4.0 m/s); winds are faster than average in the spring and 31 slower than average in late summer (NCDC 2012b, 2012c). Peak wind gusts were 69 mph 32 (30.8 m/s) in Allentown (NCDC 2012 c) and 75 mph (33.5 m/s) in Philadelphia (NCDC 2012 b). 33 In Allentown, monthly mean temperatures range from a low of 27.9
°F (-2.3 °C) in January to a 34 high of 74.1 °F (23.4 °C) in July (NCDC 2012b). In Philadelphia, monthly mean temperatures 35 are slightly warmer and range from 32.3 °F (0.2 °C) in January to 77.6 °F (25.3 °C) in July 36 (NCDC 2012 b). Recent monthly mean temperature observations taken at the LGS site are 37 consistent with these ranges (Exelon 2012 b). 38 Normal annual liquid precipitation is 42.05 in. (1 ,068 mm) in Philadelphia (NCDC 2012 b) and 39 45.17 in. (1 , 147 mm) in Allentown (NCDC 2012 c). The precipitation during the wettest year 40 from the most recent 30
-year period of record was 71.72 in. (1 , 822 mm) in 2011 (NCDC 2012 c); 41 during the driest year from the same period it was 30.41 in. (772 mm) in 1992 (NCDC 2012 b). 42 The summer months of June, July, and August are the wettest, averaging 4.0 in. (102 mm) of 43 precipitation each month at both locations (NCDC 2012b, 2012c). February is the driest month, 44 averaging 2.75 in. (70 mm) of precipitation (NCDC 2012b, 2012c). Precipitation trends 45 measured at LGS (Exelon 2012c) are consistent with trends observed at Allentown and 46 Philadelphia. Average annual snowfall for the area is 19.3 in. (49.0 cm) in Philadelphia 47 Purpose and Need for Action 2-26 (NCDC 2012 b) and 32.3 in. (80.0 cm) in Allentown (NCDC 2012 c). The higher snowfall 1 amounts at Allentown are likely to be more representative of the LGS site because the 2 Philadelphia NWS station is warmer because of its more southeastern location as well as 3 additional heating from the urban environment. 4 Thunderstorms are normally observed on 27 days throughout the year (NCDC 2012b, 2012c). 5 Severe weather in the form of hail, tornadoes, or hurricanes is not commonly observed in the 6 region. In the past 5 years, there have been 29 large hail (more than 0.75 in. [1.9 cm] in 7 diameter) events reported in both Montgomery and Chester Counties, but many of the hail 8 reports are associated with the same storm (NCDC 2012d). Tornadoes do not occur frequently 9 in the region. In the past 5 years, no tornadoes were reported in Montgomery County and one 10 tornado (classified on the Enhanced Fujita scale as an EF0, with a 65 -85 mph (29.1-38.0 m/s) 11 3-second wind gust) occurred in Chester County (NCDC 2012d). Using tornado data for the 12 period from January 1, 1950, through August 31, 2003, the annual best -estimate tornado strike 13 probability for a 1 -degree box that includes the LGS site is 1.59x10-4 (Ramsdell and 14 Rishel 2007). Tropical cyclones are rarely of hurricane strength by the time they are in the 15 vicinity of the LGS site. The National Oceanic and Atmospheric Administration (NOAA) 16 maintains a database of tropical cyclone tracks and intensities that covers the period from 17 1842 through 2010. During this time, only two Category 1 hurricanes, with maximum sustained 18 winds of 7495 mph (33.0-42.5 m/s), have passed within 80 km (50 miles) of the LGS site 19 (NOAA 2012). 20 2.2.2.1. Air Quality 21 Under the Clean Air Act (CAA) of 1963, EPA has set primary and secondary National Ambient 22 Air Quality Standards (NAAQSs, 40 CFR 50) for six common criteria pollutants to public health 23 and the environment. The NAAQS criteria pollutants include carbon monoxide, lead, nitrogen 24 dioxide, ozone, sulfur dioxide, and particulate matter (PM). PM is further categorized by 25 size-PM 10 (diameter of 10 micrometers or less) and PM2.5 (diameter of 2.5 micrometers or 26 less). 27 EPA designates areas of "attainment" and "nonattainment" with respect to the NAAQSs. Areas 28 for which insufficient data are available to determine designation status are denoted as 29 "unclassifiable ." Areas that were once in nonattainment, but are now in attainment, are called 30 "maintenance" areas; these areas are under a 10 -year monitoring plan to maintain the 31 attainment designation status. 32 Air quality designations are generally made at the county level. For the purpose of planning and 33 maintaining ambient air quality with respect to the NAAQSs, EPA has developed Air Quality 34 Control Regions (AQCRs). AQCR s are intrastate or interstate areas that share a common 35 airshed (40 CFR 81). The LGS site is located in Montgomery and Chester Counties, 36 Pennsylvania; these counties are part of the Metropolitan Philadelphia Int erstate AQCR 37 (40 CFR 81.15). Additional counties in this AQCR include Bucks, Delaware, and Philadelphia 38 Counties. With regard to the NAAQSs, Montgomery and Chester Counties are designated as 39 unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM 10 40 and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 41 States have primary responsibility for ensuring attainment and maintenance of the NAAQSs. 42 Under Section 110 of the CAA (42 USC 7410) and related provisions, states are to submit, for 43 EPA approval, State Implementation Plans (SIPs) that provide for the timely attainment and 44 maintenance of the NAAQSs. On March 26, 2012, EPA approved and promulgated the 45 PADEP's SIP for ozone in the Philadelphia area, including Montgomery and Chester Counties 46 (77 FR 17341). Similarly, on March 29, 2012, EPA approved and promulgated PADEP's 47 revisions to the SIP for PM2.5 (77 FR 18987). 48 Purpose and Need for Action 2-27 As required under 25 Pa. Code Chapter 127, Exelon maintains a Title V operating permit 1 (TVOP-46-00038) for sources of air pollution at the LGS site (Exelon 2011b). Permitted sources 2 include two cooling towers, a spray pond, several standby diesel generators and boilers, a 3 solvent-based degreasing unit, and air emissions from various sources of waste oil 4 (Exelon 2011b). As a condition of the Title V operating permit, Exelon is required to submit an 5 annual compliance certification to the PADEP, which includes fuel usage and estimated air 6 pollutant emissions (Exelon 2012 b). Table 2-1 lists the total diesel fuel usage and associated 7 air emissions for the most recent 5 years (Exelon 2012b). There are no plans for refurbishment 8 of structures or components at LGS for license renewal. Therefore, there are no expected new 9 air emissions associated with license renewal (Exelon 2011b). 10 Table 2-1. Annual Fuel Use and Estimated Air Emission Estimates for Significant 11 Sources at LGS 12 Year Fuel Usage (gal)(a) NO x (T)(b) CO (T)(b) SO x (T)(b) PM2.5 (T)(b) PM10 (T)(b) VOC (T)(b) Pb (T)(b) 2007 1,128,502 29.3 22.7 6.1 0.44 42.3 0.80 0.0000 2008 927,297 31.2 19.8 4.8 0.47 42.2 0.90 0.0010 2009 858,760 28.4 18.5 3.8 0.41 42.7 1.97 0.0005 2010 1,003,210 35.3 21.8 4.0 0.72 161.1 c 2.13 0.0006 2011 1,145,960 32.8 24.2 7.8 0.80 166.3 c 2.10 0.0010 (a) To convert gallons to liters, multiply by 3.8. (b) To convert T to MT, multiply by 0.91. (c) Beginning in 2010, the emission calculation for PM 10 was changed for reporting purposes; no actual change in operations occurred and therefore no change in actual PM 10 emissions (LGS RAI Reply E1-1). NO x = nitrogen oxides; CO = carbon monoxide; SO x = sulphur oxides; PM2.5 = particulate matter with a diameter of 2.5 micrometers or less; PM 10 = particulate matter with an aerodynamic diameter between 2.5 and 10 micrometers; VOC = volatile organic compounds; Pb = lead. Source: Exelon 2012b 40 CFR 81 Subpart D lists mandatory Class I Federal Areas where visibility is an important 13 value. There are no mandatory Class I Federal areas within 50 miles (80 km) of the LGS site. 14 The closest mandatory Class I Federal area is the Brigantine Wilderness in New Jersey, which 15 is approximately 78 miles (127 km) southeast of the LGS site (40 CFR 81.420). Because of the 16 significant distance from the site and prevailing wind direction, no adverse impacts on Class I 17 areas are anticipated from LGS operation. 18 2.2.3. Geologic Environment 19 This section describes the current geologic environment of the LGS site and vicinity including 20 landforms, geology, soils, and seismic setting. 21 Physiography. LGS is located within the Gettysburg -Newark Lowland Section of the Piedmont 22 physiographic province. This region is generally comprised of rolling lowlands, shallow valleys, 23 and isolated hills and mainly underlain by red shale, siltstone, and sandstone, with some 24 conglomerate and diabase (DCNR 20 00). 25 The main plant complex, including the LGS nuclear island, is situated on a broad, semi -circular 26 ridge on the eastern bank of the Schuylkill River. Site topography slopes steeply to the west 27 and south toward the Schuylkill River and Possum Hollow Creek, respectively. Elevations 28 range from less than 110 ft (34 m) above MSL at the Schuylkill River to approximately 280 ft 29 Purpose and Need for Action 2-28 (85 m) MSL at the highest elevation near the cooling towers. Blasting and other construction 1 activities have modified the natural land surface across the plant site (Exelon 2011b). 2 Geology. Thick bedrock consisting of reddish -brown siltstone and interbedded sandstone and 3 shale of the Brunswick Formation underlies the majority of the LGS site and vicinity. Rocks of 4 the Sanatoga Member of the Lockatong Formation interfinger with the Brunswick in the northern 5 part of the LGS site area and occur in the area of the spray pond, but do not occur beneath the 6 cooling towers or the main plant structures. The Sanatoga is a bluish -gray, calcareous argillite 7 with beds of black shale. This rock is relatively harder than the siltstone and other rocks of the 8 Brunswick. In total, the uppermost bedrock sequence beneath the site is more than 5,000 ft 9 (1,520 m) thick (Exelon 2008 b). 10 The sediments that now comprise the Brunswick and other formations making up the near 11 surface bedrock were deposited by streams feeding into one of a series of down -warped or 12 down-faulted basins that formed during the late Triassic (i.e., between about 200 and 13 228 million year s ago). LGS overlies the northern (Newark) portion of one such basin, the 14 Newark-Gettysburg Basin. The sediments that now constitute the rocks of the Brunswick 15 Formation originally were deposited by an ancient river system in the form of a large alluvial fan 16 while the Lockatong was deposited in a shallow lake environment (Exelon 2008 b). 17 Subsequent to the deposition and consolidation of the basin sediments, the region was uplifted, 18 tilted, and deformed. In addition, the sedimentary materials have been broken by numerous 19 small faults and fractures and locally include interbeds of and intrusions by volcanic rocks. 20 Numerous intrusions of the basin's sedimentary rocks by volcanic diabase have been mapped 21 throughout southeast Pennsylvania. One such prominent feature is a diabase dike (named the 22 Downingtown Dike) that extends from about 11 miles (18 km) southwest of Downingtown, 23 Pennsylvania, through Sanatoga Station, just north of the site, and continues about 3 miles 24 (5 km) to the northeast. The sedimentary rock immediately bordering this feature has been 25 thermally altered to a tough gray hornfels. Age dating of the numerous dikes in the region 26 indicates that they were emplaced between about 140 and 198 million years ago 27 Exelon 2008 b). 28 Across the LGS site and region, bedrock is overlain by up to 40 ft (12 m) of residual soil, 29 developed in place by the weathering and decomposition of the bedrock. This material 30 (regolith) grades into weathered rock (saprolite), then into fresh, unweathered rock; no clearly 31 defined boundary exists between soil and rock. Holocene (recent) alluvium consisting of silt, 32 sand, and gravel occurs along the Schuylkill River and tributaries such as Possum Hollow Run 33 (Exelon 2008 b). 34 Numerous small faults and fractures occur in the Triassic strata underlying LGS. These 35 features formed as a result of regional uplift that occurred following the consolidation of 36 sediments in the Newark basin (Exelon 2008 b). Most notable on a regional basis, the northwest 37 border of the Newark basin in northern New Jersey and southeastern New York State is marked 38 by a system of normal faults known as the Ramapo fault system. This fault system has been 39 extensively studied by various investigators, including the USGS, in part because historical 40 epicenters of small earthquakes have been loosely associated with this fault system (Crone and 41 Wheeler 2000). Information compiled by Exelon (2008 b) indicated that there is no clear 42 association between the Ramapo fault and earthquake epicenters in the region, and no 43 evidence for fault reactivation or fault offset at the surface. USGS's review of data for evidence 44 of Quaternary fault activity (i.e., within the last 1.6 million years) encompassing the Eastern 45 United States supports these conclusions, finding that geologic evidence is insufficient to 46 demonstrate either the existence of a tectonic fault or Quaternary slip or deformation associated 47 Purpose and Need for Action 2-29 with the feature (Crone and Wheeler 2000, Wheeler 200 6). Further, the Ramapo is not included 1 in the USGS' s latest Quaternary Fault and Fold Database (USGS 2012a). 2 Three small faults, the Sanatoga, the Brooke Evans, and the Linfield, occur within 2 miles 3 (3.2 km) of the LGS site. The nearest approach of any fault, the Sanatoga fault, to the reactor 4 area is 1,300 ft (400 m) to the west. The fault plane is intruded by Triassic diabase, which is 5 part of the Downingtown Dike. The Brooke Evans fault passes within 2,800 ft (850 m) to the 6 south of the plant area, and the trace of the Linfield fault lies about 2 miles (3.2 km) southeast of 7 the LGS site. All three of these faults are associated with the Jurassic -Triassic events that 8 occurred some 140 to 200 million years ago. Field studies of diabase intrusions of these faults 9 indicate that they have been inactive for at least 140 million years (Exelon 2008 b). Thus, none 10 of these faults are active or considered "capable" of producing earthquakes per 10 CFR 100, 11 Appendix A. 12 During foundation excavation for the plant, several features, including shear -fractures with some 13 small offsets (displacement), were encountered. While not unusual for the region and not 14 posing a hazard to plant structures, these areas were treated as necessary to ensure 15 subsurface stability. Treatment included excavating any soft or otherwise weathered material 16 down to competent bedrock and/or by replacing excavated material with concrete, as further 17 described in the updated final safety analysis report (UFSAR) (Exelon 2008 b). 18 There are no outstanding mineral rights within the LGS exclusion area (Exelon 2008 b). There is 19 one quarry (Pottstown Trap Rock Sanatoga Quarry) located about 0.8 miles (1.2 km) from the 20 center of the main plant complex and adjacent to LGS' s northern property boundary. 21 Operations at the quarry consist of blasting, crushing, grading, and stockpiling rock 22 (Exelon 2008 b). The Sanatoga Quarry produces red aggregate stone for use in construction 23 and landscaping applications. The site also has an asphalt production operation (H&K 24 Group 2012). 25 Soils. Soils at the site, where present, consist predominantly of residual clayey silts 26 (Exelon 2008 b). Soil unit mapping by the Natural Resources Conservation Service (NRCS) 27 identifies the majority of the LGS site complex as Urban land -Udorthents, shale and sandstone 28 complex, 8 to 25 percent slopes. Consistent with the developed nature of the LGS site, this soil 29 mapping unit is used to identify buildings and other impervious surfaces on hills and other 30 uplands on graded land surfaces underlain by shale and sandstone. Natural soils bordering the 31 main plant complex to the north and northeast include Penn silt loam, Readington silt loam, and 32 Reaville silt loam, 0 to 8 percent slopes. These are generally moderately to well -drained soils 33 on hills and hillslopes that developed from residuum weathered from sandstone and shale 34 parent material. Depth to bedrock ranges from 20 to 40 in. (50 to 100 cm), which imparts a 35 slight limitation for building site development. These soils are all prime farmland soils or 36 farmland of statewide importance, where otherwise not committed to developed uses 37 (7 CFR 657.5). This includes a continuous area totaling about 25 ac (10 ha) of Penn silt loam, 38 3 to 8 percent slopes just to the northeast of the spray pond. To the south and southeast along 39 the north side of Possum Hollow Run, the soils are mapped as Klinesville channery silt loam, 40 35 to 60 percent slopes. These soils are relatively shallow and somewhat excessive drained. 41 Soils along both banks of the Schuylkill River in the vicinity of LGS are mapped as Gibraltar silt 42 loam. These soils are relatively deep, well -drained soils occupying valley flats, hills, and levees. 43 Their parent material is coal overwash (i.e., materials derived from upstream coal mining) over 44 alluvium derived from shale and siltstone. These soils are very limited for building site 45 development because of the threat of ponding and flooding (NRCS 2012). 46 Foundations for all seismic Category I (safety -related) structures at LGS are founded on hard, 47 competent bedrock or were excavated to unweathered bedrock. In addition, no other localized 48 Purpose and Need for Action 2-30 geologic hazards, old landslides, rock slips, or landslide scars have been identified near plant 1 structures (Exelon 2008 b). 2 Seismic Setting. Eastern Pennsylvania lies within a region that has experienced a moderate 3 level of earthquake activity. However, zones of major earthquakes are located more than 4 200 miles (340 km) from the site and have not had an appreciable effect at LGS 5 (Exelon 2008 b). Probabilistic analysis that considers both the occurrence and intensity of 6 earthquakes within and outside Pennsylvania indicate a relatively low seismic risk overall 7 (DCNR 2003). 8 Pennsylvania is affected by small earthquakes that occur on local faults (DCNR 2003). Within a 9 radius of 62 miles (100 km) of LGS, a total of 56 earthquakes have been recorded since 1973. 10 The largest was a magnitude 4.6 event in January 1994, centered 24 miles (39 km) west of the 11 site near Reading, Pennsylvania. The closest event was a magnitude 2.7 event in 12 November 2003 with an epicenter 15 miles (24 km) west-northwest of LGS (USGS 2012b). 13 These earthquakes are generally in association with the Lancaster Seismic Zone, an area of 14 increased seismic activity, which encompasses recorded seismic events in Lancaster, York, 15 Lebanon, and Berks Counties. This is the most active seismic zone in Pennsylvania. 16 Southeastern Pennsylvania is not known to have experienced an earthquake with a magnitude 17 greater than 4.7 (DCNR 2003). 18 The largest earthquake recorded to date within the Commonwealth's borders was a magnitude 19 5.2 event on September 25, 1998, in northwestern Pennsylvania, some 280 miles (450 km) 20 northwest of LGS. It caused only minor structural damage near the epicenter (e.g., bricks 21 shaken from chimneys) and was classified by the USGS as producing Modified Mercalli 22 Intensity (MMI) VI shaking. It was felt throughout northern Ohio and most of Pennsylvania and 23 into bordering states (Dewey and Hopper 2009; USGS 2012c, 2012d). By comparison, a 24 magnitude 6 earthquake occurring in southeastern New York or northern New Jersey could 25 affect the easternmost counties of Pennsylvania. Historically, such events (i.e., in 1737 and 26 1884) have produced MMI IV shaking in eastern Pennsylvania (DCNR 2003). Such a level of 27 shaking would likely result in little to no damage to structures. 28 As documented in the LGS UFSAR, evaluation of tectonic structures and the historical seismic 29 record for the region indicated that a plant design for MMI VII shaking was adequately 30 conservative for the site. MMI VII shaking was determined to correspond with a peak ground 31 acceleration (PGA) of 0.13 g (i.e., force of acceleration relative to that of Earth's gravity, "g"). 32 For additional conservatism, 0.15 g was adopted for the LGS safe -shutdown earthquake (SSE) 33 (Exelon 2008 b). 34 For the purposes of comparing the plant SSE with a more contemporary measure of predicted 35 earthquake ground motion for the site, the NRC staff also reviewed current PGA data from the 36 USGS National Seismic Hazard Mapping Project. The PGA value cited is based on a 2 percent 37 probability of exceedance in 50 years. This corresponds to an annual frequency (chance) of 38 occurrence of about 1 in 2,500 or 4x10-4 per year. For LGS, the calculated PGA is 39 approximately 0.11 g (USGS 2008). 40 2.2.4. Surface Water Resources 41 2.2.4.1. Site Description and Surface Water Hydrology 42 The LGS main plant site is situated on a terraced hill that adjoins and overlooks the eastern 43 bank of the Schuylkill River, a nd is located approximately 4 river miles (6.6 km) downriver from 44 Pottstown, Pennsylvania. The plant site also lies 49 miles (79 km) upstream from the 45 Purpose and Need for Action 2-31 Schuylkill's confluence with the Delaware River (Exelon 2011b). The Schuylkill River is within 1 the boundaries of the Delaware River Basin. 2 In addition to being bordered by the Schuylkill River, the LGS property is also cut by two 3 northeast to southwest trending tributaries to the Schuylkill River, Possum Hollow Run, and 4 Brooke Evans Creek. Possum Hollow Run runs along the southeastern boundary of the main 5 plant complex and receives stormwater runoff from plant facilities (see Section 2.2.4.2). The 6 only other notable surface water features on the LGS site are the spray pond and a small 7 holding pond. Part of the emergency cooling system (see Section 2.1.6), the spray pond is a 8 clay-lined, man -made impoundment covering 9.9 ac (4 ha). The holding pond is a 9 concrete-lined structure located south of the power block and beyond the main plant protected 10 area. It covers less than 0.5 ac (0.2 ha) and receives industrial wastewater from various plant 11 systems; it is an internal NPDES monitoring point (outfall 201) to the plant's main outfall 001 12 (Exelon 2010d, 2011a). These features are not further assessed from the perspective of 13 surface water hydrology. 14 As described in Sections 2.1.6 and 2.1.7, all the water needs for the plant are provided by a 15 combination of multiple subbasins' flows in addition to flow from the mainstem Delaware River. 16 While the Schuylkill River is the primary source of water for the plant, makeup water for 17 consumptive (evaporative cooling) use must be supplemented with water taken from Perkiomen 18 Creek during low flow periods on the Schuylkill River. Perkiomen Creek and its tributary (East 19 Branch Perkiomen Creek) provide a channel to convey water pumped from the Delaware River 20 to LGS. The nonconsumptive water withdrawals and other plant effluents are discharged to the 21 Schuylkill River downstream of the LGS Schuylkill River intakes. 22 Schuylkill River. The Schuylkill River flows for approximately 130 miles (209 km) to its 23 confluence with the Delaware River at Delaware River Mile (RM) 92.5. Its watershed 24 encompasses approximately 1,916 m 2 (4,962 km 2) and is one of the two largest tributaries t o 25 the Delaware River. Exelon's Schuylkill Pumphouse is located at Schuylkill RM 48 26 (Exelon 2011b). The mean annual discharge measured at the USGS gage at Pottstown, 27 Pennsylvania, for water years 1928 through 2010 is 1,935 cfs (54.8 m 3/s). The 90 percent 28 exceedance flow is 482 cfs (13.6 m 3/s) (USGS 2010a, 2012e). For water year 2011, the mean 29 discharge was 3,145 cfs (89.1 m 3/s). The 90 percent exceedance flow is an indicator value that 30 a drought warning is appropriate. It signifies that the current 30 -day average flow has been 31 exceeded 90 percent of the time, as compared to the average flow for the period of record 32 (DEP 2012). For the Schuylkill River, August is the low -flow month and March is the high -flow 33 month over the period of record. 34 East Branch Perkiomen Creek. The East Branch Perkiomen Creek flows for a distance of 35 24 miles (39 km) and enters Perkiomen Creek at a point about 11 stream miles (18 km) from the 36 confluence of Perkiomen Creek with the Schuylkill River. Its flow is highly variable and, before 37 the establishment of the diversion of water from Exelon's Bradshaw Reservoir, the creek was 38 reportedly intermittent in nature during the summer and fall (Exelon 2011b). Based on water 39 year data from 1990 through 2011, the mean annual discharge and 90 percent exceedance flow 40 measured at the USGS gage at Dublin, Pennsylvania, are 35.8 cfs (1.0 m 3/s) and 13 cfs 41 (0.37 m 3/s), respectively (USGS 2011a). 42 Perkiomen Creek . Perkiomen Creek drains an area of some 363 m 2 (940 km 2) and joins with 43 the Schuylkill River at a point approximately 16 stream miles (26 km) downstream from LGS. 44 For the period of 1915 through 1956 and prior to flow regulation due to Green Lane Reservoir 45 beginning in late 1956, the reported mean annual discharge and 90 percent exceedance flow at 46 the USGS gage at Graterford, Pennsylvania, are 389 cfs (11 m 3/s) and 42 cfs (1.2 m 3/s), 47 respectively. As previously described (see Section 2.1.6), water has been diverted to the creek 48 Purpose and Need for Action 2-32 since August 1989 from the Delaware River at Point Pleasant to Bradshaw Reservoir and then 1 pumped from the reservoir to East Branch Perkiomen Creek. For the period 1957 through 2 2011, the measured mean annual discharge and 90 percent exceedance flow values are 3 435 cfs (12.3 m 3/s) and 65 cfs (1.8 m 3/s), respectively (USGS 2011b). 4 Delaware River. The Delaware River flows 330 miles (531 km) from its origin in southern New 5 York to the Delaware Bay, and it is the longest un -dammed river in the United States east of the 6 Mississippi (DRBC 2012). The tidal portion of the Delaware River extends upriver from the 7 estuary at Delaware Bay to Trenton, New Jersey. Upriver salinity intrusion varies according to 8 increases or decreases in upriver inflows. The boundary of salinity intrusion, also known as the 9 salt line, fluctuates with flow changes. The salt line is the point where the average sodium 10 chloride concentration in the river exceeds 250 mg/L. The Point Pleasant Pumping Station used 11 to transfer Delaware River water is located at Delaware RM 157, which is above the salt line 12 (Exelon 2011b). Based on data for 1913 through 2010, the mean annual discharge and 13 90 percent exceedance flow measured at the USGS gage at Trenton, New Jersey, are 14 11,900 cfs (337 m 3/s) and 3,080 cfs (87.2 m 3/s), respectively. This gage site is at Delaware 15 RM 134.5, about 20 river miles (32.2 km) downstream from the Point Pleasant Pumping Station 16 (USGS 2010b). 17 2.2.4.2. Surface Water Quality and Effluents 18 Among the powers and duties assigned to the DRBC are classifying all waters in the basin as to 19 use, setting basin -wide water quality standards, establishing pollutant treatment and control 20 regulations, and reviewing projects or other undertakings with the potential to affect basin water 21 resources for conformance with the DRBC Comprehensive Plan (DRBC 2001). DRBC has also 22 promulgated water quality standards for the basin under 18 CFR 410. The DRBC acts in 23 cooperation with the States and other parties that are signatories to the DRBC Compact 24 (DRBC 1961) and who retain their authority to set more stringent standards necessary to protect 25 the water resources of the basin. Article 3.8 of the DRBC Compact (DRBC 1961) requires that 26 the DRBC approve a project whenever it finds and determines that the project would not 27 substantially impair or conflict with the Comprehensive Plan. DRBC's Comprehensive Plan 28 already accounts for existing LGS operations (DRBC 2001). 29 The Commonwealth of Pennsylvania has established surface water quality standards for 30 individual rivers, streams, and unnamed tributaries, including wetlands, along with associated 31 numeric water quality criteria to protect the desired and designated uses of the water bodies. 32 Relative to the LGS site, PADEP has specifically designated the main stem of the Schuylkill 33 River traversing Montgomery County to its mouth with the Delaware River for use in the 34 maintenance and propagation of warm water fishes (WWF) and the passage, maintenance, and 35 propagation of migratory fishes (MF). The main stem of Perkiomen Creek is also designated as 36 WWF and MF. East Branch Perkiomen Creek is designed for use in the maintenance of 37 stocked trout from February 15 to July 31 of each year, in addition to WWF and MF during the 38 rest of the year. It should be noted that all surface waters in Pennsylvania are protected for 39 water supply (public, industrial, and wildlife use) and for recreational uses (25 P
- a. Code 93). 40 Ambient water quality data Exelon compiled (Exelon 2011b) to support its 2010 NPDES permit 41 renewal application and as part of the DRBC monitored demonstration study (Exelon 2012 d) 42 were reviewed by NRC staff during the course of the LGS license renewal environmental 43 review. Comparison of the available data with the water quality criteria established by the DEP 44 under 25 Pa. Code 93.7 and 93.9 for the designated uses of the Schuylkill River and tributaries 45 indicate that existing water quality is supportive of designated uses. Section 2.2.6 discusses 46 key trends in ambient water quality and its influence on aquatic biota.
47 Purpose and Need for Action 2-33 Section 303(d) of the Federal Clean Water Act (CWA) requires the Commonwealth of 1 Pennsylvania and other states to identify all waters for which effluent limitations and pollution 2 control activities are not sufficient to attain water quality standards in such waters. The 303(d) 3 list includes those water quality limited segments that require the development of total maximum 4 daily loads (TMDLs) to assure future compliance with water quality standards. While the 5 Schuylkill River is listed as supporting its designated aquatic life uses, Pennsylvania's dra ft 6 2012 Clean Water Act Section 303(d) list of impaired waters continues to list the main stem of 7 the Schuylkill River in the plant vicinity as impaired because of polychlorinated biphenyl (PCB) 8 contamination from unidentified upstream sources (DEP 2011, Exelon 2011 b). 9 Industrial wastewater, cooling water, and stormwater discharges from LGS are governed by a 10 Pennsylvania DEP -issued NPDES permit (No. PA0051926) and regulated under PADEP's 11 regulations at 25 P
- a. Code 92a. Exelon's current permit sets effluent quality limits and 12 monitoring requirements for the plant's discharges covering some 24 outfall locations. These 13 include 17 outfalls discharging stormwater either to the Schuylkill River or Possum Hollow Run, 14 with one outfall discharging stormwater runoff north to the headwaters of Sanatoga Creek.
15 Six outfalls discharge industrial wastewater (mainly noncontact cooling water) or comingled 16 noncontact cooling water with stormwater. Most notably, cooling tower blowdown, closed-cycle 17 cooling water, spray pond water, stormwater via the plant's holding pond, and other plant 18 wastewaters (e.g., liquid radwaste treatment system and laundry drain wastes) are discharged 19 through the plant's primary outfall (no. 001) to the Schuylkill River (Exelon 2010 d, 2011 b). In 20 particular, the treated liquid radwaste is batch discharged to the cooling tower blowdown line 21 where it is diluted by the normal blowdown flow. This ensures that radionuclides discharged 22 through outfall 001 comply with 10 CFR 20 limits (Exelon 2011b). 23 The cooling tower blowdown line is also equipped with an overflow vent, which is monitored as 24 a separate NPDES outfall (no. 023) (Exelon 2010d, 2011b). The vent, which NRC staff 25 observed during the November 2011 environmental site audit (NRC 2012), is located south of 26 the power block and just downslope from the plant's holding pond. 27 LGS's current NPDES permit for plant operations was issued by PADEP with an effective date 28 of April 1, 2006; the permit expired on March 31, 2011 (Exelon 2011 b, 2012 b). However , 29 Exelon submitted a permit renewal application to PADEP on September 28, 2010, which the 30 PADEP accepted as administratively complete on December 15, 2010 (PADEP 2010; 31 Exelon 2010 d, 2012 a). As a result, LGS's NPDES permit for LGS operations remains in effect 32 (i.e., administratively continued) because Exelon submitted an application for renewal at least 33 180 days before the expiration of the current permit in accordance with 25 P
- a. C ode 92a.7. 34 Exelon has a separate PADEP-issued NPDES permit (No. PA0052221) for the discharge of 35 diversion water from the Bradshaw Reservoir to East Branch Perkiomen Creek. The permit was 36 issued with an effective date of July 1, 2009, and expires June 30, 2014. 37 Continued NPDES permit coverage is an indication that Exelon's discharges from LGS and 38 other facilities meet applicable water quality standards, while satisfying state Water Quality 39 Certification requirements under Section 401 of the Federal Clean Water Act. This is because, 40 in Pennsylvania, the 401 Water Quality Certification process is integrated with other 41 PADEP-issued permits and approvals, including those under the NPDES permit program.
42 The NRC staff's review of the last 3 years of NPDES Discharge Monitoring Reports (DMRs) 43 submitted by Exelon to the PADEP revealed no unusual conditions or exceedances of effluent 44 limitations. Further, the staff determined that Exelon has not received any Notices of Violation, 45 nonconformance notifications, or related infractions associated with the site's NPDES permits or 46 related to other water quality matters within the past 5 years (Exelon 2012 a). 47 Purpose and Need for Action 2-34 2.2.5. Groundwater Resources 1 2.2.5.1. Site Description and Hydrogeology 2 Groundwater beneath LGS and vicinity occurs in the thick bedrock of the Brunswick and 3 Lockatong Formations, as described in Section 2.2.3. 4 The USGS has grouped the water -bearing portions (i.e., aquifers) of these formations into the 5 Aquifers in the Early Mesozoic Basins system (Trapp and Horn 1997). The Brunswick bedrock 6 aquifer is the most widespread source of groundwater in the plant region and across the 7 Triassic lowlands of the Newark Basin (Exelon 2008 a). In general, aquifer zones occur in 8 association with secondary fractures, joints, and bedding planes in the rock where groundwater 9 is stored and may move along (Exelon 2008 a , 2011 b; Trapp and Horn 1997). In strata where 10 approximately vertical sets of joints are tightly spaced and have some degree of 11 interconnection, aquifer permeability is increased and groundwater flow and yield to wells are 12 greatly enhanced. However, these localized zones of enhanced aquifer permeability vary 13 vertically and laterally through the rock, especially as the basin strata dips to the north and 14 northwest at 10 to 20 degrees on a regional basis and strikes approximately east to west 15 (Exelon 2008 a). Consequently, individual bedrock aquifer zones also dip downward and may 16 run in the downdip direction for only a few hundred feet but can be continuous in extent for 17 thousands of feet along (parallel to) the bedrock strike (Trapp and Horn 1997). As such, 18 groundwater yield to individual wells can vary greatly over relatively short distances 19 (Exelon 2008a, Trapp and Horn 1997). Because of decreasing fracture density with depth, 20 groundwater movement primarily occurs in the upper 600 ft (180 m) of the Brunswick system 21 (Exelon 2008 b). In fact, within the Newark Basin in Pennsylvania, yields are highest from wells 22 with completion depths ranging from 200 to 500 ft (60 to 150 m). Groundwater yields from 23 large-diameter wells within the basin typically range from about 12 gpm (45 L/min) in shale and 24 argillite up to 80 gpm (300 L/min) in massive sandstones (Trapp and Horn 1997). 25 Recharge to the bedrock aquifer occurs from precipitation that falls over the higher elevations of 26 the region's groundwater basins, and which is able to infiltrate through the overlying soils and 27 regolith (Exelon 2008 a, 2011 b). While overlying surficial materials (i.e., soils, regolith, and 28 stream alluvium), where present in the region, are not typically thick enough to be a sustained 29 source of groundwater to wells by themselves, thick deposits do help to increase the availability 30 of water to wells withdrawing from the underlying bedrock (Trapp and Horn 1997). 31 Nevertheless, the majority of the precipitation and runoff occurring in recharge areas moves 32 laterally downgradient through the regolith and discharges to streams or low -lying areas rather 33 than recharging groundwater (Trapp and Horn 1997). The regolith across the LGS site is 34 relatively thin at no more than 12 ft (3.7 m) in thickness, and well measurements indicate that 35 the materials are not water -bearing (Exelon 2011b). 36 Beneath LGS, groundwater occurs under water table (unconfined) conditions but can occur 37 under confined (artesian) conditions at depth. From static water levels recorded in the plant's 38 primary production wells, the depth to the water table surface beneath the plant ranges from 39 20 to 30 ft (6 to 9 m) below ground surface. The water table approximates the surface 40 topography, with groundwater generally flowing to the south and southwest beneath the site and 41 discharging to Possum Hollow Run and the Schuylkill River. The groundwater flow rate through 42 the Brunswick bedrock is estimated to be on the order of 0.07 ft (0.02 m) per day or about 26 ft 43 (7.9 m) per year, based on the results of the site's 2006 hydrogeologic investigation, as further 44 described in Section 2.2.5.2. Locally on the plant site, a groundwater high point and 45 groundwater flow divide (striking northeast to southwest) is evident just northeast of the cooling 46 towers adjacent to the spray pond (Exelon 2008 a, 2011a). Water table mapping does not 47 Purpose and Need for Action 2-35 indicate any groundwater mounding beneath the spray pond, an observation that would be 1 expected if significant seepage were occurring from the pond. 2 LGS's four groundwater production wells are completed in the Brunswick aquifer system. 3 These wells range in depth from 198 ft (60 m) to 585 ft (178 m), as further described in 4 Section 2.1.7. They are located within a groundwater protected area (Schuylkill -Sprogels Run 5 Subbasin) designated by the DRBC, and site groundwater withdrawals are otherwise subject to 6 Pennsylvania reporting requirements as also described in Section 2.1.7. As for other 7 groundwater users in the vicinity of LGS, a search of Pennsylvania water well records revealed 8 54 wells within a 1 -mi le (1.6-km) radius from the center of the LGS site. This number includes 9 eight wells attributed to the LGS property, although only four remain in service. Other than the 10 LGS wells, only 3 of the 54 wells reportedly are used for other than domestic (i.e., residential) 11 purposes. Most of the recorded residential wells range in depth from 120 to 200 ft (37 to 61 m). 12 For the other nondomestic wells, they include one public water supply well at a mobile home 13 park located northeast of the plant; the well depth is not recorded. One other nondomestic 14 (commercial/industrial) supply well is located at the Pottstown Trap Rock -Sanatoga Quarry 15 located just to the north of the LGS property boundary. This well is recorded as 100 ft (30 m) 16 deep. The remaining well supplies a local bed and breakfast business located southeast of 17 LGS; the well is recorded as 96 ft (29 m) in depth (Exelon 2011b, DCNR 2012). 18 2.2.5.2. Groundwater Quality 19 Regional groundwater is characteristically of the calcium bicarbonate type and is generally 20 suitable for a wide range of purposes (Exelon 2008 a, Trapp and Horn 1997). However, the 21 natural quality of groundwater from the region's bedrock aquifers is typically hard with TDS 22 concentrations averaging 230 mg/L and hardness (measured as calcium carbonate) of 23 160 mg/L (Trapp and Horn 1997). Groundwater from the Brunswick aquifer system can 24 naturally have a TDS in excess of 500 mg/L, which exceeds the EPA secondary drinking water 25 standard (DWS) primarily established for aesthetic (taste) purposes (40 CFR 143). Data 26 collected from the plant's production wells to establish background water quality indicated 27 moderately hard water ranging from 134 to 618 mg/L with TDS concentrations from 199 to 28 1,052 mg/L (Exelon 2008 a). As noted in Section 2.1.7, groundwater used at LGS is treated, as 29 necessary, including that withdrawn to meet the potable needs of LGS site personnel. 30 Exelon initiated a program at LGS in 2006 to characterize the hydrogeologic environment of the 31 plant site and to specifically assess the potential impacts on groundwater quality of any 32 inadvertent releases of tritium or other LGS -related radionuclides. The assessment conducted 33 at LGS was part of a fleet -wide effort by Exelon to assess conditions at all of its nuclear plants 34 and which was undertaken consistent with its participation in the Nuclear Energy Institute's 35 Groundwater Protection Initiative (NEI 2007). These efforts provided the framework for the 36 plant's ongoing Radiological Groundwater Protection Program (RGPP) (CRA 2006, 37 Exelon 2011a). The RGPP incorporates knowledge gained from the LGS pre -operational 38 Radiological Environmental Monitoring Program (REMP) assessment conducted between 1982 39 and 1984 (CRA 2006). 40 The 2006 hydrogeologic investigation and its associated report (CRA 2006) considered 41 historical releases from LGS facilities to include the structures, systems, and components 42 (SSCs) and areas that may have the potential to contribute to releases. Consequently, a 43 groundwater monitoring well network was designed, sited, and installed as part of the study to 44 include wells located at appropriate upgradient and downgradient locations (i.e., relative to 45 groundwater flow) so as to assess the potential for radionuclides to migrate off site. The 46 monitoring network established as part of the investigation initially included use of seven 47 (i.e., nos. P3, P11, P12, P14, P16, P17, and SP22) of the 22 wells that were installed on site 48 Purpose and Need for Action 2-36 before and during LGS construction plus eight new wells (wells MW -LR-1 through MW-LR-8). 1 The wells have total depths in the Brunswick Formation ranging from 34 to 115 ft (10 to 35 m) 2 below ground surface. Aside from groundwater, surface water samples also were collected and 3 analyzed for tritium and other radionuclides (CRA 20 06, Exelon 2011 b). 4 From the initial 2006 sampling, no strontium -90 or gamma -emitting radionuclides were detected 5 in groundwater or surface water above analytical detection limits. Tritium was detected in 5 of 6 16 wells sampled (i.e., in well nos. MW -LR-4, MW-LR-5, MW-LR-8, MW-LR-9, and P12). 7 Observed tritium concentrations ranged from 222 +/-118 pCi/L to 4,360 +/-494 pCi/L, all below the 8 EPA primary DWS of 20,000 pCi/L (40 CFR 141). From three of the five wells with detectable 9 tritium (MW -LR-4, MW-LR-5, MW-LR-8), levels ranged from 222 +/-121 pCi/L to 305 +/-121 pCi/L, 10 which are within the range of background levels (established as 200 pCi/L) documented for the 11 site and vicinity. The highest tritium level measured, at 4,360+/-494 pCi/L, was from monitoring 12 well P12 located almost immediately south and within 100 ft (30.5 m) of the LGS power block 13 perimeter. A subsequent sample yielded a comparable result. At the same time, a sample from 14 the power block foundation sump had tritium at 2,020 +/-154 pCi/L. Nevertheless, it was affirmed 15 during the site investigation that well P12 was completed in a discrete zone normally located 16 above the water table and thus not representative of overall site groundwater flow conditions 17 (CRA 2006). This also had been noted before the start of plant operations, as documented in 18 the UFSAR (Exelon 2008 a). As a result, well MW -LR-9 was installed nearby to a depth of 100 ft 19 (30.5 m) below ground surface to take the place of well P12. The new well was sampled in 20 August 2006 and yielded a tritium concentration of 1,500 +/-210 pCi/L (CRA 2006). 21 Tritium was also detected in one surface water sample collected from the plant's holding pond. 22 The holding po nd is located approximately 500 ft (152 m) due south and downgradient from 23 wells P12 and MW -LR-9. Tritium was measured at 523 +/-137 pCi/L. This concrete -lined 24 structure receives nonradioactive wastewater, roof, and plant yard runoff from power block 25 buildings, and collected drainage from the power block sump (CRA 2006). It is also an internal 26 monitoring point (outfall 201) under the site's NPDES permit, as discussed in Section 2.2.4.1 27 (Exelon 2010 d, 2011 b). 28 The 2006 hydrogeologic investigation identified two possible sources of tritium to account for the 29 levels in the referenced monitoring wells: (1) releases that occurred in December 2004 and 30 February 2005 from the Unit 1 Condensate Storage Tank dike because of heating steam valves 31 leaking condensation and (2) the release of tritiated steam condensation to the ground from an 32 auxiliary heating steam pipe in October 2002. The releases could have migrated directly 33 downgradient and through bedrock fractures toward the wells or were collected by the power 34 block drain system and into the sump, which then migrated through the bedrock fracture s to 35 groundwater. From observations the staff made during the November 2011 environmental site 36 audit (NRC 2012) and the data reviewed, the conclusions presented in the 2006 hydrogeologic 37 report are reasonable. 38 Under the ongoing RGPP at LGS, groundwater and surface water samples are collected and 39 analyzed for tritium and other radionuclides at least semi -annually. The results are reported as 40 a component of the annual Radiological Environmental Operation (REOP) reports 41 (Exelon 2008 a, 2009, 2010 c, 2011b, 2012c) submitted to the NRC. Exelon continues to adhere 42 to a detection limit of 200 pCi/L for tritium, which is lower than the detection threshold 43 (2,000 pCi/L) recommended by industry guidance (NEI 2007) and the site ODCM. This enables 44 early detection and response to any releases (Exelon 2011b). As documented in the annual 45 REOPs referenced above, a number of releases of tritiated water from plant SSCs have been 46 documented and for which investigative and corrective action was taken, as necessary. 47 Between 2007 and 2011, the highest tritium level observed was 1,750 pCi/L in well MW -LR-9 in 48 2009 and was attributed to a release of condensate from the outside of the Unit 1 and 2 49 Purpose and Need for Action 2-37 condenser bays in February 2009. Tritium in MW -LR-9 had decreased to a maximum of 1 1,154 pCi/L by April 2011 (Exelon 2012c). Overall, the RGPP results reveal that there is no 2 migration of tritium in groundwater at LGS at concentrations exceeding 2,000 pCi/L, and 3 observed tritium levels have been well within the EPA primary DWS at all onsite monitoring 4 wells. 5 2.2.6. Aquatic Resources 6 Potentially affected waterbodies primarily occur within the Piedmont physiographic province 7 portion of the Delaware River Basin, including the Schuylkill River, Perkiomen Creek, East 8 Branch Perkiomen Creek, and the Delaware River near the Point Pleasant Pump Station 9 (Figure 2-9). LGS relies on consumptive and nonconsumptive water primarily from the 10 Schuylkill River, as described in Section 2.1.6. When temperature and flow conditions in the 11 Schuylkill River do not meet DRBC criteria for water use, LGS secondarily relies on water from 12 Perkiomen Creek. Withdrawing water from Perkiomen Creek often requires augmentation of 13 flow by transferring water from the Delaware River. A series of pumping stations delivers 14 Delaware River water from the Point Pleasant Pump Station by pipeline to the Bradshaw 15 Reservoir, which is then delivered by pipeline to the East Branch Perkiomen Creek. Water 16 ultimately flows from the East Branch Perkiomen Creek to the Perkiomen Creek. The rate of 17 flow into the East Branch Perkiomen Creek equals the LGS consumptive water demand plus an 18 additional 3 percent to account for evaporative losses (Exelon 2011b). Because of the complex 19 water diversion system, descriptions of the biological communities for each water body appear 20 as separate resources. 21 2.2.6.1. Description of the Aquatic Resources Associated With Limerick Generating Station 22 Schuylkill River 23 The Schuylkill River flows 209.2 km (130 miles) from headwaters at Tuscarora Springs, 24 Pennsylvania, to the confluence of the Delaware River in Philadelphia, Pennsylvania. LGS is 25 located on the Schuylkill River, 6.4 river km (4 river miles) downriver of Pottstown, 26 Pennsylvania, and 56.3 river km (35 river miles) upriver of Philadelphia, Pennsylvania. 27 The Schuylkill River historically contained abundant aquatic resources, including large 28 populations of mussels and anadromous fish. Around the turn of the 18 th century, coal mining 29 became a predominant industry near the headwaters of the Schuylkill River. Mining waste 30 effluents degraded downstream water quality and reduced optimal habitat for aquatic life 31 (Rhoads and Block 2008). For example, the flow of acidic waters from mines, known as acid 32 mine drainage, lowered pH values and increased dissolution of heavy metals in the river. 33 Aquatic biota often cannot survive in waters with low pH values and increased concentrations of 34 heavy metals (Sadak 2008). Water quality throughout the Schuylkill River basin continues to be 35 influenced by mining activities from the last several decades (Interlandi and Crockett 2003). 36 The Schuylkill River once supported large numbers of anadromous fishes such as the American 37 shad (Alosa sapidissima), alewife (A. pseudoharengus), and river herring (or blueback herring, 38 A. aestivalis), which spawn in freshwater and inhabit marine waters as adults. Anadromous fish 39 would migrate from the Atlantic Ocean to the Delaware and Schuylkill Rivers to spawn. 40 However, construction of the Fairmont Dam, built in 1820, and eight subsequent dams built in 41 the 1800s, cut off access to upriver spawning locations for anadromous fish. Starting in the 42 1970s, fish passage systems, such as vertical fish slots and the removal of dams along the 43 Schuylkill River, have helped to reestablish migration upriver. For example, Pennsylvania Fish 44 and Boating Commission (PFBC) conducted fish ladder passage counts in 2004 and 2005 and 45 observed a total of 91 and 41 American shad migrating upriver, respectively (PFBC 2012b). In 46 addition, the PFBC has been stocking American shad fry in the Schuylkill River for the past 47 Purpose and Need for Action 2-38 13 years in an effort to restore the legacy fishery (PFBC 2012a, NMFS 2012c). PFBC collected 1 migrating shad between 2003 and 2007 in the Schuylkill River and observed that 95 percent 2 were of hatchery origin. PFBC plans to continue to stock American shad fry annually until 3 monitoring results indicate a self -sustaining fishery with spring runs averaging 300,000 to 4 850,000 returning adults (PFBC 2012b). 5 Biological Communities in the Schuylkill River 6 The aquatic ecology of eastern U.S. streams and rivers is made up of producers and consumers 7 that transfer energy through food web interactions. The base of the food web is primary 8 producers, which convert light energy into organic matter. Common primary producers in the 9 Schuylkill River include diatoms (a common phytoplankton), filamentous green alga such as 10 Cladophora, and Myriophyllum, a fresh water flowering plant (NRC 1984). Detritus, nonliving 11 organic matter such as leaves, is also an important base of the foodweb. Primary producers are 12 consumed by zooplankton (small animals that float, drift, or weakly swim in the water column of 13 any body of water), icthyoplankton (fish eggs and larvae), and herbivorous fish and 14 invertebrates (e.g., aquatic insects, worms, and snails). Predatory invertebrates and fish, such 15 as sunfish (Lepomis spp.) and brown bullhead (Ictalurus nebulosus ), in turn consume 16 zooplankton (including ichthyoplankton) and herbivorous fish and invertebrates. 17 Prior to LGS operations, LGS -related aquatic surveys conducted in the Schuylkill River near the 18 LGS site provided baseline information for aquatic plant, benthic invertebrate, and fish 19 assemblages. Surveys included sampling for phytoplankton (microscopic floating 20 photosynthetic organisms), macrophytes (aquatic plants), macroinvertebrates, ichthyoplankton 21 (fish eggs and larvae), and fish, from 1970 through 1984 (PECO 1984; RMC 1984, 1985, 1989). 22 Subsequent sampling after LGS began operations included sampling for macroinvertebrates, 23 ichthyoplankton, and fish from 1985 through 2009 (RMC 1986, 1987, 1988, 1989; Exelon 2001, 24 2002, 2003, 2004, 2005; NAI 2010a). 25 Periphyton, Phytoplankton, and Macrophytes. To support the operating license for LGS, 26 PECO (1984) surveyed the seasonal abundances of periphyton (sessile algae and crustaceans 27 that grow attached to hard surfaces) and phytoplankton (microscopic plants) from 1973 through 28 1974 and macrophytes (plants that can be observed with the naked eye) from 1974 through 29 1977. PECO (1984) observed peak productivity during summer and fall when light and 30 temperature requirements are optimal for plant growth in shallow, lotic systems. Commonly 31 collected periphyton and phytoplankton included diatoms (Navicula , Diatoma, and 32 Gomphonema) and blue green algae. PECO (1984) observed 10 species of macrophytes. No 33 additional LGS -related studies were conducted to examine plankton and periphyton 34 communities since 1977. 35 Macroinvertebrates. For macroinvertebrate surveys, RMC -Environmental Services (RMC) 36 placed buried cylinder samplers in sediments upstream and downstream of LGS and collected 37 the colonized samplers after several months of deployment (RMC 1984, 1985, 1986). 38 Oligochaetes, true flies (Diptera) and the snail, Goniobasis viginica dominated downriver 39 macroinvertebrate communities. In 1984, RMC characterized the macroinvertebrate community 40 as typical of other U.S. temperate rivers (RMC 1984). 41 From 1985 through 1988, RMC surveyed macroinvertebrates using the same sampling methods 42 as described above for pre -operational surveys. Oligochaetes, snails, beetles (Coleoptera) and 43 flies (Dipteria and Trichoptera) dominated the macroinvertebrate surveys both upstream and 44 downstream of the Schuylkill River intake and discharge structures. RMC (1988) did not 45 observe a substantial variation in the macroinvertebrate community when comparing 46 pre-operational samples to post -operational samples at the same sampling sites (RMC 1988). 47 Similarly, RMC (1988) did not observe a significant change in the benthic macroinvertebrates 48 Purpose and Need for Action 2-39 community when comparing the 3 years of data after LGS operations began. During this time 1 period, LGS solely relied upon the Schuylkill River water for makeup water and did not use 2 Perkiomen Creek (RMC 1988). 3 In 2009, NAI (2010a) surveyed the macroinvertebrate community in the Schuylkill River using 4 kicknets. Although NAI used different sampling methods than RMC in the 1980s, approximately 5 95 percent of the taxa collected in the 1980s were also collected in 2009. Both studies found 6 midges (Diptera and Trichoptera) and snails to be among most the abundant taxa. 7 Fish. RMC (1984) used drift and push nets to survey fish eggs and larvae; seines to survey fish 8 fry, juveniles, and small fish; and electrofishing to survey larger fish in the Schuylkill River. 9 Sunfish, goldfish (Carassius auratus), and unidentified minnows dominated egg and larval fish 10 samples, which were highest in May, June, and July (PECO 1984). Spot -fin shiner (Notropis 11 spilopterus), swallowtail shiner (Notropis procne), and redbreast sunfish (Lepomis auritus) 12 dominated seine samples. During electrofishing surveys, RMC (1984) captured redbreast 13 sunfish, white sucker (Catastomus commersonii), goldfish, brown bullhead, and pumpkinseed 14 (Lepomis gibbosus) most often. 15 RMC (1987) conducted the most recent surveys of icthyoplankton, in the Schuylkill River near 16 LGS in 1986. The species composition and relative abundances of the most common species 17 were similar to that found in pre -operational surveys. The most common taxa included minnows 18 and sunfish (RMC 1987). 19 Several juvenile and adult fish studies have occurred since LGS began operations. From 1985 20 through 1988, RMC surveyed juvenile and adult fish using the same sampling methods as 21 described above for pre -operational surveys (RMC 1986, 1987, 1989). RMC collected shiner 22 species, redbreast sunfish, and goldfish most often during seining and electrofishing surveys 23 from 1985 through 1988 (RMC 1986, 1987, 1988, 1989). RMC (1988) noted no obvious shifts 24 in fish population abundances or species diversity in the area of the LGS discharge. 25 NAI (2010a) compared the fish community from 1987 to 2009. However, the timing and 26 frequency of sampling efforts varied slightly among studies: NAI (2010a) conducted 27 electrofishing and seining surveys in September and October whereas RMC sampled monthly 28 from spring through fall. The most commonly collected species in 2009 were spotfin shiner 29 (73.8 percent of the total catch), swallowtail shiner (8.1 percent), banded killifish (Fundulus 30 heteroclitus) (3.7 percent), and tessellated darter (Etheostoma olmstedi) (3.4 percent) 31 (NAI 2010a). In 1987, spotfin shiner was also the most abundant species, although the relative 32 abundance (53.9 percent of the total catch) was lower compared to 2009 surveys. NAI 33 collected all age groups of fish (fry, juveniles, and adults) for most fish families observed, with 34 the exception of sunfishes, which were primarily fry and juveniles. NAI electroshocking surveys 35 collected primarily adult and juvenile redbreast sunfish (27.7 percent of the total catch). Other 36 commonly collected species included white sucker (17.4 percent), rock bass (Ambloplites 37 rupestris) (17.2 percent), common carp (Cyprinus carpio) (16.9 percent), and smallmouth bass 38 (Micropterus dolomieu) (8.3 percent). In 1987 the most abundant species was rock bass 39 (19.0 percent), followed by goldfish (17.6 percent), redbreast sunfish (15.7 percent), yellow 40 bullhead (Ameiurus natalis) (8.8 percent), and pumpkinseed (8.6 percent). Despite the 41 increased sampling frequency during earlier fish surveys, NAI (2010a) concluded that the 42 overall species diversity was similar to the earlier fish surveys by RMC in 1987. However, the 43 relative abundance of certain species changed between 1987 and 2009. For example, common 44 carp replaced goldfish as one of the more abundant species in 2009 (NAI 2010a). In addition, 45 goldfish (an introduced species) was not collected in 2009 and a single brown bullhead was 46 collected in 2009. Both of these species were one of the five most commonly collected specie s 47 during 1987 surveys. 48 Purpose and Need for Action 2-40 The Schuylkill River supports recreational fishing, although there is little public access to the 1 river near the LGS site. Creel surveys indicate that the most common recreational species 2 include sunfishes and smallmouth bass (NRC 1984; RMC 1984; 1985; 1986). 3 Schuylkill River Flow Augmentation 4 In 2003, Exelon started a flow augmentation demonstration project, which pumped water from 5 the Wadesville mine pool into the Schuylkill River. NAI and URS (2004 and 2011) conducted 6 monitoring studies to determine the potential effects of the flow augmentation demonstration 7 project on aquatic biota. Monitoring studies during the first year of the project indicated that the 8 flow augmentation had no effect on water quality parameters such as total dissolved solids and 9 pH (NAI and URS 2004). Aquatic biota monitoring included an assessment of 10 macroinvertebrate and fish community composition and abundances before and after initiation 11 of the demonstration project at upstream and downstream locations of the Norwegian Creek 12 confluence with the Schuylkill River (NAI and URS 2004). NAI and URS sampled 13 macroinvertebrates using kick nets and fish using electroshocking. Prior to the initiation of the 14 demonstration project, predominant fish species included blacknose dace (Rhinichthys 15 atratulus), creek chub (Semotilus atromaculatus), white sucker and green sunfish (Lepomis 16 cyanellus), while macroinvertebrate sampling revealed limited species diversity with decapods, 17 oligochaetes, and Trichoptera comprising the majority of samples. Fish abundances and 18 community composition remained similar following commencement of the demonstration 19 project. However, macroinvertebrate diversity and abundance increased below the confluence 20 of Norwegian Creek and the Schuylkill River (NAI and URS 2004). Exelon and the DRBC have 21 extended the initial demonstration project on a year -to-year basis. The most recent assessment 22 compared water quality and aquatic biotic from 2003 to 2011. NAI and URS (2011) reported no 23 significant changes to water quality or aquatic biota species diversity or abundances within the 24 Schuylkill River due to use of the Wadesville Mine Pool water using sampling methods 25 described for the initial study conducted in 2003. As described in Section 2.1.6, Exelon plans to 26 continue to rely more on use of Schuylkill River water for consumptive water use rather than 27 Perkiomen Creek in the future (Exelon 2012b). 28 Perkiomen Creek 29 As described in Section 2.1.6, LGS withdraws water from Perkiomen Creek, rather than t he 30 Schuylkill River, if the flow and temperature conditions in the Schuylkill River do not meet DRBC 31 criteria for water use. Maintenance of minimal flow in Perkiomen Creek to meet the DRBC 32 criteria often requires diversion of Delaware River water via East Branch Perkiomen Creek as 33 discussed in Section 2.1.6. 34 The Perkiomen Creek enters the middle reach of the Schuylkill River at RM 32.3 which is 35 25.7 stream km (16 stream miles) downstream of LGS (Exelon 2011b). Perkiomen Creek 36 supports a warm water fishery with migratory fishes (Rhoads and Block 2008). The watershed 37 includes predominantly agricultural and increasingly more residential land uses. Few large 38 industrial facilities operate within the watershed, although some municipal wastewater treatment 39 plants discharge to Perkiomen Creek (PECO 1984, PADEP 2003). The Perkiomen Railroad 40 historically ran along a portion of Perkiomen Creek. The rail bed today is now part of the 41 Perkiomen Trail used for recreation (Rhoads and Block 2007). The PFBC, in partnership with 42 American Rivers, is currently proposing to restore habitat in the creek for diadromous fish, 43 including American eels, alewife, and blueback herring (NMFS 2012c). 44 Biological Communities in Perkiomen Creek 45 Pre-operational biotic sampling of Perkiomen Creek began in 1970 and included surveys of 46 macroinvertebrates and fish in the 1970s and early 1980s, ichthyoplankton from 1973 through 47 Purpose and Need for Action 2-41 1975, and phytoplankton in 1974 (PECO 1984; RMC 1984, 1985, 1989). Post-operational biotic 1 sampling included surveys of macroinvertebrates from 1996 through 2007 (Stroud 2011) and 2 fish from 1985 to 1987 (RMC 1986, 1987, 1988). 3 Periphyton and Phytoplankton. Surveys from 1973 through 1974 indicated that diatoms 4 dominated periphyton and phytoplankton communities (PECO 1984). The most common 5 diatom was Navicula, which is a benthic diatom that occurs throughout the year in Perkiomen 6 Creek. No additional LGS -related studies were conducted to examine plankton and periphyton 7 communities since 1974. 8 Macroinvertebrates. Pre-operational benthic macroinvertebrate surveys indicated that a 9 diverse and productive macrobenthos occurs within Perkiomen Creek (NRC 1984). Caddisflies, 10 black flies, and Chironomidae (midges) dominated the collected species. PECO (1984) 11 collected the greatest overall biomass during the fall. 12 Stroud Water Research Center (Stroud) conducted a diversity assessment of 13 macroinvertebrates between 1996 and 2007 using hand -picked collection off rocks and Hess 14 samplers (Stroud 2011). The goal of the study was to use macroinvertebrate diversity as an 15 indicator of water and habitat quality. Stroud evaluated the diversity at different areas of 16 Perkiomen Creek by calculating the macroinvertebrate aggregated index for streams (MAIS) 17 score. The MAIS score incorporates 10 indices, such as the number of sensitive taxa and 18 diversity of certain taxa, to come up with a score of 0 through 20. Sites with an MAIS score of 19 0 to 6 are considered "Poor," 6.1 to 13 "Fair," and 13.1 to 20 "Good." Stroud (2011) ranked the 20 lower Perkiomen Creek as fair and assigned the site an MAIS value of 9.5 (Stroud 2011). The 21 most abundant taxa included Chironomidae (midges), Elmidae (riffle beetles), and Oligochaetes 22 (aquatic earthworms; Stroud 2011). Midges also dominated samples collected during 23 pre-operational studies (PECO 1984). 24 Fish. Pre-operational studies employed seines and electrofishing to survey juvenile and adult 25 fish (PECO 1984). In addition, drift and shoreline traps were used to survey fish larvae 26 (PECO 1984). Fish sampling efforts between 1970 and 1987 indicated that Perkiomen Creek 27 supports fish assemblages typical of same -sized southeastern Pennsylvania lotic systems 28 (PECO 1984; RMC 1984, 1985, 1986, 1987, 1988). Carp and minnows dominated larval fish 29 collections, while dominant adult and juvenile species included minnows and sunfishes 30 (PECO 1984). 31 After operations began at LGS, RMC sampled Perkiomen Creek as part of the annual 32 nonradiological monitoring program for LGS from 1985 through 1986. Species diversity for 33 adult fish remained similar to pre -operational studies with redbreast sunfish being the 34 predominant species (RMC 1986, 1987, and 1988). 35 LGS-related studies did not include icthyoplankton surveys after operations began or juvenile or 36 adult surveys following initiation of the Point Pleasant Water Diversion Project in 1988. 37 However, the current fish community in Perkiomen Creek is likely similar to the current fish 38 community in the East Branch Perkiomen Creek, which NAI (2010b, 2010c) sampled for fish 39 from 2001 through 2009, as described below. The two creeks likely have similar fish 40 communities because the creeks are in the same watershed, the East Branch Perkiomen 41 Creeks flows into Perkiomen Creek, similar land uses (and related anthropogenic stresses) 42 surround both creeks, and because both creeks provide similar habitats for fish. Furthermore, 43 LGS-related studies collected a total of 54 fish species in East Branch Perkiomen Creek and 44 Perkiomen Creek between 1970 and 2009 (Exelon 2011b). Of the 54 fish species collected, 45 47 species (87 percent) were collected in both waterbodies (Exelon 2011b). Based on the 46 historical similarities in fish communities, the hydraulic connection of the two creeks, and similar 47 Purpose and Need for Action 2-42 habitats, NRC staff expects that the current fish communities would be similar in Perkiomen 1 Creek and East Branch Perkiomen Creek. 2 Recreational fishing in Perkiomen Creek existed historically for sunfishes, pike fishes, and carp 3 (NRC 1984). Currently, the PFBC stocks Perkiomen Creek with brown trout (Salmo trutta) and 4 rainbow trout (Onchorhynchus mykiss) in Montgomery County (PFBC 2011a). 5 East Branch Perkiomen Creek 6 As part of the transfer of water from the Delaware River to the Perkiomen Creek, a series of 7 pumping stations delivers Delaware River water from the Point Pleasant Pump Station to the 8 Bradshaw Reservoir by pipeline and then to East Branch Perkiomen Creek by pipeline (see 9 Section 2.1.6). The water then flows from the East Branch of the Perkiomen Creek to 10 Perkiomen Creek. 11 The East Branch Perkiomen Creek joins the Perkiomen Creek approximately 18 stream km 12 (11.2 stream miles) upstream of the Perkiomen Creek and Schuylkill River confluence. The 13 East Branch Perkiomen Creek is a warm water stream with riffles, runs, and shallow pools 14 (Exelon 2011b). 15 Biological Communities in East Branch Perkiomen Creek 16 Aquatic sampling in the East Branch Perkiomen Creek before LGS operations included surveys 17 of phytoplankton from 1973 through 1974, macroinvertebrates and fish in the 1970s through 18 1984, and ichthyoplankton from 1973 through 1975 (PECO 1984; RMC 1984, 1985, 1989). 19 Aquatic sampling after LGS operations began includes surveys of macroinvertebrates and fish 20 from 1985 through 1986 and 2001 through 2009 (RMC 1986, 1987; Exelon 2011 b; NAI 2010b, 21 2010c). 22 Periphyton and Phytoplankton . Surveys from 1973 through 1974 indicated that diatoms 23 dominated periphyton and phytoplankton communities (PECO 1984). The most common 24 diatoms were Navicula , Melosira, Synedra , Nitzschia, and Cocconeis. No additional 25 LGS-related studies were conducted to examine plankton and periphyton communities 26 since 1974. 27 Macroinvertebrates . Aquatic sampling for macroinvertebrates occurred from 1970 through 28 1987, 1979 through 1986, and 2001 through 2009 (PECO 1984, RMC 1986, 1987; 29 Exel on 2011 b; NAI 2010b, 2010c). Sampling methods followed those previously described 30 under the studies described for Perkiomen Creek. Pre -operational sampling indicated that a 31 diverse macroinvertebrate community made up of a variety of aquatic insects, annelids, and 32 mollusks occurred within the East Branch of Perkiomen Creek (PECO 1984). Subsequent 33 sampling between 1983 and 1986 showed similar diversity with the earlier studies. In addition, 34 the biotic communities in the East Branch Perkiomen Creek resembled those found in the 35 Perkiomen Creek with regard to macroinvertebrates assemblages (Exelon 2011b). After LGS 36 operations began, RMC (1986 and 1987) reported the most abundant taxa as oligochaetes, 37 stoneflies, caddisflies, snails, and clams from 1985 through 1986. 38 After the initiation of the Point Pleasant water diversion project, which transported water from 39 the Delaware River to East Branch Perkiomen Creek, NAI (2010b, 2010c) sampled 40 macroinvertebrates between 2001 and 2009 using methods similar to those reported by RMC. 41 This study was part of an analysis to examine post -operational effects of the Point Pleasant 42 water diversion effort (Exelon 2011b). NAI (2010b, 2010c) observed similar levels of 43 macroinvertebrate species diversity as compared to pre -diversion sampling. Midges and 44 oligochaetes dominated samples both before and after the diversion project. However, after the 45 Purpose and Need for Action 2-43 diversion project, less variability existed along the stream gradient and pollution -sensitive 1 species increased in abundance over time (NAI 2010b, 2010c). 2 Fish. Fish studies from 1970 through 1976 examined fish larvae using drift nets and juvenile 3 and adult fish using seines and electroshocking (PECO 1984). White sucker, yellow bullhead, 4 sunfish, and minnows dominated larval fish samples (PECO 1984). Common species collected 5 in juvenile and adult fish surveys included minnows, sunfish, shiners, banded killifish, suckers, 6 catfish, and pike (PECO 1984). Species abundances varied by sampling site, suggesting 7 possible species zonation along the regions sampled. 8 From 1985 through 1987, dominant species in the seining and electrofishing studies included 9 shiners, minnows, suckers, and sunfish (RMC 1986, 1987, 1988). NAI (2010b, 2010c) sampled 10 for fish in East Branch of Perkiomen Creek from 2001 through 2009. Dominant species 11 included sunfishes and minnows, which is similar to the dominant species captured in previous 12 studies (NAI 2010b, 2010c). NAI (2010b, 2010c) did not observe approximately one quarter of 13 the species identified in the 1970s and 1980s surveys. NAI (2010b, 2010c) may not have 14 observed these species because they are no longer present or because the aquatic biota was 15 sampled more frequently in the 1970s and 1980s, which would make it more likely that the 16 surveys captured more species (Exelon 2011b). As with the macroinvertebrate sampling, 17 NAI (2010b, 2010c) noted that pollution -sensitive fish species increased in abundance and that 18 less variability existed between sampling locations. 19 Recreational fishing in East Branch Perkiomen Creek existed historically for catfish, sunfishes, 20 and pike fishes (NRC 1984). Currently, the PFBC stocks East Branch Perkiomen Creek with 21 brown trout and rainbow trout in Montgomery County (PFBC 2011a). 22 Delaware River 23 The Delaware River flows 531 km (330 miles) from its origin in southern New York to the 24 Delaware Bay. Historically, degradation of the Delaware River began as early as the late 1700s 25 and by 1940, the Delaware River was considered one of the most polluted rivers in the United 26 States. The Delaware River has high vessel traffic ports along with a large concentration of 27 industry and oil -refinery plants (Albert 1988). The toxicity and low dissolved oxygen levels of 28 the estuarine and tidal portions of the Delaware River presented a chemical barrier for fish to 29 complete migration from the tidal to freshwater portions of the Delaware River. Restoration 30 efforts started in the 1960s and continue to this day. The DRBC manages water resources and 31 contaminant levels in the Delaware River (Albert 1988). 32 The Point Pleasant Pump Station, which withdraws water that is transferred to the East Branch 33 Perkiomen Creek, occurs at RM 157. The Point Pleasant Pump Station is above the salt line, or 34 the boundary where salt intrudes the river from tidal flows (Exelon 2011b). Riffle, run, and pool 35 habitat characterize the Delaware River within 2.5 km (1.5 miles) upstream and downstream of 36 the Point Pleasant Pump Station. 37 Biological Communities in the Delaware River 38 Aquatic sampling in the Delaware River before LGS operations included surveys for 39 macrophytes, macroinvertebrates, and fish from 1972 through 1973 and ichthyoplankton from 40 1979 through 1984 (NRC 1984; PECO 1984; RMC 1984, 1985). Once operations began, RMC 41 (1986) sampled ichthyoplankton in 1985. 42 Periphyton and Macrophytes . Similar to the other waterbodies discussed above, diatoms 43 dominated periphyton samples collected in the early 1970s (Exelon 2011b) . Pre-operational 44 monitoring for macrophytes indicated that water milfoils (Myriophyllum sp.) were common in 45 back eddies near the Point Pleasant Pump Station (Exelon 2011b). No additional LGS -related 46 Purpose and Need for Action 2-44 studies have been conducted near the Point Pleasant Pump Station to examine periphyton and 1 macrophyte communities since 1973. 2 Macroinvertebrates . Aquatic sampling for macroinvertebrates occurred from 1972 through 3 1973 using dip nets, hand removal, and stationary fine mesh nets. Sampling areas included 4 approximately 2 km (1.2 miles) upstream to 2.4 km (1.5 miles) downstream of Point Pleasant 5 Pump Station. Samples included aquatic insects, snails, clams, mollusks, and worms 6 (Exelon 2011b). Dominant taxa within dip net samples included chironomid midges and 7 amphipods (Exelon 2011b). No additional LGS -related macroinvertebrate studies have been 8 conducted near the Point Pleasant Pump Station since 1973. 9 DRBC conducted a diversity assessment of macroinvertebrates between 2001 and 2008 10 throughout the non -tidal portion of the Delaware River (DRBC 2009). DRBC collected 11 invertebrates annually using kick nets at 25 sites along the river, including two sites within 3 RM 12 of the Point Pleasant Pump Station. DRBC calculated a multi -metric Index of Biotic Integrity 13 (IBI) score, which was composed of 6 ecological metrics, including species richness (total 14 number of species), EPT Richness (total number of species within three insect orders: 15 Ephemeroptera, Plecoptera, Trichoptera), Shannon-Wiener Diversity (an index of species 16 diversity based on the relative abundance and total number of species), the Biotic Index (an 17 index based on the relative abundance species sensitive to environmental stress), Intolerant 18 Percent Richness (the percent of species intolerant to environmental stress relative to the 19 overall number of species), and Scraper Richness (degree of overlap and number of select 20 invertebrate species). The IBI score for the two sites near the Point Pleasant Pump Station was 21 generally similar to or slightly less than the IBI score of upriver sites within the Delaware 22 Watergap National Recreation Area and the Upper Delaware Scenic & Recreational River 23 (DRBC 2009). These results suggest that the area surrounding the Point Pleasant Pump 24 Station is similar to, or slightly more disturbed, than upriver sites within Federally -designated 25 areas. 26 Fish. RMC and PECO surveyed ichthyoplankton in the Delaware River from 1972 through 27 1973 and 1979 through 1985 using drift and push nets (PECO 1984; RMC 1984, 1985, 1986). 28 RMC sampled ichthyoplankton near the Point Pleasant Pump Station and downriver to RM 138 29 near Yardley, Pennsylvania (RMC 1984, 1985, 1986). Dominant species within ichthyoplankton 30 samples included herring (Clupeidae), sunfish, American shad, and common carp eggs and 31 larvae. 32 Adult fish studies were conducted from 1972 through 1973 and 1979 through 1980 in the vicinity 33 of the Point Pleasant Pump Station using seines, fyke nets, and trap nets (Exelon 2011b). The 34 most common taxa included sunfishes, shiners, and catfishes (Exelon 2011b). The adult fish 35 studies also observed anadromous species such as the alewife, American shad, and blueback 36 herring (Exelon 2011b). These species used this region of the Delaware River as a nursery 37 area (Exelon 2011b). No additional LGS -related studies have been conducted near the Point 38 Pleasant Pump Station to examine adult fish communities since 1980. 39 PFBC sampled American shad in the non -tidal portion of the Delaware River at RM 178.9, 40 which is approximately 20 RM upstream of the Point Pleasant Pump Station (PFBC 2011c). 41 RFBC conducted the electrofishing surveys during the spring from 1997 through 2001 and 2010 42 through 2011. The average annual catch per unit effort (CPUE) ranged from approximately 11 43 to 50 shad per hour (PFBC 2011c). All females collected in 2011 were gravid, indicating that 44 the females had produced eggs but had not yet spawned or released the eggs into the river. 45 Recreational and commercial fishing occur in the Delaware River (NYSDEC 2009). Common 46 recreational species caught in the non -tidal portion of the Delaware River include American 47 shad, American eel, channel catfish, rainbow trout, smallmouth bass, striped bass (Morone 48 Purpose and Need for Action 2-45 saxatilis), and walleye (Versar 2003, PFBC 2012d). In 2003, river herring and hickory shad 1 comprised a small portion of the catches (Versar, 2003). As of October 2012, river herring and 2 hickory shad fisheries are closed in the Delaware River (PFBC 2012d). 3 Onsite Water Bodies 4 Two streams, Possum Hollow Run and Brooke Evans Creek, run parallel to each other and flow 5 through the LGS site. LGS discharges industrial wastewater and stormwater to Possum Hollow 6 Run under NPDES compliance (Exelon 2012b). Brooke Evans Creek is a freestone stream and 7 a tributary to the Schuylkill River (PADEP 2006a). The State of Pennsylvania designates both 8 streams with water use protection for maintenance and propagation of flora and fauna 9 indigenous to warm water habitat (Pa. Code 93.3). 10 Exelon has not conducted any sampling or monitoring of aquatic biota in Possum Hollow Run 11 (Exelon 2012b). PADEP (2006a) conducted an evaluation of indigenous aquatic biota as an 12 indicator of long -term water quality conditions in Brook Evans Creek. PADEP staff collected 13 benthic macroinvertebrate data and assessed habitat using a modified index of biotic integrity 14 protocols under PADEP's antidegradation implementation guidance (PADEP 2006a). PADEP 15 observed relatively high abundances of macroinvertebrates tolerant of water quality 16 degradation, indicating that human activity in the basin has influenced the habitat quality and 17 composition of aquatic biota within Brooke Evans Creek. 18 2.2.6.2. NOAA Trust Resources 19 NOAA trust resources include, but are not limited to, commercial and recreational fishery 20 resources, anadromous species (fish that spawn in fresh water and then migrate to salt water), 21 catadromous species (species that spawn in salt water and then migrate to fresh water), and 22 threatened and endangered species. NOAA trust resources in the Schuylkill River and 23 Perkiomen Creek include alewife, blueback herring, American shad, striped bass, hickory shad, 24 bluefish, yellow perch, white perch, bay anchovy, and American eel and their habitat 25 (NMFS 2012a). Alewife, blueback herring, American shad, striped bass, hickory shad, and 26 white perch are anadromous species that spawn in fresh water, such as the Delaware River and 27 its estuary, and then return to the Atlantic Ocean after spawning (PFBC 2012c). American eel is 28 a catadromous species that spawns in the Atlantic Ocean and returns to the Delaware River 29 after spawning (PFBC 2012c). Table 2 -2 describes the NOAA trust species that have been 30 observed in LGS -related surveys of the Delaware River, Perkiomen Creek, East Branch of the 31 Perkiomen Creek, and the Schuylkill River. As noted above, dams throughout the Schuylkill 32 River historically have limited the movement of migrating fish. More recent efforts to remove 33 dams, the addition of fish ladders, and stocking rivers with fry have helped to increase the 34 population of anadromous fish (NMFS 2012 a). 35 Purpose and Need for Action 2-46 Table 2-2. NOAA Trust Resources Observed in LGS -related Aquatic Studies 1 Schuylkill River a East Branch Perkiomen Creek b Perkiomen Creek c Delaware River d Alewife X X American eel X X X X American shad X X Bay anchovy Blueback herring Bluefish Hickory shad Striped bass White perch X X Yellow perch X X X X (a) LGS-related surveys occurred from 1970 -1976, 1979 -2004, and 2009. (b) LGS-related surveys occurred from 1970 -1976, 1979 -1987, and 2001 -2009. (c) LGS-related surveys occurred from 1970 -1977 and 1979 -1987. (d) LGS-related surveys occurred from 1972 -1973 and 1982-1985 near the Point Pleasant Pumping Station on the Delaware River. Note: A blank cell indicates that the species was not observed during LGS -related surveys. Source: Exelon 2011 2.2.6.3. Invasive or Introduced Aquatic Species 2 Hydrilla (Hydrilla verticillata) forms dense mats at the surface of waterbodies and reduces light 3 to aquatic plants residing below. Hydrilla can also impair commercial water use by clogging 4 pipes and reducing flow rates (Sea Grant Pennsylvania 2012). Hydrilla grows in freshwater 5 habitats and tolerates a wide range of environmental conditions. Hydrilla occurs in the 6 Schuylkill River near Philadelphia, Pennsylvania (Exelon 2011b). 7 The Asiatic clam (Corbicula fluminea) can be problematic for nuclear facilities in terms of 8 biofouling in the intake and circulating water systems (NRC 1996). NAI indicated that this 9 invasive organism is present in the Schuylkill River upstream and downstream of LGS 10 (NAI 2010a, 2010d), in Perkiomen Creek near the Perkiomen Pumphouse (NAI 2010d), East 11 Branch Perkiomen Creek (NAI 2010b, 2010c), and the Delaware River near the Point Pleasant 12 Pump Station (RMC 1989). 13 Zebra mussels (Dreissena polymorpha) actively filter feed large amounts of freshwater and 14 remove available plankton food sources making less food available for other aquatic organisms 15 (Sea Grant Pennsylvania 2007). Exelon conducted surveys to determine if any zebra mussels 16 were present near the LGS intakes in the Schuylkill River and in Perkiomen Creek 17 (Exelon 2011b). Exelon did not find evidence of zebra mussels in the Schuylkill River or 18 Perkiomen Creek (NAI 2010d, Exelon 2011b). 19 Purpose and Need for Action 2-47 2.2.7. Terrestrial Resources 1 LGS Ecoregion 2 The LGS site lies in the Triassic Lowlands portion of the Northern Piedmont ecoregion 3 (EPA 2010). The Triassic Lowlands contain wide undulating ridges and broad nearly level 4 valleys with limited local relief. Appalachian oak forest dominated by white oak (Quercus alba) 5 and red oak (Q. rubra) is the most prevalent forest community. Hickory (Carya spp.) is more 6 abundant in this region of the Piedmont because of the less acidic soils, while red maple (Acer 7 rubrum) and black tupelo (Nyssa sylvatica) are present but less abundant than in other portions 8 of the Northern Piedmont ecoregion (EPA 2010). Streams, wetlands, and a few ponds occur in 9 the Triassic lowlands. Farms and houses have replaced much of the native vegetation, and 10 suburban development intensifies nearer to Philadelphia (EPA 2010), which lies about 21 miles 11 (34 km) southeast of the LGS site. In the immediate vicinity of the LGS site, land uses include 12 light residential development, agriculture, old fields, and woodlands. 13 The LGS site is included in the Upper Schuylkill Conservation Landscape. The Montgomery 14 County Planning Commission designated this as one of 13 conservation landscapes in the 15 county that have high natural biodiversity. The Upper Schuylkill Conservation Landscape totals 16 2,392 ac (968 ha) and extends from just above Royersford Borough to the Berks County line. 17 The conservation landscape includes 1,064 ac (431 ha) of forest, about 275 ac (111 ha) of 18 which qualify as interior forest. Although this area, especially along the Schuylkill River, has 19 been the site of intensive industrial development, riparian habitat remains along the Schuylkill 20 River and some of its tributaries, such as Possum Hollow Run and Brook Evans Run, which 21 enter the Schuylkill River from the LGS site (Rhoads and Block 2008). 22 The riparian area of the Schuylkill River is included in the river's designation as a Pennsylvania 23 Scenic River (PDCNR 2010). The Pennsylvania Department of Conservation and Natural 24 Resources (PDCNR) manages designated scenic rivers that are free-flowing and capable of 25 supporting water -based recreation and aquatic life. 26 Pennsylvania State Game Land #234 lies abou t 2 miles (3.2 km) southeast of the LGS site on 27 the east side of the Schuylkill River in close proximity to the Limerick to Cromby 230 -kV 28 transmission line corridor (22 -60 line) (PGC 2011). Pennsylvania State Game Lands are 29 managed by the Pennsylvania Game Commission for hunting , trapping, and fishing. 30 LGS Site 31 Before construction of the LGS plant, the LGS site consisted primarily of immature, nearly 32 climax oak -hickory forest, and some fruit orchards (AEC 1973). LGS construction disturbed 33 about 270 ac (110 ha; 42 percent of the current LGS site) (AEC 1973). PECO (which 34 constructed and first operated LGS) seeded temporarily disturbed areas with perennial grasses 35 after construction (AEC 1973, NRC 1984). When LGS first began operating in 1984, mixed 36 deciduous forest occurred along the Schuylkill River, Possum Hollow Run, and in an area 37 approximately 50 m (164 ft) west of the LGS Unit 1 cooling tower (NRC 1984). Today, riparian 38 and upland forest, small forested and emergent wetlands, pioneer herbaceous, old fields, 39 agricultural fields, and developed areas occupy the site (Exelon 2011a, WHC 2006). A 40 description of each of these habitats appears below. Several linear corridors run through the 41 LGS site, including utility distribution rights-of-way that are maintained as grass or scrub -shrub 42 habitat (WHC 2006). 43 Forest habitat on the LGS site includes both lowland riparian and upland communities. Riparian 44 forest occurs along the banks of the Schuylkill River and smaller tributaries such as Brooke 45 Evans Creek and Possum Hollow Run. Tree species in these areas include silver maple (Acer 46 saccharinum), American sycamore (Plantanus occidentalis), American elm (Ulmus americana), 47 Purpose and Need for Action 2-48 and slippery elm (U. rubra). Riparian forest provides food, cover, and reproductive habitat to 1 wildlife. For example, during spring, forest depressions may collect water and form ephemeral 2 pools that amphibians use for breeding and waterfowl and neotropical migrant birds use as 3 stopover habitat. Riparian forest provides dispersal and seasonal migration corridors. Upland 4 forest supports common tree species, such as white ash (Fraxinus Americana), tulip poplar 5 (Liriodendron tulipifera), red maple, chestnut oak (Quercus prinus), American elm, black walnut 6 (Juglans nigra), slippery elm (Ulmus rubra), flowering dogwood (Cornus florida), bitternut 7 hickory (Carya cordiformis), American beech (Fagus grandifolia), and red oak. Upland forest 8 also provides food, cover, and reproductive habitat for wildlife (Exelon 2010a). 9 Small palustrine forested and emergent wetlands on the LGS site are important habitat for 10 wildlife, especially amphibians. Red maple and silver maple typically dominate the palustrine 11 forested wetlands on the LGS site. Common vegetation in palustrine emergent wetlands 12 includes sedges (Carex spp.), microstegium (Eulalia viminea), bedstraws (Galium spp.), 13 arrow-leaf tearthumb (Polygonum sagittatum), halberd -leaf tearthumb (Polygonum arifolium), 14 flatsedges (Cyperus spp.), hollow joe -pye-weed (Eupatoriadelphus fistulosus), and swamp 15 milkw eed (Ascelpias incarnata) (Exelon 2010 a). 16 Pioneer herbaceous habitat on the LGS site consists of plant communities that colonize areas 17 following disturbances such as construction, grading, and periodic mowing. This plant 18 community typically consists of wineberry (Rubus phoenicolasius), mugwort (Artemisia vulgaris), 19 multiflora rose (Rosa multiflora), lesser celandine (Ranunculus ficaria), orchardgrass (Dactylis 20 glomerata), foxtails (Alopecurus spp.), white goosefoot (Chenopodium album), spotted lady's 21 thumb (Polygonum persicaria), Pennsylvania smartweed (Polygonum pensylvanicum), 22 cespitose knotweed (Polygonum cespitosum), curly dock (Rumex crispus), wild carrot (Daucus 23 carota), white amaranth (Amaranthus albus), butter-and-eggs (Linaria vulgaris), red clover 24 (Trifolium pretense), yellow sweetclover (Melilotus officinalis), white sweetclover (Melilotus 25 alba), and Deptford pink (Dianthus armeria). This habitat is of low value to native wildlife, but it 26 is beneficial to some species such as white -tailed deer, eastern cottontail (Sylvilagus 27 floridanus), and meadow vole (Microtus pennsylvanicus) (Exelon 2010a). 28 Old field habitat on the LGS site consists of abandoned agricultural areas that are either in the 29 meadow (grasses and forbs) or scrub/shrub state of succession. Old field meadow habitat 30 supports grasses such as fescue (Festuca spp.), Kentucky bluegrass (Poa pratensis), timothy 31 (Phleum pretense), and orchardgrass, and forbs such as Canada goldenrod (Solidago 32 canadensis), daisy fleabane (Erigeron strigosus), evening primrose (Oenothera biennis), dwarf 33 cinquefoil (Potentilla candensis), wild carrot, teasel (Dipsacus fullonum), red clover, smartweeds 34 (Polygonum spp.), and shrubs such as brambles (Rubus spp.). Common wildlife species 35 include white -tailed deer, red fox (Vulpes vulpes), eastern cottontail, raccoon (Procyon lotor), 36 and Virginia opossum (Didelphis virginiana) (Exelon 2010a). 37 Agricultural fields on the LGS site contain crops such as corn, wheat, barley, soybeans, and 38 hay. Agricultural areas also support hedgerows of upland tree species such as black cherry 39 (Prunus serotina), black walnut (Juglans nigra), Osage orange (Maclura pomifera), white ash 40 (Fraxinus americana), red cedar (Juniperus virginiana), tulip poplar (Liriodendron tulipfera), 41 sassafras (Sassafras albidum), and common hackberry (Celtis occidentalis). These areas 42 provide cover and food for wildlife species such as white -tailed deer that are adapted to edge 43 habitats (Exelon 2010a). 44 Buildings, asphalted parking lots, roads, landscaping, and mowed lawns occupy the developed 45 portions of the LGS site. Mowed lawns consist largely of non -native cool season grasses that 46 are of minimal value to native wildlife species. Landscaped areas contain mostly non -native 47 Purpose and Need for Action 2-49 ornamental species, some of which may serve as nesting habitat, cover, and food sources for 1 some native bird species (Exelon 2010a). 2 Common mammal species on the LGS site include the white -tailed deer, raccoon, striped skunk 3 (Mephitis mephitis), red fox, Virginia opossum, eastern cottontail, gray squirrel (Sciurus 4 carolinensis), groundhog (Marmota monax ), and white-footed mouse (Peromyscus leucopus) 5 (Exelon 2010 a, NRC 1984, Kriner and MacDonald 2009). 6 Common bird species on the LGS site include game birds such as Canada goose (Branta 7 canadens is) and mourning dove (Zenaida macroura); raptors such as red -tailed hawk (Buteo 8 jamaicensis) and turkey vulture (Cathartes aura); resident songbird species such as northern 9 cardinal (Cardinalis cardinalis); and neotropical migrant songbirds such as Baltimore oriole 10 (Icterus galbula), indigo bunting (Passerina cyanea), and red -eyed vireo (Vireo olivaceous). 11 Other avian species include eastern bluebird (Sialia sialis), American robin (Turdus migratorius), 12 eastern towhee (Pipilo erythrophthalmus), tufted titmouse (Baeolophus bicolor), downy 13 woodpecker (Picoides pubescens), blue jay (Cyanocitta cristata), American crow (Corvus 14 brachyrhynchus), killdeer (Charadrius vociferous), barn swallow (Hirundo rustica), tree swallow 15 (Tachycineta bicolor), purple martin (Progne subis), and the introduced European starling 16 (Sturnus vulgaris) (Blye 1973, Exelon 2010 a, Kriner and MacDonald 2009). The 17 U.S. Geological Survey has also regularly recorded all of these species during its annual 18 Breeding Bird Survey along the Schwensksvill route (Sauer et al. 2011). This route, which runs 19 near Pottstown (USGS 2001), lies about 3 miles to the northwest of the LGS site. 20 Reptiles that inhabit the riparian habitat bordering the Schuylkill River and its tributaries on the 21 LGS site include the northern black racer (Coluber constricter), northern ring -necked snake 22 (Diadophis punctatus punctatus), eastern garter snake (Thamnophis sirtalis), water snake 23 (Nerodia sipedon), spotted turtle (Clemmys guttata), mud turtle (Trachemys scripta), eastern 24 box turtle (Terrapene carolina carolina), and eastern painted turtle (Chrysemys picta picta). 25 Amphibians that inhabit the LGS site include the red -backed salamander (Plethodon cinereus), 26 long-tailed salamander (Eurycea longicauda), northern two -lined salamander (Eurycea 27 bislineata bislineata), American toad (Bufo americanus), spring peeper (Pseudacris crucifer), 28 bullfrog (Rana catesbeiana), leopard frog (Rana pipiens), and green frog (Rana clamitans) 29 (Exelon 2010a, Kriner and MacDonald 2009). The amphibians range from fully aquatic 30 (e.g., bullfrog) to semi -aquatic (e.g., toad species) and are closely tied to water habitats, 31 including streams, wetlands, and temporary pools where they reproduce. The frog and toad 32 species, except the bullfrog, also make extensive use of adjacent terrestrial habitats, such as 33 forest, grassland, and cropland as juveniles and adults. The turtle species leave the water to 34 nest (egg deposition) in nearby soft substrates. 35 Exelon joined the Wildlife Habitat Council in 2005, and since that time has formed an 36 Environmental Stewardship Committee that has developed a Wildlife Management Plan 37 (Exelon 2010 b). The Wildlife Management Plan is a comprehensive strategy that outlines the 38 goals of the wildlife habitat program for the LGS site and describes projects and milestones to 39 achieve these goals. As part of the program, Exelon places and monitors artificial avian nesting 40 structures and bat roost boxes (WHC 2006). In 2007, Exelon installed structures around the 41 perimeter of the LGS site for eastern blue birds, purple martins, owls, raptors, other perching 42 birds, and bats. In addition, in 2010, Exelon installed a 300 -ft-(90-m)-long barrier between 43 Possum Hollow Run and an adjacent road and parking area on the east side of the LGS site to 44 decrease the mortality of amphibians during post -natal dispersal (Exelon 2010 b). Exelon staff 45 continues to develop the wildlife habitat enhancement program and evaluate future projects that 46 would enhance the quality of the natural environment on the site. In 2010, Exelon received 47 WHC's Corporate Wildlife Habitat Certification in recognition of its implementation of the wildlife 48 habitat enhancement program (Exelon 2011 b). 49 Purpose and Need for Action 2-50 Transmission Line Corridors 1 Section 2.1.5 describes the transmission lines that were built to connect the LGS to the regional 2 electricity grid and that are within the scope of this SEIS. Section 2.1.5 also describes 3 vegetation maintenance along the transmission line corridors. The NRC is not aware of any 4 biological field surveys or studies of these transmission line corridors. Habitat within the 5 corridors is highly variable and includes suburban, residential, agricultural, forested, 6 wetland/floodplain, and open water. The lines also traverse several parks and natural heritage 7 areas, including the Evansburg State Park and Schuylkill River National and State Heritage 8 Area (Exelon 2011 b). 9 The NRC staff did not identify any ecological surveys or studies that provide information on 10 habitats and species along the transmission line corridors. However, some studies on the 11 transmission lines in southeastern Pennsylvania provide information on common vegetation and 12 species along the LGS transmission line corridors. Common tree species in transmission line 13 corridors in the northern Piedmont ecoregion of Pennsylvania include white ash , red maple , and 14 sassafras (Bramble et al. 1992, Yahner et al. 2001, Yahner and Yahner 2007). Common shrub 15 species include multiflora rose, Japanese honeysuckle (Lonicera japonica), blackberry (Rubus 16 allegheniensi s), dewberry (R. hispidus), gray dogwood (Cornus paniculata), black haw 17 (Viburnum prunifolium ), and poison ivy (Toxicodendron radicans) (Bramble et al. 1992, 1997; 18 Yahner and Yahner 2007). Common forb species include goldenrod (Solidago spp.), strawberry 19 (Fragaria virginiana ), common cinquefoil (Potentilla simplex), goosegrass (Galium aparine ), 20 sow-thistle (Sonchus oleraceus), and mile-a-minute (Polygonum perfoliatum) (Bramble et al. 21 1992, 1997; Yahner and Yahner 2007). Common grass species include fall panic grass 22 (Panicum spp.), deertongue grass (Panicum clandestinum ), foxtail grass (Setaria glauca ), and 23 broomsedge (Andropogon virginicus) (Bramble et al. 1992, 1997; Yahner and Yahner 2007). 24 Common breeding bird species in transmission line corridors in the northern Piedmont 25 ecoregion of Pennsylvania include the field sparrow (Spizella pusilla), black-throated blue 26 warbler (Dendroica caerulescens), gray catbird (Dumetella carolinensis), rufous-sided towhee 27 (Pipilo erythrophthalmus), common yellowthroat (Geothlypis trichas), American goldfinch 28 (Carduelis tristis), and indigo bunting (Bramble et al. 1992). Amphibian species include the 29 Jefferson salamander (Ambystoma jeffersonianum), redbacked salamander (Plethodon 30 cinereus), spotted salamander (Ambystoma maculatum), and the American toad (Yahner et 31 al. 2001). Reptile species include the eastern garter snake, northern ringneck snake (Diadophis 32 punctatus edwards), black rat snake (Pantherophis obsoletus), and eastern box turtle (Yahner 33 et al. 2001). Small mammals include the white -footed mouse, northern short -tailed shrew 34 (Blarina brevicauda), and meadow vole (Yahner and Yahner 2007). Common butterfly species 35 include the cabbage white (Pieris rapae), little wood -satyr (Megisto cymela), and great spangled 36 fritillary (Speyaria cybele) (Bramble et al. 1997). 37 2.2.8. Protected Species and Habitats 38 The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) 39 jointly administer the Endangered Species Act (ESA) of 1973 (16 USC 1531 et seq.). The FWS 40 manages the protection of and recovery effort for listed terrestrial and freshwater species, while 41 the NMFS manages the protection of and recovery effort for listed marine and anadromous 42 species. 43 Within Pennsylvania, the PGC, the PFBC, and the PDCNR oversee the protection of 44 Commonwealth -listed species under the Pennsylvania Endangered Species Program. The 45 PGC, PFBC, and PDCNR manage the recovery efforts for wild birds and mammals 46 Purpose and Need for Action 2-51 (34 Pa. Code 133); fish, amphibians, reptiles, and aquatic organisms (30 Pa. Code 75); and 1 native plants (17 Pa. Code 45), respectively. 2 The Magnuson -Stevens Fishery Conservation and Management Act (MSA), as amended, is 3 administered by the NMFS. The MSA requires Federal agencies to consider the impact of 4 Federal actions on essential fish habitat (EFH) and to consult with the NMFS if any activities 5 may adversely affect EFH. The NMFS has not designated any EFH under the MSA within the 6 affected waterbodies. However, in a letter dated June 27, 2012, NMFS stated that the Schuylkill 7 River and Perkiomen Creek provide habitat for a variety of prey species consumed by Federall y 8 managed species whose EFH has been designated in the mixing zone of the Delaware River 9 (NMFS 2012c). The NRC staff's EFH assessment will be issued separately as part of the staff's 10 consultation with NMFS under the MSA . 11 The FWS and NMFS have not designated any critical habitat under the ESA within the action 12 area, nor has either agency proposed the listing or designation of any new species or critical 13 habitat within the action area (Exelon 2011b; FWS 2011, 2012d; NMFS 2012a, 2012c). 14 2.2.8.1. Action Area 15 For the purposes of its protected species and habitat discussion and analysis, the NRC 16 considers the action area, as defined by the ESA regulations at 50 CFR 402.02, to include the 17 lands and waterbodies described below. The following sections only consider terrestrial and 18 aquatic species that occur or have the potential to occur within this action area. 19 LGS site and surrounding area within a 6 -mi le (10-km) radius. The majority of the LGS site 20 lies in Limerick Township, Montgomery County, although a portion of the property extends into 21 the adjacent Lower Pottsgrove Township in Montgomery County, and East Coventry Township 22 in Chester County, directly across the Schuylkill River. 23 Transmission line corridors and 1 -mi le (1.6-km) buffer on either side of the lines. Of the 24 five in-scope transmission lines (described in Section 2.1.5), three of the lines terminate within 25 Montgomery County. One of lines -the 220-61 line-runs parallel to the Schuylkill River on the 26 Chester County side for about 8 miles (12.9 km). Another line-the 220-60 line-crosses the 27 Schuylkill River into East Pikeland Township, Chester County, just before terminating. 28 Waterbodies and facilities associated with the LGS makeup water supply system. The 29 makeup water supply system includes a number of waterbodies and facilities off site of the LGS 30 site. These include the Perkiomen Pumphouse (Montgomery County); the Bradshaw Reservoir 31 and Bradshaw Pumphouse (Bucks County), which are located on 42 ac (17 ha) of 32 Exelon-owned property; and the Bedminster Water Processing Facility (Bucks County), which is 33 located on a 3 ac (1.2 ha) Exelon -owned property. Section 2.1.6 describes the LGS makeup 34 water supply system in detail. 35 2.2.8.2. Aquatic Species and Habitats 36 The aquatic species described in this section and summarized in Table 2-3 are Federally listed 37 or Pennsylvania -listed threatened, endangered, or species of special concern that may occur in 38 the action area, as defined above. The three Federally listed species appear in bold. 39 FWS, NMFS, and/or PFBC list the species in Table 2-3 as occurring within Montgomery, 40 Chester, or Bucks Counties, Pennsylvania, which are the three counties associated with LGS. 41 LGS infrastructure and associated waters bodies within Montgomery County include the main 42 plant site (e.g., power block), the Schuylkill River, Perkiomen Creek and Pumphouse, and the 43 East Branch Perkiomen Creek. LGS infrastructure and associated waterbodies in Chester 44 County include portions of the main plant site on the other side of the Schuylkill River and 45 transmission lines. LGS infrastructure and associated waterbodies in Bucks County include the 46 Purpose and Need for Action 2-52 Delaware River and Point Pleasant Pumping Station, the Bradshaw Reservoir and Bradshaw 1 Pumphouse, and the Bedminster Water Processing (Treatment) Facility. 2 Table 2-3. Federally and Pennsylvania -Listed Aquatic Species 3 Scientific Name Common Name Federal Status(a) State Status (b) County(ies) of Occurrence(c) Fish Acipenser brevirostrum shortnose sturgeon FE PE B Acipenser oxyrinchus oxyrinchus Atlantic sturgeon FE PE B Alosa aestivalis blueback herring CS - B, C, M Alosa pseudoharengus Alewife CS - B, C, M Enneacanthus obesus banded sunfish
- PE B Lepomis megalotis longear sunfish - PE B Notropis chalybaeus ironcolor shiner - PE B, M Invertebrates Alasmidonta heterodon dwarf wedgemussel FE PE B, C, M (d) Stygobromus pizzinii Pizzini's cave amphipod - SSC C, M Aquatic Plants Myriophyllum farwellii Farwell's water
-milfoil - PE B Myriophyllum heterophyllum broad-leaved water milfoil - PE B Nymphoides cordata floating-heart - PT B Potamogeton pulcher spotted pondweed
- PE B (a) Federal status determined by the FWS and NMFS under the authority of the Endangered Species Act; CS = candidate species (NMFS 2012c, 2012a; FWS 2012d); FE = endangered, FT = threatened, - = not listed.
(b) Commonwealth of Pennsylvania status determined by the PFBC under the Pennsylvania Endangered Species Program; PE = endangered, PT = threatened, SSC = species of special concern; - = not listed (PNHP 2012a). (c) The LGS site lies in Montgomery County; the in -scope transmission lines traverse Montgomery and Chester Counties; and the offsite facilities associated with the LGS makeup water system lie in Montgomery and Bucks Counties. B = Bucks County, C = Chester County, M = Montgomery County. (d) FWS (2012d) lists the dwarf wedgemussel as known to or believed to occur in Monroe, Pike, and Wayne Counties, Pennsylvania, which do not contain LGS -related infrastructure or waterbodies. PNHP (2012a) lists the dwarf wedgemussel as potentially occurring in Bucks, Chester, and Montgomery Counties. PECO (1984) observed rare, unidentified species of the genus Alasmidonta in the Schuylkill River in the 1970s and it is unknown whether the specimen was the dwarf wedgemussel (Exelon 2011b). In addition to the species listed in the above table, LGS collected bridle shiner (Notropis 4 bifrenatus), a Pennsylvania -listed endangered species, through 1977. LGS did not observe 5 bridle shiner since 1977 (Exelon 2011b). Furthermore, PNHP (2012a) does not list this species 6 as occurring within Bucks, Chester, or Montgomery Counties and PBFC (2011b) did not identify 7 the species as a concern regarding the proposed license renewal. Therefore, this species is not 8 considered further within this SEIS. 9 Purpose and Need for Action 2-53 Fish 1 Shortnose Sturgeon (Acipenser brevirostrum ) 2 The shortnose sturgeon was initially listed as a Federally endangered species in 1967 and is 3 designated as a Pennsylvania endangered species (NMFS 2012b, PNHP 2012a). Adult 4 shortnose sturgeon use freshwater for spawning and estuarine and marine habitats for feeding. 5 Juveniles migrate downriver to estuarine waters and may go back and forth between freshwater 6 and estuarine habitats for several years before maturing to adults. Adults sometimes migrate to 7 marine habitats for feeding, but primarily inhabit estuarine habitats (Rohde et al. 1994, 8 NMFS 2012b). Spawning occurs in freshwaters characterized by low -to-moderate velocities 9 and over substrates that include clay, sand, gravel, and woody debris. Eggs are adhesive and 10 survival depend s on water having little turbidity (Rohde et al. 1994). Sturgeon feed on benthic 11 invertebrates such as snails, insect larvae, crustaceans, and worms (Gilbert 1989). 12 In Pennsylvania, populations of shortnose sturgeon inhabit the Delaware River 13 (Hastings et al. 1987, O'Herron et al. 1993). Hastings et al. (1987) surveyed shortnose 14 sturgeon movement in the Delaware River and estimated an overwintering population of about 15 6,000 to 14,000 fish in the upper tidal portion of the Delaware River near Trenton, NJ at river 16 kilometer (RKm) 211.8 (river mile [RM] 131.6) (Hastings et al. 1987). Sturgeon moved 17 upstream into the non -tidal reach of the river in late March presumably to spawn before traveling 18 downstream to lower tidal waters near Philadelphia (O'Herron et al. 1993). Hastings et al. 19 (1987) observed upstream movement to non -tidal water as far as Lambertville, NJ at RKm 238 20 (RM 147.9). This location is approximately 15 river km (9.1 river miles) from the Point Pleasant 21 Pumping Station, which is located at RM 157 (RKm 253). 22 Shortnose sturgeon occur in Bucks County (PNHP 2012a , NMFS 2012a). On the Delaware 23 River, LGS -related studies from 1979 to 1985 did not capture shortnose sturgeon eggs or larvae 24 near the Point Pleasant Pumping Station and downriver to RM 138 (RKm 222.1) (Exelon 2011a; 25 RMC 1984, 1985, 1986). NMFS (2012a) concluded that no species listed under the ESA occur 26 within the action area. 27 Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus ) 28 The Atlantic sturgeon is currently listed as a Federally endangered species for the New York 29 Bight distinct population segment, which includes the Delaware River (77 FR 5880). The 30 Atlantic Sturgeon is also designated as a Pennsylvania State endangered species 31 (PNHP 2012a). Atlantic sturgeon share many life -history characteristics with the shortnose 32 sturgeon in that adults migrate to freshwater to spawn and feed on benthic invertebrates such 33 as worms, crustaceans, and aquatic insects (Gilbert 1989). Unlike shortnose sturgeon, adult 34 Atlantic sturgeon prefer more marine habitats and make extensive migrations away from natal 35 estuaries beginning as subadults (Gilbert 1989). 36 Atlantic sturgeon occur in Bucks County (PNHP 2012a, NMFS 2012a). Historically, the 37 Delaware River supported the largest population of Atlantic sturgeon along the Atlantic coast 38 (Secor and Waldman 1999). Tagging studies in 2005 and 2006 indicated that Atlantic sturgeon 39 followed similar migration patterns as shortnose sturgeon with spawning potentially occurring 40 between mid to late June in the upper tidal Delaware reaches between Philadelphia, 41 Pennsylvania, and Trenton, New Jersey (Simpson and Fox undated). 42 LGS-related studies from 1979 to 1985 did not observe Atlantic sturgeon eggs or larvae near 43 the Point Pleasant Pumping Station and downriver to RM 138 (RKm 222.1) (Exelon 2011 b; 44 RMC 1984, 1985, 1986). NMFS concluded that no species listed under the ESA occur within 45 the action area (NMFS 2012c). 46 Purpose and Need for Action 2-54 Alewife and Blueback Herring (Alosa pseudoharengus and A. aestivalis ) 1 Blueback herring and alewife are candidate species that occur in the project area (NMFS 2012, 2 76 FR 67652). As candidate species, blueback herring and alewife are not afforded any 3 procedural or substantive protections under ESA. NFMS currently is considering whether to list 4 blueback herring and alewife under ESA (69 FR19976). Blueback herring and alewife also are 5 NMFS species of concern. A species is designated as a species of concern if NMFS has some 6 concerns about the species' status and threats, but there is insufficient information to indicate a 7 need to list the species under the ESA (NMFS 2012). This status level does not carry any 8 procedural or substantive protections under the ESA (NMFS 2012b). 9 Alewife and blueback herring are both part of the herring family, Clupeidae (PFBC 2012). The 10 two species look similar to one another. However, blueback herring generally are more slender 11 and darker in color than alewife (PFBC 2012c). Blueback herring grow to a maximum of 15 in. 12 (38 cm) and 1 lb (0.45 kg). Herring are an important component of freshwater, estuarine, and 13 marine food webs because they are prey for many predatory fish and help transport nutrients to 14 freshwater systems. Alewife and blueback herring prey include zooplankton, shrimp, small fish, 15 and fish eggs (PFBC 2012c). 16 Blueback herring and alewife spawn in freshwater during the spring and migrate to estuaries or 17 marine waters during the summer and cooler months. Alewife begin their spring migration to 18 freshwater earlier than blueback herring and alewife spawn earlier (Collette and 19 Klein-MacPhee 2002). In Pennsylvania, blueback herring spawn in the lower Delaware River 20 and the Delaware estuary (PFBC 2012c). Alewife spawn in similar areas, but they also may 21 inhabit and spawn in freshwater lakes and impoundments. In streams and rivers, spawning 22 habitat includes fresh water several miles upstream of the tidal line in the Delaware River and in 23 areas with a rocky, firm bottom (PFBC 2012c). Eggs are demersal and adhesive (PFBC 2012). 24 Adults return to salt water after spawning, although adult alewife also can inhabit freshwater. 25 Historically, dams have severely limited movement of blueback herring and alewife to and from 26 spawning grounds (NMFS 2012c). 27 In Pennsylvania, blueback herring only occur in the lower Delaware River and the Delaware 28 estuary (PFBC 2012). LGS -related surveys did not observe blueback herring in the Schuylkill 29 River, East Branch of the Perkiomen Creek, Perkiomen Creek, or the Delaware River near the 30 Point Pleasant Pump Station (Table 2-2; Exelon 2011 b). LGS-related studies captured alewife 31 in the Schuylkill and Delaware Rivers, but did not observe this species in the East Branch of the 32 Perkiomen Creek or the Perkiomen Creek (Table 2-2; Exelon 2011 b). Studies from 1979 -80 33 indicated that American shad, alewife, and blueback herring used the Delaware River in the 34 vicinity of Point Pleasant as a nursery area. 35 Banded Sunfish (Enneacanthus obesus ) 36 The Commonwealth of Pennsylvania lists the banded sunfish as endangered (PNHP 2012a). 37 Banded sunfish prefer a restricted home range in coastal habitats such as small ponds, 38 backwaters of creeks and rivers, and slow -moving waters that have high acidity and abundant 39 vegetation. Banded sunfish prey on insects and microcrustaceans (PNHP 2012b). Spawning 40 over gravel or sand nests occurs in April through July, and the buoyant eggs drift with the slow 41 current (Rohde et al. 1994). 42 Banded sunfish occur in Bucks County (PNHP 2012a). Waters in Bucks County associated with 43 the LGS cooling system include the Delaware River at the Point Pleasant Pumping Station. 44 However, this area is not a preferred habitat for the banded sunfish as it is far upriver from the 45 coast and banded sunfish occur in the lower Delaware River (PNHP 2012b). LGS -related 46 studies from 1979 to 1985 did not observe banded sunfish eggs or larvae in surveys in the 47 Purpose and Need for Action 2-55 Delaware River at the Point Pleasant Pumping Station and downriver to RM 138 (RKm 222.1) 1 (Exelon 2011 b; RMC 1984, 1985, 1986). 2 Longear Sunfish (Lepomis megalotis ) 3 The Commonwealth of Pennsylvania lists the longear sunfish as endangered (PNHP 2012a). 4 Longear sunfish prefer slow -moving, shallow, headwater streams where they prey on 5 invertebrates, fish eggs, and smaller fish. Spawning occurs in spring and summer. Males 6 defend eggs and fry (PNHP 2012c). 7 Before 1980, the longear sunfish occurred in Bucks County (PNHP 2012a). However, 8 Pennsylvania records since 1980 do not list longear sunfish as occurring in Bucks County 9 (PNHP 2012c). LGS -related studies from 1979 to 1985 did not observe longear sunfish eggs or 10 larvae during surveys in the Delaware River at the Point Pleasant Pumping Station and 11 downriver to RM 138 (RKm 222.1) (Exelon 2011 b; RMC 1984, 1985, 1986). 12 Ironcolor Shiner (Notropis chalybaeus ) 13 The Commonwealth of Pennsylvania lists the ironcolor shiner as endangered (PNHP 2012a). 14 Little is known about the habitat preference and life cycle of ironcolor shiner in Pennsylvania. 15 Rohde et al. (1994) assumes that ironcolor shiner prefer habitats of headwaters in creeks or 16 small rivers with sandy or rocky bottoms. They likely spawn during spring months and prey on 17 insect larvae and algae, as is common among many shiner species along the eastern 18 U.S. coast. 19 PNHP (2012a) lists ironcolor shiners as possibly extirpated in both Bucks and Montgomery 20 Counties. LGS -related studies from 1979 to 1985 did not observe ironcolor shiner eggs or 21 larvae during surveys on the Delaware River at the Point Pleasant Pumping Station and 22 downriver to RM 138 (RKm 222.1) (Exelon 2011 b; RMC 1984, 1985, 1986). In the East Branch 23 Perkiomen Creek, Perkiomen Creek, and the Schuylkill River, LGS -related studies did not 24 observe ironcolor shiner eggs, larvae, juveniles, or adults during fish surveys between 1970 and 25 2009 (Exelon 2001, 2002, 2003, 2004, 2005, 2011; NAI 2010a, 2010b, 2010c; PECO 1984; 26 RMC 1984, 1985, 1986, 1987, 1988, 1989). 27 Invertebrates 28 Dwarf Wedgemussel (Alasmidonta heterodon ) 29 The dwarf wedgemussel is currently listed as a Federally endangered species wherever it 30 occurs, and is designated as a Pennsylvania -endangered species (FWS 2012a, PNHP 2012a). 31 The dwarf wedgemussel prefers habitat characterized by mud, sand, or gravel bottom in 32 slow-to-moderate, clear flowing streams and rivers (FWS 1992). Reproduction requires mussel 33 larvae (glochidia) to attach to host fish gills before completion of metamorphosis into juveniles. 34 The dwarf wedgemussel uses a number of different fish host species for glochidial reproduction, 35 including darter and sculpin fish species (FWS 2007b). 36 FWS lists the dwarf wedgemussel as known to or believed to occur in Monroe, Pike, and Wayne 37 Counties, Pennsylvania, which do not contain any LGS -associated infrastructure or waterbodies 38 (FWS 2012c). PNHP lists the dwarf wedgemussel as potentially occurring in Bucks, Chester, 39 and Montgomery Counties (PNHP 2012a). PECO observed rare, unidentified species of the 40 genus Alasmidonta in the Schuylkill River in the 1970s and it is unknown whether the 41 specimens were the dwarf wedgemussel (PECO 1984, Exelon 2011b). Other than the rare 42 Alasmidonta specimens observed in the 1970s in the Schuylkill River, LGS-related studies did 43 not observe dwarf wedgemussels during benthic surveys in East Branch Perkiomen Creek, 44 Perkiomen Creek, and the Schuylkill River between 1970 and 2009 (Exelon 2011 b; NAI 2010c; 45 PECO 1984; RMC 1984, 1985, 1986, 1987, 1989). 46 Purpose and Need for Action 2-56 Pizzini's Cave Amphipod (Stygobromus pizzinii ) 1 The Commonwealth of Pennsylvania lists the Pizzini's cave amphipod, previously named 2 Stygonectes pizzinii, as a Pennsylvania species of concern. The Pizzini's cave amphipod is an 3 invertebrate that occurs within a variety of groundwater habitats, such as seeps, small springs, 4 small spring and seep -fed streams, mines, wells, and caves (Holsinger 1978). As of 1978, the 5 Schuylkill River was the northern most portion of the known geographic range for this species 6 (Holsinger 1978). Although the Pizzini's cave amphipod is not listed as a candidate, threatened, 7 or endangered species, PFBC (2011b) noted that the species may be listed "in the not so 8 distant future." This species is threatened by habitat destruction and poor water quality 9 (PFBC 2011b). 10 Pizzini's cave amphipod is possibly extirpated in Montgomery and Chester Counties 11 (PNHP 2012a). PECO (1984) observed Stygonectes pizzinii and Stygonectes sp. during 12 surveys of the Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek conducted 13 between 1970 and 1976. RMC reported Stygobromus sp. (not specifically identified as 14 Stygobromus pizzinii) during a survey in the East Branch Perkiomen Creek in 1983 (RMC 1984) 15 and during surveys in the Schuylkill River in 1985 and 1986 (RMC 1986, 1987). However, from 16 1986 until 1988, LGS -related studies did not observe Stygobromus species in the East Branch 17 Perkiomen Creek nor the Schuylkill River (Exelon 2011a; RMC 1987, 1988, 1989). Based the 18 Pennsylvania Natural Diversity Inventory (PNDI) database and PFBC files, PFBC (2011b) 19 stated in its letter to the NRC that globally rare amphipod and/or isopod species are known to 20 occur within the vicinity of the LGS site. 21 Aquatic Plants 22 Farwell's Water -Milfoil (Myriophyllum farwellii ) 23 The Commonwealth of Pennsylvania lists the Farwell's water -milfoil as an endangered aquatic 24 plant (PNHP 2012a). Farwell's water -milfoil is a submerged plant that will grow up to 1 ft 25 (0.3 m) in length. This species of milfoil grows in lakes and ponds (PNHP 2012d). Farwell's 26 water-milfoil is often confused with other invasive milfoil species (PNHP 2012d). 27 PNHP reports no current observations of Farwell's water -milfoil in the three counties associated 28 with LGS. However, this plant was present in the coastal region of Bucks County before 1980 29 (PNHP 2012d). PECO (1984) did not observe Farwell's water -milfoil during aquatic surveys in 30 the Delaware River near the Point Pleasant Pumping Station, East Branch Perkiomen Creek, 31 Perkiomen Creek, or the Schuylkill River between 1970 and 1976. 32 Broad-Leaved Water -Milfoil (Myriophyllum heterophyllum ) 33 The Commonwealth of Pennsylvania lists the broad -leaved water -milfoil as an endangered 34 aquatic plant (PNHP 2012a). Broad-leaved water -milfoil colonizes slow -moving freshwater 35 habitats and has both submerged and emergent foliage. Reproduction occurs when part of the 36 plant breaks off, grows roots, and settles in a new location (NHDES 2010). 37 The br oad-leaved water -milfoil is possibly extirpated in Bucks County (PNHP 2012a). PECO 38 (1984) did not observe broad -leaved water -milfoil during aquatic surveys in the Delaware River 39 at Point Pleasant Pumping Station, East Branch Perkiomen Creek, Perkiomen Creek, or the 40 Schuylkill River between 1970 and 1976. 41 Floating-Heart (Nymphoides cordata ) 42 The Commonwealth of Pennsylvania lists the floating -heart as a threatened aquatic plant 43 (PNHP 2012a). Floating -heart grows in lakes and ponds and resembles a small water-lily 44 (PNHP 2012e). In the spring, floating -heart propagates, or creates new plants, as rhizomes, 45 tubers, or seeds sprout new growth. 46 Purpose and Need for Action 2-57 Floating-heart is listed as possibly extirpated in Bucks County (PNHP 2012e). PECO (1984) did 1 not observe floating -heart during aquatic surveys in the Delaware River at Point Pleasant 2 Pumping Station, East Branch Perkiomen Creek, Perkiomen Creek, or the Schuylkill River 3 between 1970 and 1976. 4 Spotted Pondweed (Potamogeton pulcher ) 5 The Commonwealth of Pennsylvania lists the spotted pondweed as an endangered aquatic 6 plant (PNHP 2012a). Leaves are floating or submerged and flowering occurs between June 7 and September. Spotted pondweed grows in wetlands characterized by acidic, standing water 8 (PNHP 2012f). 9 Spotted pondweed occurs within coastal regions of Bucks County (PNHP 2012f). PECO (1984) 10 did not observe spotted pondweed during aquatic surveys in the Delaware River at Point 11 Pleasant Pumping Station, or in East Branch Perkiomen Creek, Perkiomen Creek, or the 12 Schuylkill River between 1970 and 1976. 13 2.2.8.3. Terrestrial Species and Habitats 14 Before LGS construction, PECO compiled lists of plants and animals likely to occur on the site 15 and along the transmission line corridors based on species' ranges and habitat requirements. 16 In the late 1970s, PECO conducted surveys to confirm the presence of these species on the 17 site. The final environmental statement (FES) for construction of LGS (AEC 1973) includes 18 tables of those species PECO observed on the site as well as those species not specifically 19 observed during surveys but that are likely to occur on the site or along the transmission line 20 corridors. The NRC published an FES for operation of LGS in 1984 (NRC 1984), although this 21 FES did not document any new surveys or studies not already mentioned in the previous FES. 22 Exelon staff and Normandeau Associates, Inc. (Normandeau) performed reconnaissance 23 surveys to confirm the accuracy of the pre -construction site surveys in 2009 and 2010, and 24 Exelon's ER (Exelon 2011b) and the LGS Wildlife Management Plan (Exelon 2010 b) include 25 information on the results of these reconnaissance surveys. The WHC's "Site Assessment and 26 Wildlife Management Opportunities for Exelon Corporation's Limerick Generating Station" 27 (WHC 2006) also provides information on LGS site habitats and species. The NRC staff did not 28 identify any ecological surveys or studies that include the transmission line corridors or the 29 offsite facilities within the action area or that might provide additional information about the 30 occurrence of protected species and habitats. 31 Neither the pre -construction surveys nor the recent reconnaissance surveys identified any 32 Federally listed species on the LGS site. However, several Federally listed species (see 33 Table 2-4) have the potential to occur in the action area. In pre-operational surveys and 34 ongoing informal surveys, Normandeau has identified 10 Pennsylvania -listed bird species on 35 the LGS site. The PDCNR (2011) identified eight Pennsylvania -listed plants that occur along or 36 near the transmission line corridors. Exelon's LGS Wildlife Management Plan (Exelon 2010 a) 37 identifies two additional Pennsylvania -listed plants that occur on the LGS site. The 38 PFBC (2011 b) identified one reptile -the eastern redbelly turtle (Pseudemys rubriventris)-as 39 occurring in the vicinity of the LGS site. Federally and Pennsylvania -listed species are 40 discussed in more detail below. 41 Table 2-4 identifies the Federally and Pennsylvania -listed species that occur or have the 42 potential to occur in the action area. The three Federally listed species appear in bold. The 43 staff compiled this table from the FWS's online species search by county (FWS 2012a); the 44 Pennsylvania Natural Heritage Program (PNHP)'s online species database (PNHP 2012 a); and 45 correspondence with the F WS (2011), the PGC (2011), the PFBC (2011 b), and the 46 PDCNR (2011). The NRC staff did not identify any proposed species, proposed critical habitat, 47 Purpose and Need for Action 2-58 or designated critical habitat in the action area. In its correspondence with the NRC, the 1 FWS (2011) also did not identify these categories of species or habitats. The Pennsylvania 2 Endangered Species Program does not designate insects or spiders as Pennsylvania 3 endangered or threatened; therefore, no insects or spiders appear in Table 2-4. 4 Table 2-4. Federally and Pennsylvania -listed Terrestrial Species 5 Scientific Name Common Name Federal Status(a) State Status (b) County(ies) of Occurrence(c) Amphibians Acris crepitans northern cricket frog
- PE B, C, M Lithobates sphenocephalus utricularius southern leopard frog - PE B, C Pseudacris kalmi New Jersey chorus frog - PE B, M Scaphiopus holbrookii eastern spadefoot - PE B Birds Ardea alba great egret - PE M(e) Asio flammeus short-eared owl - PE B Asio otus long-eared owl - PT C Bartramia longicauda upland sandpiper - PT B, C, M Botaurus lentiginosus American bittern - PE C Cistothorus platensis sedge wren - PE B, C Dendroica striata blackpoll warbler - PE M(e) Empidonax flaviventris yellow-bellied flycatcher - PE M(e) Falco peregrinus peregrine falcon - PE B Haliaeetus leucocephalus bald eagle - PT B, C, M Ixobrychus exilis least bittern - PE C Nyctanassa violacea yellow-crowned night
-heron - PE M Nycticorax nycticorax black-crowned night -heron - PE C Pandion haliaetus osprey - PT B, C Rallus elegans king rail - PE C Spiza Americana dickcissel
- PE C Mammals Cryptotis parva least shrew - PE C Myotis leibii eastern small
-footed myotis
- PT B Myotis sodalist Indiana bat FE PE B, C, M (d) Plants Andropogon gyrans Elliott's beardgrass - PR B, C, M Arabis missouriensis Missouri rock
-cress - PE M Arabis patens spreading rock -cress - PT B, C, M Purpose and Need for Action 2-59 Scientific Name Common Name Federal Status(a) State Status (b) County(ies) of Occurrence(c) Cuscuta campestris dodder - PT B, C, M Cyperus schweinitzii Schweinitz's flatsedge
- PR C, M Ilex opaca American holly - PT B, C Iris prismatica slender blue Iris - PE B, C, M Isotria medeoloides small-whorled pogonia FT PE C Ranunculus fascicularis tufted buttercup - PE C, M Rotala ramosior tooth-cup - PR B, C, M Viburnum nudum wild raisin - PE B, C, M Reptiles Glyptemys muhlenbergii bog turtle FT PE B, C, M Opheodrys aestivus rough green snake - PE C Plestiodon laticeps broadhead skink - PC C Pseudemys rubriventris eastern redbelly turtle - PT B, C, M (a)Federal status determined by the FWS under the authority of the Endangered Species Act; FE = endangered, FT = threatened, - = not listed.
(b)Commonwealth of Pennsylvania status determined by the PDCNR, PGC, and PFBC under the Pennsylvania Endangered Species Program; PE = endangered, PT = threatened, PR = rare (plants), PC = candidate (amphibians and reptiles). (c)The LGS site lies in Montgomery County; the in -scope transmission lines traverse Montgomery and Chester Counties; and the offsite facilities associated with the LGS makeup water system lie in Montgomery and Bucks Counties. B = Bucks County, C = Chester County, M = Montgomery County. (d)The FWS (2012a) identifies the species as occurring in Montgomery, Chester, or Bucks Counties; however the PNHP (2012a) does not identify the Indiana bat as occurring in any of these three counties. (e)The PNHP (2012a) does not identify the great egret, blackpoll warbler, or yellow -bellied flycatcher as occurring in Montgomery County. However, according to Exelon's Wildlife Management Plan (Exelon 2010a), Normandeau staff has observed these species on the LGS site. Sources: FWS 2011, 2012a; PDCNR 2011; PGC 2011; PFBC 2011b; PNHP 2012a In addition to the species listed in the Table 2-4, the NRC identified an additional 1 14 Pennsylvania -listed amphibians, birds, and reptile species and about 100 additional plant 2 species that occur within Montgomery, Chester, or Bucks Counties (PNHP 2012 a). The table 3 does not include these species, and this section does not consider these species further 4 because the PGC, PFBC, and PDCNR, which oversee the recovery efforts of 5 Pennsylvania -listed species, did not identify these species as occurring in the action area in 6 correspondence with Exelon or the NRC (PDCNR 2011, PFBC 2011b, PGC 2011 ). 7 Species and Habitats Protected under the Endangered Species Act 8 Bog Turtle (Glyptemys muhlenbergii ) 9 The FWS listed the northern population of the bog turtle, which occurs from New York and 10 Massachusetts south to Maryland, as threatened under the ESA in 1997 (62 FR 59605). The 11 FWS has not designated critical habitat for this species (FWS 2012 a). This species is also 12 listed as endangered by the PFBC. 13 The bog turtle is one of the smallest turtles in North America. Its upper shell is 3 to 4 in. 14 (8 to 10 cm) long and light brown to black in color. Each side of its black head has a distinctive 15 Purpose and Need for Action 2-60 patch of color that is bright orange to yellow. The bog turtle is diurnal and semiaquatic; it 1 forages on land and in water for its varied diet of insects and other invertebrates, frogs, plants, 2 and carrion. In Pennsylvania, the bog turtle usually is active from late March through late 3 September and hibernates the remainder of the year under water in soft mud and crevices. Bog 4 turtles construct nests in sphagnum moss or on tussock sedges, which allows them to deposit 5 eggs above the wetland inundation level. Females lay one to six eggs in June and July. Eggs 6 incubate unattended for 6 to 8 weeks, which often leaves them vulnerable to mice, raccoons, 7 skunks, foxes, birds, and other predators. Young hatch during late August through early 8 September (FWS 2001 , 2010). 9 Northern bog turtles primarily inhabit early to mid -successional wetlands fed by groundwater or 10 associated with the headwaters of streams and dominated by emergent vegetation (spring 11 seeps and open marshy meadows) (FWS 2001). These habitats typically have shallow, cool, 12 slow-flowing water, early to mid -successional vegetation, open canopies, and wet meadows of 13 sedges (Carex spp.) (FWS 2001, PADEP 2006 b). The species is also associated with spike 14 rushes (Eleocharis spp.) and bulrushes (Juncus spp. and Scirpus spp.) (FWS 2001, 15 PADEP 2006 b). The species' continued existence is threatened by loss and fragmentation of 16 wetlands; hydrologic alterations that affect groundwater and surface water quantity and quality; 17 livestock grazing and associated nutrient loading; habitat alterations associated with invasive 18 plant species; and illegal collection and trade (FWS 2010). 19 In Pennsylvania, the bog turtle occurs in the southeastern part of the state. As of 2000, the 20 FWS (2001) identified 14 Pennsylvania counties (including Montgomery, Chester, and Bucks 21 Counties) with extant populations on bog turtles (FWS 2001). Two additional counties 22 historically contained bog turtles, and the FWS (2001) considers a third county's population 23 extirpated. In total, the FWS (2001) identified 75 extant populations, many of which occur within 24 the Delaware River and Susquehanna River watersheds. 25 None of the available surveys or reports of the LGS site (described in the first paragraph of this 26 section; AEC 1973; Exelon 2010 a, 2011 a; NRC 1984; WHC 2006) identified the bog turtle as 27 occurring on the LGS site. However, no bog turtle habitat (Phase 1) surveys have been 28 completed in the action area. Small sections of the LGS site along the Schuylkill River contain 29 palustrine emergent and forested wetlands. Wetlands also occur along each of the 30 transmission line corridors. Thus, the species may occur within suitable wetland habitat in these 31 areas. 32 Indiana Bat (Myotis sodalis) 33 The FWS listed the Indiana bat as endangered wherever found in 1967 under the Endangered 34 Species Preservation Act of 1966, the predecessor regulation to the ESA (32 FR 4001). The 35 FWS has not designated critical habitat for the species in Pennsylvania (41 FR 41914). This 36 species is also listed as endangered by the PGC. 37 The Indiana bat is an insectivorous, migratory bat that occurs within the central portion of the 38 eastern United States and hibernates colonially in caves and mines. Menzel et al. (2005) 39 concluded that habitat use is highly correlated with insect abundance, which means that Indiana 40 bats often forage in riparian areas where insect densities are highest. Menzel et al. (2005) also 41 found that Indiana bats were more closely associated with linear landscape features (forest 42 corridors and roads) than open areas (agricultural land, grasslands, or meadows). 43 Reproductive females migrate and form maternity colonies in wooded riparian areas, 44 bottomlands, floodplains, wetlands, and upland areas. Males and nonreproductive females may 45 stay close to their hibernation site or migrate to summer habitat, but they do not roost in 46 colonies. Indiana bats create roosts in the exfoliating bark of large (often dead) trees. Both 47 males and females return to hibernation sites in late summer or early fall to mate and enter 48 Purpose and Need for Action 2-61 hibernation. Destruction and degradation of caves from mining, tourism, and physical barriers 1 (such as construction of doors or gates) threaten hibernation habitat (FWS 2007 a). Loss and 2 degradation of forest habitat, which affects migration pathways, maternity roosts, and breeding 3 areas, also has contributed to the decline of the species (FWS 2007 a). 4 The PGC (2010) reports that about 1,000 Indiana bats hibernate in 18 sites within 5 11 Pennsylvania counties. The PGC (2010) also has identified nine summer maternity sites in 6 seven counties. According to the draft Indiana bat draft recovery plan (FWS 2007 a), no 7 hibernation or maternity sites occur in Montgomery, Chester, or Bucks Counties. The closest 8 hibernation site is north of the LGS site in Luzerne County, and the closest maternity colony to 9 the LGS site is in Berks County, which borders the northwest edges of Montgomery and 10 Chester Counties (FWS 2007 a, PGC 2010). 11 None of the available surveys or reports of the LGS site (described in the first paragraph of this 12 section; AEC 1973; Exelon 2010 a, 2011 a; NRC 1984; WHC 2006) identified the Indiana bat as 13 occurring on the LGS site. No FWS-qualified Indiana bat surveyor has conducted formal 14 surveys on the site, and the NRC staff did not identify any other ecological studies that would 15 provide information on the Indiana bat in the action area. Based on the species' historic 16 distribution (FWS 2007 a) and the lack of records for the action area, the NRC staff cannot 17 preclude the potential presence of the Indiana bat in the action area. Therefore, the NRC staff 18 assumes that the species may occur in areas of suitable habitat within the action area. 19 Small-Whorled Pogonia (Isotria medeoloides ) 20 The FWS listed the small -whorled pogonia as threatened wherever found in 1982 21 (47 FR 39827). The FWS has not designated critical habitat for this species (FWS 2012b). This 22 species is also listed as endangered by the PDCNR. 23 The small-whorled pogonia is a small, herbaceous, perennial orchid. Its primary range extends 24 through the Atlantic seaboard states, but it also occurs in adjacent states, including 25 Pennsylvania. The species generally grows in young and maturing stands of mixed -deciduous 26 or mixed-deciduous/coniferous forests that are in second- or third-growth stages of succession. 27 The species inhabits areas with sparse to moderate ground cover, a relatively open understory, 28 or areas in proximity to logging roads, streams, or other features that create long -persisting 29 breaks in the forest canopy. In the northern part of its range, it has been associated with the 30 following canopy species that are also prevalent in the action area: red maple (Acer rubrum), 31 northern red oak (Quercus rubra), and American beech (Fagus grandifolia) (see Section 2.2.7). 32 Throughout its range, the small -whorled pogonia is associated with understories containing red 33 maple and oak species (Quercus spp.) (FWS 1992). Habitat destruction, disease, and 34 predation by deer and rabbits threaten the species' continued existence (FWS 1992, 2008). 35 None of the available surveys or reports of the LGS site (described in the first paragraph of this 36 section; AEC 1973; Exelon 2010 a, 2011 a; NRC 1984; WHC 2006) identified the small -whorled 37 pogonia as occurring on the LGS site. However, PECO conducted the last botanical surveys of 38 the site before construction of LGS, and the FES for operation of LGS (NRC 1984) indicates 39 that PECO did not complete any surveys along the transmission line corridors before its 40 construction. During its license renewal application review, the staff did not identify any 41 ecological surveys or studies of the transmission line corridors or the offsite facilities within the 42 action area since LGS began operating that might provide additional information about the 43 occurrence of the small -whorled pogonia within the action area. 44 As of 2007, FWS (2008) reported three extant populations in Pennsylvania and an additional six 45 populations that were historic, extirpated, or of unknown status. Historic population occurred in 46 both Montgomery and Berks Counties (FWS -PA 2012). Both the PNHP online species 47 Purpose and Need for Action 2-62 database (PNHP 2012 a) and the FWS Pennsylvania Field Office W eb site (FWS-PA 2012) 1 indicate that the species occurs in Chester County. The NRC did not identify any more specific 2 information on the location of the three extant populations; therefore, the NRC assumes that the 3 species has the potential to occur in the action area in areas of suitable habitat along or near 4 the transmission line corridor that runs through Chester County. 5 Species Protected under the Bald and Golden Eagle Protection Act 6 The Bald and Golden Eagle Protection Act of 1940, as amended, prohibits anyone from taking 7 bald eagles (Haliaeetus leucocephalus) or golden eagles (Aquila chrysaetos), including their 8 nests or eggs without an FWS -issued permit. The term "take" in the Act is defined as, among 9 other things, to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, destroy, 10 molest, or disturb (50 CFR 22.3). "Disturb" means, among other things, to take action that 11 (1) causes injury to an eagle; (2) decreases its productivity or nest abandonment , by 12 substantially interfering with breeding, feeding, or sheltering behavior (50 CFR 22.3). 13 Pennsylvania maintains a Bald Eagle Management Plan (Gross and Brauning 2010), which lays 14 out management goals and objectives to increase the number of successful nesting pairs and to 15 delist the bald eagle from Pennsylvania -threatened to a secure, protected status. As of 2009, 16 the PGC identified 174 active nests that produced 244 young in 48 Pennsylvania counties. In 17 the same year, the PGC recorded three active nests in Bucks County, three in Chester County, 18 and one in Montgomery County. Data from the 2008 FWS midwinter bald eagle survey indicate 19 that the bald eagle is also present in Bucks and Chester Counties in the winter months (Gross 20 and Brauning 2010). 21 Species Protected under the Migratory Bird Treaty Act 22 The FWS administers the Migratory Bird Treaty Act of 1918, as amended (MBTA), which 23 prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. The MBTA 24 definition of a "take" differs from that of the ESA. Under the MBTA, take means to pursue, hunt, 25 shoot, wound, kill, trap, capture, or collect, or any attempt to carry out these activities 26 (50 CFR 10.12). Unlike a take under the ESA, a take under the MBTA does not include habitat 27 alteration or destruction. The MBTA protects a total of 1,007 migratory bird species 28 (75 FR 9282). Of these 1,007, the FWS allows for the legal hunting of 58 species as game 29 birds (FWS undated). Within Pennsylvania, the PGC manages migratory bird hunting seasons 30 and associated licenses for woodcock, pheasant, ruffed grouse, and a number of waterfowl 31 species. All Federally and Pennsylvania -listed bird species that appear in Tables 2-4 and 2-5 32 are protected under the MBTA. Additionally, the MBTA protects all U.S. -native bird species that 33 belong to the families, groups, or species listed at 50 CFR 10.13. 34 Species Protected by the Commonwealth of Pennsylvania 35 This section only discusses those Pennsylvania -listed species from Table 2-4 for which the 36 NRC has specific occurrence information within the action area. The remaining species in the 37 table have the potential to occur in the action area, but were not identified during early surveys 38 of the site (AEC 1973, NRC 1984), or in subsequent reports (Exelon 2010 a, 2011a), or were not 39 identified as species of specific concern in correspondence with the PDCNR (2011), 40 PGC (2011), or PFBC (2011 b) regarding the proposed LGS license renewal. 41 Birds 42 Normandeau conducted bird surveys on the LGS site from 1972 to 1985. Since 1985, 43 Normandeau has maintained a running checklist of bird species on the site (Exelon 2010 a). 44 Normandeau has identified 10 state -listed bird species. These species and their habitat 45 requirements appear in Table 2-5. Because more recent occurrence information is based on 46 Purpose and Need for Action 2-63 Normandeau's running checklist, the year in which each bird species was last observed is not 1 available (Exelon 2010 a). 2 Table 2-5. Pennsylvania -listed Bird Species in the Action Area 3 Species Habitat American bittern (Botaurus lentiginosus) dense freshwater marshes; wet meadows bald eagle (Haliaeetus leucocephalus ) riparian areas near rivers or open water bodies black-crowned night heron (Nycticorax nycticorax ) coastlines; swamps; river and stream riparian areas; canals; wet agricultural fields blackpoll warbler (Dendroica striata ) second-growth scrub; woodlands; dense conifer forests great egret (Ardea alba ) marshes; river margins; lakeshores; coastal swamps; lagoons least bittern (Ixobrychus exilis) dense marshland containing cattails and reeds osprey (Pandion haliaetus ) lakes, ponds, rivers, and other open water bordered by trees peregrine falcon (Falco peregrines ) cliffs, buildings, and other high structures overlooking rivers yellow-bellied flycatcher (Empidonax flaviventris ) shady coniferous forests and forested wetlands at higher elevations; mossy, poorly drained swamps and bogs yellow-crowned night heron (Nyctanassa violacea ) small, shallow streams often associated with sycamores Plants 4 The PDCNR (2011) identified eight Pennsylvania -listed plants that occur along or near the 5 transmission line corridors. None of the available surveys or reports (AEC 1973; Exelon 2010 a , 6 2011 a; NRC 1984; WHC 2006) indicate that these species occur on the LGS site; however, two 7 additional Pennsylvania -listed plants occur on the LGS site. Exelon's Wildlife Management Plan 8 (Exelon 2010 a) identifies American holly (Ilex opaca) and wild raisin (Viburnum nudum var. 9 cassinoides), which are Pennsylvania -listed as threatened and endangered, respectively, as 10 having been identified on the site in 1978 during surveys associated with the construction of 11 LGS. The continued occurrence of these species on the site today cannot be confirmed 12 because no vegetation surveys have been completed on the site since the 1970s. 13 American Holly (Ilex opaca ). American holly is an evergreen shrub or small tree that grows to 14 15 m (50 ft) in height. The species grows on wooded slopes and streambanks from coastal 15 New England south and west into Florida and Texas (PNHP 2007a). Exelon's ER 16 (Exelon 2011b) and the LGS Wildlife Management Plan (Exelon 2010 a) identify American holly 17 as having occurred on the LGS site in 1978 during surveys associated with the construction of 18 the LGS. The continued occurrence of this species on the site today cannot be confirmed 19 because no vegetation surveys have been completed on the site since the 1970s. A 2007 20 PNHP Pennsylvania distribution map does not indicate that the species occurs within 21 Montgomery, Chester, or Bucks Counties (PNHP 2007a). 22 Purpose and Need for Action 2-64 Dodder (Cuscuta campestris ). Dodder is an annual stem parasitic plant that lacks normal roots 1 and leaves, but bears flowers and fruits that inhabit thickets and waste ground. In its 2 correspondence with Exelon, the PDCNR (2011) indicated that this species occurs in an old 3 impounding basin near the Schuylkill River along the 220 -63 and 220 -64 transmission line 4 corridors. 5 Elliott's Beardgrass (Andropogon gyrans ). Elliott's beardgrass is an erect, bunched, perennial 6 grass that may grow to 3 ft (1 m) in height. It grows in dry to damp grasslands, clearings, open 7 slopes, and successional old fields from New Jersey to Illinois and south into Florida and Texas 8 (PNHP 2011a). Though it has not been identified on the LGS site, a 2011 PNHP Pennsylvania 9 distribution map indicates that the species occurs in southwestern Montgomery County and 10 throughout Chester County (PNHP 2011a). Additionally, in its correspondence with Exelon, the 11 PDCNR (2011) indicated that the species occurs in an old field near the 220 -63 and 220 -64 12 transmission line corridor. 13 Missouri Rock -Cress (Arabis missouriensis ). Missouri rock -cress is an herbaceous biennial 14 from a taproot, with stems 2 to 5 cm (0.8 to 2 in.) high. The species occurs on dry slopes 15 across the central and eastern United States (NatureServe 2010a, PDCNR 2011). In its 16 correspondence with Exelon, the PDCNR (2011) indicated that Missouri rock -cress occurs on a 17 dry forested slope with scattered outcrops of Brunswick red shale located just east of the 220 -60 18 and 220-61 transmission line corridors. 19 Schweinitz's Flatsedge (Cyperus schweinitzii ). Schweinitz 's flatsedge is a grass -like perennial 20 with stems 10- to 40-cm (4- to 16-in.) high. The species occurs on dry or moist sand flats and 21 dunes across much of the continental United States (NatureServe 2010b, PDCNR 2011). In its 22 correspondence with Exelon, the PDCNR (2011) indicated that Schweinitz 's flatsedge occurs in 23 association with tooth -cup (described below) in a wet wooded area along the west side of the 24 Schuylkill River near the 220 -60 and 220 -61 transmission line corridors. 25 Slender Blue Iris (Iris prismatica ). Slender blue iris is a tall perennial forb with grass -like leaves 26 and dark purple flowers. The species occurs in moist meadows and sandy or gravelly shores 27 throughout the eastern seaboard of the United States from Maine to Georgia 28 (NatureServe 2010c, PDCNR 2011). In its correspondence with Exelon, the PDCNR (2011) 29 indicated that the species occurs on gently sloping land, open with scattered red maples in a 30 mossy floodplain of Perkiomen Creek near the 220 -62 and 5031 transmission line corridors. 31 Spreading Rock-Cress (Arabis patens ). Spreading rock -cress is a slender, perennial herb. It 32 occurs in moist, rocky woods over much of the central and southeastern portions of the eastern 33 United States (NatureServe 2010d, PDCNR 2011). In its correspondence with Exelon, the 34 PDCNR (2011) indicated that spreading rock -cress occurs in moist, shaded northwest -facing 35 rock faces near the 220 -60, 220-61, 220-62, 220-63, and 220 -64 transmission line corridors. 36 Tooth-Cup (Rotala ramosior ). Tooth-cup is a small annual herb that has smooth stems that may 37 grow up to 12 in. (30 cm) in height. It grows on exposed shorelines, stream margins, streambed 38 outcrops, and other damp, open places across much of the continental United States 39 (PNHP 2011b). A 2011 PNHP Pennsylvania distribution map indicates that the species occurs 40 in the Schuylkill River watershed between Montgomery and Chester Counties (PNHP 2011 b). 41 In its correspondence with Exelon, the PDCNR (2011) indicated that the species occurs in a wet 42 wooded stretch along the west side of the Schuylkill River near the 220 -60 and 220 -61 43 transmission line corridor s and on an exposed mud flat and sandy -cobbly shores of seasonally 44 flooded shallow basins near the 220 -63 and 220 -64 transmission line corridors. 45 Tufted Buttercup (Ranunculus fascicularis). Tufted buttercup is a small perennial forb with 46 five-petal yellow flowers. It inhabits dry, thick woods and exposed calcareous slopes and edges 47 Purpose and Need for Action 2-65 across the central and eastern United States (NatureServe 2010e). In its correspondence with 1 Exelon, the PDCNR (2011) indicated that the species occurs in a ridgetop glade in a state park 2 near the 220 -62 and 5031 transmission line corridors. 3 Wild Raisin (Viburnum nudum var. cassinoides). Wild raisin (also called possum -haw) is a 4 deciduous shrub or small tree that grows up to about 12 ft (4 m) in height. The species inhabits 5 swamps, wet thickets, and pond margins from New York west and south into Texas and Florida 6 (PNHP 2007 b). The LGS Wildlife Management Plan (Exelon 2010 a) identifies wild raisin as 7 having occurred on the LGS site in 1978 during surveys associated with construction of LGS. 8 The continued occurrence of this species on the site today cannot be confirmed because no 9 vegetation surveys have been completed on the site since the 1970s. A 2007 PNHP 10 Pennsylvania distribution map indicates that the species occurs in southwestern Montgomery 11 County, northern Chester County, and central Bucks County (PHNP 2007b). 12 Reptiles 13 Eastern Redbelly Turtle (Pseudemys rubriventris ). The eastern redbelly turtle is one of 14 Pennsylvania 's largest turtles. It occurs in large water bodies including lakes, ponds, marshes, 15 slow-moving rivers, and creeks from New York to North Carolina (PNHP 2007 c). Redbelly 16 turtles prefer areas with deeper water with sandy or muddy substrate and aquatic vegetation in 17 proximity to basking sites. Females nest in upland habitat within 100 m (330 ft) of water. A 18 2007 PNHP Pennsylvania distribution map indicates that the species occurs throughout 19 Montgomery, Bucks, and Chester Counties. In its correspondence with the NRC, the PFBC 20 (2011 b) noted that the eastern redbelly turtle occurs in the vicinity of the LGS site. 21 2.2.9. Socioeconomics 22 This section describes current socioeconomic factors that have the potential to be directly or 23 indirectly affected by changes in operations at LGS. LGS and the communities that support it 24 can be described as a dynamic socioeconomic system. The communities provide the people, 25 goods, and services required to operate the nuclear power plant. Power plant operations, in 26 turn, provide wages and benefits for people and dollar expenditures for goods and services. 27 The measure of a communities' ability to support LGS operations depends on the ability of the 28 community to respond to changing environmental, social, economic, and demographic 29 conditions. 30 The socioeconomic region of influence (ROI) is defined by the area where LGS employees and 31 their families reside, spend their income, and use their benefits, thereby affecting the economic 32 conditions of the region. The ROI consists of a three -county area (Montgomery, Chester, and 33 Berks Counties), where approximately 84 percent of LGS employees reside. 34 Exelon employs a permanent workforce of 821 full time workers at LGS (Exelon 2011b). As 35 previously discussed, approximately 84 percent live in Montgomery, Berks, and Chester 36 Counties (see Table 2-6). Most of the remaining 16 percent of the workforce are divided 37 among 12 counties across Pennsylvania and other states, with numbers ranging from 1 to 38 35 employees per county. Given the residential locations of LGS employees, the most 39 significant impacts of plant operations are likely to occur in Montgomery, Berks, and Chester 40 Counties. The focus of the socioeconomic impact analysis in this SEIS is therefore on the 41 impacts of continued LGS operations on these three counties. 42 Purpose and Need for Action 2-66 Table 2-6. Limerick Generating Station, Employee Residence by County 1 County Number of Employees Percentage of Total Pennsylvania Montgomery 339 41 Berks 249 30 Chester 105 13 Delaware 35 4 Bucks 18 2 Lancaster 18 2 Lehigh 13 2 Other 31 4 Other States 13 2 Total 821 100 Source: Exelon 2011a Refueling outages at LGS normally occur at 24 -month intervals. During refueling outages, site 2 employment increases by as many as 1,400 temporary workers for approximately 20 to 30 days 3 (Exelon 2011b). Most of these workers are assumed to be located in the same geographic 4 areas as LGS employees. The following sections describe the housing, public services, offsite 5 land use, visual aesthetics and noise, population demography, and the economy in the 6 socioeconomic ROI surrounding LGS. 7 2.2.9.1. Housing 8 Table 2-7 lists the total number of occupied and vacant housing units, vacancy rates, and 9 median value in the two -county ROI. According to American Community Survey estimates, 10 there were approximately 683,000 housing units in the socioeconomic region, of which 11 approximately 648,000 were occupied. The median value of owner -occupied housing units in 12 the socioeconomic region was: Berks County, $175,700; Chester County, $350,500; and 13 Montgomery County, $295,300. All three counties had a homeowner vacancy rate of less than 14 2 percent (USCB 2011). 15 Table 2-7. Housing in Berks, Chester, and Montgomery Counties in 2010 16 Berks Chester Montgomery ROI Total 164,861 192,614 325,733 683,208 Occupied housing units 155,329 184,160 308,233 647,722 Vacant units 9,532 8,454 17,540 35,526 Vacancy rate (percent) 1.2 1.2 1.6 1.3 Median value (dollars)
- 175,700 350,500 295,300 273,833 Key: *estimated.
Source: USCB, 2011; 2010 American Community Survey 1 -Year Estimates
Purpose and Need for Action 2-67 2.2.9.2. Public Services 1 This section presents information regarding public services including water supply, education, 2 and transportation. 3 Water Supply 4 The discussion of public water supply systems is limited to major municipal water systems in 5 Berks, Chester, and Montgomery Counties. Information about municipal water suppliers in 6 these counties, their average daily production, system capacity, and population served are 7 presented in Table 2-8. 8 Berks County is served by 75 water systems, with the Reading Area Water Authority serving the 9 largest population at 87,000 (EPA 2012a). Water for this surface water system is primarily 10 drawn from Lake Ontelaunee, a reservoir built and owned by the city of Reading. The system 11 storage capacity is approximately 76 million gallons (Exelon 2011b). 12 Chester County is served by 83 water systems, with the Pennsylvania American Water 13 Company serving the largest population at 44,000 (EPA 2012a). Montgomery County is served 14 by 39 water systems, with Aqua Pennsylvania, Inc., serving the largest population at 785,000 15 (EPA 2011). 16 LGS withdraws water primarily from the Schuylkill River; however, the specific water source(s) 17 from which LGS makeup water may be withdrawn at any particular time is subject to conditions 18 and limitations established by the DRBC. The DRBC has jurisdiction over withdrawals and uses 19 of water in the Delaware River Basin, which includes the Schuylkill Valley Subbasin where LGS 20 is located (Exelon 2011b). 21 Purpose and Need for Action 2-68 Table 2-8. Public Water Supply Systems in Berks, Chester, and Montgomery Counties 1 (in million gallons per day [mgd]) 2 Water Supplier Primary Water Source Average Daily Production (mgd) System Capacity (mgd) Population Served Berks County Reading Area Water Authority SW 14.0 40.0 87,000 Paw Penn District GW 2.5 3.7 29,552 Western Berks Water Authority SW 3.5 8.0 25,000 Paw Glen Alsace Division SW 1.4 28.1 23,251 Muhlenberg Township Municipal Authority GW 4.1 8.5 21,000 Chester Count y PA American Water Company Main System SW 2.5 5.8 44,000 PA American Coatesville SW 3.8 8.0 35,600 Aqua PA West Chester SW 5.0 8.0 35,000 Aqua PA Uwchlan SW 2.0 3.2 22,000 Phoenixville Water Department SW 2.5 10.3 16,438 Montgomery County Aqua Pennsylvania Main System SW 87.6 125.0 784,939 North Penn Water Authority SW 10.0 24.0 82,822 Pennsylvania American Water -Norristown SW 9.6 16.9 91,000 North Wales Water Authority SW 7.4 13.3 68,656 Pottstown Borough water Department SW 6.0 12.0 36,000 Key: Surface Water = SW, Groundwater = GW Sources: EPA 2012; Exelon 2011a Montgomery County has 22 school districts with 155 schools. LGS is located in the Spring -Ford 3 Area School District in Montgomery County, Pennsylvania. The Spring -Ford Area School 4 District has 12 public schools and had a total enrollment of approximately 7,700 students in 5 2010-2011 (PDE 2011). Berks County has 18 school districts with 108 schools, and Chester 6 County has 12 school districts with 92 schools (NCES 2011). During the 2010 -2011 school 7 year, public school enrollment in Montgomery County was 108,768 students, with 70,517 and 8 83,589 students in Berks and Chester Counties, respectively (PDE 2011). 9 Transportation 10 There is a high concentration of Interstates and major roadways in the vicinity of LGS. 11 Highways and other major roadways within a 50 -mi le (80-km) radius of LGS include 12 U.S. Interstates I -78, I-176, I-178, I-276, and I -476, as well as US -30, US-1, and US-422 (known 13 as "the Pottstown Expressway"). US -422 provides a direct link to Philadelphia, to the east. To 14 the west, US -422 connects Reading to Lebanon, Harrisburg, and the Capitol region. 15 Montgomery County is traversed by Interstate Highways I -76 (known as the "Schuylkill 16 Expressway"), I -276 (the East -West Pennsylvania Turnpike), and I -476 (known as the 17 Purpose and Need for Action 2-69 "Northeast Extension of the Pennsylvania Turnpike" north of I -276 and as the "Blue Route" or 1 "Mid-County Expressway" south of I -276). The Northeast Extension can be accessed 2 approximately 15 miles (24.1 km) east of the LGS plant site. I -76, I-276, and I -476 are about 3 15 miles (24.1 km) south of LGS and can be accessed by US-422. 4 The LGS plant site can only be accessed by Evergreen Road, either directly from the Sanatoga 5 exit of US -422 or indirectly from the Limerick Linfield exit of US -422 by several local roads. 6 US-422 runs northwest from the Sanatoga exit through Pottstown Borough and the City of 7 Reading, and then continues west through Berks County. 8 Table 2-9 lists common commuting routes to LGS and average annual daily traffic (AADT) 9 volume values. The AADT values represent traffic volumes for a 24 -hour period factored by 10 both day of week and month of year. 11 Table 2-9. Major Commuting Routes in the Vicinity of LGS, 2010 Average Annual Daily 12 Traffic Count 13 Roadway and Location Annual Average Daily Traffic (AADT) Montgomery County US-422 east of Sanatoga Interchange 49,000 South Pleasantview/Linfield Road, between Evergreen Road and Ridge Pike 1,300-2,500 Linfield Road between Linfield and US -422 6,600 Sanatoga/Limerick Center Road between Evergreen Road and Limerick Road 1,600-1,900 North and South Lewis Road and Main Street from Royersford to US -422 Limerick-Linfield Interchange 14,000 Main Street Royersford from Linfield Road (bridge) 7,000 Evergreen Road 3,000 Berks County PA-82/PA-345 from PA -724 Birdsboro to US -422 8,400 PA 662 North of US -422 from Douglassville 8,900 PA-724 from Birdsboro 5,800-7,000 US-422 East of Douglassville/US-422 West of Douglassville 28,000-36,000 Chester County US-422 West of Armand Hammer Interchange 53,000 PA-100 from PA -23 North to PA -724 17,000-20,000 PA-724 West of PA -100 5,800-7,000 PA-724 East of PA -100 8,900-14,000 Linfield Road (bridge) to Main Street Royersford 5,700 PA-100 South of US -422 25,000 (a) All AADTs represent traffic volume during the average 24 -hour day during 2009. Source: PennDOT 2012 2.2.9.3. Offsite Land Use 14 Offsite land use conditions in Berks, Chester, and Montgomery Counties are described in this 15 section. More than 84 percent of the LGS permanent workforce lives in these three counties. 16 Purpose and Need for Action 2-70 Within the region of the LGS, approximately 44 percent of the land is developed urban or rural 1 land, 32 percent agricultural land, 23 percent woodlands, and 1 percent fresh water bodies 2 (Exelon 2011b). 3 Montgomery County occupies approximately 483 square miles (1,251 square k m) (USCB 2011). 4 Agricultural land is used principally as cropland (68.2 percent) and pasture (20.0 percent). Crop 5 sales (mostly nursery and floriculture products) comprise 63 percent of the total market value of 6 products sold in the county while livestock products (mostly milk, hogs, and cattle) comprise the 7 remaining 37 percent. The number of farms in Montgomery County decreased just over 8 1 percent from 2002 to 2007. Farmland acreage in the county decreased over 13 percent 9 during the same period, and the average size of a farm decreased 12 percent to 58 ac (23 ha) 10 (USDA 2009). 11 Chester County occupies approximately 751 square miles (1,945 square k m) (USCB 2011). 12 Agricultural land is used principally as cropland (70.2 percent) and pasture (18.6 percent). Crop 13 sales (mostly nursery, greenhouse, floriculture, and sod) comprise 73 percent of the market 14 value of agricultural products sold from the county while livestock sales (mostly milk and poultry 15 products) comprise the remaining 27 percent. The number of farms in Chester County 16 decreased from 2002 to 2007 by 9.6 percent. In the same period, the number of farmland acres 17 decreased by less than 1 percent, however, the average size of farms increased by over 18 9 percent to 96 ac (39 ha) (NASS 2009). 19 Berks County occupies approximately 857 square miles (2,220 square k m) (USCB 2011). 20 Agricultural land is used principally as cropland (76.9 percent) and pasture (10.7 percent). 21 Livestock sales (mostly milk and poultry products) comprise 55 percent of the market value of 22 agricultural products sold from the county while crop sales (mostly nursery, greenhouse, 23 floriculture, and sod) comprise the remaining 45 percent. The number of farms in Berks County 24 increased from 2002 to 2007 by 10.2 percent. The number of farmland acres increased nearly 25 3 percent, however, the average size of farms decreased by over 6 percent to 1 12 ac (45 ha) 26 (NASS 2009). 27 Even though population growth is projected to continue, there is ample urban and rural land to 28 accommodate the anticipated growth over the next 20 years. Agriculture will continue to be the 29 major land use outside urban areas. 30 2.2.9.4. Visual Aesthetics and Noise 31 LGS is situated in gently rolling countryside, traversed by numerous valleys containing small 32 creeks or streams that empty into the Schuylkill River. LGS is surrounded by urbanized areas, 33 the Borough of Pottstown being the closest at 1.7 miles. Predominate features of the site 34 include the reactor enclosures, turbine enclosures, two cooling towers (154.2 m high), electrical 35 substations, independent spent fuel storage installation, Schuylkill River Pumphouse, cooling 36 tower blowdown discharge line and associated structures, spray pond (17.2 ac), administrative 37 buildings, and miscellaneous supporting buildings (Exelon 2011b). 38 Noise from nuclear plant operations can be detected off site. Sources of noise at LGS include 39 the turbines and large pump motors. Given the industrial nature of the station, noise emissions 40 from the station are generally nothing more than an intermittent minor nuisance. However, 41 noise levels may sometimes exceed the 55 dBA level that EPA uses as a threshold level to 42 protect against excess noise during outdoor activities (EPA 1974). However, according to EPA 43 this threshold does "not constitute a standard, specification, or regulation," but was intended to 44 provide a basis for State and local governments establishing noise standards (EPA 1974). 45 Purpose and Need for Action 2-71 2.2.9.5. Demography 1 According to the 2010 Census, an estimated 1,365,850 people live within 32.2 km (20 miles) of 2 the LGS plant site, producing a population density of 420 persons per square km 3 (1,087 persons per square mile) (Exel on 2011b). This translates to a Category 4, "least sparse" 4 population density using the GEIS measure of sparseness (greater than or equal to 120 persons 5 per square mile within 20 miles). Approximately 8,311,616 people live within 80.4 km (50 miles) 6 of LGS, which equates to a population density of 409 persons per square km (1,058 persons 7 per square mile) (Exelon 2011b). As the ROI has a population greater than or equal to 8 190 persons per square mile within 80.4 km (50 miles), this translates to a Category 4 (greater 9 than or equal to 190 persons per square mile within 50 miles). Therefore, LGS is classified as 10 being located in a high population area based on the GEIS sparseness and proximity matrix. 11 Table 2-10 shows population projections and growth rates from 1970 to 2050 in Berks, Chester, 12 and Montgomery Counties in Pennsylvania. All counties experienced an increased growth rate 13 during the 2000 to 2010 time period. Montgomery County showed the smallest population 14 increase between 2000 and 2010 (6.6 percent). All three county populations are expected to 15 continue to increase at lower rates in the next decades through 2050. 16 Table 2-10. Population and Percent Growth in Berks, Chester, and Montgomery Counties 17 from 1970 to 2000 and Projected for 2010 -2050 18 Berks Chester Montgomery Year Population Percent Change (a) Population Percent Change (a) Population Percent Change (a) 1970 296,382 - 278,311 - 623,799 - 1980 312,497 5.4 316,660 13.8 643,621 3.2 1990 336,523 7.7 376,396 18.9 678,111 5.4 2000 373,638 11.0 433,501 15.2 750,097 10.6 2010 411,442 10.1 498,886 15.1 799,874 6.6 2020 450,718 9.5 604,385 21.1 854,994 6.9 2030 491,914 9.1 692,054 14.5 888,265 3.9 2040 531,830 8.1 791,610 14.4 936,102 5.4 2050 572,066 7.6 888, 194 12.2 980,298 4.7 (a) Percent growth rate is calculated over the previous decade. Sources: Population data for 1970 through estimated population data for 2009 (USCB 2011); population projections for 2012 to 2030 by Pennsylvania State Data Center, October 2010 (PASDC, 2010); 2040 to 2050 calculated. Demographic Profile 19 The 2010 (estimate) demographic profiles of the three -county ROI population are presented in 20 Table 2-11. In 2010, minorities (race and ethnicity combined) comprised 20.6 percent of the 21 total three -county population. The largest minority populations in the three county area are 22 Hispanic or Latino (7.8 percent) and Black or African American (6.6 percent). 23 Purpose and Need for Action 2-72 Table 2-11. Demographic Profile of the Population in the Limerick Generating Station 1 Socioeconomic Region of Influence in 2010 2 Berks Chester Montgomery Region of Influence Population 411,142 498,886 799,874 1,710,202 Race (Not Hispanic or Latino) - percent of total population White 76.9 82.1 79.0 79.4 Black or African American 4.0 5.9 8.4 6.6 American Indian and Alaska Native 0.1 0.1 0.1 0.1 Asian 1.3 3.9 6.4 4.4 Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0 0.0 Some other race 0.1 0.1 0.2 0.1 Two or more races 1.2 1.4 1.6 1.4 Ethnicity Hispanic or Latino 67,355 32,503 34,233 134,091 Percent of total population 16.4 6.5 4.3 7.8 Total minority 95,036 89,325 168,090 352,451 Percent minority 23.1 17.9 21.0 20.6 Source: USCB 2011 Transient Population 3 Within 50 miles (80 km) of LGS, colleges and recreational opportunities attract daily and 4 seasonal visitors who create demand for temporary housing and services. In 2010, there were 5 approximately 354,728 students attending colleges and universities within 50 miles (80 km) of 6 LGS (NCES 2011). 7 In 2010, all three counties in the direct ROI had a similar percentage of temporary housing for 8 seasonal, recreational, or occasional use; Berks at 0.4 percent, Chester at 0.6 percent and 9 Montgomery at 0.5 percent (USCB 2011). In comparison, the highest percent of temporary 10 housing for seasonal, recreational, or occasional use in the counties located within 50 miles 11 (80 km) of LGS is Monroe County, Pennsylvania, at 16.9 percent (UCSB 2010). Table 2-12 12 provides information on seasonal housing for the 26 counties located all or partly within 50 miles 13 (80 km) of LGS. 14 Purpose and Need for Action 2-73 Table 2-12. Seasonal Housing in Counties Located within 50 Miles (80 Km) of the 1 Limerick Generating Station(a) 2 County Housing Units: Total Vacant Housing Units: For Seasonal; Recreational; or Occasional Use Percent Pennsylvania Berks 164,827 724 0.4 Bucks 245,956 1,536 0.6 Carbon 34,299 5,033 14.7 Chester 192,462 1,064 0.6 Delaware 222,902 621 0.3 Lancaster 202,952 930 0.5 Lebanon 55,592 506 0.9 Lehigh 142,613 663 0.5 Monroe 80,359 13,590 16.9 Montgomery 325,735 1,498 0.5 Northampton 120,363 755 0.6 Philadelphia 670,171 2,22 8 0.3 Schuylkill 69,323 1,360 2.0 York 9,870 1,117 11.3 County Subtotal 2,537,424 31,625 1.2 Maryland Cecil 41,103 1,912 4.7 Harford 95,554 451 0.5 County Subtotal 136,657 2,363 1.7 New Jersey Burlington 175,615 696 0.4 Camden 204,943 551 0.3 Cumberland 55,834 627 1.1 Gloucester 109,796 316 0.3 Hunterdon 49,487 512 1.0 Mercer 143,169 558 0.4 Salem 27,417 150 0.5 Somerset 123,127 173 0.1 Warren 44,925 457 1.0 County Subtotal 934,313 4,040 0.4 Delaware New Castle 217,511 712 0.3 Total 3,825,905 38,740 1.0 (a) Counties within 50 miles (80 km) of LGS with at least one block group located within the 50 -mile (80-km) radius Source: USCB 2011
Purpose and Need for Action 2-74 Migrant Farm Workers 1 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 2 crops. These workers may or may not have a permanent residence. Some migrant workers 3 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 4 Others may be permanent residents near LGS who travel from farm to farm harvesting crops. 5 Migrant workers may be members of minority or low -income populations. Because they travel 6 and can spend a significant amount of time in an area without being actual residents, migrant 7 workers may be unavailable for counting by census takers. If uncounted, these workers would 8 be "underrepresented" in USCB minority and low -income population counts. 9 Information on migrant farm and temporary labor was collected in the 2007 Census of 10 Agriculture. Table 2-13 provides information on migrant farm workers and temporary farm labor 11 (less than 150 days) within 50 miles (80 km) of the LGS. According to the 2007 Census of 12 Agriculture, approximately 6,205 farm workers were hired to work for less than 150 days and 13 were employed on 6,324 farms within 50 miles (80 km) of LGS. Pennsylvania had the largest 14 number of farms hiring workers for less than 150 days (1,212), with Chester County containing 15 the largest number of farms hiring workers for less than 150 days at 580. 16 In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 17 any hired migrant workers, defined as a farm worker whose employment required travel that 18 prevented the migrant worker from returning to their permanent place of residence the same 19 day. A total of 528 farms in the 50 -mile (80-km) radius of LGS reported hiring migrant workers 20 in the 2007 Census of Agriculture. Chester County, Pennsylvania, hired the largest number of 21 migrant workers at 101, followed by Cumberland County, New Jersey (65) (USDA 2011). 22 In the direct ROI, 591 temporary farm workers (those working fewer than 150 days per year) 23 were employed on 458 farms in Berks County; 652 temporary farm workers (those working 24 fewer than 150 days per year) were employed on 580 farms in Chester County; 208 temporary 25 farm workers (those working fewer than 150 days per year) were employed on 105 farms in 26 Montgomery County (USDA 2011). 27 Purpose and Need for Action 2-75 Table 2-13. Migrant Farm Workers and Temporary Farm Labor in Counties Located 1 within 50 Miles (80 Km) of Limerick Generating Station 2 County(a) Number of Farms with Hired Farm Labor(b) Number of Farms Hiring Workers for Less Than 150 days (b) Number of Farm Workers Working for Less Than 150 days (b) Number of Farms Reporting Migrant Farm Labor(b) Pennsylvania Berks 458 180 591 32 Bucks 265 100 375 23 Carbo n 27 12 59 6 Chester 580 233 653 101 Delaware 25 8 15 2 Lancaster 1,716 60 138 7 Lebanon 324 137 317 6 Lehigh 118 44 161 5 Monroe 155 23 66 0 Montgomery 155 71 208 14 Northampton 97 24 89 2 Philadelphia 5 2 (D) 0 Schuylkill 165 100 323 12 York 4 04 218 657 22 County Subtotal 4,494 1,212 3,652 232 Maryland Cecil 128 52 213 5 Harford 155 62 154 12 County Subtotal 283 114 367 17 New Jersey Burlington 217 93 326 39 Camden 52 25 85 17 Cumberland 192 60 230 65 Gloucester 163 57 216 56 Hunterd on 283 144 353 18 Mercer 86 39 102 8 Salem 172 71 248 33 Somerset 132 52 147 6 Warren 169 94 321 27 County Subtotal 1,466 635 2,028 269 Delaware New Castle 81 34 158 10 Total 6,324 1,995 6,205 528 (a) Counties within 50 miles (80 km) of LGS with at least one block group located within the 50 -mile (80-km) radius. (b) Table 7. Hired farm Labor - Workers and Payroll: 2007. (D) - Withheld to avoid disclosing data for individual farms. Source: 2007 Census of Agriculture - County Data (USDA 2009)
Purpose and Need for Action 2-76 2.2.9.6. Economy 1 This section contains a discussion of the economy, including employment and income, 2 unemployment, and taxes. 3 Employment and Income 4 Between 2000 and 2010, the civilian labor force in Berks, Chester, and Montgomery Counties 5 increased slightly. Chester County experienced the highest percentage of growth with 6 10.2 percent (229,469 civilian worker to 252,993), while Berks and Montgomery experienced a 7 similar growth of civilian labor force by 1.4 percent (190,552 civilian workers to 193,364) and 8 2.2 percent (402,653 civilian workers to 411,517 ),respectively (USCB 2000, 2010). 9 In 2010, educational, health, and social services represented the largest sector of employment 10 (24.4 percent) in the ROI followed by manufacturing and (13.2 percent) and professional, 11 scientific, management, administration, and waste management (13 percent). A list of some of 12 the major employers by industry in each county and the ROI area is provided in Table 2-14. 13 Table 2-14. Major Employers by Industry in the LGS ROI in 2010 14 Industry Berks Chester Montgomery Total Percent Total employed civilian workers 193,364 252,993 411,517 857,874 Construction 10,555 12,814 23,472 46,841 5.5 Manufacturing 32,843 33,512 47,202 113,557 13.2 Wholesale Trade 6,246 7,38 4 12,669 26,299 3.1 Retail Trade 21,699 28,157 43,224 93,080 10.9 Transportation, warehousing, and utilities 9,077 8,482 14,631 32,190 3.8 Information 3,462 4,615 9,183 17,260 2.0 Finance, insurance, real estate, rental, and leasing 10,613 24,447 41,825 76,885 9.0 Professional, scientific, management, administrative, and waste management services 16,398 36,113 58,720 111,231 13.0 Educational, health, and social services 49,407 57,072 102, 572 209,051 24.4 Arts, entertainment, recreation, accommodation, and food services 14,904 17,876 26,997 59,777 7.0 Other services (except public administration) 10,856 10,254 17,919 39,029 4.5 Public administration 4,021 5,522 11,353 20,896 13.2 Source: UCSB 2011 The top eight employers in Montgomery County are listed in Table 2 -15. King of Prussia 15 currently houses the largest number of private sector employers (SGP 2007). 16 Purpose and Need for Action 2-77 Table 2-15. Largest Private Sector Employers - Montgomery County - 2007 1 Company Industry Number of Employees Merck & Company Pharmaceutical and Vaccines: Global R&D HQ 12,000 Abington Memorial Hospital Hospitals, General Market and Surgical 5,896 Allied Barton Security Services Security, Integrated Asset Protection 5,160 Northwestern Human Services Outpatient Mental Health and Substance Abuse Centers 4,000 Lockheed Martin Systems Integrations, Systems Engineering, Software Development, and Program Management 3,700 Aetna Managed Care, Health Insurance 3,000 Unisys Information and Technology Solutions and Services 3,400 Citizens Bank Commercial Banking 3,000 Source: SGP 2007 Estimated income information for the socioeconomic ROI and Pennsylvania is presented in 2 Table 2-16. According to the U.S. Census Bureau's 2010 American Community Survey 1-Year 3 Estimates, people living in the ROI had median household and per capita incomes above the 4 state average. Chester County had the highest median household and per capita income 5 among the three counties. Berks County has the highest percentages of persons (14.1 percent) 6 living below the official poverty level when compared to the other two counties and the 7 Commonwealth as a whole. Chester and Montgomery Counties had 6.2 and 5.5 percent, 8 respectively, and the Commonwealth of Pennsylvania as a whole had 13.4 percent. The 9 percentage of families living below the poverty level in Chester and Montgomery Counties 10 (3.6 percent) was lower than the percentage of families in Berks County and the Commonwealth 11 of Pennsylvania as a whole (9.3 percent and 10.9 percent, respectively) (USCB 2011). 12 Table 2-16. Estimated Income Information for the Limerick Generating Station Region of 13 Influence in 2010 14 Berks Chester Montgomery Pennsylvania Median household income (dollars) a 51,719 84,284 75,448 49,288 Per capita income (dollars) a 25,384 40,138 38,792 26,374 Individuals living below the poverty level (percent) 14.1 6.2 5.5 13.4 Families living below the poverty level (percent) 10.9 3.6 3.6 9.3 (a) In 2010 inflation -adjusted dollars. Source: USCB 2011 Unemployment 15 According to the U.S. Census Bureau's 2010 American Community Survey 1 -Year Estimates, 16 the unemployment rates in 2010 were: Berks County, 10.2 percent; Chester County, 17 6.2 percent; and Montgomery County, 7.3 percent. Comparatively, the Commonwealth of 18 Pennsylvania's unemployment rate during the same time period was 9.6 percent (USCB 2011). 19 Purpose and Need for Action 2-78 Taxes 1 Exelon pays real estate taxes directly to local taxing authorities for the parcels of company -2 owned property located within its tax jurisdiction. The taxing authorities include the counties, 3 municipalities, and school districts in which these properties are located. LGS parcels are 4 located only in Montgomery, Chester, and Bucks Counties. There are no LGS parcels located 5 in Berks County. 6 Exelon is the sole owner of the LGS plant site along with the following components of the LGS 7 makeup water supply system, which include the Perkiomen Pumphouse, the Bradshaw 8 Reservoir; the Bradshaw Pumphouse; and the Bedminster Water Processing Facility. PECO, 9 rather than Exelon, owns or has rights to the LGS transmission system beyond the two onsite 10 substations (Exelon 2011b). 11 The discussion of taxes in this section is limited to the taxes paid by Exelon, because taxes paid 12 by PECO for the LGS transmission system would continue, whether or not the LGS operating 13 licenses are renewed. 14 Table 2-17 shows the tax payments made by Exelon for LGS from years 2006 -2010. 15 Table 2-18 lists the 2010 budgets for each of the LGS taxing authorities and the percentages of 16 the 2010 budget represented by LGS tax payments. The budgets are funded through payments 17 made to the local government jurisdictions either directly (e.g., property tax payments) or 18 indirectly (e.g., state tax and revenue -sharing programs). In all cases, the LGS property tax 19 payments represent a small percentage (generally 3.1 percent or less) of the budget for each of 20 the taxing authorities (Exelon 2011b). 21 Currently, Exelon pays the majority of its annual real estate taxes to Limerick 22 Township/Montgomery County and the Spring -Ford Area School District because most of the 23 taxable Exelon -owned LGS assets are located in Limerick Township. Limerick Township 24 provides a portion of these taxes to Montgomery County to fund county services such as county 25 operations, the judicial system, public safety, public works, cultural and recreational programs, 26 human services, and conservation and development programs. Limerick Township property tax 27 revenues fund various operations, including libraries, hospitals, roads, school districts, and fire 28 departments. The Exelon payments to Limerick Township and the Spring -Ford Area School 29 District represent approximately 3.1 percent of the Township's budget and 2.2 percent of the 30 School District's budget, respectively (Exelon 2011b). 31 Real estate taxes paid by Exelon to the following taxing authorities represent less than 32 1 percent of each of their respective budgets: 33 Lower Pottsgrove Township/Montgomery County and the Pottsgrove School 34 District, 35 East Coventry Township/Chester County and the Owen J. Roberts School 36 District, 37 Plumstead Township/Bucks County and the Central Bucks School District, 38 and 39 Bedminster Township/Bucks County and the Pennridge School District. 40 Purpose and Need for Action 2-79 Table 2-17. Limerick Generation Station Tax Distribution, 2006 -2010 1 Calendar Year 2006 2007 2008 2009 2010 Montgomery County Limerick Township 368,376 402,404 479,143 495,044 466,315 Spring-Ford Area School District 2,340,454 2,184,62 7 2,193,537 2,429,533 2,271,282 Lower Pottsgrove Township 1,802 1,849 1,797 1,817 1,804 Pottsgrove School District 10,482 10,943 11,479 11,988 12,271 Total 2,721,114 2,599,823 2,685,956 2,938,382 2,751,672 Chester County Chester County 6,207 6,383 6,383 6,654 6,654 East Coventry Township 2,517 2,517 5,319 5,034 5,035 Owen J. Roberts School District 39,052 40,210 41,770 42,794 43,919 Total 47,776 49,110 53,472 54,482 55,608 Bucks County Plumstead Township 6,481 6,481 6,481 6,481 7,372 Central Bucks School District 21,373 22,178 23,148 24,048 24,971 Bedminster Township 5,097 4,920 4,920 4,920 4,920 Pennridge School District 17,461 18,664 19,484 19,977 20,557 Total 50,412 52,243 54,033 55,426 57,820 Total Taxes 2,819,302 2,701,176 2,793,461 3,048,290 2,865,100 Source: Exelon 2011
Purpose and Need for Action 2-80 Table 2-18. Payment as a Percentage of Taxing Authority 2010 Adopted Budget 1 Taxing Authority 2010 Adopted Budget ($ millions) a LGS Property Tax Payment as Percentage of Budget b Montgomery County Montgomery County - Through Limerick Township 407.7 Less than 0.1% Limerick Township 14.5 3.1% Spring-Ford Area School District 125.5 2.2% Montgomery County - Through Lower Pottsgrove Township 403.9 Less than 0.1% Lower Pottsgrove Townshi p 5.4 Less than 0.1% Pottsgrove School District 56.8 Less than 0.1% Chester County Chester County 420.7 Less than 0.1% East Coventry Township 3.2 Less than 0.1% Owen J. Roberts School District 103.0 Less than 0.1% Bucks County Bucks County
- Through Plumstead Township 460.1 Less than 0.1%
Plumstead Township 4.3 0.17% Central Bucks School District 283.2 Less than 0.1% Bucks County - Through Bedminster Township 460.1 Less than 0.1% Bedminster Township 2.0 0.2% Pennridge School District 111.4 Less than 0.1% (a) Municipal budget is for calendar year; school district budget is for school year 2010 -2011. (b) Percentages are based on 2010 LGS property tax payments shown in Table 2 -17. Source: Exelon 2011a 2.2.10. Historic and Archaeological Resources 2 In accordance with 36 CFR 800.8(c), the NRC has elected to coordinate compliance with 3 Section 106 of the National Historic Preservation Act (NHPA) with steps it has taken to meet its 4 requirements under NEPA. In addition, NUREG -1555 (NRC 2000) provides guidance to staff 5 on how to conduct historic and cultural resource analysis in its environmental reviews. 6 In the context of NHPA, the NRC has determined that the area of potential effect (APE) for a 7 license renewal action is the area at the power plant site and its immediate environment that 8 may be affected by post -license renewal and land -disturbing activities associated with the 9 proposed action (NRC 2011a) The APE may extend beyond the immediate environs in 10 instances where post -license renewal and land -disturbing activities or refurbishment activities 11 Purpose and Need for Action 2-81 specifically related to license renewal may potentially have an effect on historic properties 1 (NRC 2011a). Figure 2-3 shows the area under review. 2 2.2.10.1. Cultural Background 3 This section discusses the cultural background and the known historic and archaeological 4 resources at the LSG site and in the surrounding area. The cultural background for the State of 5 Pennsylvania has been characterized by the staff in the following license renewal environmental 6 impact statements and therefore, will be briefly described in this section: 7 Generic Environmental Impact Statement for License Renewal of Nuclear 8 Plants, Supplement 10, Regarding Peach Bottom Nuclear Reactor, Units 2 9 and 3, January 2003 (NRC 2003) 10 Generic Environmental Impact Statement for License Renewal of Nuclear 11 Plants, Supplement 35, Regarding Susquehanna Steam Electric Station, 12 Units 1 and 2, March 2009 (NRC 2009a) 13 Generic Environmental Impact Statement for License Renewal of Nuclear 14 Plants, Supplement 36, Regarding Beaver Valley Power Station, Units 1 and 15 2, May 2009 (NRC 2009b) 16 Generic Environmental Impact Statement for License Renewal of Nuclear 17 Plants, Supplement 37, Regarding Three Mile Island Nuclear Station, Unit 1, 18 June 2009 (NRC 2009c) 19 The Paleo-Indian Period occurred approximately 10,000 to 15,000 years ago. The 20 Paleo-Indians were hunters and gathers and this period is largely characterized by the Clovis 21 point (NRC 2009a). 22 The Early Archaic Period occurred approximately 3,000 to 10,000 years ago. As the glaciers 23 retreated northward, larger fauna became extinct and people adapted to the resources in the 24 surrounding environment. As the resources improved, the population of the Archaic people 25 increased. Recent archaeological evidence suggests larger populations by the end of the 26 Archaic era (NRC 2009a). 27 The Woodland Period occurred approximately 3,000 years ago until the point of European 28 contact. The Woodland Period is characterized by being dependent on maize agriculture, 29 people living in villages, and the introduction of the bow and arrow for hunting (NRC 2009a). 30 The Late Woodland peoples were known as the Delaware, Nanticoke, Shawnee, Iroquois, and 31 Susquehannock (NRC 2009a). Early Native American contact with European colonists and 32 events associated with that contact make it difficult to associate present -day tribal groups with 33 the territory in the vicinity of the LGS site. The contacts led to tribal movements, alliances with 34 either the French or English, armed conflicts, epidemics, shifting inter -tribal confederacies, and 35 eventual removal, or extinction in some cases, as the European expansion took place 36 (NRC 2003). 37 The historic period can be traced to 1681 when King Charles II granted William Penn a charter 38 for a tract of land running from the Delaware River toward Maryland. William Penn founded the 39 City of Philadelphia, which contained 600 houses by 1685. William Penn also established 40 Chester, Bucks, and Philadelphia Counties in 1682. The earliest colonists were farmers. 41 Milling, distilling, and other processing industries were established along streams. A dramatic 42 increase in the development of political organization and infrastructure can be seen through the 43 period of 1784 to 1870. Because efficient means of transportation were needed to support the 44 movement of settlers westward, turnpikes, canals, and railways were built. 45 Purpose and Need for Action 2-82 The Schuylkill Navigation Company constructed a canal system between Philadelphia and the 1 coal fields of Schuylkill County. The canal opened in 1824 and ran from south of Reading to 2 Parker Ford, following the west bank of the Schuylkill River through land that is currently LGS 3 property. The canal development spurred the farming industry in the area and, from 1857 to 4 1937, a farming and commercial center arose around the locks. Locks 54, 55, and a two -story 5 stone lockkeeper's house (now part of Fricks Lock Historic District) were built by the canal 6 company on property owned by John Frick (Exelon 2011b). 7 The Philadelphia and Reading Railroad, which also passed through land that is now on LGS 8 property, ran along the east bank of the Schuylkill River. It was one of the first railroads built in 9 the Unites States and was completed in 1843. The Reading Company, an owner of the railroad, 10 operated successfully until 1971 when it declared bankruptcy. Another railroad line, the 11 Schuylkill Branch of the Pennsylvania Railroad, was built along the western bank of the river in 12 1884. It served primarily as a commuter line, but was abandoned by the 1950s (Exelon 2011b). 13 2.2.10.2. Historic and Cultural Resources at the Limerick Generating Station Site 14 The following information was used to identify the historic and cultural resources at the LGS 15 site: 16 original construction FES (NRC 1973), 17 original operating FES (NRC 1984), 18 Exelon, Applicant 's Environmental Report, Operating License Renewal State, 19 LGS Units 1 & 2 (Exelon 2011b), 20 site audit (NRC 2012a), 21 LGS, request for additional information (Exelon 2012b), 22 consultation with Pennsylvania BHP, and 23 consultation with trib es. 24 Exelon's ER describes the cultural resources investigations that occurred on the LGS site for 25 the initial construction and operation of LGS Units 1 and 2 (Exelon 2011b). An archaeological 26 survey of the LGS plant site was conducted to identify prehistoric archaeological resources and, 27 as a result, four areas of occupation were identified. Three were located on the western shores 28 of the Schuylkill River, in the vicinity of Fricks Locks, and are identified as 36CH38, 36CH103, 29 and 36CH364. The other site was recorded on the eastern side of the Schuylkill and is 30 recorded as site 36MG37. The artifacts associated with these sites were those associated with 31 the Archaic, Early Woodland, and Middle Woodland cultural periods (Exelon 2011b) 32 On October 5, 1983, the BHP stated that the operations of "LGS would have no effect on 33 significant historic or archaeological resources provided that archaeological surveys/mitigation 34 were undertaken for the proposed transmission lines and provided that measures were taken to 35 mitigate visual impacts to historic sites" (Exelon 2011b). The mitigation measures were 36 reviewed and approved by the BHP. Archaeological surveys were conducted for the five 37 transmission system lines: Lines 220-60, 220-61, 220-62, 220-63/64, and 5031, and the results 38 of these surveys are summarized in Exelon's ER (Exelon 2011b). 39 In 2011 the NRC performed a query of the Pennsylvania Cultural Resources Geographic 40 Information System, a database maintained by the State of Pennsylvania through its BHP office, 41 to identify historic and archaeological resources and their NRHP determinations within the APE 42 and surrounding area. A total of 164 aboveground historic resources and 3 archeological sites 43 are listed on the NRHP in Montgomery County, and 380 aboveground historic resources and 44 6 archeological sites are listed in Chester County. Directly within the APE, the query noted two 45 Purpose and Need for Action 2-83 aboveground historic resources and six archeological sites. All eight sites are located within the 1 LGS owner-controlled area. The six archaeological resource sites are recorded as 36MG37, 2 36CH37, 36CH38, 36CH103, 36CH364, and 36CH382, and date to the prehistoric time period. 3 The aboveground historic resources are recorded as the Fricks Locks Historic District and the 4 Schuylkill Navigation Company Canal, and both could contain associated archaeological 5 material (Exelon 2011 a, 2012b). 6 Site 36MG37 (Underpass Site), a multi -component 44 -acre site, extends along the eastern 7 terrace of the Schuylkill River. The site reflects evidence from the Middle Archaic through 8 Transitional Archaic periods, along with Late Woodland. Because of insufficient data, no 9 determination has been made for eligibility for inclusion in the National Register of Historic 10 Places (NRHP) (Exelon 2012b). 11 Site 36CH37 (Warehouse Field) is located upland to the west of the Schuylkill River. Evidence 12 suggests the site is from the Late and Transitional Archaic period. NRHP eligibility has not been 13 determined (Exelon 2012b). 14 Site 36CH38 (Turkey Point House), an 8-acre prehistoric site, is located on the west side of the 15 Schuylkill River and is commonly referred to as the Turkey Point House site. NRHP eligibility 16 has not been determined (Exelon 2012b) 17 Site 36CH103 (Fricks Lock Site), a 22-acre site, is located on the west terrace of the Schuylkill 18 River, directly east of the Fricks Lock Historic District. It is commonly referred to as the Fricks 19 Lock site. Evidence collected from the site suggests Archaic and Early Woodland occupations. 20 Data recovery was performed at the site; however, the NRHP status is listed as undetermined 21 (Exelon 2012b). 22 Site 36CH364 (Payne #1) is located south of site 36CH103 and is approximately 2 acres. No 23 specific components were noted, other than the site was prehistoric and the NRHP eligibility 24 was undetermined (Exelon 2012b). 25 Site 36CH382 (Locus 25) was recorded through an archaeological survey for transmission 26 line 220-61 and the site is listed as Late Archaic. "Subsurface testing was conducted, but did 27 not provide sufficient data for NRHP eligibility determination" (Exelon 2012b). 28 The Fricks Locks Historic District is 18 acres. Its buildings were built between 1757 and 1937 29 as part of a farming hamlet. The site was listed on the NRHP in 2003 under Criteria A (local 30 historical significance) and C (engineering significance) and the eligibility under Criterion D 31 (information potential) has not been determined (Exelon 2012b). The district contains historic 32 buildings, the Schuylkill Navigation Company's Girard Canal, the filled -in remains of Lock s 54 33 and 55, and the Lock Keeper's House (Exelon 2012b). Currently, Exelon is working with East 34 Coventry Township and Chester County to rehab and mothball the site. The rehabilitation and 35 mothballing activities are specified to meet the Secretary of Interior's Standards for 36 Rehabilitation and construction activity is expected to begin in 2012 (Exelon 2012b). In addition 37 to historic archaeological deposits, prehistoric artifacts have been produced within the 38 boundaries of the Fricks Locks Historic District (Exelon 2012b). 39 The Schuylkill Navigation Company Canal was determined eligible for listing in the NRHP in 40 2003 under Criteria A (local historical significance) and C (engineering significance) 41 (Exelon 2012 b). The 5-mile section of the canal, Locks 52 -53 and Locks 54 -55, originally was 42 part of the 17 -mile-long Girard Lock. "There are several intact remnants of the canal in this 43 NRHP-eligible linear resource. However, the canal prism (channel) and Fricks Locks Historic 44 District are the only canal -related resources recorded within the LGS property" (Exelon 2012b). 45 Purpose and Need for Action 2-84 2.2.10.3. Consultation 1 In September 2011, the NRC initiated consultation on the proposed action with the Advisory 2 Council on Historic Preservation, Pennsylvania's Bureau of Historic Preservation, and 3 15 Federally recognized tribes. An overview of consultation activities that occurred during the 4 preparation of the SEIS is given in Section 4.9.6. 5 2.3. Related Federal and State Activities 6 The staff reviewed the possibility that activities of other Federal agencies might affect the 7 renewal of the operating license for LGS. Any such activity could result in cumulative 8 environmental impacts and the possible need for a Federal agency to become a cooperating 9 agency in the preparation of NRC's SEIS for LGS. 10 There are no Federal projects that would make it necessary for another Federal agency to 11 become a cooperating agency in the preparation of this SEIS. There are no known American 12 Indian lands within 50 miles (80 km) of LGS. The only Federally owned facility within 50 miles 13 (80 km) of LGS is Valley Forge National Park. 14 The NRC is required, under Section 102(2)(c) of NEPA, to consult with and obtain the 15 comments of any Federal agency that has jurisdiction by law or special expertise with respect to 16 any environmental impact involved. The NRC has consulted with the FWS, the NMFS, and the 17 State of Pennsylvania SHPO. Federal agency consultation correspondence is listed in 18 Appendix D. 19 2.4. References 20 7 CFR Part 657. Code of Federal Regulations, Title 7, Agriculture, Part 657, "Prime and unique 21 farmlands." 22 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 23 protection against radiation." 24 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 25 production and utilization facilities." 26 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 27 protection regulations for domestic licensing and related regulatory functions." 28 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing 29 requirements for land disposal of radioactive waste." 30 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and 31 transportation of radioactive material." 32 10 CFR Part 72. Code of Federal Regulations, Title 51, Energy, Part 72, "Licensing 33 requirements for the independent storage of spent nuclear fuel, high -level radioactive waste, 34 and reactor -related greater than Class C waste." 35 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor site 36 criteria." 37 18 CFR Part 410. Code of Federal Regulations, Title 18, Conservation of Power and Water 38 Sources, Part 410, "Basin regulations; water code and administrative manual part III water 39 quality regulations." 40 Purpose and Need for Action 2-85 18 CFR Part 430. Code of Federal Regulations, Title 18, Conservation of Power and Water 1 Sources, Part 430, "Ground water protected area: Pennsylvania." 2 36 CFR Part 800. Code of Federal Regulations. Title 36, Parks, Forests, and Public Property , 3 Part 800, "Protection of historic properties." 4 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of the Environment, Part 50, 5 "National primary and secondary ambient air quality standards." 6 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 7 "Designation of areas for air quality planning purposes." 8 40 CFR Part 112. Code of Federal Regulations, Title 40, Protection of Environment, Part 112, 9 "Oil pollution prevention." 10 40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141, 11 "National primary drinking water regulations." 12 40 CFR Part 143. Code of Federal Regulations, Title 40, Protection of Environment, Part 143, 13 "National secondary drinking water regulations." 14 40 CFR Parts 239-259. Code of Federal Regulations, Title 40, Protection of Environment , 15 Parts 239-259, "Solid (nonhazardous) waste." 16 40 CFR Parts 239-299. Code of Federal Regulations, Title 40, Protection of Environment , 17 Parts 239-299, "Solid wastes" and "Resource Conservation Recovery Act (RCRA)." 18 40 CFR Part 260. Code of Federal Regulations, Title 40, Protection of Environment, Part 260, 19 "Hazardous waste management system: general." 20 40 CFR Parts 260-279. Code of Federal Regulations, Title 40, Protection of Environment , 21 Parts 260-279, "Hazardous waste." 22 40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261, 23 "Identification and listing of hazardous waste." 24 40 CFR Part 262. Code of Federal Regulations, Title 40, Protection of Environment, Part 262, 25 "Standards applicable to generators of hazardous waste." 26 40 CFR Part 266. Code of Federal Regulations, Title 40, Protection of Environment, Part 266, 27 "Standards for the management of specific hazardous wastes and specific types of hazardous 28 waste management facilities." 29 50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, "General 30 provisions." 31 50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, "Eagle 32 permits." 33 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 34 "Interagency cooperation -Endangered Species Act of 1973, as amended." 35 32 FR 4001. U.S. Fish and Wildlife Service. Native fish and wildlife; endangered species. 36 Federal Register 32(48):4001. March 11, 1967. Available at 37 <http://ecos.fws.gov/docs/federal_register/fr18.pdf> (accessed 10 May 2012). 38 41 FR 41914. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants, 39 determination of critical habitat for American crocodile, California condor, Indiana bat, and 40 Florida manatee. Federal Register 41(187):41914 -41916. September 24, 1976. Available at 41 <http://ecos.fws.gov/docs/federal_register/fr115.pdf> (accessed 8 May 2012). 42 Purpose and Need for Action 2-86 47 FR 39827. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants, 1 determination of Isotria medeoloides (small-whorled pogonia) to be an endangered species. 2 Federal Register 47(178):39827 -39831. September 9, 1982. Available at 3 <http://ecos.fws.gov/docs/federal_register/fr621.pdf> (accessed 10 May 2012). 4 62 FR 59605. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; 5 final rule to list the northern population of the bog turtle as threatened and the southern 6 population as threatened due to similarity of appearance. Federal Register 62(213): 7 59605-59623. November 4, 1997. Available at 8 <http://ecos.fws.gov/docs/federal_register/fr3175.pdf> (accessed 10 May 2012). 9 63 FR 31268. U.S. Environmental Protection Agency. Emergency planning and community 10 right-to-know programs; amendments to hazardous chemical reporting thresholds, streamlining 11 requirements; proposed rule. Federal Register 63(109):31268 -31317. June 8, 1998. Available 12 at <http://www.gpo.gov/fdsys/pkg/FR -1998-06-08/pdf/98-14490.pdf> (accessed April 2012). 13 75 FR 9282. U.S. Fish and Wildlife Service. General provisions; revised list of migratory birds. 14 Federal Register 75(39):9282 -9314. March 1, 2010. 15 77 FR 5880. National Oceanic and Atmospheric Administration. Endangered and threatened 16 wildlife and plants; threatened and endangered status for distinct population segments of 17 Atlantic Sturgeon in the Northeast region." Federal Register 77(24):5880 -5912. 18 February 6, 2012. 19 77 FR 17341. U.S. Environmental Protection Agency. Approval and promulgation of air quality 20 implementation plans; Delaware, Maryland, New Jersey, and Pennsylvania; determinations of 21 attainment of the 1997 8 -hour ozone standard for the Philadelphia -Wilmington -Atlantic City 22 moderate nonattainment area. Federal Register 77(58):17341 -17344. March 26, 2012. 23 77 FR 18987. U.S. Environmental Protection Agency. Approval and promulgation of air quality 24 implementation plans; Pennsylvania; nonattainment new source review; fine particulate matter 25 (PM2.5). Federal Register 77(61):18987 -18990. March 29, 2012. 26 17 Pa. Code 45. Pennsylvania Code, Title 17, Conservation and Natural Resources , 27 Chapter 45, "Conservation of Native Wild Plants." January 1, 1988. Pennsylvania Department of 28 Conservation and Natural Resources. 29 25 Pa. Code 92a. Pennsylvania Administrative Code, Part 1, Department of Environmental 30 Protection, Title 25, Environmental Protection, Chapter 92a, "National Pollutant Discharge 31 Elimination System Permitting, Monitoring and Compliance." Available at 32 <http://www.pacode.com/secure/data/025/025toc.html> (accessed 16 May 2012). 33 25 Pa. Code 93. Pennsylvania Administrative Code, Part 1, Department of Environmental 34 Protection, Title 25, Environmental Protection, Chapter 93, "Water Quality Standards." Available 35 at <http://www.pacode.com/secure/data/025/025toc.html> (accessed 16 May 2012). 36 25 Pa. Code 110. Pennsylvania Administrative Code, Part 1, Department of Environmental 37 Protection, Title 25, Environmental Protection, Chapter 110, "Water Resources Planning." 38 Available at <http://www.pacode.com/secure/data/025/025toc.html> (accessed 16 May 2012). 39 25 Pa. Code 127. Pennsylvania Administrative Code, Part 1, Department of Environmental 40 Protection, Title 25, Environmental Protection Chapter 127, "Construction, Modification, 41 Reactivation, and Operations of Sources." Available at 42 <http://www.pacode.com/secure/data/025/chapter127/chap127toc.html > (accessed May 2012). 43 Purpose and Need for Action 2-87 25 Pa. Code 260a. Pennsylvania Administrative Code, Part 1, Department of Environmental 1 Protection, Title 25, Environmental Protection, Chapter 260a, "Hazardous Waste Management 2 System." Available at 3 <http://www.pacode.com/secure/data/025/chapter260a/chap260atoc.html > (accessed 4 April 2012). 5 25 Pa. Code 266b. Pennsylvania Administrative Code, Part 1, Department of Environmental 6 Protection, Title 25, Environmental Protection, Chapter 266b, "Universal Waste Management." 7 Available at <http://www.pacode.com/secure/data/025/chapter266b/chap266btoc.html > 8 (accessed April 2012). 9 25 Pa. Code 271. Pennsylvania Administrative Code, Part 1, Department of Environmental 10 Protection, Title 25, Environmental Protection, Chapter 271, "Municipal Waste Management." 11 Available at <http://www.pacode.com/secure/data/025/chapter271/chap271toc.html> (accessed 12 April 2012). 13 25 Pa. Code 287. Pennsylvania Administrative Code, Part 1, Department of Environmental 14 Protection, Title 25, Environmental Protection, Chapter 287, "Residual Waste Management." 15 Available at <http://www.pacode.com/secure/data/025/chapter287/chap287toc.html > (accessed 16 April 2012). 17 30 Pa. Code 75. Pennsylvania Code, Title 30, Fish and Boat Code, Chapter 75, "Endangered 18 Species." Revised February 9, 1991. Pennsylvania Fish and Boat Commission. 19 34 Pa. Code 133. Pennsylvania Code, Title 34, Game and Wildlife Code, Chapter 133, "Wildlife 20 Classification." Revised December 1, 1990. Pennsylvania Game Commission. 21 42 USC 11001. United States Code, Title 42, The Public Health and Welfare, Chapter 116, 22 Emergency Planning and Community Right -To-Know, Subchapter I, Emergency Planning and 23 Notification, Section 11001, "Establishment of State commissions, planning districts, and local 24 communities." Available at <http://uscode.house.gov/download/pls/42C116.txt > (accessed 25 April 2012). 26 [AEC] U.S. Atomic Energy Commission. 1973. Final Environmental Statement Related to the 27 Proposed Limerick Generating Station Units 1 and 2. Washington, DC: AEC. June 1973. 700 p. 28 ADAMS Accession No. ML11313A215. 29 Albert RC. 1988. The historical context of water quality management for the Delaware Estuary. 30 Estuaries 11(2):99 -107. 31 [BHP] Bureau of Historic Preservation. 2011. Letter from D.C. McLearen, Pennsylvania 32 Historical and Museum Commission Bureau for Historic Preservation, to D.H. Frens, Frens and 33 Frens.
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NRC: Limerick Generating Station Relicensing Project, Fricks Lock Village 34 Rehabilitation and Mothballing, E. Coventry Twp., Chester Co. October 19, 2011. Agencywide 35 Documents Access and Management System (ADAMS) Accession No. ML11318A295. 36 Blye RW. 1973. Relative abundance of bird species during migration. Limerick Generating 37 Station 16 p. ADAMS Accession No. ML12110A231. 38 Bramble WC, Yahner RH, Byrnes WR. 1992. Breeding bird population changes following 39 right-of-way maintenance treatments. Journal of Arboriculture 18(1):23 -32. Available at 40 <http://joa.isa -arbor.com/request.asp?JournalID=1&ArticleID=2476&Type=2> (accessed 41 8 May 2012). 42 Purpose and Need for Action 2-88 Bramble WC, Yahner RH, Byrnes WR. 1997. Effect of herbicides on butterfly populations of an 1 electric transmission right -of-way. Journal of Arboriculture 23(5):196 -206. Available at 2 <http://joa.isa -arbor.com/request.asp?JournalID=1&ArticleID=2775&Type=2 >. Accessed 22 3 August 2012) 4 Clean Air Act of 1963, as amended. 42 U.S.C. §7401 et seq. 5 Clean Water Act of 1972, as amended. 33 U.S.C. §1251 et seq. 6 Collette BB, Klein -MacPhee G, editors. 2002. Bigelow and Schroeder's Fish of the Gulf of 7 Maine. 3rd ed. Washington, DC: Smithsonian Institution Press. 748 p. 8 [CRA] Conestoga -Rovers & Associates. 2006. Hydrogeologic Investigation Report, Fleetwide 9 Assessment Limerick Generating Stations, Pottstown, Pennsylvania. September 2006. ADAMS 10 Accession No. ML12110A228. 11 Crone AJ, Wheeler RL. 2000. Data for Quaternary faults, liquefaction features, and possible 12 tectonic features in the Central and Eastern United States, east of the Rocky Mountain front. 13 Reston, VA: U.S. Geological Survey. Open-File Report 00 -260. 2000. 332
- p. Available at 14 <http://pubs.usgs.gov/of/2000/ofr 0260> (accessed 13 June 2012).
15 Dewey JW, Hopper MG. 2009. "Intensity Distribution and Isoseismal Maps for the Pymatunin g 16 (Northwestern Pennsylvania) Earthquake of 25 September, 1998." January 29, 2009. 17 U.S. Geological Survey, Earthquake Hazards Program. Available at 18 <http://earthquake.usgs.gov/research/groundmotion/field/pymatuning/intensity.php> (accessed 19 6 April 2012). 20 [DRBC] Delaware River Basin Commission. 1961. Delaware River Basin Compact. Available at 21 <http://www.state.nj.us/drbc/about/regulations/ > (accessed 11 May 2012). 22 [DRBC] Delaware River Basin Commission. 1999. Ground Water Protected Area Regulations 23 Southeastern Pennsylvania. June 23, 1999. Available at 24 <http://www.state.nj.us/drbc/about/regulations/> (accessed 16 May 2012). 25 [DRBC] Delaware River Basin Commission. 2001. Comprehensive Plan. July. Available at 26 <http://www.state.nj.us/drbc/about/regulations> (accessed 11 May 2012). 27 [DRBC] Delaware River Basin Commission. 2004. Docket No. D 210 CP 28 (Final)(Revision 12), Exelon Generation Company, LLC Limerick Generating Station Water 29 Supply Modification Demonstration Project and Wadesville Mine Pool Withdrawal and 30 Streamflow Augmentation Demonstration Project, Montgomery, Bucks, Schuylkill, Berks and 31 Chester Counties, Pennsylvania. October 27, 2004. Available at 32 <http://www.nj.gov/drbc/library/documents/D1969 -210CPfinalRev12 -102704.pdf> (accessed 33 11 May 2012). 34 [DRBC] Delaware River Basin Commission. 2009. Interim Methodology for Bioassessment of 35 the Delaware River for the DRBC 2010 Integrated Assessment. July 24, 2009. Available at 36 <http://www.nj.gov/drbc/library/documents/10IntegratedList/Bioassessment -draft-37 July2009rev.pdf > (accessed 22 October 2012). 38 [DRBC] Delaware River Basin Commission. 2011a. Resolution NO. 20011 -12. 39 December 8, 2011. Available at <http://www.state.nj.us/drbc/library/documents/Res2011 -40 12Exelon.pdf> (accessed 11 May 2012). 41 [DRBC] Delaware River Basin Commission. 2011b. Delaware River Basin Commission Meeting 42 of May 11, 2011. Series 11, Number 2. May 11, 2011. Available at 43 <http://www.state.nj.us/drbc/library/documents/5 11_minutes.pdf> (accessed 11 May 2012). 44 Purpose and Need for Action 2-89 [DRBC] Delaware River Basin Commission. 2012. "Basin Information." May 7, 2012. Available 1 at <http://www.state.nj.us/drbc/basin/> (accessed 16 May 2012). 2 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq. 3 [EPA] U.S. Environmental Protection Agency. 1974. "Information on Levels of Environmental 4 Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety." 5 Report 550/9 004, Washington, DC. Available at <http://www.epa.gov/nscep/index.html >. 6 (accessed January 2011). 7 [EPA] U.S. Environmental Protection Agency. 2010. "Ecoregions of EPA Region 3: Delaware, 8 Maryland, Pennsylvania, Virginia, and West Virginia." Available at 9 <http://www.epa.gov/wed/pages/ecoregions/reg3_eco.htm > (accessed 8 May 2012). 10 [EPA] U.S. Environmental Protection Agency. 2012a. "Office of Solid Waste." Available at 11 <http://www.epa.gov/osw/ > (accessed April 2012). 12 [EPA] U.S. Environmental Protection Agency. 2012b. "Waste Environmental Management 13 Systems." Available at <http://www.epa.gov/osw/inforesources/ems/index.htm > (accessed 14 April 2012). 15 [EPA] U.S. Environmental Protection Agency . 2012c. "Safe Drinking Water Information System 16 (SDWIS)," County Search. Berks, Chester, Montgomery County, Pennsylvania. Last updated 17 February 7, 2012. Available at 18 <http://oaspub.epa.gov/enviro/sdw_form_v2.create_page?state_abbr=PA > (accessed 19 April 2012). 20 [Exelon] Exelon Generation Company, LLC. 2001. Letter from J. Doering, Vice President, to 21 U.S. Nuclear Regulatory Commission. 2000 Annual Environmental Operating Report 22 (Non-Radiological). April 16, 2001. 23 [Exelon] Exelon Generation Company, LCC. 2002. Letter from R. Braun, Plant Manager, to 24 U.S. Nuclear Regulatory Commission. 2001 Annual Environmental Operating Report 25 (Non-Radiological). April 9, 2002. 26 [Exelon] Exelon Generation Company, LLC. 2003. Letter from R. Braun, Vice President, to 27 U.S. Nuclear Regulatory Commission. 2002 Annual Environmental Operating Report 28 (Non-Radiological). April 30, 2003. 29 [Exelon] Exelon Generation Company, LLC. 2004. Letter from R. DeGregorio, Vice President, to 30 U.S. Nuclear Regulatory Commission. 2003 Annual Environmental Operating Report 31 (Non-Radiological). April 26, 2004. 32 [Exelon] Exelon Generation Company, LLC. 2005. Letter from R. Degregorio, Vice President, to 33 U.S. Nuclear Regulatory Commission. 2004 Annual Environmental Operating Report 34 (Non-Radiological). April 25, 2005 35 [Exelon] Exelon Generation Company, LLC. 2006. Letter to U.S. Nuclear Regulatory 36 Commission. 2005 Annual Environmental Operating Report (Non -Radiological). April 6, 2006. 37 [Exelon] Exelon Generation Company, LLC. 2007. "Wildlife at Work: Bird and Bat Project 38 Summary Sheet." 9
- p. ADAMS Accession No. ML12110A289.
39 [Exelon] Exelon Generation Company, LLC. 2008a. Limerick Generating Station, Units 1 and 2. 40 Annual Radiological Environmental Operating Report, Report No. 23, 1 January through 41 31 December 2007. Sanatoga, PA. April 2008. ADAMS Accession No. ML081260681. 42 [Exelon] Exelon Generation Company, LLC. 2008b. Updated Final Safety Analysis Report, 43 Limerick Generating Station Units 1 and 2. Revision 13. Kennett Square, PA. September 2008. 44 Purpose and Need for Action 2-90 [Exelon] Exelon Generation Company, LLC. 2009. Limerick Generating Station, Units 1 and 2, 1 Annual Radiological Environmental Operating Report, Report No. 24, 1 January through 2 31 December 2008. Sanatoga, PA. April 2009. ADAMS Accession No. ML091280061. 3 [Exelon] Exelon Generation Company, LLC. 2010a. "Wildlife at Work: Frog Project Summary 4 Sheet." 4 p. ADAMS Accession No. ML12110A289. 5 [Exelon] Exelon Generation Company, LLC. 2010b. Exelon Corporation Limerick Generating 6 Station Wildlife Management Plan. 66 p. ADAMS Accession No. ML12110A289. 7 [Exelon] Exelon Generation Company, LLC. 2010c. Limerick Generating Station, Units 1 and 2, 8 Annual Radiological Environmental Operating Report, Report No. 25, 1 January through 9 31 December 2009. Sanatoga, PA. April 2010. ADAMS Accession No. ML101250333. 10 [Exelon] Exelon Generation Company, LLC. 2010d. Limerick Generating Station, Units 1 and 2, 11 Limerick Township, Montgomery County, Pennsylvania, NPDES Permit No. PA0051926 12 Renewal Application. Submitted to Pennsylvania Department of Environmental Protection, 13 Southeast Regional Office, Norristown, PA. September 2010. ADAMS Accession 14 No. ML12110A229. 15 [Exelon] Exelon Generation Company, LLC. 2011a. Limerick Generating Station, Units 1 and 2, 16 Annual Radiological Environmental Operating Report, 1 January through 31 December 2010. 17 Sanatoga, PA: Exelon Generation Company. April 2011. ADAMS Accession No. ML11126A169. 18 [Exelon] Exelon Generation Company, LLC. 2011b. Applicant's Environmental Report -19 Operating License Renewal Stage, Limerick Generating Station, Units 1 and 2, Docket Numbers 20 50-352 and 50 -353, License Numbers NPF -39 and NPF -85. Exelon Generation Company, LLC. 21 ADAMS Accession No. ML11179A104. 22 [Exelon] Exelon Generation Company, LLC. 2012a. "Corporate Policy, Environment." EN -AC-1 23 Revision 3, Effective Date: March 16, 2012. Available at 24 <http://www.exeloncorp.com/assets/environment/docs/EnvironmentPolicy.pdf> (accessed 25 3 May 2012). 26 [Exelon] Exelon Generation Company, LLC. 2012b. Letter from M.P. Gallagher, Vice President, 27 License Renewal Projects, to NRC Document Desk.
Subject:
Response to NRC request for 28 additional information, dated February 28th, 2012, related to the Limerick Generating Station 29 license renewal application. March 27, 2012. ADAMS Accession No. ML12088A366, 30 ML12110A227. 31 [Exelon] Exelon Generation Company, LLC. 2012c. Limerick Generating Station, Units 1 and 2, 32 Annual Radiological Environmental Operating Report, 1 January through 31 December 2011. 33 Sanatoga, PA: Exelon Generation Company. April 2012. ADAMS Accession No. ML12121A620. 34 [Exelon] Exelon Generation Company, LLC. 2012d. The Limerick Generating Station Water 35 Supply Modification Demonstration Project and Wadesville Mine Pool Withdrawal and Stream 36 Flow Augmentation Demonstration Project Annual Update. Kennett Square, PA: Exelon. 37 February 21, 2012. Available at <http://www.nj.gov/drbc/library/documents/wadesville/annual -38 update-mtg022112.pdf> (accessed 11 May 2012). 39 [FWS] U.S. Fish and Wildlife Service. 1992. Small -whorled Pogonia (Isotria medeoloides) 40 Recovery Plan. First Revision. Newton Corner, MA: FWS Region 5. 77 p. Available at 41 <http://ecos.fws.gov/docs/recovery_plan/921113b.pdf> (accessed 10 May 2012). 42 [FWS] U.S. Fish and Wildlife Service. 2001. Bog Turtle (Clemmys muhlenbergii) Northern 43 Population Recovery Plan. Hadley, MA: FWS. 109 p. Available at 44 <http://ecos.fws.gov/docs/recovery_plan/010515.pdf> (accessed 10 May 2012). 45 Purpose and Need for Action 2-91 [FWS] U.S. Fish and Wildlife Service. 2007a. Indiana Bat (Myotis sodalis) Draft Recovery Plan. 1 First Revision. Fort Snelling, MN: FWS Region 3. 258 p. Available at 2 <http://ecos.fws.gov/docs/recovery_plan/070416.pdf > (accessed 10 May 2012). 3 [FWS] U.S. Fish and Wildlife Service. 2007b. Dwarf Wedgemussel Alasmidonta heterodon 4 5-Year Review: Summary and Evaluation. Concord, NH: FWS. June 22, 2007. Available at 5 <http://www.fws.gov/northeast/endangered/PDF/DwarfWedgemussel.pdf > (accessed 6 20 April 2012). 7 [FWS] U.S. Fish and Wildlife Service. 2008. Small -whorled Pogonia (Isotria medeoloides) 8 5-Year Review: Summary and Evaluation. Concord, NH: FWS New England Field Office. 26 p. 9 Available at <http://ecos.fws.gov/docs/five_year_review/doc2002.pdf > (accessed 10 May 2012). 10 [FWS] U.S. Fish and Wildlife Service. 2010. "Bog Turtle, Clemmys muhlenbergii." October 2010. 11 Available at <http://www.pa.nrcs.usda.gov/programs/whip/WLFW/Documents/BogTurtle_ 12 FWS_FS.pdf > (accessed 10 May 2012). 13 [FWS] U.S. Fish and Wildlife Service. 2011. Letter from C. Riley, Pennsylvania Field Office 14 Supervisor, FWS, to D. Wrona, RPB2 Branch Chief, NRC.
Subject:
Reply to request for 15 protected species information. USFWS Project #2011 -0365. November 22, 2011. ADAMS 16 Accession No. ML11339A043. 17 [FWS] U.S. Fish and Wildlife Service. 2012a. "Find Endangered Species." Search by County for 18 Bucks, Chester, and Montgomery Counties, Pennsylvania. Available at 19 <http://www.fws.gov/endangered/?s8fid=112761032793&s8fid=112762573903&countyName=m 20 ontgomery> (accessed 10 May 2012). 21 [FWS] U.S. Fish and Wildlife Service. 2012b. "Species Profile: Small -Whorled Pogonia (Isotria 22 medeoloides)." Available at 23 <http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1XL > (accessed 24 10 May 2012). 25 [FWS] U.S. Fish and Wildlife Service. 2012c. "Species profile Dwarf wedgemussel (Alamidonta 26 heterodon)." April 26, 2012. Available at 27 <http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=F029 > (accessed 28 10 April 2012). 29 [FWS] U.S. Fish and Wildlife Service. Undated. "Migratory Birds & Habitat Programs: Migratory 30 Bird Treaty Act." Available at <http://www.fws.gov/pacific/migratorybirds/mbta.htm> (accessed 31 10 May 2012). 32 [FWS-PA] U.S. Fish and Wildlife Service Pennsylvania Field Office. 2012. "Federally Listed, 33 Proposed, and Candidate Species in Pennsylvania." Revised February 14, 2012. Available at 34 <http://www.fws.gov/northeast/pafo/endangered_species_list.html > (accessed 10 May 2012). 35 Gilbert CR.1989. Species Profiles: Life Histories and Environmental Requirements of Coastal 36 Fishes and Invertebrates (Mid -Atlantic Bight), Atlantic and Shortnose Sturgeons. Biological 37 Report 82(11.122). Sidell, LA: U.S. Fish and Wildlife Service. Available at 38 <http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11 -122.pdf>( accessed 11 April 2012). 39 Gross DA, Brauning DW. 2010. Bald Eagle Management Plan for Pennsylvania (2010 -2019). 40 Harrisburg, PA: Pennsylvania Game Commission. 60 p. Available at 41 <http://academic.keystone.edu/jskinner/WildlifeFisheries/Bald%20Eagle%20Management%20Pl 42 an%2020101.pdf > (accessed 11 May 2012). 43 Purpose and Need for Action 2-92 H&K Group. 2012. "Pottstown Trap Rock Quarries Santoga Quarry." Available at 1 <http://www.hkgroup.com/companies/pottstown -trap-rock-sanatoga-quarry> (accessed 2 6 April 2012). 3 Hastings RW, O'Herron JC, Schick K, Lazzari, MA. 1987. Occurrence and Distribution of 4 Shortnose Sturgeon, Acipenser brevirostrum, in the Upper Tidal Delaware River. Estuaries 5 10(4):337-341. 6 Holisinger JR. 1978. Systematics of the Subterranean Amphipod Genus Stygobromus 7 (Crangonyctidae), Part II: Species of the Eastern United States. Smithsonian Contributions to 8 Zoology Number 266. Smithsonian Institution Press, Washington, DC. 9 Interlandi SJ, Crockett, CS. 2003. Recent water quality trends in the Schuylkill River, 10 Pennsylvania, USA: A preliminary assessment of the relative influences of climate, river 11 discharge, and suburban development. Water Research 37:1737 -1748. 12 [ISO] International Organization for Standardization. 2009. Environmental Management: The 13 ISO 14000 Family of International Standards. 12 p. Available at 14 <http://www.iso.org/iso/theiso14000family_2009.pdf > (accessed 1 May 2012). Kriner EN, 15 MacDonald L. 2009. "Environmental Working Committee -Biodiversity Evaluation of Possum 16 Hollow Run." 5 p. ADAMS Accession No. ML12110A231. 17 Menzel JM, Ford WM, Menzel MA, Carter TC, Gardner JE, Gardner JD, Hofmann JE. 2005. 18 Summer habitat use and home -range analysis of the endangered Indiana bat. Journal of Wildlife 19 Management 69(1):430 -436. Available at 20 <http://www.fs.fed.us/ne/newtown_square/publications/other_publishers/OCR/ne_2005_Menzel 21 001.pdf> (accessed 8 May 2012). 22 Miller RH. 2007. Best Management Practices: Integrated Vegetation Management. Companion 23 Publication to the ANSI A300 Part 7: Tree, Shrub, and Other Woody Plant Maintenance -24 Standard Practices. Champaign, IL: International Society of Arboriculture. 36 p. 25 [NAI] Normandeau Associates, Inc. 2010a. Fish and benthic macroinvertebrate community 26 composition in the Schuylkill River in the vicinity of Limerick Generating Station during 2009. 27 February 2010. 28 [NAI] Normandeau Associates, Inc. 2010b. East Branch Perkiomen Creek aquatic biology 29 assessment XIII, 2008 monitoring period. May 20
- 10. 30 [NAI] Normandeau Associates, Inc. 2010c. East Branch Perkiomen Creek aquatic biology 31 assessment XIV, 2009 monitoring period. July 2010.
32 [NAI] Normandeau Associates, Inc. 2010d. Letter from W. Ettinger to G. Sprissler, Exelon 33 Nuclear, regarding zebra mussel/Asiatic clam survey. November 11, 2010. 34 [NAI and URS] Normandeau Associates, Inc. and URS Corporation. 2004. Year one (2003) 35 interim report for the Wadesville mine water demonstration project. Available at 36 <http://www.nj.gov/drbc/library/documents/wadesville/2003_interim -report.pdf> (accessed 37 9 April 2012). 38 [NAI and URS] Normandeau Associates, Inc. and URS Corporation. 2011. 2011 Interim report 39 for the Limerick Generating Station water supply modification demonstration project and 40 Wadesville Mine Pool withdrawal and streamflow augmentation demonstration project. Available 41 at <http://www.nj.gov/drbc/library/documents/wadesville/2011_interim -report.pdf > (accessed 42 9 April 2012). 43 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq. 44 Purpose and Need for Action 2-93 National Historic Preservation Act of 1966. 16 U.S.C. §470 et seq. 1 [NatureServe] NatureServe Explorer. 2010a. NatureServe Explorer: An online encyclopedia of 2 life. Version 7.1. "Missouri rock -cress (Arabis missourienis)." Available at 3 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Arabis+missouriensis> 4 (accessed 10 May 2012). 5 [NatureServe] NatureServe Explorer. 2010b. NatureServe Explorer: An online encyclopedia of 6 life. Version 7.1. "Schweinitz's flatsedge (Cyperus schweinitzii)." Available at 7 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Cyperus+schweinitzii> 8 (accessed 10 May 2012). 9 [NatureServe] NatureServe Explorer. 2010c. NatureServe Explorer: An online encyclopedia of 10 life. Version 7.1. "Slender blue iris (Iris prismatica)." Available a t 11 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Iris+prismatica> 12 (accessed 10 May 2012). 13 [NatureServe] NatureServe Explorer. 2010d. NatureServe Explorer: An online encyclopedia of 14 life. Version 7.1. "Spreading rock -cress (Arabis patens)." Available at 15 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Arabis+patens> 16 (accessed 10 May 2012). 17 [NatureServe] NatureServe Explorer. 2010e. NatureServe Explorer: An online encyclopedia of 18 life. Version 7.1. "Tufted buttercup (Ranunculus fascicularis)." Available at 19 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Ranunculus+fascicular 20 is> (accessed 10 May 2012). 21 [NCDC] National Climatological Data Center. 2012a. Climate of Pennsylvania. Asheville, North 22 Carolina. Available at <http://climate.met.psu.edu/data/ncdc_pa.pdf> (accessed 6 April 2012). 23 NCDC] National Climatological Data Center. 2012b. 2011 Local Climatological Data Annual 24 Summary with Comparative Data -Philadelphia, Pennsylvania. Asheville, North Carolina. 25 Available at <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html> (accessed 6 April 2012). 26 [NCDC] National Climatological Data Center. 2012c. 2011 Local Climatological Data Annual 27 Summary with Comparative Data -Allentown, Pennsylvania. Asheville, North Carolina. 28 Available at <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html> (accessed 6 April 2012) 29 [NCDC] National Climatological Data Center. 2012d. Storm Events Database. Asheville, North 30 Carolina. Available at <http://www.ncdc.noaa.gov/stormevents/> (accessed 6 April 2012). 31 [NCES] National Center for Education Statistics. 2011. Institute of Educational Science (IES). 32 U.S. Department of Education. "College Opportunities Online Locator." Zip Code 19464 Data 33 release date August 16, 2011. Available at <http://nces.ed.gov/ipeds/cool/RefineSearch.aspx >. 34 Search for Public School Districts. Available at <http://www.nces.ed.gov/ccd/districtsearch/> 35 (accessed January 2011). 36 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative - Final 37 Guidance Document. Washington, DC: Nuclear Energy Institute. NEI 07 -07 [Final]. 38 August 2007. ADAMS Accession No. ML091170588. 39 [NHDES] New Hampshire Department of Environmental Services. 2010. Environmental Fact 40 Sheet, Variable milfoil (Myriophyllum heterophyllum). Available at: 41 <http://www.tuftonboro.org/Pages/TuftonboroNH_boards/facts > (accessed 10 April 2012). 42 [NMFS] National Marine Fisheries Service. 2012a. "Marine/Anadromous Fish Species Under the 43 Endangered Species Act (ESA)." March 9, 2012. Available at 44 <http://www.nmfs.noaa.gov/pr/species/esa/fish.htm > (accessed 9 April 2012). 45 Purpose and Need for Action 2-94 [NMFS] National Marine Fisheries Service. 2012b. "Shortnose Sturgeon (Acipenser 1 brevirostrum)." March 14, 2012. Available at 2 <http://www.nmfs.noaa.gov/pr/species/fish/shortnosesturgeon.htm > (accessed 9 April 2012). 3 [NMFS] National Marine Fisheries Service. 2012c. Letter from M.A. Colligan, Assistant Regional 4 Administrator for Protected Resources, NMFS, to J. Susco, Acting Branch Chief, NRC. June 2, 5 2012. ADAMS Accession No. ML12226A163. 6 [NOAA] National Oceanic and Atmospheric Administration. 2012. Historical Hurricane Tracks. 7 Available at <http://www.csc.noaa.gov/hurricanes/#> (accessed 6 April 2012). 8 [NRC] U.S. Nuclear Regulatory Commission. 1973. Final Environmental Statement Related to 9 the Proposed Limerick Generating Stations Units 1 and 2. Washington, DC: NRC. ADAMS 10 Accession No ML11313A215. 11 [NRC] U.S. Nuclear Regulatory Commission. 1984. Final Environmental Statement Related to 12 Operation of Limerick Generating Station, Units 1 and 2. Washington, DC: NRC. NUREG -0974. 13 April 1984. ADAMS Accession No. ML11221A204. 14 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 15 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 16 ADAMS Accession Nos. ML040690705 and ML040690738. 17 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 18 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 19 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 20 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 21 No. ML04069720. 22 [NRC] U.S. Nuclear Regulatory Commission. 2000. Environmental Standard Review Plan: 23 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. Washington, DC: 24 NRC. NUREG -1555. 25 [NRC] U.S. Nuclear Regulatory Commission. 2003. Generic Environmental Impact Statement 26 for License Renewal of Nuclear Plants, Supplement 10, regarding Peach Bottom Atomic Power 27 Plant, Units 2 and 3. Washington, DC: NRC. NUREG -1437, Supplement 10. ADAMS Accession 28 No. ML030270059. 29 [NRC] U.S. Nuclear Regulatory Commission. 2009a. Generic Environmental Impact Statement 30 for License Renewal of Nuclear Plants, Supplement 35, regarding Susquehanna Steam Electric 31 Station, Units 1 and 2. Washington, DC: NRC. NUREG -1437, Supplement 35. ADAMS 32 Accession No. ML090700454. 33 [NRC] U.S. Nuclear Regulatory Commission. 2009b. Generic Environmental Impact Statement 34 for License Renewal of Nuclear Plants, Supplement 36, regarding Beaver Valley Power Station, 35 Units 1 and 2. Washington, DC: NRC. NUREG -1437, Supplement 36. 36 [NRC] U.S. Nuclear Regulatory Commission. 2009c. Generic Environmental Impact Statement 37 for License Renewal of Nuclear Plants, Supplement 37, regarding Three Mile Island Nuclear 38 Station, Unit 1. Washington, DC: NRC. NUREG -1437, Supplement 37. 39 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Letter from D. Wrona, Branch Chief, to 40 J. Cutler, Bureau of Historic Preservation. Limerick Generating Station license renewal 41 environmental review (SHPO File No. ER 2004 -2024-091-B). September 15, 2011. ADAMS 42 Accession No. ML11221A265. 43 Purpose and Need for Action 2-95 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from D. Wrona, Branch Chief, to 1 T. McCulloch, Advisory Council on Historic Preservation.
Subject:
Limerick Generating Station 2 license renewal environmental review (SHPO File No. ER 2 004-2024-091-B). 3 September 16, 2011. ADMAS Accession No. ML11245A083. 4 [NRC] U.S. Nuclear Regulatory Commission. 2011c. E -mail from Ann, BHP, to T.K. O'Neil, 5 PNNL. LGS license renewal -SHPO meeting. November 1, 2011. ADAMS Accession 6 No. ML12255A291 7 [NRC] U.S. Nuclear Regulatory Commission. 2011d. "Official Transcript of Proceedings- 8 Limerick Generating Station License Renewal: Evening Session." October 26, 2011. ADAMS 9 Accession No ML11287A211. 10 [NRC] U.S. Nuclear Regulatory Commission. 2011e. Memo from L. Regner to D. Wrona, Branch 11 Chief.
Subject:
Summary of public scoping meetings conducted on September 22, 2011, related 12 to the review of the Limerick Generating Stations, Units 1 and 2, license renewal application. 13 October 26, 2011. 14 [NRC] U.S. Nuclear Regulatory Commission. 2011f. Letter from D. Wrona, Branch Chief, to 15 Olivia Braun, Environmental Planner, Pennsylvania Game Commission.
Subject:
Request for list 16 of protected species within the area under evaluation for the Limerick Generating Stations, 17 Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession 18 No. ML11234A065. 19 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Summary of Site Audit in Support to the 20 Environmental Review of the License Renewal Application for Limerick Generating Station, 21 Units 1 and 2." May 2012. ADAMS Accession No. ML12124A127. 22 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Letter from J. Susco, RERB Acting Branch 23 Chief, NRC, to D. Morris, Acting Regional Administrator National Marine Fisheries Service. 24
Subject:
Request for list of Federal protected species within the area under evaluation for the 25 Limerick Generating Station, Units 1 and 2, license renewal application review. May 30, 2012. 26 ADAMS Accession No. ML12138A347. 27 [NRCS] Natural Resources Conservation Service. 2012. "Web Soil Survey, Soil Map - Chester 28 County, Pennsylvania, and Montgomery County, Pennsylvania." (Search parameters: soil map; 29 soil data explorer -suitabilities and limitations for use, building site development, farmland 30 classification; soil reports). February 17, 2012. U.S. Department of Agriculture, National 31 Cooperative Soil Survey. Available at <http://websoilsurvey.nrcs.usda.gov/app> (accessed 32 6 April 2012). 33 [NYSDEC] New York State Department of Environmental Conservation. 2009. "Delaware River 34 American Shad Stock Status, Status of American Shad in the Delaware River." Albany, NY: 35 NYSDEC. August 2009. Available at <http://www.dec.ny.gov/animals/57679.html> (accessed 36 9 April 2012). 37 O'Herron JC, Able KW, Hastings RW. 1993. Movements of shortnose sturgeon (Acipenser 38 brevirostrum) in the Delaware River. Estuaries 16(2):235 -240. 39 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2000. 40 Physiographic Provinces of Pennsylvania. Harrisburg, PA: Commonwealth of Pennsylvania, 41 Bureau of Topographic and Geological Survey. Map 13. Available at 42 <http://www.dcnr.state.pa.us/ucmprd1/groups/public/documents/multimedia/dcnr_008642.pdf> 43 (accessed 6 April 2012). 44 Purpose and Need for Action 2-96 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2003. 1 Earthquake Hazard in Pennsylvania. Harrisburg, PA: Commonwealth of Pennsylvania. Bureau 2 of Topographic and Geological Survey. Educational Series 10. May 2003. Available at 3 <http://www.dcnr.state.pa.us/ucmprd2/groups/public/documents/document/dcnr_006704.pdf> 4 (accessed 6 April 2012). 5 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2010. "Scenic 6 Rivers." Available at 7 <http://www.dcnr.state.pa.us/brc/conservation/rivers/scenicrivers/index.htm > (accessed 8 8 May 2012). 9 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2011. Letter from 10 R. Bowen, Environmental Review Manager, for C. Firestone, Wild Plant Program Manager, 11 Bureau of Forestry, PDCNR, to M. Gallagher, Exelon Nuclear.
Subject:
Pennsylvania Natural 12 Diversity Inventory review for renewal of operating licenses for Limerick Generating Station, 13 Units I and 2, Chester, Montgomery & Bucks Counties. March 9, 2011. 14 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2012. PaGWIS 15 Records. (Well radial search parameters: Latitude 40.22483 N, Longitude -75.5874 W, Radius 16 1 mi). Harrisburg, PA: Commonwealth of Pennsylvania. Bureau of Topographic and Geological 17 Survey, Pennsylvania Ground Water Information System. Available at 18 <http://www.dcnr.state.pa.us/topogeo/groundwater/pagwis/records/index.htm> (accessed 19 30 May 2012). 20 [PADE] Pennsylvania Department of Education - Division of Data Quality. 2011. "Enrollment 21 Data and Statistics." "Public School Enrollment Reports," 4/20/2011. Available at 22 <http://www.portal.state.pa.us/portal/server.pt/community/enrollment/7407/public_school_enroll 23 ment_reports/620541 > (accessed April 2012). 24 [PADEP] Pennsylvania Department of Environmental Protection. 2003. Watershed restoration 25 action strategy (WRAS) state water plan subbasin 03E, Perkiomen Creek Watershed, 26 Montgomery, Bucks, Berks, and Lehigh counties. Bureau of Watershed Management. 27 [PADEP] Pennsylvania Department of Environmental Protection. 2006a. Water Quality 28 Standards Review Stream Redesignation Evaluation Report. October 2006. Available at 29 <http://files.dep.state.pa.us/water/Drinking%20Water%20and%20Facility%20Regulation/Water 30 QualityPortalFiles/Stream_Packages/Big%20Brook/Brooke_Evans.pdf > (accessed 31 8 August 2012). 32 [PADEP] Pennsylvania Department of Environmental Protection. 2006b. "General Permit 33 BWM-GP-11: Maintenance, Testing, Repair, Rehabilitation, or Replacement of Water 34 Obstructions or Encroachments." December 2006 Revision. 30 p. Available at 35 <http://www.elibrary.dep.state.pa.us/dsweb/Get/Document -85002/3930 -PM-WM0511-36 Entire%20Package.pdf> (accessed 18 April 2012). 37 [PADEP] Pennsylvania Department of Environmental Protection. 2010. Letter from P. Patel, 38 Permits Section, Water Management Program, to E.W. Callan, Plant Manager, Exelon 39 Generation Co. LLC, Pottstown, PA.
Subject:
Limerick Generating Station Application 40 No. PA0051926. December 15, 2010. ADAMS Accession No. ML12110A229. 41 Purpose and Need for Action 2-97 [PADEP] Pennsylvania Department of Environmental Protection. 2011. Draft 2012 Pennsylvania 1 Integrated Water Quality Monitoring and Assessment Report, Clean Water Act Section 305(b) 2 and 303(d) List. Harrisburg, PA: Bureau of Point and Non -Point Source Management. Available 3 at 4 <http://www.portal.state.pa.us/portal/server.pt/community/water_quality_standards/10556/integr5 ated_water_quality_report_ -_2012/1127203> (accessed 25 May 2012). 6 [PADEP] Pennsylvania Department of Environmental Protection. 2012. Drought Management in 7 Pennsylvania. 3940-BK-DEP2742. Bureau of Safe Drinking Water, Planning and Conservation 8 Division. March 2012. Available at 9 <http://www.portal.state.pa.us/portal/server.pt/community/fact_sheets___guidelines/10609> 10 (accessed 16 May 2012). 11 [PASDC] Pennsylvania State Data Center. 2010. "Pennsylvania Population Projections: 12 2000-2030." Published 10/21/2010. Middletown, PA. Available at 13 <http://pasdc.hbg.psu.edu/Data/Projections/tabid/1013/Default.aspx > (accessed May 2012). 14 [PECO] Philadelphia Electric Company. 1984. Environmental Report Operating License Stage 15 Limerick Generating Station Units 1 & 2, Vol. 1. 16 [PennDOT] Pennsylvania Department of Transportation. 2012. "2010 Traffic Volume Map" 17 Available at 18 <http://www.dot.state.pa.us/Internet/Bureaus/pdPlanRes.nsf/infoBPRTrafficInfoTrafficVolumeMa 19 p?openform > (accessed April 2012). 20 [PFBC] Pennsylvania Fish and Boat Commission. 2011a. "Adult Trout Stocking by County." 21 Available at <http://pfbc.state.pa.us/pfbc_webgis/TroutStockingDetails.aspx> (accessed 22 9 April 2012). 23 [PFBC] Pennsylvania Fish and Boat Commission. 2011b. Letter from C.A. Urban, Natural 24 Diversity Section Chief, Division of Environmental Service, PFBC, to D. Wrona, RPB2 Chief, 25 NRC.
Subject:
Species Impact Review (SIR) -rare, candidate, threatened and endangered 26 species, renewal of operating licenses for Limerick Generating Station, Units 1 and 2, 27 Montgomery and Chester County, Pennsylvania. October 5, 2011. ADAMS Accession 28 No. ML11291A077. 29 [PFBC] Pennsylvania Fish and Boat Commission. 2011c. "American shad spring spawning 30 monitoring, Biologist Report, Delaware River, Monroe and Northampton Counties." Available at 31 <http://fishandboat.com/images/reports/2011bio/del2011shad.pdf > (accessed 32 16 October 2012). 33 [PFBC] Pennsylvania Fish and Boat Commission. 2012a. "Schuylkill River American Shad." 34 Available at <http://fishandboat.com/shad_schu.htm> (accessed 5 April 2012). 35 [PFBC] Pennsylvania Fish and Boat Commission. 2012b. "2004 and 2005 Fairmont Fish Ladder 36 Passage Data Compared to Historical Counts." Available at 37 <http://fishandboat.com/pafish/shad/schuylkill/fairmount2005.htm > (accessed April 26, 2012). 38 [PFBC] Pennsylvania Fish and Boating Commission. 2012c. "Gallery of Pennsylvania Fishes." 39 Available at <http://fishandboat.com/pafish/fishhtms/chapindx.htm > (accessed 8 August 2012) 40 [PFBC] Pennsylvania Fish and Boating Commission. 2012d. "Summary Book, 2012 41 Pennsylvania Fishing Laws and Regulations, Regulations by Location, Delaware River." 42 Available at <http://fishandboat.com/fishpub/summary/delaware.html > (accessed 43 16 October 2012). 44 Purpose and Need for Action 2-98 [PGC] Pennsylvania Game Commission. 2010. "Indiana Bat." Available at 1 <http://www.portal.state.pa.us/portal/server.pt/document/775661/indiana_bat_pdf> (accessed 2 9 May 2012). 3 [PGC] Pennsylvania Game Commission. 2011. Letter from O.A. Mowery, Environmental 4 Planner, Division of Environmental Planning and Habitat Protection, to D. Wrona, Chief, Divisio n 5 of License Renewal, NRC.
Subject:
Re: Limerick Generating Station and transmission lines -6 license renewal, Montgomery and Chester Counties, Pennsylvania. November 17, 2011. 7 ADAMS Accession No. ML11329A060. 8 [PNHP] Pennsylvania Natural Heritage Program. 2007a. "American Holly, Ilex opaca." Available 9 at <http://www.naturalheritage.state.pa.us/factsheets/12926.pdf> (accessed 10 May 2012). 10 [PNHP] Pennsylvania Natural Heritage Program. 2007b. "Possum -haw, Viburnum nudum." 11 Available at <http://www.naturalheritage.state.pa.us/factsheets/13672.pdf> (accessed 12 10 May 2012). 13 [PNHP] Pennsylvania Natural Heritage Program. 2007c. "Redbelly Turtle (Pseudemys 14 rubriventris)." Available at <http://www.naturalheritage.state.pa.us/factsheets/11525.pdf > 15 (accessed 24 July 2012). 16 [PNHP] Pennsylvania Natural Heritage Program. 2011a. "Elliott's beardgrass (Andropogon 17 gyrans)." Available at <http://www.naturalheritage.state.pa.us/factsheets/15497.pdf> (accessed 18 10 May 2012). 19 [PNHP] Pennsylvania Natural Heritage Program. 2011b. "Toothcup (Rotala romosior)." 20 Available at <http://www.naturalheritage.state.pa.us/factsheets/14149.pdf> (accessed 21 10 May 2012). 22 [PNHP] Pennsylvania Natural Heritage Program. 2012a. "Species of Special Concern Lists." 23 Search by County for Bucks, Chester, and Montgomery Counties. Available at 24 <http://www.naturalheritage.state.pa.us/Species.aspx> (accessed 10 May 2012). 25 [PNHP] Pennsylvania Natural Heritage Program. 2012b. "Species Fact Sheet, Banded sunfish 26 (Enneacanthus obesus)." Available at 27 <http://www.naturalheritage.state.pa.us/factsheets/11395.pdf > (accessed 10 April 2012). 28 [PNHP] Pennsylvania Natural Heritage Program. 2012c. "Species Fact Sheet, Longear sunfish 29 (Lepomis megalotis)." Available at 30 <http://www.naturalheritage.state.pa.us/factsheets/11401.pdf> (accessed 10 April 2012). 31 [PNHP] Pennsylvania Natural Heritage Program. 2012d. "Species Fact Sheet, Farwell's 32 Water-milfoil (Myriophyllum farwellii)." Available at 33 <http://www.naturalheritage.state.pa.us/factsheets/13979.pdf > (accessed 10 April 2012). 34 [PNHP] Pennsylvania Natural Heritage Program. 2012e. "Species Fact Sheet, Floating -heart 35 (Nymphoides cordata)." Available at 36 <http://www.naturalheritage.state.pa.us/factsheets/14174.pdf > (accessed 10 April 2012). 37 [PNHP] Pennsylvania Natural Heritage Program. 2012f. "Species Fact Sheet, Spotted 38 Pondweed (Potamogeton pulcher)." Available at 39 <http://www.naturalheritage.state.pa.us/factsheets/15786.pdf > (accessed 10 April 2012). 40 Ramsdell JV, Rishel JP. 2007. Tornado Climatology of the Contiguous United States. 41 Washington, DC: U.S. Nuclear Regulatory Commission. NUREG/CR -4461, Rev. 2. 42 Resource Conservation and Recovery Act of 1976, as amended. 42 U.S.C. §6901 et seq. 43 Purpose and Need for Action 2-99 Rhoads AF, Block TA. 2008. Montgomery County, Pennsylvania: Natural Areas Inventory 1 Update. Philadelphia, PA: Morris Arboretum of the University of Pennsylvania. Submitted to the 2 Montgomery County Planning Commission. June 30, 2007. 401 p. Available at 3 <http://planning.montcopa.org/planning/cwp/view,a,3,q,66753.asp> (accessed 8 May 2012). 4 [RMC] RMC Environmental Services. 1984. Progress Report, Non -radiological environmental 5 monitoring for Limerick Generating Station 1979 -1983. October 1984. 6 [RMC] RMC Environmental Services. 1985. Progress Report, Non -radiological environmental 7 monitoring for Limerick Generating Station 1984. December 1985. 8 [RMC] RMC Environmental Services. 1986. Progress Report, Non -radiological environmental 9 monitoring for Limerick Generating Station 1985. September 1986. 10 [RMC] RMC Environmental Services. 1987. Progress Report, Non -radiological environmental 11 monitoring for Limerick Generating Station 1986. November 1987. 12 [RMC] RMC Environmental Services. 1988. Progress Report, Non -radiological environmental 13 monitoring for Limerick Generating Station 1987. September 1988. 14 [RMC] RMC Environmental Services. 1989. Progress Report, Non -radiological environmental 15 monitoring for Limerick Generating Station 1988. December 1989. 16 Rohde FC, Arndt RG, Lindquist DG, Parnell JF. 1994. Freshwater Fishes of the Carolinas, 17 Virginia, Maryland, and Delaware. University of North Carolina Press, Chapel Hill, North 18 Carolina. 19 Rothbart P, Capel S. 2006. Chapter 3: "Maintaining and Restoring Grasslands." In: Oehler JD, 20 Covell DF, Capel S, Long B, editors. Managing Grasslands, Shrublands, and Young Forest 21 Habitats for Wildlife: a Guide for the Northeast. Westborough, MA: Massachusetts Division of 22 Fisheries & Wildlife, Northeast Upland Habitat Technical Committee. Available at 23 <http://www.wildlife.state.nh.us/Wildlife/Northeast_Mgt_Guide/Ch03_Maintaining_Grasslands. 24 pdf> (accessed 8 May 2012). 25 Sadak T. 2008. Acid mine drainage pollution in the West Branch Schuylkill and Upper Schuylkill 26 River, Schuylkill County, Pennsylvania: a case study and recommendations for the future. 27 Presented to the faculties of the University of Pennsylvania in partial fulfillment of the 28 requirements for the degree of Master of environmental studies 2008. Available at 29 <http://repository.upenn.edu/mes_capstones/34> (accessed 23 August 2012). 30 Sauer JR, Hines JE, Fallon JE, Pardieck KL, Ziolkowski Jr. DJ, Link WA. 2011. The North 31 American Breeding Bird Survey, Results and Analysis 1966 -2006. Version 12.07.2011. Species 32 List for Schwenksville, Pennsylvania. Laurel, MD: U.S. Geological Survey Patuxent Wildlife 33 Research Center. Available at <http://www.mbr -pwrc.usgs.gov/cgi-bin/rtena210.pl?72182> 34 (accessed 8 May 2012). 35 Sea Grant Pennsylvania. 2007. Zebra Mussel and Quagga Mussel, Dreissena polymorpha and 36 Dreissena rostriformis bugensis. Available at 37 <http://seagrant.psu.edu/publications/fs/zebraquagga2007.pdf> (accessed 29 April 2012). 38 Sea Grant Pennsylvania. 2012. Hydrilla, Hydrilla verticillata. Available at 39 <http://seagrant.psu.edu/publications/fs/Hydrilla.pdf> (accessed 29 April 2012). 40 Secor DH, Waldman, JR. 1999. Historical Abundance of Delaware Bay Atlantic Surgeon and 41 Potential Rate of Recovery. American Fisheries Society Symposium 23:203 -216. 42 Purpose and Need for Action 2-100 Select Greater Philadelphia (SGP). 2007. Montgomery County Data Economic Profile. Largest 1 Private Sector Employers. Available at 2 <http://www.selectgreaterphiladelphia.com/data/counties/montgomery.cfm > (accessed 3 January 2011). 4 Simpson PC, Fox DA. undated. Atlantic sturgeon in the Delaware River: contemporary 5 population status and identification of spawning areas. Dover, DE: Delaware State University. 6 Available at 7 <http://www.nero.noaa.gov/StateFedOff/grantfactsheets/DE/FINAL%20REPORTS/FINAL%20N8 A05NMF4051093.pdf > (accessed 27 August 2012). 9 [Stroud] Stroud Water Research Center. 2011. Schuylkill River Project. Available at 10 <http://www.stroudcenter.org/research/projects/schuylkill/index.shtm> (accessed 11 25 October 2011). 12 Trapp H, Horn, MA.1997. Ground Water Atlas of the United States, Delaware, Maryland, New 13 Jersey, North Carolina, Pennsylvania, Virginia, West Virginia. Washington, DC: U.S. Geological 14 Survey. HA -730-L. Available at <http://pubs.usgs.gov/ha/ha730/ch_l/L -text4.html> (accessed 15 30 May 2012). 16 [USCB] U.S. Census Bureau. 2011. American FactFinder, Census 2010, 3 -Year Estimate, 17 American Community Survey, State and County QuickFacts on Berks, Chester, and 18 Montgomery Counties. Land Area in Square Miles, 2010; Housing Characteristics, 2010; Major 19 Employers, 2010; Available at <http://factfinder.census.gov> and <http://quickfacts.census.gov> 20 (accessed January 2011 and April 2012). 21 [USDA] U.S. Department of Agriculture. National Agricultural Statistics Service (NASS). 2009. 22 2007 Census of Agriculture. Volume 1 Chapter 2: County Level Data for Pennsylvania. Table 1. 23 County Summary Highlights: 2007 and Table 7. Hired Farm Labor -Workers and Payroll: 2007. 24 Released February 4, 2009 and updated in December 2009. Available at 25 <http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_ 26 Level/Pennsylvania/st42_2_001_001.pdf > and 27 <http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_ 28 Level/Pennsylvania/st42_2_007_007.pdf > (accessed April 2012). 29 [USGS] U.S. Geological Survey. 2001. "North American Breeding Bird Survey: Route Location 30 and Availability." Available at <http://www.pwrc.usgs.gov/bbs/results/routemaps/index.html> 31 (accessed 8 May 2012). 32 [USGS] U.S. Geological Survey. 2008. "Geologic Hazards Team Interactive Map Server, 33 National Seismic Hazard Maps -2008." April 23, 2008. Available at <http://gldims.cr.usgs.gov> 34 (accessed 6 April 2012). 35 [USGS] U.S. Geological Survey. 2010a. Water-Data Report 2010, 01472000 Schuylkill River at 36 Pottstown, PA, Lower Delaware Basin Schuylkill Subbasin. Available at 37 <http://wdr.water.usgs.gov/wy2010/pdfs/01472000.2010.pdf> (accessed 16 May 2011). 38 [USGS] U.S. Geological Survey. 2010b. Water-Data Report 2010, 01463500 Delaware River at 39 Trenton, NJ, Delaware River Basin. Available at 40 <http://wdr.water.usgs.gov/wy2010/pdfs/01463500.2010.pdf> (accessed 16 May 2011). 41 [USGS] U.S. Geological Survey. 2011a. Water-Data Report 2011a, 01472620 East Branch 42 Perkiomen Creek near Dublin, PA, Lower Delaware Basin Schuylkill Subbasin. Available at 43 <http://wdr.water.usgs.gov/wy2011/pdfs/01472620.2011.pdf> (accessed 16 May 2011). 44 Purpose and Need for Action 2-101 [USGS] U.S. Geological Survey. 2011b. Water-Data Report 2011, 01473000 Perkiomen Creek 1 at Graterford, PA, Lower Delaware Basin Schuylkill Subbasin. Available at 2 <http://wdr.water.usgs.gov/wy2011/pdfs/01473000.2011.pdf> (accessed 16 May 2011). 3 [USGS] U.S. Geological Survey. 2012a. "Quaternary Fault and Fold Database of the United 4 States." February 25, 2011. Earthquake Hazards Program. Available at 5 <http://earthquake.usgs.gov/hazards/qfaults> (accessed 6 April 2012). 6 [USGS] U.S. Geological Survey. 2012b. "Circular Area Earthquake Search, NEIC: Earthquake 7 Search Results, U.S. Geological Survey Earthquake Data Base." (Search parameters: 8 USGS/NEIC (PDE) 1973 database, latitude 40.225 N, longitude -75.5873 W, radius 100 km). 9 March 2, 2012. Earthquake Hazards Program, National Earthquake Information. Available at 10 <http://earthquake.usgs.gov/earthquakes/eqarchives/epic/epic_circ.php> (accessed 11 6 April 2012). 12 [USGS] U.S. Geological Survey. 2012c. "Historic United States Earthquakes, Pennsylvania." 13 November 23, 2009. Earthquake Hazards Program. Available at 14 <http://earthquake.usgs.gov/earthquakes/states/historical_state.php> (accessed 6 April 2012). 15 [USGS] U.S. Geological Survey. 2012d. "Magnitude/Intensity Comparison." February 22, 2010. 16 Earthquake Hazards Program. Available at 17 <http://earthquake.usgs.gov/learn/topics/mag_vs_int.php> (accessed 6 April 2012). 18 Versar, Inc. 2003. The Delaware River Creel Survey 2002. Prepared for Pennsylvania Fish & 19 Boat Commission. May 2003. 20 [WHC] Wildlife Habitat Council. 2006. Site Assessment and Wildlife Management Opportunities 21 for Exelon Corporation's Limerick Generating Station. Report submitted to Limerick Generating 22 Station, Exelon Corporation. Silver Spring, MD: WHC. August 2006. 119 p. ADAMS Accession 23 No. ML12110A289. 24 Wheeler RL. 2006. Quaternary tectonic faulting in the Eastern United States. Engineering 25 Geology 82:165 -186. 26 Yahner RH, Bramble WC, Byrnes WR. 2001. Response of amphibian and reptile populations to 27 vegetation maintenance of an electric transmission line right -of-way. Journal of Arboriculture 28 27(4):215-221. Available at <http://joa.isa -arbor.com/request.asp? JournalID=1&ArticleID=2933 29 &Type=2> (accessed 8 May 2012). 30 Yahner RH, Yahner RT. 2007. Populations of small mammals on an electric transmission line 31 area in southeastern Pennsylvania. U.S. Arboriculture and Urban Forestry 33(6):433 -434. 32 Available at <http://joa.isa -arbor.com/request.asp?JournalID=1&ArticleID=3022&Type=2> 33 (accessed 8 May 2012). 34
3-1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHME NT 1 Facility owners or operators may need to undertake or, for economic or safety reasons, may 2 choose to perform refurbishment activities in anticipation of license renewal or during the license 3 renewal term. The major refurbishment class of activities characterized in the Generic 4 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996) is 5 intended to encompass actions which typically take place only once in the life of a nuclear plant, 6 if at all. Examples of these activities include, but are not limited to, replacement of boiling water 7 reactor recirculation piping and pressurized water reactor steam generators. These actions may 8 have an impact on the environment beyond those that occur during normal operations and may 9 require evaluation, depending on the type of action and the plant -specific design. Table 3 -1 lists 10 the environmental issues associated with refurbishment that the U.S. Nuclear Regulatory 11 Commission (NRC) staff (the staff) determined to be Category 1 issues in the GEIS. 12 Table 3-1. Category 1 Issues Related to Refurbishment 13 Issue GEIS Section(s) 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 Table 3-2 lists environmental issues related to refurbishment that the staff determined to be 14 plant-specific or inconclusive in the GEIS. These issues are Category 2 issues. The definitions 15 of Category 1 and 2 issues can be found in Section 1.4. 16 Environmental Impacts of Refurbishment 3-2 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 Threatened or endangered species (for all plants) Threatened or endangered species 3.9 E Air quality Air quality during refurbishment (nonattainment and maintenance areas) 3.3 F Socioeconomics 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 Environmental justice Environmental justice(a) Not addressed Not addressed (a) 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 Table B-2 of the GEIS identifies systems, structures, and components (SSCs) that are subject 2 to aging and might require refurbishment to support continued operation during the license 3 renewal period of a nuclear facility. In preparation for its license renewal application, Exelon 4 Generation Company, LLC (Exelon) performed an evaluation of these SSCs pursuant to Title 10 5 of the Code of Federal Regulation (10 CFR 54.21), in order to identify the need to undertake 6 any major refurbishment activities that would be necessary to support the continued operation of 7 Limerick Generating Station Units 1 and 2 (LGS) during the proposed 20 -year period of 8 extended operation. 9 In its SSC evaluation, Exelon did not identify the need to undertake any major refurbishment or 10 replacement actions associated with license renewal to support the continued operation of LGS 11 beyond the end of the existing operating license (Exelon 2011). Therefore, the staff will not 12 assess refurbishment activities in this SEIS. 13 Environmental Impacts of Refurbishment 3-3 3.1. References 1 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 2 Protection Regulations for Domestic Licensing and Related Regulatory Functions." 3 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 4 Renewal of Operating Licenses for Nuclear Power Plants." 5 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 6 Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating 7 License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) 8 Accession No. ML11179A104. 9 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact 10 Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. 11 May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 12 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 - Transportation, Table 9.1, 13 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants. In: 14 Generic Environmental Impact Statement for License Renewal of Nuclear Plants. 15 Washington, DC: NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS 16 Accession No. ML04069720. 17
4-1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 1 This chapter addresses potential environmental impacts related to the period of extended 2 operation of Limerick Generating Station, Units 1 and 2 (LGS). These impacts are grouped and 3 presented according to resource. Generic issues (Category 1) rely on the analysis presented in 4 the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants 5 (NRC 1996), unless otherwise noted. Site-specific issues (Category 2) have been analyzed for 6 LGS and assigned a significance level of SMALL, MODERATE, or LARGE, accordingly. Some 7 issues are not applicable to LGS because of site characteristics or plant features. For an 8 explanation of the criteria for Category 1 and Category 2 issues, as well as the definitions of 9 SMALL, MODERATE, and LARGE, refer to Section 1.4. 10 4.1. Land Use 11 Section 2.2.1 of this supplemental environmental impact statement (SEIS) describes the land 12 use around LGS. 13 Land use in the vicinity of nuclear power plants could be affected by the license renewal 14 decision. However, as discussed in the GEIS, onsite land use and power line right of way 15 (ROW) conditions are expected to remain unchanged during the license renewal term at all 16 nuclear plants and any impacts would therefore be SMALL. These issues were classified as 17 Category 1 issues in the GEIS and are listed in Table 4-1. 18 Exelon Generation Company, LLC's (Exelon) Environmental Report (ER) (Exelon 2011 a), 19 scoping comments, and other available information about land use in the vicinity of LGS, 20 Units 1 and 2 were reviewed and evaluated for new and significant information. The review 21 included a data gathering site visit to LGS. No new and significant information was identified 22 during this review that would change the conclusions in the GEIS. Therefore, for these 23 Category 1 issues, impacts during the renewal term are not expected to exceed those 24 discussed in the GEIS. 25 Montgomery County has been working to develop an interconnected system of open space and 26 trails along the Schuylkill River and within other natural resource areas of the county. The LGS 27 site contains land along the Schuylkill River that has been identified as part of the Schuylkill 28 River Greenway in the county plan. Onsite land use conditions at LGS are expected to remain 29 unchanged during the license renewal term. Therefore, activities associated with continued 30 reactor operations during the license renewal term are not expected to affect the use and 31 management of LGS lands identified as part of the Schuylkill River Greenway. 32 Table 4-1. Land Use Issues 33 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 Environmental Impacts of Operation 4-2 4.2. Air Quality 1 Section 2.2.2 of this report describes the meteorology and air quality in the vicinity of the LGS 2 site. One Category 1 air quality issue is applicable to LGS -air quality effects of transmission 3 lines. No Category 2 issues apply for air quality, as there is no planned refurbishment 4 associated with license renewal. The U.S. Nuclear Regulatory Commission (NRC) staff did not 5 identify any new and significant information related to the Category 1 air quality issue during the 6 review of Exelon's ER, the site audit, or during the scoping process. Therefore, there are no 7 impacts related to this issue beyond those discussed in the GEIS. For this issue, the GEIS 8 concluded that the impacts are SMALL. 9 Table 4-2. Air Quality Issues 10 Issue GEIS Section Category Air quality effects of transmission lines 4.5.2 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 4.3. Geologic Environment 11 4.3.1. Geology and Soils 12 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 13 protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51 , 14 "Environmental protection regulations for domestic licensing and related regulatory functions." 15 With respect to the geologic environment of a plant site, the revised rule amends Table B-1 in 16 Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 issue, "Geology and 17 soils." This new issue has an impact level of SMALL. This new Category 1 issue considers 18 geology and soils from the perspective of those resource conditions or attributes that can be 19 affected by continued operations during the renewal term. An understanding of geologic and 20 soil conditions has been well established at all nuclear power plants and associated 21 transmission lines during the current licensing term, and these conditions are expected to 22 remain unchanged during the 20 -year license renewal term for each plant. The impact of these 23 conditions on plant operations and the impact of continued power plant operations and 24 refurbishment activities on geology and soils are SMALL for all nuclear power plants and not 25 expected to change appreciably during the license renewal term. Operating experience shows 26 that any impacts to geologic and soil strata would be limited to soil disturbance from 27 construction activities associated with routine infrastructure renovation and maintenance 28 projects during continued plant operations. Implementing best management practices would 29 reduce soil erosion and subsequent impacts on surface water quality. Information in 30 plant-specific SEISs prepared to date and reference documents has not identified these impacts 31 as being significant. 32 Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to 33 LGS. The NRC staff did not identify any new and significant information with regard to th is 34 Category 1 (generic) issue based on review of the ER (Exelon 2011a), the public scoping 35 process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS 36 and as identified in the ER (Exelon 2011a), Exelon has no plans to conduct refurbishment or 37 replacement actions associated with license renewal to support the continued operation of LGS. 38 Further, Exelon anticipates no new construction or other ground disturbing -activities or changes 39 in operations and that operation and maintenance activities would be confined to previously 40 Environmental Impacts of Operation 4-3 disturbed areas or existing ROWs. Based on this information, it is expected that any 1 incremental impacts on geology and soils during the license renewal term would be SMALL. 2 4.4. Surface Water Resources 3 The Category 1 (generic) and Category 2 surface water use and quality issues applicable to 4 LGS, Units 1 and 2 are discussed in the following sections and listed in Table 4 -3. Surface 5 water resources -related aspects and conditions relevant to the LGS site are described in 6 Sections 2.1.7.1 and 2.2.4. 7 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 Water use conflicts (plants with cooling ponds or cooling towers using makeup water from a river with low flow) 4.3.2.1 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 4.4.1. Generic Surface Water Issues 9 The NRC staff did not identify any new and significant information with regard to the Category 1 10 (generic) surface water issues based on review of the ER (Exelon 2011a), the public scoping 11 process, or as a result of the environmental site audit. As a result, no information or impacts 12 related to these issues were identified that would change the conclusions presented in the 13 GEIS. Therefore, it is expected that there would be no incremental impacts related to these 14 Category 1 issues during the renewal term beyond those discussed in the GEIS. For these 15 surface water issues, the GEIS concludes that the impacts are SMALL. 16 4.4.2. Surface Water Use Conflicts 17 This section presents the NRC staff's review of plant -specific (Category 2) surface water use 18 conflict issues as listed in Table 4-3. 19 4.4.2.1. Plants Using Makeup Water from a Small River with Low Flow 20 For nuclear power plants utilizing cooling towers or cooling ponds supplied with makeup water 21 from a small river, the potential impact on the flow of the river and related impacts on instream 22 and riparian ecological communities is considered a Category 2 issue, thus, requiring a 23 plant-specific assessment. A small river is defined in 10 CFR 51.53(c)(3)(ii)(A) as one whose 24 annual flow rate is less than 3.15x10 12 ft 3/yr (9x10 10 m 3/yr) or 100,000 cfs (2,820 m 3/s). LGS has 25 a closed-cycle, heat -dissipation system that uses natural draft cooling towers with makeup 26 Environmental Impacts of Operation 4-4 water pumped from the Schuylkill River (see Section 2.1.7). As noted in Section 2.2.4.1, the 1 Schuylkill River near the LGS site has a mean annual flow rate of less than 2 6.3 x 10 10 ft 3/yr (2,000 cfs). Therefore, an assessment of the impact of the proposed action on 3 the flow of the river is required. 4 Flow conditions in the Schuylkill River have required Exelon to supplement LGS' s water 5 sources. As discussed in Section 2.2.4.1, the mean annual flow and 90 percent exceedance 6 flow for the Schuylkill River, as measured at the U.S. Geological Survey (USGS) Pottstown, 7 Pennsylvania, gage station, total 1,935 cfs (54.8 m 3/s) and 482 cfs (13.6 m 3/s), respectively. 8 Against these measures of flow, the withdrawal of water at the maximum consumptive use 9 permitted by the Delaware River Basin Commission (DRBC) (65 cfs (1.84 m 3/s)) represents a 10 3.4 percent and a 13 percent reduction, respectively, in the flow of the Schuylkill River 11 downstream of LGS. In order to limit downstream, including aquatic and riparian, impacts in the 12 Schuylkill River during low flow, the DRBC requires LGS to augment its consumptive use of 13 water when the river flow falls to 560 cfs (15.9 m 3/s), based on two -unit operation. This is 14 accomplished either through withdrawing makeup water directly from other DRBC -approved 15 water sources or through augmentation of the flow in the Schuylkill River through surface water 16 diversion, as described in Section s 2.1.6 and 2.1.7.1 of this SEIS. 17 In 2003, as part of a demonstration project approved by the DRBC, Exelon included water from 18 Wadesville Mine Pool and the Still Creek Reservoir in its portfolio of water sources for flow 19 augmentation. Since their use presently remains a demonstration project and has not received 20 final docket approval from the DRBC (Docket No. D 210, as revised), the NRC staff did not 21 consider these alternative water sources in its impact level determination. Before 2003, the 22 frequency of water withdrawals by LGS for consumptive use was approximately 50 percent from 23 the Schuylkill River , 4 percent from Perkiomen Creek natural flow, and 46 percent from 24 Perkiomen Creek supplemented by water diverted from the Delaware River. Under the 25 demonstration project with releases from the Wadesville Mine Pool to the Schuylkill River, the 26 frequency of withdrawals from the Schuylkill River to support LGS consumptive uses has 27 increased (Exelon 2012a). This trend toward an increasing reliance on augmented flows in the 28 Schuylkill River would be expected to increase during the license renewal term should the 29 demonstration project continue or be made permanent by DRBC, as requested by Exelon. 30 Regardless of the above considerations, the DBRC Comprehensive Plan (DRBC 2001) includes 31 consideration of LGS operations. The DBRC 's mission includes water conservation, control, 32 use, and management, which is to be accomplished through the adoption and promotion of 33 uniform and coordinated policies basin -wide (DRBC 1961). The DBRC requirement that LGS 34 shift to alternative water sources when the flow of the Schuylkill River falls to 560 cfs (15.9 m 3/s) 35 ensures that LGS cooling water withdrawals and associated consumptive use will not reduce 36 river flow by more than 12 percent during low -flow periods. During average flows, LGS 37 operations will reduce the flow by about 3 percent. Therefore, because DRBC imposes 38 requirements to ensure that LGS's consumptive water use from the Schuylkill River remains 39 within acceptable limits , the NRC staff concludes that the impact on surface water resources 40 and downstream water availability from consumptive water use by LGS, Units 1 and 2 during 41 the license renewal term would be SMALL. 42 4.5. Groundwater Resources 43 The Category 1 (generic) and Category 2 groundwater use and quality issues applicable to LGS 44 are discussed in the following sections and listed in Table 4-4. Groundwater resources related 45 aspects and conditions relevant to the LGS site are described in Sections 2.1.7.2 and 2.2.5. 46 Environmental Impacts of Operation 4-5 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(a) 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b 4.5.1. Generic Groundwater Issues 2 Section 2.2.5 of this SEIS discusses groundwater use and quality at LGS. The NRC staff did 3 not identify any new and significant information with regard to Category 1 (generic) groundwater 4 issues based on the review of the ER (Exelon 201 1a), the public scoping process, or as a result 5 of the environmental site audit. NRC staff also reviewed other sources of information, such as 6 various permits and data reports. As a result, no information or impacts related to these issues 7 were identified that would change the conclusions presented in the GEIS. Therefore, for the 8 single issue found to be directly applicable to LGS, it is expected that there would be no 9 incremental impacts related to this Category 1 issue during the renewal term beyond those 10 discussed in the GEIS. For this groundwater issue, the GEIS concludes that the impacts are 11 SMALL. 12 4.5.2. Groundwater Use and Quality Conflicts 13 This section presents the NRC staff's review of pl ant-specific (Category 2) groundwater 14 resources issues as listed in Table 4-4. 15 4.5.2.1. Plants Using Cooling Towers Withdrawing Makeup Water from a Small River, Alluvial 16 Aquifers 17 For nuclear power plants utilizing cooling towers supplied with makeup water from a small river 18 (as defined in Section 4.3.2 .1), the potential impact on alluvial aquifers is also considered a 19 Category 2 issue, thus, requiring a plant -specific assessment. This groundwater aspect was 20 classified as a Category 2 issue in the GEIS because consumptive use of water withdrawn from 21 a small river could adversely affect groundwater aquifer recharge. Low river flow conditions are 22 of particular interest. 23 Based on the topography of the plant site and review of local groundwater elevations, NRC staff 24 determined that groundwater flow across and in the vicinity of the plant site predominately 25 discharges to the Schuylkill River and Possum Hollow Run. Groundwater provides baseflow to 26 these surface waters. For groundwater use conflicts to occur due to reduced streamflow, the 27 affected stream segments must also be a principal source of recharge to an affected aquifer, 28 which is not the case. Recharge to the bedrock aquifer (Brunswick) in the region predominantly 29 occurs in upgradient areas from precipitation and runoff, as described in Section 2.2.5.1 of the 30 SEIS. In addition, the alluvial sediments and regolith overlying the area's bedrock are relatively 31 thin and not used as a source of groundwater. A review of Pennsylvania water well records 32 within a 1-mi (1.6-km) radius of the LGS site revealed that all recorded wells are in the 33 Brunswick Formation rather than in surficial materials . Therefore, the NRC staff concludes that 34 Environmental Impacts of Operation 4-6 continued withdrawals of surface water for the operation of LGS, Units 1 and 2 during low -flow 1 periods would have a SMALL impact on groundwater recharge during the license renewal term. 2 4.5.2.2. Radionuclides Released to Groundwater 3 In its ER (Exelon 2011a), Exelon identified the presence of tritium in groundwater as new, but 4 not significant, information based on site groundwater monitoring. In response, the NRC staff 5 specifically reviewed information relating to the current state of knowledge on groundwater 6 quality beneath and downgradient of LGS, as detailed in Section 2.2.5.2 and summarized 7 below. 8 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 9 protection regulation, 10 CFR Part 51. With respect to groundwater quality, the revised rule 10 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 11 Category 2 issue, "Radionuclides released to groundwater," with an impact level range of 12 SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from 13 plant systems into groundwater. This new Category 2 issue has been added to evaluate the 14 potential impact to groundwater quality from the discharge of radionuclides from plant systems, 15 piping, and tanks. This issue was added because, within the past several years, there have 16 been events at nuclear power reactor sites that involved unknown, uncontrolled, and 17 unmonitored releases of radioactive liquids into the groundwater. 18 Exelon commissioned a hydrogeologic investigation in 2006 (CRA 2006), in part, to evaluate the 19 potential impacts on groundwater quality of any inadvertent releases of tritium or other 20 LGS-related radionuclides and to identify and eliminate contributing sources of radionuclides to 21 groundwater. The investigation provided the basis for the site's current Radiological 22 Groundwater Protection Program (RGPP). 23 As part of the 2006 investigation, a network of 15 onsite groundwater monitoring wells was 24 installed in the Brunswick Formation (bedrock aquifer) at LGS. From the initial 2006 sampling, 25 no strontium -90 or gamma -emitting radionuclides were detected in groundwater or surface 26 water above analytical detection limits. Tritium was detected in five of the monitoring wells at 27 relatively low wells, but one well (P12), located immediately south and downgradient of the 28 power block, had a concentration of 4,360 +/- 494 pCi/L. At the same time, a sample from the 29 power block foundation sump had tritium at 2,020 +/- 154 pCi/L. As noted in Section 2.2.5.2, 30 well P12 was replaced with well no. MW -LR-9 in August 2006, to be more representative of 31 water table conditions beneath the site. Sampling of this new well yielded tritium at 32 1,500 +/- 210 pCi/L. 33 Under the ongoing RGPP at LGS, groundwater and surface water samples are collected and 34 analyzed for tritium and other radionuclides at least semi -annually. The results are reported in 35 annual radiological environmental operati ng (REOP) reports (Exelon 2008 a, 2009 a, 2010 a , 36 2011b, 2012b) that are submitted to the NRC. Since 2006, there have been no detections in 37 groundwater of gamma -emitting radionuclides or strontium -90 associated with LGS operations. 38 The peak tritium level observed in groundwater was 1,750 pCi/L in well MW-LR-9 in 2009. 39 Exelon traced this to a condensate release in February 2009, which was corrected (see 40 Section 2.2.5.2). Tritium in MW-LR-9 had decreased to a maximum of 1,154 pCi/L by 41 April 2011. It is noted that tritium concentrations have exceeded 2,000 pCi/L in samples from 42 the power block foundation sump since 2006 (Exelon 2011a). Regardless, monitoring data 43 indicate s that there is no migration of tritium in groundwater at LGS at concentrations exceeding 44 2,000 pCi/L, and observed tritium levels have been well within the U.S. Environmental 45 Protection Agency (EPA) primary drinking water standard (i.e., 20,000 pCi/L) at all onsite 46 monitoring wells. In addition, there are no potable water wells downgradient of the LGS power 47 block and no drinking water pathway. The plant's potable water supply well (well 1) is located 48 Environmental Impacts of Operation 4-7 about 1,000 ft (300 m) upgradient and slightly cross -gradient (northeast) of MW -LR-9 and the 1 power block sump pit. Based on the information presented and the NRC staff's review, NRC 2 staff concludes that inadvertent releases of tritium have not substantially impaired site 3 groundwater quality or affected groundwater use downgradient of the LGS site. The NRC staff 4 further concludes that groundwater quality impacts would remain SMALL during the license 5 renewal term. 6 4.6. Aquatic Resources 7 Section 2.1.6 of this SEIS describes the L GS cooling-water system; Section 2.2.5 describes the 8 aquatic resources. Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 , 9 which are applicable to the operation of the LGS cooling-water systems during the renew ed 10 license term, are listed in Table 4-5. There are no Catego ry 2 issues that apply to aquatic 11 resources at LGS. The NRC staff did not find any new and significant information during the 12 review of the applicant's ER (Exelon 2011a), the site audit, the scoping process, or the 13 evaluation of other available information; therefore, the NRC staff concludes that there are no 14 impacts related to aquatic resource issues beyond those discussed in the GEIS (NRC 1996) 15 and the revised rule (NRC 2012b). Consistent with the GEIS, the NRC staff concludes that the 16 impacts are SMALL, and additional site -specific mitigation measures are unlikely to be 17 sufficiently beneficial to warrant implementation. 18 Table 4-5. Aquatic Resources Issues 19 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 Exposure of aquatic organisms to radionuclides To be determined(a) 1 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 Heat shock 4.3.3 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b Environmental Impacts of Operation 4-8 4.6.1. Exposure of Aquatic Organisms to Radionuclides 1 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 2 protection regulation, 10 CFR Part 51. With respect to the aquatic organisms, the revised rule 3 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 4 Category 1 issue, "Exposure of aquatic organisms to radionuclides," among other changes. 5 This new Category 1 issue considers the impacts to aquatic organisms from exposure to 6 radioactive effluents discharged from a nuclear power plant during the license renewal term. An 7 understanding of the radiological conditions in the aquatic environment from the discharge of 8 radioactive effluents within NRC regulations has been well established at nuclear power plants 9 during their current licensing term. Based on this information, the NRC concluded that the 10 doses to aquatic organisms are expected to be well below exposure guidelines developed to 11 protect these organisms and assigned an impact level of SMALL. 12 The NRC staff has not identified any new and significant information related to the exposure of 13 aquatic organisms to radionuclides during its independent review of LGS's ER, the site audit, 14 and the scoping process. Section 2.1.2 of this SEIS describes the applicant's radioactive waste 15 management program to control radioactive effluent discharges to ensure that they comply with 16 NRC regulations in 10 CFR Part 20, "Standards for protection against radiation." Section 4.9.3 17 of this SEIS contains the NRC staff's evaluation of the LGS's radioactive effluent and 18 radiological environmental monitoring programs. LGS's radioactive effluent and radiological 19 environmental monitoring programs provide further support for the conclusion that the impacts 20 of aquatic organisms from radionuclices are SMALL. The NRC staff concludes that there would 21 be no impacts to aquatic organisms from radionuclides beyond those impacts contained in 22 Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule and, therefore, the 23 impacts to aquatic organisms from radionuclides are SMALL. 24 4.7. Terrestrial Resources 25 The Category 1 (generic) and Category 2 (site-specific) terrestrial resources issues applicable to 26 LGS are discussed in the following sections and listed in Table 4-6. Terrestrial resources 27 issues that apply to LGS are described in Sections 2.2.7 and 2.2.8. 28 Table 4-6. Terrestrial Resources Issues 29 Issue GEIS Section Category Cooling tower impacts on crops and ornamental vegetation 4.3.4 1 Cooling tower impacts on native plants 4.3.5.1 1 Bird collisions with cooling towers 4.3.5.2 1 Power line right -of-way management (cutting herbicide application) 4.5.6.1 1 Bird collisions with power lines 4.5.6.2 1 Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 1 Floodplains and wetland on power line right -of-way 4.5.7 1 Exposure of terrestrial organisms to radionuclid es To be determined(a) 1 Effects on terrestrial resources (non -cooling system impacts) To be determined(a) 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b Environmental Impacts of Operation 4-9 4.7.1. Generic Terrestrial Resources Issues 1 For the Category 1 terrestrial resources issues listed in Table 4 -6, the NRC staff did not identify 2 any new and significant information during the review of the E R (Exelon 2011a), the NRC staff's 3 site audit, the scoping process, or the evaluation of other available information. Therefore, there 4 are no impacts related to these issues beyond those discussed in the GEIS and the revised rule 5 (NRC 2012b). For these issues, the GEIS and the revised rule concluded that the impacts are 6 SMALL, and additional site -specific mitigation measures are not likely to be sufficiently 7 beneficial to warrant implementation. 8 4.7.1.1. Exposure of Terrestrial Organisms to Radionuclides 9 As described in Section 1.4 of this draft SEIS, the NRC has approved a revision to its 10 environmental protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, 11 the revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a 12 new Category 1 issue, "Exposure of terrestrial organisms to radionuclides," among other 13 changes. This new issue has an impact level of SMALL. This new Category 1 issue considers 14 the impacts to terrestrial organisms from exposure to radioactive effluents discharged from a 15 nuclear power plant during the license renewal term. An understanding of the radiological 16 conditions in the terrestrial environment from the discharge of radioactive effluents within NRC 17 regulations has been well established at nuclear power plants during the ir current licensing 18 term. Based on this information, the NRC concluded that the doses to terrestrial organisms are 19 expected to be well below exposure guidelines developed to protect these organisms and 20 assigned an impact level of SMALL. 21 The NRC staff has not identified any new and significant information related to the exposure of 22 terrestrial organisms to radionuclides during its independent review of LGS's ER, the site audit, 23 and the scoping process. Section 2.1.2 of this SEIS describes the applicant's radioactive waste 24 management program to control radioactive effluent discharges to ensure that they comply with 25 NRC regulations in 10 CFR Part 20. Section 4.9.3 of this SEIS contains the NRC staff's 26 evaluation of LGS's radioactive effluent and radiological environmental monitoring programs, 27 which provide further support for the conclusion that the impacts from radioactive effluents are 28 SMALL. 29 Therefore, the NRC staff concludes that there would be no impact to terrestrial organisms from 30 radionuclides beyond those impacts contained in Table B -1 in Appendix B, Subpart A, to 31 10 CFR Part 51of the revised rule and, therefore, the impacts to terrestrial organisms from 32 radionuclides are SMALL. 33 4.7.2. Effects on Terrestrial Resources (Non-Cooling System Impacts) 34 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 35 protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revised rule 36 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by expanding the 37 Category 2 issue, "Refurbishment impacts," among others, to include normal operations, 38 refurbishment, and other supporting activities during the license renewal term. This issue 39 remains a Category2 issue with an impact level range of SMALL to LARGE; however, the 40 revised rule renames this issue "Effects on terrestrial resources (non -cooling system impacts)." 41 Section 2.2.7 describes the terrestrial resources on and in the vicinity of the LGS site and 42 vicinity, and Section 2.2.8 describes protected species and habitats. During construction of 43 LGS, approximately 42 percent of the plant site (270 ac (110 ha )) was cleared for building s , 44 parking lots, roads, and other infrastructure. The remaining terrestrial habitats have not 45 changed significantly since construction. As discussed in Chapter 3 of this SEIS and according 46 Environmental Impacts of Operation 4-10 to the applicant's ER (Exelon 2011a), Exelon has no plans to conduct refurbishment or 1 replacement actions associated with license renewal to support the continued operation of LGS. 2 Further, Exelon (2011a) anticipates no new construction or other ground-disturbing activities, 3 changes in operations, or changes in existing land use conditions because of license renewal. 4 Exelon (2011a) reports that operation and maintenance activities would be confined to 5 previously disturbed areas or existing ROWs. As a result, Entergy (2011a) anticipates no new 6 impacts on the terrestrial environment on the LGS site or along the in-scope transmission line 7 corridors during the license renewal term. Based on the staff's independent review, the staff 8 concurs that operation and maintenance activities that Exelon might undertake during the 9 renewal term, such as maintenance and repair of plant infrastructure (e.g., roadways, piping 10 installations, onsite transmission lines, fencing, and other security infrastructure), likely would be 11 confined to previously disturbed areas of the LGS site. Therefore, the staff expects non -cooling 12 system impacts on terrestrial resources during the license renewal term to be SMALL. 13 4.8. Protected Species and Habitats 14 Section 2.2.7 of this SEIS describes the action area, as defined by the ESA regulations at 15 50 CFR 402.02, and describes the protected species and habitats within the action area 16 associated with the LGS license renewal. Table 4-7 lists the one Category 2 issue related to 17 protected species and habitats that is applicable to LGS. 18 Table 4-7. Protected Species and Habit ats Issues 19 Issue GEIS Section Category Threatened or endangered species 4.1 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 4.8.1. Correspondence with Federal and State Agencies 20 In accordance with Section 7 of the Endangered Species Act (ESA), in a letter to the U.S. Fish 21 and Wildlife Service (FWS), dated September 8, 2011, the NRC staff requested information 22 regarding Federally listed species in the action area (NRC 2011d). Also in accordance with 23 Section 7 of the ESA, the NRC staff sent a similar request regarding Federally listed species to 24 the National Marine Fisheries Service (NMFS) (NRC 2012a). The NRC staff sent further 25 requests to the Pennsylvania Fish and Boat Commission (PFBC) (NRC 2011e), Pennsylvania 26 Game Commission (PGC) (NRC 2011g), and Pennsylvania Department of Conservation and 27 Natural Resources (PDCNR) (NRC 2011f) regarding the presence of Pennsylvania -listed 28 species in the action area. The PFBC, PGC, FWS, and NMFS responded to the NRC staff in 29 letters dated October 5, 2011 (PFBC 2011 b); November 17, 2011 (PGC 2011); 30 November 22, 2011 (FWS 2011 b); and June 2, 2012 (NMFS 2012c), respectively. The PFBC 31 noted that the eastern redbelly turtle (Pseudemys rubriventris) and globally rare amphipods 32 and/or isopods may be in the project area (PFBC 2011 b); Section 4.7.3 considers the potential 33 effects to this species. The PGC determined that no impacts to Pennsylvania -listed threatened 34 or endangered birds or mammals under PGC responsibility would be likely from the proposed 35 license renewal (PGC 2011). The FWS indicated that the proposed project is within the known 36 range of the bog turtle (Clemmys muhlenbergii) (FWS 2011 b); Section 4.7.3 considers the 37 potential effects to this species. However, because FWS concluded that the proposed action is 38 not likely to have an adverse effect on the bog turtle, no further consultation with FWS under 39 Section 7 of the ESA is required. NMFS stated that no species listed under the ESA occur 40 Environmental Impacts of Operation 4-11 within the action area (NMFS 2012c). NMFS also stated that two candidate species -alewife 1 (Alosa pseudoharengus) and blueback herring (Alosa aestivalis) -occur in the project area. 2 However, as candidate species, NMFS is still considering whether the species should be listed 3 and protected under ESA. Therefore, no further consultation with NMFS under Section 7 of the 4 ESA is required. The NRC staff has not received a response from the PDCNR to date. 5 However, in a March 9, 2011, letter to Exelon, the PDCNR identified several plant species that 6 occur within the action area near LGS transmission line corridors (PDCNR 2011). The PDCNR 7 indicated that because the proposed license renewal does not involve new construction, 8 refurbishment, ground disturbance, or changes to operations or existing land -use conditions, no 9 impact is likely to occur to species under the PDCNR's jurisdiction (PDCNR 2011). 10 4.8.2. Aquatic Species and Habitats 11 For purposes of its protected species and habitat discussion and analysis, the NRC staff 12 considers the action area, as defined by 50 CFR 402.02, to include the lands and waterbodies 13 associated with LGS, as defined in Section 2.2.7. Two fish species and one aquatic 14 invertebrate protected under the ESA may occur in the Delaware River or in small waterbodies 15 throughout Pennsylvania (FWS 2012, NMFS 2012a). Two fish within the action area are 16 considered candidate species and species of concern by NMFS (NMFS 2012c). Three 17 additional fish species, one additional aquatic invertebrate, and four aquatic plant species listed 18 as a species of special concern, endangered, or threatened by the Commonwealth of 19 Pennsylvania may occur in waterbodies in Bucks, Chester, or Montgomery Counties 20 (PNHP 2012a). 21 4.8.2.1. Federally Protected Species 22 Shortnose Sturgeon (Acipenser brevirostrum ) 23 The endangered shortnose sturgeon uses the tidal, estuarine, and lower portion of the Delaware 24 River in Bucks County, Pennsylvania (NMFS 2012b). LGS-related studies from 1979 -1985 did 25 not observe shortnose sturgeon eggs or larvae at the Point Pleasant Pumping Station and 26 downriver to river mi (RM) 138 (river km (RKm) 222.1) (Exelon 2011a; RMC 1984, 1985, 1986). 27 The most recent population studies observed the farthest upriver migration up to 9 RM 28 (15 RKm) below the Point Pleasant Pumping Station, which is located at RM 157 (RKm 253) 29 (Hastings et al. 1987, O 'Herron et al. 1993). NMFS stated that no species listed under the ESA 30 occur within the action area (NMFS 2012c) . 31 The NRC staff concludes that the proposed LGS license renewal would have no effect on the 32 shortnose sturgeon because: 33 NMFS (2012 c) stated that no species listed under the ESA occur within the 34 action area, 35 the LGS intake at the Point Pleasant Pumping Station is approximately 9 RM 36 (15 RKm) upriver of the farthest known upriver occurrence of this species, 37 LGS-related studies from 1979 -1985 did not observe Atlantic sturgeon eggs 38 or larvae near the Point Pleasant Pumping Station, and 39 no new construction, refurbishment, ground -disturbing activities, or changes 40 to existing land use conditions at the Point Pleasant Pumping Station would 41 occur. 42 Environmental Impacts of Operation 4-12 Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus ) 1 The endangered Atlantic sturgeon uses the tidal, estuarine, and lower portion of the Delaware 2 River in Bucks County, Pennsylvania (NMFS 2012b). LGS-related studies from 1979 to 1985 3 did not observe Atlantic sturgeon eggs or larvae at the Point Pleasant Pumping Station and 4 downriver to 138 RM (222.1 RKm) (Exelon 2011 a; RMC 1984, 1985, 1986 ). Tagging studies 5 in 2005 and 2006 indicated that Atlantic sturgeon followed similar migration patterns as 6 shortnose sturgeon with spawning potentially occurring in the upper tidal Delaware reaches 7 between Philadelphia, Pennsylvania, and Trenton, New Jersey (Simpson and Fox undated). 8 NMFS (2012 c) stated that no species listed under the ESA occur within the action area. 9 The NRC staff concludes that the proposed LGS license renewal would have no effect on 10 Atlantic sturgeon because: 11 NMFS (2012) stated that no species listed under the ESA occur within the 12 action area, 13 LGS-related studies from 1979 to1985 did not observe Atlantic sturgeon eggs 14 or larvae near the Point Pleasant Pumping Station, and 15 no new construction, refurbishment, ground -disturbing activities, or changes 16 to existing land use conditions at the Point Pleasant Pumping Station would 17 occur. 18 Dwarf Wedgemussel (Alasmidonta heterodon ) 19 FWS (2012 b) lists the endangered dwarf wedgemussel as known to or believed to occur in 20 Monroe, Pike, and Wayn e Counties, Pennsylvania, which is not part of the action area. PNHP 21 (2012a) lists the dwarf wedgemussel as potentially occurring in Bucks, Chester, and 22 Montgomery Counties. The Philadelphia Electric Company (PECO 1984) observed rare, 23 unidentified species of the genus Alasmidonta in the Schuylkill River in the 1970s and it is 24 unknown whether the specimens were the dwarf wedgemussel (Exelon 2011 a). Other than the 25 rare Alasmidonta specimens observed in the 1970s in the Schuylkill River, LGS-related studies 26 did not observe dwarf wedgemussels during benthic surveys in East Branch Perkiomen Creek, 27 Perkiomen Creek, and the Schuylkill River between 1970 and 2009 (Exelon 2011 a; NAI 2010c; 28 PECO 1984; RMC 1984, 1985, 1986, 1987, 1989). 29 Both Exelon and the NRC sta ff contacted FWS to request information on potential impacts to 30 Federally protected species. In a March 22, 2011, letter to Exelon, FWS (2011a) did not identify 31 the dwarf wedgemussel as a concern in regard to LGS's proposed license renewal. In a 32 November 22, 2011, letter to the NRC, the FWS (2011b) confirmed that the conclusions in their 33 previous letter to Exelon were still appropriate. 34 Therefore, the NRC staff concludes that the proposed LGS license renewal would have no 35 effect, on dwarf wedgemussel because effects to the species would be insignificant, 36 discountable, or beneficial . 37 4.8.2.2. Pennsylvania -Protected Species, Candidate Species, and Species of Concern 38 Fish 39 The Commonwealth of Pennsylvania lists the banded sunfish (Enneacanthus obesus) and the 40 longear sunfish (Lepomis megalotis) as endangered in Bucks County (PNHP 2012a). The 41 Pennsylvania endangered ironcolor shiner (Notropis chalybaeus) occurs in Bucks and 42 Montgomery Counties (PNHP 2012a). Blueback herring and alewife are considered candidate 43 species and NMFS species of concern (NMFS 2012). 44 Environmental Impacts of Operation 4-13 LGS-related activity in Bucks County that could affect the blueback herring, alewife, banded 1 sunfish, longear sunfish, or ironcolor shiner and their habitat is the intermittent withdrawal of 2 Delaware River water for the LGS cooling system. Direct impacts could include impingement or 3 entrainment and indirect impacts could include impingement or entrainment of prey. Blueback 4 herring and alewife eggs are demersal and adhesive, which make them less likely to be 5 entrained. Eggs and larvae entrained in the Point Pleasant Pumping Station would be 6 transported from the Delaware River to the East Branch Perkiomen Creek. Eggs and larvae 7 would experience sudden pressure fluctuations, velocity shear forces, and physical abrasion in 8 the pumps at Point Pleasant and Bradshaw Reservoir and throughout the pipeline. If any eggs 9 or larvae survive the transport, successful development would depend on organisms finding 10 suitable habitat. Prey species that survive the transport would no longer be available as prey for 11 fish in the Delaware River. 12 LGS license renewal would include continued operation at the Point Pleasant Pumping Station. 13 However, as described in Section 2.1.6, Exelon 's withdrawal of water from the Delaware River 14 is secondary to its withdrawal of water from the Schuylkill River, and Exelon plans to continue to 15 rely less on the Delaware River and more on the Schuylkill River in the future (Exelon 2012 a). 16 LGS license renewal would not involve new construction, refurbishment, ground -disturbing 17 activities, or changes to existing land use conditions at the Point Pleasant Pumping Station. 18 Transmission lines associated with LGS do not cross any portion of the Delaware River 19 (Exelon 2011 a). 20 In addition to Bucks County, blueback herring, alewife, and the ironcolor shiner may occur in 21 Montgomery County. Waters in Montgomery County associated with LGS include East Branch 22 Perkiomen Creek, Perkiomen Creek, and the Schuylkill River.LGS license renewal would 23 include continued operation at the Perkiomen Pumphouse, the Schuylkill Pumphouse, and the 24 Schuylkill River discharge structure . Direct effects could include mortality if fish are impinged or 25 entrained. Blueback herring and alewife eggs are demersal and adhesive, which make them 26 less likely to be entrained. Indirect effects could include a decrease in habitat quality from 27 thermal discharge in the Schuylkill River. However, the flow, temperature, and other conditions 28 of the discharge are regulated by LGS's NPDES permit, which would limit changes in water 29 quality. Indirect effects could also occur from the Delaware River intrabasin transfer of water, 30 which involves diversion of Delaware River water to the East Branch Perkiomen Creek that 31 discharges by gravity flow to Perkiomen Creek in order to augment the flow in Perkiomen 32 Creek. As described in Section 2.2.6, NAI (2010 a) sampled aquatic biota between 2001 33 and 2009 as part of an analysis to examine post -operational effects of the water diversion effort 34 (Exelon 2 011 a). Species diversity remained relatively consistent and samples continued to be 35 dominated by midges and oligochaetes. In addition, less variability existed along the stream 36 gradient and over time
- NAI noted that pollution
-sensitive species increased in abundance 37 (NAI 2010 a , 2010c). 38 The LGS license renewal would include continued operation and maintenance of four 39 transmission lines that extend from the Limerick site and travel and cross portions of the 40 Schuylkill River and Perkiomen Creek (Section 2.1.5 describes the in -scope transmission lines 41 in more detail). The transmission lines associated with LGS cross rivers and streams that have 42 the potential to be blueback herring, alewife, or ironcolor shiner habitat. PECO must maintain 43 the transmission lines and associated structures and manage vegetation along the transmission 44 line corridors to prevent interference with the lines. Line and vegetation maintenance may result 45 in a temporary decline in habitat quality from increased sedimentation and turbidity during 46 maintenance activities. 47 If PECO needs to perform maintenance in or near waterbodies , it takes a number of precautions 48 to avoid impacts to blueback herring, alewife, and ironcolor shiners or their habitat. First, PECO 49 Environmental Impacts of Operation 4-14 typically performs mechanical vegetation maintenance activities on foot and does not operate 1 heavy machinery near wetlands and water bodies. This type of maintenance avoids the 2 potential for heavy machinery to affect fish habitat by reducing the amount of sedimentation and 3 turbidity in the stream. Foot traffic could result in some minimal disturbance of fish habitat. 4 However, foot traffic would create impacts that are insignificant (i.e., those impacts that would 5 never reach the scale where fish mortality would occur) or discountable (i.e., those impacts that 6 cannot be meaningfully measured, detected, or evaluated). In addition, PECO must obtain 7 several permits and certifications for maintenance activities in wetlands or near waterbodies, 8 which for a given work area may include: (1) a General Permit or Water Obstruction and 9 Encroachment General Permit issued jointly by the USACE and P ADEP, (2) a CWA 404 permit 10 issued by the USACE, or (3) an erosion and sedimentation control plan from the appropriate 11 county conservation district. 12 LGS license renewal would not involve new construction, refurbishment, ground -disturbing 13 activities, or changes to existing land use conditions at LGS-associated facilities or transmission 14 lines. 15 The NRC staff contacted PFBC to request information on potential impacts to 16 Pennsylvania -protected species. In an October 5, 2011, letter to the NRC, PFBC (PFBC 2011 b) 17 did not identify the banded sunfish, longear sunfish, or the ironcolor shiner as a concern in 18 regard to LGS's proposed license renewal. 19 Pizzini's Amphipod 20 The Pizzini's cave amphipod (Stygobromus pizzinii), previously named Stygonectes pizzinii , is a 21 Pennsylvania species of concern and is possibly extirpated in Montgomery and Chester 22 Counties (PNHP 2012 a). Based on the Pennsylvania Natural Diversity Inventory (PNDI) 23 database and PFBC files, PFBC (2011) stated in its letter to the NRC that globally rare 24 amphipod and/or isopod species are known to occur within the vicinity of the LGS site. 25 LGS license renewal would include continued operation at the Perkiomen Pumphouse, the 26 Schuylkill Pumphouse, and the Schuylkill River discharge structure . Direct effects could include 27 mortality if amphipods are entrained. Indirect effects could include a decrease in habitat quality 28 from thermal discharge in the Schuylkill River. However, the flow, temperature, and other 29 conditions of the discharge are regulated by LGS's NPDES permit, which would limit changes in 30 water quality. Indirect effects could also occur from the Delaware River intrabasin transfer of 31 water, which involves diversion of Delaware River water to the East Branch Perkiomen Creek 32 that discharges by gravity flow to Perkiomen Creek in order to augment the flow in Perkiomen 33 Creek. As described in Section 2.2.6, NAI (2010 a) sampled aquatic biota between 2001 34 and 2009 as part of an analysis to examine post -operational effects of the water diversion effort 35 (Exelon 2011 a). Species diversity remained relatively consistent and samples continued to be 36 dominated by midges and oligochaetes. In addition, less variability existed along the stream 37 gradient and over time; NAI noted that pollution -sensitive species increased in abundance 38 (NAI 2010 a , 2010c). 39 The LGS license renewal would include continued operation and maintenance of four 40 transmission lines that extend from the Limerick site and travel and cross portions of the 41 Schuylkill River and Perkiomen Creek (Section 2.1.5 describes the in -scope transmission lines 42 in more detail). The transmission lines associated with LGS cross rivers and streams that have 43 the potential to be Pizzini's cave amphipod habitat. PECO must maintain the transmission lines 44 and associated structures and manage vegetation along the transmission line corridors to 45 prevent interference with the lines. Line and vegetation maintenance may result in direct 46 impacts to Pizzini's cave amphipod if instream work is required that could crush the amphipods. 47 Potential indirect effects could include a temporary decline in habitat quality from increased 48 Environmental Impacts of Operation 4-15 sedimentation and turbidity during maintenance activities. In PFBC's (2011) letter to the NRC, 1 PFBC noted that the Pizzini's cave amphipod is threatened by habitat destruction and poor 2 water quality. If PECO needs to perform maintenance in or near waterbodies, it takes a number 3 of precautions to reduce the likelihood of crushing amphipods and to reduce sedimentation and 4 water quality impacts. These actions, such as performing mechanical vegetation maintenance 5 activities on foot and obtaining necessary permits, are described in more detail earlier in this 6 section. 7 LGS license renewal would not involve new construction, refurbishment, ground -disturbing 8 activities, or changes to existing land use conditions at LGS -associated facilities or transmission 9 lines. 10 The NRC staff contacted PFBC to request information on potential impacts to 11 Pennsylvania -protected species. In an October 5, 2011, letter to the NRC, PFBC (2011) 12 identified Pizzini's cave amphipod as potentially occurring in the vicinity of the LGS site. 13 However, given that license renewal would not involve new construction, earth disturbances, or 14 changes to existing land uses, PFBC did not anticipate any significant adverse impacts to this 15 species (PFBC 2011b). 16 Aquatic Plants 17 Pennsylvania lists Farwell's water -milfoil (Myriophyllum farwellii), broad-leaved water -milfoil 18 (Myriophyllum heterophyllum), floating -heart (Nymbphoides cordata), and spotted pondweed 19 (Potamogeton pulcher) as either threatened or endangered as described in Section 2.2.7. All 20 four plants have historic or current records of occurrence in coastal portions of Bucks County 21 (PNHP 2012 a). 22 LGS-related activity that could affect the Farwell's water -milfoil, broad -leaved water -milfoil, 23 floating-heart, and spotted pondweed and their habitat is the intermittent withdrawal of Delaware 24 River water for the LGS cooling system. Direct impacts could include mortality if the plants were 25 sucked into the intake at the Point Pleasant Pumping Station. As described above, preferred 26 habitat does not occur near the Point Pleasant Pumping Station. LGS license renewal would 27 include continued operation at the Point Pleasant Pumping Station. However, as described in 28 Section 2.1.6, Exelon 's withdrawal of water from the Delaware River is secondary to its 29 withdrawal of water from the Schuylkill River, and Exelon plans to continue to rely less on the 30 Delaware River and more on the Schuylkill River in the future (Exelon 2012 a). LGS license 31 renewal would not involve new construction, refurbishment, ground -disturbing activities, or 32 changes to existing land use conditions at the Point Pleasant Pumping Station. Transmission 33 lines associated with LGS do not cross any portion of the Delaware River (Exelon 2011 a). 34 The NRC staff contacted PFBC to request information on potential impacts to 35 Pennsylvania -protected species. In an October 5, 2011, letter to the NRC, PFBC (2011 b) did 36 not identify the Farwell's water -milfoil, broad -leaved water -milfoil, floating -heart, and spotted 37 pondweed aquatic plants as a concern in regard to LGS's proposed license renewal. 38 4.8.2.3. Conclusion for Aquatic Species 39 The NRC staff evaluated the three ESA -listed species, two candidate species, and eight 40 additional Pennsylvania -protected species and species of special concern that could be present 41 in the action area defined in Section 2.2.8. In its evaluation, NRC staff examined the known 42 distributions and habitat ranges of those species, the ecological impacts of the operation of LGS 43 on the species, and the LGS-related occurrence and monitoring studies described above . In 44 addition, no critical habitat occurs within the action area. Given that LGS license renewal would 45 not involve new construction, refurbishment, ground -disturbing activities, or changes to existing 46 land use conditions at LGS-associated facilities or transmission lines, the continued operation of 47 Environmental Impacts of Operation 4-16 LGS is not likely to noticeably affect these species. Thus, the NRC staff concludes that the 1 impact on protected aquatic species from the proposed license renewal would be SMALL. 2 4.8.3. Terrestrial Species and Habitats 3 Species and Habitats Protected Under the Endangered Species Act 4 Bog Turtle (Clemmys muhlenbergii ) 5 The following analysis of the impacts of LGS license renewal on the bog turtle constitutes the 6 biological assessment for that species required by the ESA. Under the ESA, an agency's 7 requirement to prepare a biological assessment is independent of consultation and can be 8 completed through the NEPA process. 9 Section 2.2.8 concludes that the bog turtle could occur in suitable wetland habitat on the LG S 10 site, within palustrine emergent and forested wetlands along the Schuylkill River, or within 11 wetland habitat along the transmission line corridors. 12 Small sections of the LGS site contain suitable habitat for bog turtles. According to Figure 10, 13 "Habitat Map of Limerick Generating Station," in Exelon's Wildlife Management Plan 14 (Exelon 2012a), palustrine emergent and forested wetlands lie along the Schuylkill River 15 adjacent to riparian forest, old field, and agricultural land. Within the LGS site, the LGS license 16 renewal would include maintenance and operation activities within developed or previously 17 disturbed areas and would not involve new construction, refurbishment, ground -disturbing 18 activities, changes to conduct of operations, or changes to existing land use conditions in either 19 natural or developed areas. The proposed license renewal would have no direct or indirect 20 adverse impacts to LGS site wetlands; therefore, it would have no direct or indirect adverse 21 effects on the bog turtle. As noted in Section 2.2.7, poaching and loss of habitat are two of the 22 primary threats to the species. Continued operation of LGS during the license renewal term 23 would preserve the existing wetlands on the LGS site. Site security would prevent public 24 access to the site, and thus, prevent poaching. Therefore, continued operation of the LGS 25 could result in beneficial effects to the species. 26 The LGS license renewal would include Exelon's continued operation and maintenance of the 27 Perkiomen Pumphouse, Bradshaw Reservoir and Pumphouse, and the Bedminster Water 28 Processing Facility. Exelon would only perform maintenance and operation activities within 29 developed or previously disturbed areas during the license renewal period. Thus, the proposed 30 license renewal would have no direct or indirect adverse impacts to habitat at these offsite 31 facilities and no direct or indirect adverse effects on the bog turtle. 32 The LGS license renewal also would include continued operation and maintenance of four 33 transmission line corridors that extend from the Limerick site and travel through Montgomery 34 and Chester Counties (Section 2.1.5 describes the in -scope transmission lines in more detail). 35 Although the NRC does not license or regulate PECO, which owns and operates the 36 transmission lines, the NRC considers all transmission lines that were constructed specifically to 37 connect the facility to the transmission system in its NEPA analysis. The transmission lines 38 associated with LGS cross rivers, streams, and wetlands that have the potential to be bog turtle 39 habitat. PECO must maintain the transmission lines and associated structures and manage 40 vegetation along the transmission line corridors to prevent interference with the lines. Line and 41 vegetation maintenance may result in direct impacts to bog turtles, including takes of bog turtles 42 or their eggs and disturbance or destruction of bog turtle habitat. Potential indirect effects could 43 include prevention of natural successional changes in transmission line plant communities over 44 time. This indirect effect could positively affect bog turtle s because they prefer early 45 successional wetlands. 46 Environmental Impacts of Operation 4-17 Generally, PECO maintains transmission line corridors to promote the growth of shrubs, 1 grasses, and other low -growing vegetation. Because bog turtles prefer shallow, open -canopy 2 wetlands, the need for maintenance in these areas is much lower. If PECO needs to perform 3 maintenance in wetland areas, it takes a number of precautions to avoid impacts to the bog 4 turtle or its habitat. 5 First, PECO trains all of its contractors to be knowledgeable about Federally protected species 6 they may encounter while working and that they are able to identify potential wetlands and 7 obtain the necessary permits before proceeding with work. 8 Second, PECO typically performs mechanical vegetation maintenance activities on foot and 9 does not operate heavy machinery near wetlands and water bodies. This type of maintenance 10 avoids the potential for heavy machinery to crush turtles or nests or to create ruts, crush 11 wetland vegetation, or otherwise alter bog turtle habitat. PECO also makes an effort to perform 12 work in wetland areas during the winter months when the ground is hard or frozen. Foot traffic 13 could result in some minimal disturbance of wetland habitat. However, foot traffic would create 14 insignificant impacts (i.e., those impacts that would never reach the scale where a take might 15 occur) or discountable impacts (i.e., those impacts that cannot be meaningfully measured, 16 detected, or evaluated). 17 Finally, PECO must obtain several permits and certifications for maintenance activities in 18 wetlands or near waterbodies, which for a given work area may include: (1) a General Permit or 19 Water Obstruction and Encroachment General Permit issued jointly by the USACE and PADEP, 20 (2) a CWA 404 permit issued by the USACE, or (3) an erosion and sedimentation control plan 21 from the appropriate county conservation district. Within Montgomery and Chester Counties 22 (through the in -scope transmission lines traverse), PADEP requires applicants for a General 23 Permit or Water Obstruction and Encroachment General Permit to comply with bog turtle 24 screening requirements, which includes a site assessment by qualified PADEP personnel 25 (PADEP 2006 c). In cases in which a site assessment identifies potential bog turtle habitat, the 26 USACE and PADEP will not issue a permit until the FWS determines that the project will not 27 have an impact on the species (PADEP 2006 c). In cases in which PECO must obtain a 28 CWA 404 permit, this permitting process triggers a PECO company process during which 29 PECO personnel must review the proposed maintenance activities for potential impacts to bog 30 turtles and coordinate with FWS to avoid such impacts. 31 PECO's maintenance of transmission line corridors to promote low -growing vegetation may 32 benefit the species by preventing or stalling natural plant succession. Successional changes 33 within wetland communities often gradually eliminate some wetland vegetation and reduce open 34 areas that bog turtles use for nesting and basking (Morrow et al. 2001). In a study of bog turtles 35 at two sites in Maryland, Morrow et al. (2001) found that bog turtles avoided dense and 36 higher-growing vegetation and sought areas with low -lying cover. 37 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts 38 to Federally protected species. In a March 22, 2011, letter to Exelon, FWS (2011a) indicated 39 that the bog turtle occurs or may occur in or near the project area, but that the proposed action 40 is not likely to have an adverse effect on the bog turtle based on the FWS's review of the project 41 description and location. In a November 22, 2011, letter to the NRC, the FWS (2011b) 42 confirmed that the conclusion in its previous letter to Exelon was still appropriate. 43 The NRC sta ff concludes that the proposed LGS license renewal may affect, but is not likely 44 to adversely affect the bog turtle because effects to the species would be insignificant, 45 discountable, or beneficial. 46 Environmental Impacts of Operation 4-18 Indiana Bat (Myotis sodalis) 1 Section 2.2.8 concludes that the Indiana bat could occur in suitable forest habitat within the 2 action area. Potential types of Indiana bat habitat that occur in the action area include summer 3 roosting habitat, foraging habitat, and commuting habitat. Summer roosting habitat includes 4 trees with exfoliating bark, cracks, or crevices in trees or snags (dead trees) that are greater 5 than 3-in. (8-cm) diameter -at-breast height (FWS 2012 a). Foraging habitat includes forest 6 patches, wooded riparian corridors, and natural vegetation adjacent to such habitats 7 (FWS 2012 a). Commuting habitat includes wooded tracts, tree lines, wooded hedgerows, 8 streams, or other linear pathways within or connected to roosting or foraging habitat 9 (FWS 2012 a). 10 The LGS license renewal would not disturb or alter any natural habitats within the LGS site or 11 offsite facilities associated with the LGS makeup water system. Thus, no direct or indirect 12 adverse effects would result from continued operation and maintenance of these facilities. If the 13 Indiana bat occurs on the LGS site, continued operation of LGS would be beneficial to the 14 species because it would preserve forest habitat that might otherwise be developed or 15 converted to some other land use. 16 Because the majority of LGS transmission line corridors contain low -growing plant communities 17 dominated by grasses, herbs, and small shrubs, PECO's continued maintenance of the lines 18 generally would not alter the existing habitat. Occasionally, PECO may need to remove trees 19 that either grow tall enough to interfere with the lines or trees that die and could fall on the lines. 20 In such cases, PECO could have to remove trees that provide summer roosting habitat for 21 Indiana bats. However, PECO trains all of its contractors to be knowledgeable about Federally 22 protected species they may encounter while working. If a tree that provided potential Indiana 23 bat habitat required removal, PECO would typically coordinate with FWS and the appropriate 24 state agencies. PECO could also perform such maintenance in the fall or winter months when 25 the Indiana bat has migrated to hibernation sites. Thus, this potential ly adverse impact would 26 be insignificant because it is unlikely to result in a take. 27 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts 28 to Federally protected species. The FWS did not mention that the Indiana bat was of particular 29 concern in either its March 22, 2011, letter to Exelon (FWS 2011a) or its November 22, 2011, 30 letter to the NRC (FWS 2011b). 31 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely 32 to adversely affect the Indiana bat because effects to the species would be insignificant. 33 Small-Whorled Pogonia (Isotria medeoloides ) 34 Section 2.2.8 indicates that three extant populations of the small -whorled pogonia occur in 35 Pennsylvania, and at least one of these populations occurs in Chester County. Thus, 36 Section 2.2.8 conservatively concludes that the small -whorled pogonia could occur in areas of 37 suitable habitat along or near the transmission line corridor that runs through Chester County. 38 Because the small -whorled pogonia does not occur in Montgomery or Bucks Counties, 39 continued operation and maintenance of the LGS site and offsite facilities associated with the 40 LGS makeup water system would have no direct or indirect effects on the small -whorled 41 pogonia. LGS license renewal would include continued operation and maintenance of four 42 transmission line corridors that extend from the Limerick site and travel through Montgomery 43 and Chester Counties. The corridor within Chester County is about 13 mi (21 km) long 44 (Section 2.1.5 describes the in -scope transmission lines in more detail). The small-whorled 45 pogonia generally grows in young and maturing stands of mixed -deciduous or 46 mixed-deciduous/coniferous forests in areas close to logging roads, streams, or other features 47 Environmental Impacts of Operation 4-19 that create long -persisting breaks in the forest canopy. Therefore, the species could occur near 1 the transmission line corridor, but it is unlikely to occur in the corridor itself. Because the 2 species is unlikely to occur within the corridor, it would not experience any direct adverse effects 3 such as trampling caused by worker foot traffic, crushing caused by vehicles and equipment, or 4 herbicide application when workers spray adjacent vegetation. Depending on the proximity of 5 the small-whorled pogonia to the transmission line corridor, the species could experience 6 indirect adverse effects such as taking up water containing chemicals from herbicide runoff. 7 However, PECO maintains vegetation on a 5-year cycle and selectively sprays herbicides by 8 hand, so the indirect effects from herbicide application would be so small as to not be able to be 9 meaningfully measured or detected and would not reach the scale where a take would occur. 10 Thus, such effects would be discountable and insignificant. 11 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts 12 to Federally protected species. The FWS did not mention the small -whorled pogonia was of 13 particular concern in either its March 22, 2011, letter to Exelon (FWS 2011a) or its 14 November 22, 2011, letter to the NRC (FWS 2011b). 15 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely 16 to adversely affect the sma ll-whorled pogonia because effects to the species would be 17 insignificant or discountable. 18 Designated Critical Habitat 19 The NRC staff did not identify any Federally designated critical habitat within the action area 20 during its review (see Section 2.2.7). Additionally, in its correspondence with Exelon and the 21 NRC, the FWS (2011a, 2011b) did not identify any designated critical habitat. Thus, the NRC 22 staff concludes that the proposed license renewal would have no effect on designated critical 23 habitat. 24 Proposed Species and Proposed Critical Habitat 25 The NRC staff did not identify any Federally proposed species or proposed critical habitat within 26 the action area during its review (see Section 2.2.7). Additionally, in its correspondence with 27 Exelon and the NRC, the FWS (2011a, 2011b) did not identify any proposed species or 28 proposed critical habitat. Thus, the NRC staff concludes that the proposed license renewal 29 would have no effect on Federally proposed species or proposed critical habitat. 30 Species Protected Under the Bald and Golden Eag le Protection Act 31 Though bald eagles occur throughout the action area, no known nests are in close proximity to 32 any of the LGS site buildings, parking lots, or other structures; the LGS makeup water system 33 offsite facilities; or along the transmission line corridors that could be disturbed by operations or 34 maintenance activities associated with the proposed license renewal. Because the proposed 35 license renewal does not involve construction or land disturbances, the proposed license 36 renewal would not affect any bald eagle habitat. The NRC staff concludes that the impacts of 37 the proposed LGS license renewal on the bald eagle would be SMALL. 38 Species Protected Under the Migratory Bird Treaty Act 39 As discussed in Section 2.2.7, a variety of migratory birds inhabit the LGS site and surrounding 40 region. Because the proposed license renewal does not involve construction or land 41 disturbances, the NRC staff concludes that the impacts of the proposed LGS license renewal on 42 migratory birds would be SMALL. 43 Environmental Impacts of Operation 4-20 Species Protected by the Commonwealth of Pennsylvania 1 Section 2.2.8.3 discusses species protected under the Pennsylvania Endangered Species 2 Program. Ten Pennsylvania -listed birds and two Pennsylvania -listed plants occur or have 3 occurred on the LGS site since the plant began operating. An additional eight plant species 4 occur near the transmission line corridors. One Pennsylvania -listed reptile, the eastern redbelly 5 turtle (Pseudemys rubriventris ), occurs in the vicinity of the LGS site. Because the proposed 6 license renewal does not involve construction or land disturbances, the NRC staff concludes 7 that the impacts of the proposed LGS license renewal on Pennsylvania -protected species on 8 the LGS site or at offsite facilities associated with the LGS makeup water system would be 9 SMALL. 10 Continued transmission line maintenance would not adversely affect any of the 11 Pennsylvania -listed birds or the eastern redbelly turtle. As discussed in Section 2.1.5, PECO 12 has implemented an avian management program to ensure that it does not unnecessarily 13 disturb or harm birds or nests and to ensure compliance with applicable Federal and state bird 14 regulations. The mitigative measures described above for the bog turtle would also be 15 protective of the eastern redbelly turtle. Because the eastern redbelly turtle inhabits aquatic and 16 wetland habitats, the likelihood of habitat disturbance or direct effects to this species is lower 17 because PECO follows more stringent procedures when performing work in these areas. 18 Additionally, in its February 11, 2011, letter to Exelon, the PFBC (2011a) noted that it does not 19 anticipate the proposed license renewal will have any significant adverse impacts on 20 Pennsylvania -listed species of concern under the PFBC's jurisdiction. 21 Some of the Pennsylvania -listed plants discussed in Section 2.2.8.3 occur in woodlands or other 22 habitats near, but not directly within, the transmission line corridors. Continued transmission 23 line maintenance would not affect these plant species because PECO only manages vegetation 24 within the corridor. The other plant species occur in habitats compatible with transmission lines, 25 such as old fields or other early successional communities, and PECO likely would not perform 26 intensive maintenance or use herbicides in these areas because these habitats already contain 27 low-growing vegetation. The NRC staff concludes that the impacts of the proposed license 28 renewal on Pennsylvania -listed plants along the transmission line corridors would be SMALL. 29 Conclusion 30 The NRC staff concludes that the impacts of the proposed LGS license renewal on protected 31 terrestrial species and habitats would be SMALL as defined by the NRC for the purposes of 32 NEPA. 33 Environmental Impacts of Operation 4-21 4.9. Human Health 1 Table 4-8 lists the Category 1 and 2 issues related to human health that are applicable to LGS. 2 Table 4-8. Human Health Issues 3 Issue GEIS Section Category Radiation exposure to the public during refurbishment 3.8.1 a 1 Occupational radiation exposures during refurbishment 3.8.2 a 1 Microbiological organisms (occupational health) 4.3.6 1 Microbiological organisms (public health) 4.3.6(b) 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 determined (c) 1 Physical occupational hazards To be determined (c) 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 4.9.1. Generic Human Health Issues 4 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B -1, applicable to LGS in 5 regard to human health impacts are listed in Table 4-9. Exelon stated in its ER (Exelon 2011a) 6 that it was aware of one new radiological issue associated with the renewal of the LGS 7 operating license , tritium in groundwater. Exelon's groundwater monitoring program for 8 radioactive material is discussed in Sections 2.2.5, 4.5.2, and 4.11 of this document. Based on 9 its review of LGS's groundwater monitoring data, the NRC staff concluded that the issue, while 10 new, is not significant. The NRC staff has not identified any new and significant information 11 during its independent review of Exelon's ER, the site visit, the scoping process, or its 12 evaluation of other available information. 13 4.9.1.1. New Category 1 Human Health issues 14 As described in Section 1.4 of this draft SEIS, the NRC has approved a revision to its 15 environmental protection regulation, 10 CFR Part 51. With respect to the human health, the 16 revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding two new 17 Category 1 issue s , "Human health impact from chemicals" and "Physical occupational hazards." 18 The first issue considers the impacts from chemicals to plant workers and members of the 19 public. The second issue only considers the nonradiological occupational hazards of working at 20 Environmental Impacts of Operation 4-22 a nuclear power plant. An understanding of these non -radiological hazards to nuclear power 1 plant workers and members of the public have been well established at nuclear power plants 2 during those plants' current licensing terms. The impacts from chemical hazards are expected 3 to be minimized through the licensee's use of good industrial hygiene practices as required by 4 permits and Federal and state regulations. Also, the impacts from physical hazards to plant 5 workers will be of small significance if workers adhere to safety standards and use protective 6 equipment as required by Federal and state regulations. The impacts to human health for each 7 of these new issues from continued plant operations are SMALL. 8 The NRC staff has not identified any new and significant information related to these non -9 radiological issues during its independent review of LGS's ER, the site audit, and the scoping 10 process. Therefore, the NRC staff concludes that there would be no impact to human health 11 from chemicals or physical hazards beyond those impacts described in Table B -1 in 12 Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule and, therefore, the impacts are 13 SMALL. 14 4.9.2. Radiological Impacts of Normal Operations 15 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B -1, applicable to LGS in 16 regard to radiological impacts to human health are listed in Table 4-8. The NRC staff has not 17 identified any new and significant information related to radiological issues during its 18 independent review of Exelon's ER, the site audit, the scoping process, or its evaluation of other 19 available information. Therefore, the NRC staff concludes that there would be no impact from 20 radiation exposures to the public or to workers during the license renewal term beyond those 21 discussed in the GEIS. 22 The findings in the GEIS are as follows: 23 Radiation exposures to the public (license renewal term). Based on 24 information in the GEIS, the Commission found the following: 25 Radiation doses to the public will continue at current levels associated with 26 normal operations. 27 Occupational exposures (license renewal term). Based on information in the 28 GEIS, the Commission found the following: 29 Projected maximum occupational doses during the license renewal term are 30 within the range of doses experienced during normal operations and normal 31 maintenance outages, and would be well below regulatory limits. 32 According to the GEIS, the impacts to human health are SMALL, and additional plant -specific 33 mitigation measures are not likely to be sufficiently beneficial to be warranted. 34 There are no Category 2 issues related to radiological impacts of routine operations. 35 The information presented below is a discussion of selected radiological programs conducted at 36 LGS. 37 Limerick Generating Station Radiological Environmental Monitoring Program 38 LGS conducts a Radiological Environmental Monitoring Program (REMP) to assess the 39 radiological impact, if any, to its employees, the public, and the environment from the operations 40 at LGS, Units 1 and 2. The REMP measures the aquatic, terrestrial, and atmospheric 41 environment for radioactivity, as well as the ambient radiation. In addition, the REMP measures 42 background radiation (i.e., cosmic sources, global fallout, and naturally occurring radioactive 43 material, including radon). The REMP supplements the radioactive effluent monitoring program 44 Environmental Impacts of Operation 4-23 by verifying that a ny measurable concentrations of radioactive materials and levels of radiation 1 in the environment are not higher than those calculated using the radioactive effluent release 2 measurements and transport models. 3 An annual radiological environmental operating report (REOP) is issued, which contains a 4 discussion of the results of the monitoring program. The report contains data on the monitoring 5 performed for the previous year. The REMP collects samples of environmental media in order 6 to measure the radioactivity levels that may be present. The media samples are representative 7 of the radiation exposure pathways that may affect the public. 8 The LGS REMP is made up of three categories based on the exposure pathways to the public. 9 They are as follows: atmospheric, aquatic, and ambient gamma radiation. The atmospheric 10 samples taken around LGS are airborne particulate, airborne iodine, milk, and broad leaf 11 vegetation. Airborne iodine and particulate samples are taken using vacuum pumps and glass 12 fiber filters. The aquatic pathway samples are taken from surface water and drinking water 13 sources. Also included in this pathway are sediment samples and fish samples. The ambient 14 gamma radiation pathway measures direct exposure from environmental radiation doses using 15 thermoluminescent dosimeters. 16 In addition to the REMP, LGS has a groundwater protection program designed to monitor the 17 onsite plant environment for the detection of leaks from plant systems and pipes containing 18 radioactive liquid (see Sections 2.2.5.2 and 4.5.2) . 19 The NRC staff reviewed the LGS annual REOPs for 2007 through 2011 to look for any 20 significant impacts to the environment or any unusual trends in the data (Exelon 2008a, 200 9a , 21 2010a, 20 11b, 201 2b). A 5-year period provides a data set that covers a broad range of 22 activities that occur at a nuclear power plant, such as refueling outages, routine operation, and 23 years in which there may be significant maintenance activities. Based on the NRC staff's 24 review, no adverse trends (i.e., steadily increasing buildup of radioactivity levels) were observed 25 and the data showed that there was no measurable impact to the environment from LGS 26 operations. 27 Groundwater Protection Program 28 A radioactive groundwater protection program was established at LGS in 2006 to assess 29 potential impacts to groundwater from plant's operation. 30 In 2007, the Nuclear Energy Institute (NEI) established a standard for monitoring and reporting 31 radioactive isotopes in groundwater: NEI 07-07, "Industry Ground Water Protection Initiative-32 Final Guidance Document" (NEI 2007). LGS implemented the recommendations of this industry 33 standard. Data from the groundwater monitoring program are contained in the annual 34 radiological environmental operating report submitted to the NRC in May of each year. These 35 reports are available for review by the public through the Agencywide Documents Access and 36 Management System (ADAMS) electronic reading room available through the NRC website. 37 Additional information on the groundwater protection program is discussed in Sections 2.2.5 and 38 4.5.2 of this SEIS. 39 Pennsylvania Department of Environmental Protection Bureau of Radiation Detection 40 Environmental Monitoring Program 41 The Bureau of Radiation Protection (BRP) performs its own independent environmental 42 monitoring around the LGS site and other nuclear facilities located in Pennsylvania. All 43 analyses of environmental media (i.e., soil, air, water, and vegetation) are performed by its 44 Bureau of Laboratories (BOL). The state's BRP performs the monitoring of direct radiation from 45 a facility using thermoluminescent dosimeters (TLDs). 46 Environmental Impacts of Operation 4-24 The NRC staff reviewed the state's environmental summary reports for 2003 through 2004 (the 1 most recent reports available at the time of the NRC's review) (PADEP undated). In each of the 2 reports, the state concluded that the sample data indicated no release of radioactive material to 3 the environment that exceeded the regulatory or license limits of the PADEP or the NRC. 4 Limerick Generating Station Radioactive Effluent Release Program 5 All nuclear plants were licensed with the expectation that they would release radioactive 6 material to both the air and water during normal operation. However, NRC regulations require 7 that radioactive gaseous and liquid releases from nuclear power plants must meet radiation 8 dose-based limits specified in 10 CFR Part 20, and the as low as is reasonably achievable 9 (ALARA) criteria in Appendix I to 10 CFR Part 50. Regulatory limits are placed on the radiation 10 dose that members of the public can receive from radioactive effluents released by a nuclear 11 power plant. In addition, nuclear power plants are required by 10 CFR 50.36(a) to submit an 12 annual report to the NRC that lists the types and quantities of radioactive effluents released into 13 the environment. The radioactive effluent release reports are available for review by the public 14 through the ADAMS electronic reading room available through the NRC website. 15 The NRC staff reviewed the annual radioactive effluent release reports for 2007 through 2011 16 (Exelon 2008b, 200 9b, 20 10b, 20 11c, 2012c). The review focused on the calculated doses to a 17 member of the public from radioactive effluents released from LGS. The doses were compared 18 to the radiation protection standards in 10 CFR 20.1301 and the ALARA dose design objectives 19 in Appendix I to 10 CFR Part 50. 20 Dose estimates for members of the public are calculated based on radioactive gaseous and 21 liquid effluent release data and atmospheric and aquatic transport models. The 20 11 annual 22 radioactive effluent release report (Exelon 2012d) contains a detailed presentation of the 23 radioactive discharges and the resultant calculated doses. The following summarizes the 24 calculated dose to a member of the public located outside the LGS site boundary from 25 radioactive gaseous and liquid effluents released during 2011: 26 The combined total -body dose to an offsite member of the public from LGS, 27 Units 1 and 2 radioactive liquid effluents was 8.38x10-2 mrem (8.38x10-4 28 mSv), which is well below the combined 6 mrem (0.06 mSv) dose criterion for 29 two reactor units in Appendix I to 10 CFR Part 50. 30 The organ (liver) dose to an offsite member of the public from LGS, Units 1 31 and 2 radioactive liquid effluents was 8.38x10-2 mrem (8.38x10-4 mSv), which 32 is well below the combined 20 mrem (0.20 mSv) dose criterion for two reactor 33 units in Appendix I to 10 CFR Part 50. 34 The air dose at the site boundary from gamma radiation in gaseous effluents 35 from LGS, Units 1 and 2 was 1.46x10-2 mrad (1.46x10-4 mGy), which is well 36 below the combined 20 mrad (0.2 mGy) dose criterion for two reactor units in 37 Appendix I to 10 CFR Part 50. 38 The air dose at the site boundary from beta radiation in gaseous effluents 39 from LGS, Units 1 and 2 was 8.73x10-3 mrad (8.73x10-5 mGy), which is well 40 below the combined 40 mrad (0.4 mGy) dose criterion for two reactor units in 41 Appendix I to 10 CFR Part 50. 42 The dose to an organ (bone) from radioactive iodine , radioactive particulates, 43 and carbon -14 from LGS, Units 1 and 2 was 4.13x10-1 mrem 44 (4.13x10-3 mSv), which is well below the combined 30 mrem (0.3 mSv) dose 45 criterion for two reactor units in Appendix I to 10 CFR Part 50. 46 Environmental Impacts of Operation 4-25 No radiation above background was detected at the site boundary from direct 1 radiation, as measured by TLDs. There is no dose criterion for direct 2 radiation in Appendix I to 10 CFR Part 50. The data is included in the 3 summation of doses from all radioactive effluent release pathways to 4 determine compliance with EPA's 40 CFR Part 190 dose standard of 5 25 mrem (0.25 mSv) for the total dose to members of the public from the 6 reactor units at the LGS site. 7 The NRC staff summed the applicant's data on the individual total body 8 doses from radioactive gaseous and liquid effluents from both units and 9 added it to the dose from direct radiation to obtain the maximum all pathways 10 dose to an offsite member of the public from the operation of LGS, Units 1 11 and 2. The dose to a member of the public from all radioactive releases in 12 2011 was 1.30x10-1 mrem (1.30x10-3 mSv), which is well below the 25 mrem 13 (0.25 mSv) dose standard in EPA's 40 CFR Part 190. 14 The NRC staff's review of the LGS radioactive effluent control program showed that radiation 15 doses to members of the public were controlled within Federal radiation protection standards 16 contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 40 CFR Part 190. 17 The applicant has no plans to conduct refurbishment activities during the 18 license renewal term; however, routine plant refueling and maintenance 19 activities currently performed will continue during the license renewal term. 20 Based on the past performance of the radioactive waste system to maintain 21 the dose from radioactive effluents to be ALARA, similar performance is 22 expected during the license renewal term. Continued compliance with 23 regulatory requirements is expected during the license renewal term; 24 therefore, the impacts from radioactive effluents to the public would be 25 SMALL. 26 4.9.3. Microbiological Organisms 27 The effects of thermophilic microbiological organisms on human health (see Table 4 -8), are 28 categorized as a Category 2 issue and require a plant -specific evaluation during the license 29 renewal process for plants using closed -cycle cooling, located on a small river. The Schuylkill 30 River is considered a small river because its average annual flow is approximately 31 6.3 x 10 10 cubic feet per year (ft 3/yr) (1.7 x 10 8 cubic meters per year (m 3/yr)), which is less than 32 the threshold value of 3.15 x 10 12 ft 3/yr (9 x 10 10 m 3/yr) in 10 CFR 51.53(c)(3)(ii)(G) 33 (Exelon 2011a). Therefore, the effects of the LGS cooling water discharge on microbiological 34 organisms must be addressed for LGS license renewal. 35 The Category 2 designation is based on the magnitude of the potential public health impacts 36 associated with thermal enhancement of enteric pathogens such a s Salmonella spp. and 37 Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free -living 38 amoebae Naegleria spp., and Legionella spp. bacteria (NRC 1996). Thermophilic 39 microorganisms generally occur at temperatures of 77
°F to 176 °F (25 °C to 80 °C) with an 40 optimal growth temperature range of 122 °F to 150 °F (50 °C to 66 °C), and minimum and 41 maximum temperature tolerances of 68 °F (20 °C) and 158 °F (70 °C), respectively. However, 42 thermal preferences and tolerances vary across bacterial groups. Pathogenic thermophilic 43 microbiological organisms of concern during nuclear reactor operation typically have optimal 44 growing temperatures of approximately 99 °F (37 °C) (Joklik and Smith 1972).
45 Pseudomonas aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal 46 infections in immunocompromised individuals. The organism produces toxins harmful to 47 Environmental Impacts of Operation 4-26 humans and animals. It has an optimal growth temperature of 99
°F (37 °C) (Todar 2012). 1 Legionella spp. consists of at least 46 species and 70 serogroups. It is responsible for 2 Legionnaires' disease, with the onset of pneumonia in the first 2 weeks of exposure. Risk 3 groups for Legionella spp. include elderly, cigarette smokers, persons with chronic lung or 4 immunocompromising disease, and persons receiving immunosuppressive drugs.
5 The LGS NPDES permit (No. PA0051926) requires the temperature in the thermal discharge to 6 be monitored at least once weekly for compliance with an instantaneous maximum limit of 7 110 °F (43.3 °C) for the protection of human health. Although thermophilic microbiological 8 organisms of concern during nuclear reactor operation could grow at that stated instantaneous 9 maximum temperature limit, there are several years of Discharge Monitoring Report (DMR) data 10 showing that maximum summer discharge temperatures range from 90 °F to 95 °F (32.2
°C to 11 35.0 °C) (Exelon 2011a). These temperatures are below the stated optimal growing 12 temperature of approximately 99°F (37°C); therefore, ambient river conditions are not likely to 13 support the proliferation of the pathogenic organisms of concern.
14 Exelon requested PADEP to provide comments or concerns about LGS's contribution to 15 potential health effects resulting from thermophilic organisms. Exelon requested PADEP to 16 alternatively confirm Exelon's conclusion that operation of LGS during the period of extended 17 operation would not enhance growth of thermophilic pathogens. In response, PADEP identified 18 that it does not have any data associated with thermophilic organisms in the Schuylkill River nor 19 has it conducted any investigations on the impact or potential impact of the LGS discharge on 20 thermophilic organisms in the river. As a result, PADEP is unable to make any conclusions 21 regarding the effect on public health from thermophilic organisms in the Schuylkill River 22 (Exelon 2011a). 23 DRBC designated that uses to be maintained in the Schuylkill River in the vicinity of LGS 24 include secondary contact recreation, in which body contact is either incidental or accidental, 25 and in which the probability of ingesting appreciable quantities of water, particularly through 26 nasal passages, is minimal. 27 LGS currently discharges sanitary sewage to the local publicly owned treatment works for 28 treatment, which further reduces the potential for the facility's discharge to introduce pathogenic 29 microorganisms that could present a threat to recreational users of the Schuylkill River. 30 The NRC staff reviewed all documents applicable to this Category 2 issue, including Exelon's 31 ER and the LGS NPDES permit. The NRC staff concludes that for the reasons above, 32 thermophilic microbiological organisms are unlikely to present a public health hazard as a result 33 of LGS discharges to the Schuylkill River. The NRC staff concludes that impacts on public 34 health from thermophilic microbiological organisms from continued operation of LGS in the 35 license renewal period would be SMALL. 36 4.9.4. Electromagnetic Fields -Acute Effects 37 Based on the GEIS, the Commission found that electric shock resulting from direct access to 38 energized conductors or from induced charges in metallic structures has not been found to be a 39 problem at most operating plants and generally is not expected to be a problem during the 40 license renewal term. However, site -specific review is required to determine the significance of 41 the electric shock potential along the portions of the transmission lines that are within the scope 42 of this SEIS. 43 In the GEIS (NRC 1996), the Commission found that without a review of the conformance of 44 each nuclear plant transmission line with National Electrical Safety Code (NESC) criteria, it was 45 not possible to determine the significance of the electric shock potential (IEEE 2002). 46 Environmental Impacts of Operation 4-27 Additionally, the Commission found that evaluation of individual plant transmission lines is 1 necessary because the issue of electric shock safety was not addressed in the licensing 2 process for some plants. For other plants, land use in the vicinity of transmission lines may 3 have changed, or power distribution companies may have chosen to upgrade line voltage. To 4 comply with 10 CFR 51.53(c)(3)(ii)(H), Exelon must provide an assessment of the impact of the 5 proposed action on the potential shock hazard from the transmission lines if the transmission 6 lines that were constructed for the specific purpose of connecting the plant to the transmission 7 system do not meet the recommendations of the NESC for preventing electric shock from 8 induced currents. 9 Limerick Units 1 and 2 electrical outputs are delivered to the PJM Interconnection by the LGS 10 transmission system. Each Limerick unit is provided with an independent substation, which are 11 230 kilovolts (kV) for Unit 1 and 500 kV for Unit 2. Four 230-kV transmission lines, the 12 Limerick-Cromby 220 -60 line, the Limerick -Cromby 220 -61 line, the Cromby-North Wales 13 220-62 line, and the Cromby -Plymouth Meeting 220 -63/64 line, were constructed to connect the 14 Limerick Unit 1 substation to the electric grid. One 500 -kV transmission line, the 15 Limerick-Whitpain 5031 line, was constructed to connect the Limerick Unit 2 substation to the 16 electric grid. These are the lines that are within scope of license renewal. Exelon developed an 17 electric field strength policy for the design and operation of its transmission system. The policy 18 is intended to minimize shock hazards consistent with the NESC criteria. Exelon used the 19 Electric Power Research Institute (EPRI) HERB 2.0 software to determine NESC compliance. 20 Their analysis determined that there are no locations within the right -of-way under these 21 transmission lines that have the capacity to induce more than 5 milliamperes (mA) to a vehicle 22 parked beneath the lines. Therefore, the lines meet the NESC 5 mA criterion. The maximum 23 induced current calculated for the power lines was 4.6 mA on the Cromby-Plymouth Meeting 24 220-63/64 line (Exelon 2011a). 25 The LGS transmission line corridor crosse s over highways, streets, other public places, or 26 property owned by others for which PECO, a subsidiary of Exelon Corporation, has permits, 27 grants, easements, or licenses. PECO, and owners and operators of the transmission lines, 28 conduct surveillance and maintenance activities to verify that design ground clearances will not 29 change. These procedures include routine inspection for clearance problems by aircraft 30 periodically. Ground inspections are conducted yearly for clearance problems, which are 31 brought to the attention of the appropriate organizations for maintenance. Exelon expects that 32 it, as well as PECO, will continue to use these or similar processes during the period of 33 extended operation. No land use changes are anticipated in the vicinity of the corridor. 34 Exelon's and PECO's periodic surveillance of the transmission system assures that ground 35 clearances would remain in compliance with NESC criteria (Exelon 2011a). 36 The NRC staff reviewed the available information, including Exelon's evaluation and results. 37 Based on this information, the NRC staff conclu des that the potential impacts from electric 38 shock during the renewal period would be SMALL. 39 4.9.5. Electromagnetic Fields -Chronic Effects 40 In the GEIS, the effects of chronic exposure to 60 Hertz electromagnetic fields from power lines 41 were not designated as Category 1 or 2 and will not be until a scientific consensus is reached 42 on the health implications of these fields. 43 The potential effects of chronic exposure from these fields continue to be studied and are not 44 known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs 45 related research through the U.S. Department of Energy (DOE). 46 Environmental Impacts of Operation 4-28 The report by NIEHS (NIEHS 1999) contains the following conclusion: 1 The NIEHS concludes that ELF EMF (extremely low frequency electromagnetic 2 field) exposure cannot be recognized as entirely safe because of weak scientific 3 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 4 is insufficient to warrant aggressive regulatory concern. However, because 5 virtually everyone in the United States uses electricity and therefore is routinely 6 exposed to ELF EMF, passive regulatory action is warranted such as continued 7 emphasis on educating both the public and the regulated community on means 8 aimed at reducing exposures. The NIEHS does not believe that other cancers or 9 non cancer health outcomes provide sufficient evidence of a risk to currently 10 warrant concern. 11 This statement is not sufficient to cause the NRC staff to change its position with respect to the 12 chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of 13 "UNCERTAIN" still appropriate and will continue to follow developments on this issue. 14 4.10. Socioeconomics 15 Section 2.2.9 of this SEIS describes socioeconomics in the vicinity of the LGS site. Table 4-9 16 lists the Category 1 and Category 2 issues related to socioeconomics. 17 Table 4-9. Socioeconomics Issues 18 Issues GEIS Section Category Housing impacts 4.7.1 2 Public services: public safety, social services, and tourism and recreation 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 Offsite land use (license renewal term) 4.7.4 2 Public services: transportation 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 Environmental justice minority and low -income populations To be determined(a) 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b 4.10.1. Generic Socioeconomic Issues 19 The NRC staff did not identify any new and significant information during the review of the 20 applicant's ER (Exelon 2011a), the NRC staff's site audit, the scoping process, or the evaluation 21 of other available information. Therefore, there are no impacts related to Category 1 22 socioeconomic issues beyond those discussed in the GEIS. For these issues, the GEIS 23 concluded that the impacts are SMALL, and additional site -specific mitigation measures are not 24 likely to be sufficiently beneficial to warrant implementation. 25 Environmental Impacts of Operation 4-29 4.10.2. Housing 1 Appendix C of the GEIS presents a population characterization method based on two factors, 2 sparseness and proximity (GEIS Section C.1.4). Sparseness measures population density 3 within 20 mi (32 km) of the site, and proximity measures population density and city size within 4 50 mi (80 km). Each factor has categories of density and size (GEIS Table C.1). A matrix is 5 used to rank the population category as low, medium, or high (GEIS Figure C.1). 6 According to the 2010 Census, an estimated 1,365,850 people live within 32.2 k m (20 mi) of the 7 LGS plant site, producing a population density of 420 persons per square kilometer 8 (1,087 persons per square mile) (Exelon 2011 a). This translates to a Category 4, "least sparse" 9 population density using the GEIS measure of sparseness (greater than or equal to 120 persons 10 per square mile within 20 miles). Approximately 8,311,616 people live within 80.4 kilometers 11 (50 miles) of LGS, which equates to a population density of 409 persons per square kilometer 12 (1,058 persons per square mile) (Exelon 2011 a). As the region of influence (ROI) has a 13 population greater than or equal to 190 persons per square mile within 80.4 kilometers 14 (50 miles), this translates to a Category 4 (greater than or equal to 190 persons per square mile 15 within 50 miles). Therefore, LGS is classified as being located in a high population area based 16 on the GEIS sparseness and proximity matrix. 17 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 18 are expected to be of small significance in a medium or high density population area where 19 growth-control measures are not in effect. Since LGS is located in a high population area and 20 Montgomery, Berks, and Chester Counties are not subject to growth -control measures that 21 would limit housing development; any changes in employment at LGS, Units 1 and 2 would 22 have little noticeable effect on housing availability in these counties. Since Exelon has no plans 23 to add non -outage employees during the license renewal period, employment levels at LGS, 24 Units 1 and 2 would remain relatively constant with no new demand for permanent housing 25 during the license renewal term. Based on this information, there would be no additional impact 26 on housing during the license renewal term beyond what has already been experienced. 27 4.10.3. Public Services -Public Utilities 28 Impacts on public utility services (e.g., water, sewer) are considered SMALL if the public utility 29 has the ability to respond to changes in demand and would have no need to add or modify 30 facilities. Impacts are considered MODERATE if service capabilities are overtaxed during 31 periods of peak demand. Impacts are considered LARGE if additional system capacity is 32 needed to meet ongoing demand. 33 Analysis of impacts on the public water systems considered both plant demand and 34 plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and 35 actual use of water for reactor cooling at LGS, Units 1 and 2. 36 Since Exelon has no plans to add non-outage employees during the license renewal period, 37 employment levels at LGS, Units 1 and 2 would remain relatively unchanged with no additional 38 demand for public water services. Public water systems in the region are adequate to meet the 39 demands of residential and industrial customers in the area. Therefore, there would be no 40 impact to public water services during the license renewal term beyond what is currently being 41 experienced. 42 Environmental Impacts of Operation 4-30 4.10.4. Offsite Land Use 1 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, 2 Subpart A, Appendix B, Table B-1). Table B -1 notes that "significant changes in land use may 3 be associated with population and tax revenue changes resulting from license renewal. " 4 Section 4.7.4 of the GEIS defines the magnitude of land -use changes as a result of plant 5 operation during the license renewal term as SMALL when there will be little new development 6 and minimal changes to an area 's land-use pattern, as MODERATE when there will be 7 considerable new development and some changes to the land -use pattern, and LARGE when 8 there will be large -scale new development and major changes in the land -use pattern. 9 Tax revenue can affect land use because it enables local jurisdictions to provide the public 10 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 11 the GEIS states that the assessment of tax -driven land -use impacts during the license renewal 12 term should consider: (1) the size of the plant 's tax payments relative to the community 's total 13 revenues, (2) the nature of the community 's existing land -use pattern, and (3) the extent to 14 which the community already has public services in place to support and guide development. If 15 the plant's tax payments are projected to be small relative to the community 's total revenue, 16 tax-driven land -use changes during the plant 's license renewal term would be SMALL, 17 especially where the community has pre -established patterns of development and has provided 18 public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax 19 payments by the plant owner are less than 10 percent of the taxing jurisdiction 's revenue, the 20 significance level would be SMALL. If tax payments are 10 to 20 percent of the community's 21 total revenue, new tax -driven land -use changes would be MODERATE. If tax payments are 22 greater than 20 percent of the community 's total revenue, new tax -driven land -use changes 23 would be LARGE. This would be especially true where the community has no pre -established 24 pattern of development or has not provided adequate public services to support and guide 25 development. 26 4.10.4.1. Population -Related Impacts 27 Since Exelon has no plans to add non -outage employees during the license renewal period, 28 there would be no plant operations -driven population increase in the vicinity of LGS, Units 1 29 and 2. Therefore, there would be no population -related offsite land use impacts during the 30 license renewal term beyond those already being experienced. 31 4.10.4.2. Tax Revenue -Related Impacts 32 As discussed in Chapter 2, Exelon pays property taxes for LGS to the following entities in 33 Montgomery and Chester Counties: Limerick Township, Spring -Ford Area School District, 34 Lower Pottsgrove Township, Pottsgrove School District, Chester County, East Coventry 35 Township, and Owen J. Roberts School District. Exelon also makes tax payments to taxing 36 authorities in Bucks County, but the amounts are relatively minor. Since Exelon started making 37 property tax payments to local jurisdictions, population has increased steadily and land has 38 continued to be converted to residential and commercial uses in the affected counties -adding 39 to the tax base of affected jurisdictions. Therefore, tax revenue from LGS as a proportion of 40 total tax revenue has had little or no effect on land use conditions within these counties. 41 Since employment levels would remain relatively unchanged with no increase in the assessed 42 value of LGS, annual property tax payments also would be expected to remain relatively 43 unchanged throughout the license renewal period. Based on this information, there would be no 44 tax-revenue-related offsite land use impacts during the license renewal term beyond those 45 already being experienced. 46 Environmental Impacts of Operation 4-31 4.10.5. Public Services -Transportation 1 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following: 2 Transportation impacts (level of service) of highway traffic generated during the term of the 3 renewed license are generally expected to be of SMALL significance. However, the increase in 4 traffic associated with additional workers and the local road and traffic control conditions may 5 lead to impacts of MODERATE or LARGE significance at some sites. 6 The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of 7 highway traffic generated by the proposed project on the level of service of local highways 8 during the term of the renewed license. Since Exelon has no plans to add non -outage 9 employees during the license renewal period; traffic volume and levels of service on roadways 10 in the vicinity of LGS, Units 1 and 2 would not change. Therefore, there would be no 11 transportation impacts during the license renewal term beyond those already being 12 experienced. 13 4.10.6. Historic and Archaeological Resources 14 This section provides the NRC staff's assessment of the effects on historic and archaeological 15 resources from the proposed license renewal action for LGS, Units 1 and 2. The National 16 Historic Preservation Act (NHPA) requires Federal agencies to consider the effects of their 17 undertakings on historic properties. Historic properties are defined as resources that are eligible 18 for listing on the National Register of Historic Places (NRHP). The criteria for NRHP eligibility 19 are listed in 36 CFR 60.4 and include, among other things, (1) association with significant 20 events that have made a significant contribution to the broad patterns of history, (2) association 21 with the lives of persons significant in the past, (3) embodiment of distinctive characteristics of 22 type, period, or method of construction, and (4) sites or places that have yielded or may be likely 23 to yield important information in history or prehistory. The historic preservation review process 24 (Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA)) is outlined 25 in regulations issued by the Advisory Council on Historic Preservation (ACHP) in 26 36 CFR Part 800. In accordance with 36 CFR 800.8(c), the NRC has elected to use the 27 National Environmental Policy Act of 1969, as amended (NEPA), process to comply with its 28 obligations under Section 106 of the NHPA. 29 In accordance with 36 CFR 800.8(c), on September 16, 2011, and September 15, 2011, 30 respectively, the NRC staff initiated consultations on the proposed action by writing to the 31 Advisory Council on Historic Preservation and the Pennsylvania Bureau of Historic Preservation 32 (BHP), which houses the Pennsylvania State Historic Preservation Office (NRC 2011a, 2011b). 33 Previously, Exelon, outside of the NHPA process, consulted with the BHP on January 19, 2011, 34 regarding the renewal of operating licenses for LGS, Units 1 and 2. Exelon stated in its letter to 35 the BHP that there would be no effect on historic properties from license renewal and 36 associated operation and maintenance activities (Exelon 2011a). The BHP responded to LGS 37 on February 16, 2011, concluding that "due to the nature of the activity, it is our opinion that 38 there will be no effect on these properties" (Exelon 2011a). 39 On September 13, 2011, the NRC staff initiated consultation with 15 Federally recognized 40 tribes: the Absentee -Shawnee Tribe of Oklahoma, the Heron Clan, the Delaware Nation 41 (located in Anadarko, Oklahoma), the Delaware Tribe (located in Emporia, Kansas), the Eastern 42 Shawnee Tribe of Oklahoma, the Oneida Indian Nation, the Oneida Nation of Wisconsin, the 43 Onondaga Nation, the Seneca Nations of Indians, the Seneca-Cayuga Tribe of Oklahoma, the 44 St. Regis Mohawk Tribe, the Shawnee Tribe, the Stockbridge -Munsee Band of the Mohican 45 Tribe, the Tonawanda Seneca Nation, and the Tuscarora Nation (see Appendix D for a list of 46 Environmental Impacts of Operation 4-32 these letters). In its letters, the NRC staff provided information about the proposed action, the 1 definition of APE, and indicated that the NHPA review would be integrated with the NEPA 2 process, according to 36 CFR 800.8(c). The NRC staff invited participation in the identification 3 and possible decisions concerning historic properties and also invited participation in the 4 scoping process. 5 Before the site audit in May 2011, the NRC staff contacted the BHP concerning license renewal 6 for LGS and concluded there was no need to meet during the environmental audit to discuss 7 cultural resources (NRC 2011c). 8 The NRC staff received scoping comments from two tribes, the Delaware Tribe and the 9 Stockbridge Munsee Tribe, in September 2011, and one comment from the Onondaga Nation in 10 October 2011. The tribes did not raise any concerns in their scoping comments and indicated 11 there are no religious or culturally significant sites in the project area (see Appendix D). The 12 NRC responded to the tribes concerning their scoping comments. 13 Section 2.2.10 describes the historic and cultural resources at the LGS site. Exelon currently 14 has no planned changes or ground -disturbing activities associated with license renewal at LGS 15 site (Exelon 2011a). Exelon is presently working with East Coventry Township and Chester 16 County to rehabilitate and mothball the Fricks Lock Historic District located on its property. 17 The rehabilitation and mothballing activities are specified to meet the Secretary of Interior's 18 Standards for Rehabilitation and have been approved by the Pennsylvania Historical and 19 Museum Commission Bureau for Historic Preservation (BHP 2011). Construction activity is 20 expected to begin in 2012 (Exelon 2011a). Exelon has also developed a cultural resources 21 management plan to manage known and potentially existing, or discovered archaeologically or 22 historically significant cultural resources within the Owner -Controlled Area (OCA) of the LGS. 23 The Plan addresses possible impacts from land -disturbing activities or other actions within the 24 OCA that could introduce new noise, air, or visual element impacts to known cultural resources 25 outside the OCA. The plan describes the process for initiating informal consultation with BHP 26 and provides guidance on how to manage an unexpected discovery (Exelon 2012a). 27 For the purposes of NHPA Section 106 consultation, based on the (1) historic and cultural 28 resources located within the APE, (2) tribal input, (3) Exelon's Cultural Resources Management 29 Plan and the status of the Fricks Lock rehabilitation and mothball project, (4) the fact that there 30 will be no changes or ground -disturbing activities that will occur as part of the relicensing of 31 LGS, Units 1 and 2, (5) BHP finding of "no effect," and (6) the NRC staff's cultural resource 32 analysis and consultation, the NRC staff concludes that license renewal will have no effect on 33 historic properties (36 CFR 800.4(d)(1)). 34 For the purposes of the NRC staff's NEPA analysis, based on the items that lead to the above 35 finding of no effect, the NRC staff concludes that potential impacts on historic and cultural 36 resources related to operating LGS, Units 1 and 2 during the renewal term would be SMALL. 37 4.10.7. Environmental Justice 38 As described in Secti on 1.4 of this SEIS, the NRC has approved a revision to its environmental 39 protection regulation, 10 CFR Part 51. With respect to environmental justice concerns, the 40 revised rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 41 Category 2 issue, "Minority and low-income populations," to evaluate the impacts of continued 42 operations and any refurbishment activities during the license renewal term on minority 43 populations and low-income populations living in the vicinity of the plant. Environmental justice 44 was listed in Table B-1 as a concern before this revised rule, but it was not evaluated in the 45 1996 GEIS and, therefore, is addressed in each SEIS. 46 Environmental Impacts of Operation 4-33 Under Executive Order (EO) 12898 (59 FR 7629, February 16, 1994), Federal agencies are 1 responsible for identifying and addressing, as appropriate, potential disproportionately high and 2 adverse human health and environmental impacts on minority and low -income populations. 3 In 2004, the NRC issued a Policy Statement on the Treatment of Environmental Justice Matters 4 in NRC Regulatory and Licensing Actions (69 FR 52040, August 24, 2004), which states that 5 "[t]he Commission is committed to the general goals set forth in EO 12898, and strives to meet 6 those goals as part of its NEPA review process." 7 The Council of Environmental Quality (CEQ) provides the following information in Environmental 8 Justice: Guidance under the National Environmental Policy Act (CEQ 1997): 9 Disproportionately High and Adverse Human Health Effects. Adverse health 10 effects are measured in risks and rates that could result in latent cancer fatalities, 11 as well as other fatal or nonfatal adverse impacts on human health. Adverse 12 health effects may include bodily impairment, infirmity, illness, or death. 13 Disproportionately high and adverse human health effects occur when the risk or 14 rate of exposure to an environmental hazard for a minority or low -income 15 population is significant (as employed by NEPA) and appreciably exceeds the 16 risk or exposure rate for the general population or for another appropriate 17 comparison group. 18 Disproportionately High and Adverse Environmental Effects. A 19 disproportionately high environmental impact that is significant (as defined by 20 NEPA) refers to an impact or risk of an impact on the natural or physical 21 environment in a low -income or minority community that appreciably exceeds the 22 environmental impact on the larger community. Such effects may include 23 ecological, cultural, human health, economic, or social impacts. An adverse 24 environmental impact is an impact that is determined to be both harmful and 25 significant (as employed by NEPA). In assessing cultural and aesthetic 26 environmental impacts, impacts that uniquely affect geographically dislocated or 27 dispersed minority or low -income populations or American Indian tribes are 28 considered. 29 The environmental justice analysis assesses the potential for disproportionately high and 30 adverse human health or environmental effects on minority populations and low -income 31 populations that could result from the operation of LGS during the renewal term. In assessing 32 the impacts, the following definitions of minority individuals and populations and low-income 33 population were used (CEQ 1997): 34 Minority individuals . Individuals who identify themselves as members of 35 the following population groups: Hispanic or Latino, American Indian or 36 Alaska Native, Asian, Black or African American, Native Hawaiian or Other 37 Pacific Islander, or two or more races -meaning individuals who identified 38 themselves on a Census form as being a member of two or more races 39 (e.g., Hispanic and Asian). 40 Minority populations . Minority populations are identified when the minority 41 population of an affected area exceeds 50 percent or the minority population 42 percentage of the affected area is meaningfully greater than the minority 43 population percentage in the general population or other appropriate unit of 44 geographic analysis. 45 Low-income population . Low-income populations in an affected area are 46 identified with the annual statistical poverty thresholds from the Census 47 Bureau's Current Population Reports, Series P60, on Income and Poverty. 48 Environmental Impacts of Operation 4-34 4.10.7.1. Minority Population 1 According to 2010 Census data, 34.5 percent of the population residing within a 50 -mi (80-km) 2 radius of LGS identified themselves as minority individuals. The largest minority group was 3 Black or African American (17 percent), followed by Hispanic or Latino (of any race) 4 (9.1 percent) (CAPS 2012). 5 According to 2010 Census data, minority populations in the socioeconomic ROI (Berks, 6 Chester, and Montgomery Counties) comprised 20.6 percent of the total three -county population 7 (see Table 2-9) (USCB 2011). Figure 4 -1 shows minority population block groups, using 8 2010 Census data for race and ethnicity, within a 50 -mile (80-kilometer) radius of LGS. 9 Census block groups were considered minority population block groups if the percentage of the 10 minority population within any block group exceeded 34.5 percent (the percent of the minority 11 population within the 50 -mi radius of LGS). A minority population block group exists if the 12 percentage of the minority population within the block group is meaningfully greater than the 13 minority population percentage in the 50 -mi (80-km) radius. Approximately 2,030 of the 14 5,800 census block groups located within the 50 -mi (80-km) radius of LGS were determined to 15 have meaningfully greater minority populations. 16 Minority population block groups are concentrated in the Philadelphia Metropolitan Area, with 17 smaller concentrations in Reading and Allentown, Pennsylvania. The minority population block 18 group nearest to LGS is located in Sanatoga, Limerick Township, Pennsylvania. According to 19 the 2010 Census, approximately 20.7 percent of the total Sanatoga population (which includes 20 more than one census block group) identified themselves as minority. 21 Environmental Impacts of Operation 4-35 Figure 4-1. 2010 Census Minority Block Groups within a 50 -mi Radius of the LGS 1 Source: USCB 2011 Cities .. Aggregate Minority plus Hispani c
- Limerick Generating Station D County Bound aries D 50 mile Boundary 0 3 6 12 18 24 ll*ci*-=i--iC==:::.i--
Mil es Environmental Impacts of Operation 4-36 4.10.7.2. Low-Income Population 1 According to 2010 American Community Survey Census data, an average of 7.7 percent of 2 families and 10.4 percent of individuals residing in counties within a 50 -mile radius of LGS 3 (Burlington, Camden, Gloucester, Hunterdon, Mercer, Salem, Somerset, and Warren, New 4 Jersey; Berks, Bucks, Carbon, Chester, Delaware, Lancaster, Lebanon, Lehigh, Monroe, 5 Montgomery, Northampton, Philadelphia, and Schuylkill, Pennsylvania; Cecil, Maryland; and 6 New Castle, Delaware) were identified as living below the Federal poverty threshold in 2010. 7 The 2010 Federal poverty threshold was $22,314 for a family of four (USCB 2011). 8 According to the 2010 Census, 9.3 percent of families and 13.4 percent of individuals in 9 Pennsylvania were living below the Federal poverty threshold in 2010, and the median 10 household income for Pennsylvania was $49,288 (USCB 2011). All three counties in the 11 immediate ROI of LGS had higher median household incomes and Montgomery and Chester 12 Counties had lower percentages of families and individuals living below the poverty level when 13 compared to the state average. Berks County had a median household income average 14 of $51,719 and 14.1 percent of individuals and 10.9 percent of families living below the poverty 15 level. Chester County had a median household income average of $82,284 and 6.2 percent of 16 individuals and 3.6 percent of families living below the poverty level. Montgomery County had a 17 median household income of $75,448 and 5.5 percent of individuals and 3.6 percent of families 18 living below the poverty level (USCB 2011). 19 Figure 4-2 shows low-income census block groups within a 50 -mile (80-kilometer) radius of 20 LGS. Census block groups were considered low -income population block groups if the 21 percentage of individuals living below the Federal poverty threshold within any block group 22 exceeded the percent of the individuals living below the Federal poverty threshold within the 23 50-mile radius of LGS. Approximately 2,070 of the 5,800 census block groups located within 24 the 50-mile (80-kilometer) radius of LGS were determined to have meaningfully greater 25 low-income populations . 26 Similar to the locations of minority population block groups, the majority of low -income 27 population block groups are located in the Philadelphia metropolitan area, with smaller 28 concentrations in Reading and Allentown, Pennsylvania. The nearest low -income population to 29 LGS is located in Sanatoga, Limerick Township, Pennsylvania. 30 Environmental Impacts of Operation 4-37 Figure 4-2. 2010 Census Low -Income Block Groups within a 50 -mi Radius of LGS 1 Source: UCSB 2011 Cities .. Lo w Income Popu l ation
- Li merick Generating Station D County Boundaries D 50 mile Boundary _ _i State Boundaries 0 3 6 12 18 24 J.::i.::::i.-..:::::==*-*
Mi l es Environmental Impacts of Operation 4-38 4.10.7.3. Analysis of Impacts 1 The NRC addresses environmental justice matters for license renewal through (1) identifying 2 the location of minority and low -income populations that may be affected by the continued 3 operation of the nuclear power plant during the license renewal term, and (2) determining 4 whether there would be any potential human health or environmental effects to these 5 populations and special pathway receptors, and (3) determining if any of the effects may be 6 disproportionately high and adverse. 7 Figures 4-1 and 4-2 identify the location of minority and low -income block group populations 8 residing within a 50 -mi (80-km) radius of LGS. This area of impact is consistent with the impact 9 analysis for public and occupational health and safety, which also focuses on populations within 10 a 50-mi (80-km) radius of the plant. Chapter 4 presents the assessment of environmental and 11 human health impacts for each resource area. The analyses of impacts for all environmental 12 resource areas indicated that the impact from license renewal would be SMALL. 13 Potential impacts to minority and low -income populations (including migrant workers or Native 14 Americans) would mostly consist of socioeconomic and radiological effects; however, radiation 15 doses from continued operations during the license renewal term are expected to continue at 16 current levels and would remain within regulatory limits. Socioeconomic effects were likewise 17 found to be SMALL. Chapter 5 of this SEIS discusses the environmental impacts from 18 postulated accidents that might occur during the license renewal term, which include both 19 design-basis and severe accidents. The Commission has generically determined that impacts 20 associated with design -basis accidents are small because nuclear plants are designed and 21 operated to successfully withstand such accidents, and the probability weighted impact risks 22 associated with severe accidents are also small. 23 Therefore, based on this information and the analysis of human health and environmental 24 impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high 25 and adverse impacts to minority and low -income populations from the continued operation of 26 LGS during the license renewal term. 27 As part of addressing environmental justice concerns associated with license renewal, the NRC 28 also assessed the potential radiological risk to special population groups (such as migrant 29 workers or Native Americans) from exposure to radioactive material received through their 30 unique consumption and interaction with the environment patterns, including subsistence 31 consumption of fish, native vegetation, surface waters, sediments, and local produce; 32 absorption of contaminants in sediments through the skin; and inhalation of airborne radioactive 33 material released from the plant during routine operation. This analysis is presented below. 34 4.10.7.4. Subsistence Consumption of Fish and Wildlife 35 The special pathway receptors analysis is an important part of the environmental justice 36 analysis because consumption patterns may reflect the traditional or cultural practices of 37 minority and low-income populations in the area, such as migrant workers or Native Americans. 38 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 39 appropriate, to collect, maintain, and analyze information on the consumption patterns of 40 populations that rely principally on fish and/or wildlife for subsistence and to communicate the 41 risks of these consumption patterns to the public. In this SEIS, the NRC staff considered 42 whether there were any means for minority or low -income populations to be disproportionately 43 affected, and it considered this by examining impacts to American Indian s, Hispanics, migrant 44 workers, and other traditional lifestyle special pathway receptors. Special pathways took into 45 account the levels of radiological and nonradiological contaminants in native vegetation, crops, 46 Environmental Impacts of Operation 4-39 soils and sediments, groundwater, surface water, fish, and game animals on or near LGS were 1 considered . 2 The following is a summary discussion of the NRC staff's evaluation from Section 4.9.2 of the 3 radiological environmental monitoring programs (REMPs) that assess the potential impacts for 4 subsistence consumption of fish and wildlife near the LGS site. 5 Exelon has an ongoing comprehensive REMP to assess the impact of LGS operations on the 6 environment. To assess the impact of nuclear power plant operations, samples are collected 7 annually from the environment and analyzed for radioactivity. A plant effect would be indicated 8 if the radioactive material detected in a sample was significantly larger than background levels. 9 Two types of samples are collected. The first type, control samples, are collected from areas 10 that are beyond the measurable influence of the nuclear power plant or any other nuclear 11 facility. These samples are used as reference data to determine normal background levels of 12 radiation in the environment. These samples are then compared with the second type of 13 samples, indicator samples, collected near the nuclear power plant. Indicator samples are 14 collected from areas where any contribution from the nuclear power plant will be at its highest 15 concentration. These samples are then used to evaluate the contribution of nuclear power plant 16 operations to radiation or radioactivity levels in the environment. An effect would be indicated if 17 the radioactivity levels detected in an indicator sample was significantly larger than the control 18 sample or background levels. 19 Samples of environmental media are collected from the aquatic and terrestrial pathways in the 20 vicinity of LGS. Nine hundred and twenty -six radiological environmental samples were collected 21 and analyzed in 2010. The aquatic pathways include groundwater, surface water, drinking 22 water, fish, and shoreline sediment. The terrestrial pathways include airborne particulates, milk, 23 food products (i.e., leafy vegetables, such as cabbage, collards, Swiss Chard, collected from 24 gardens in the vicinity of LGS), and wild animal feed (i.e., broad leaf vegetation). During 2010, 25 analyses performed on samples of environmental media at LGS showed no significant or 26 measurable radiological impact above background levels from site operations (Exelon 2011 b). 27 4.10.8. Conclusion 28 Based on the radiological environmental monitoring data from LGS, the NRC staff finds that no 29 disproportionately high and adverse human health impacts would be expected in special 30 pathway receptor populations in the region as a result of subsistence consumption of water, 31 local food, fish, and wildlife. 32 4.11. Evaluation of New and Potentially Significant Information 33 New and significant information is: (1) information that identifies a significant environmental 34 issue not covered in the GEIS and codified in Table B -1 of 10 CFR Part 51, Subpart A, 35 Appendix B, or (2) information that was not considered in the analyses summarized in the GEIS 36 and that leads to an impact finding that is substantially different from the finding presented in the 37 GEIS and codified in 10 CFR Part 51. 38 The new and significant assessment that Exelon conducted during the preparation of the license 39 renewal application included: (1) interviews with Exelon subject -matter experts on the validity of 40 the conclusions in the GEIS as they relate to LGS, (2) review of the results of LGS 41 environmental monitoring and reporting, as required by regulations and oversight of plant 42 facilities and operations by state and Federal regulatory agencies, (3) a review of 43 correspondence with state and Federal agencies to determine if agencies had concerns 44 relevant to their resource areas that had not been addressed in the GEIS, (4) a review for 45 Environmental Impacts of Operation 4-40 issues relevant to the LGS application of certain license renewal applications that operators of 1 other nuclear plants have previously submitted to the NRC, (5) an extensive review of 2 documents related to environmental issues at LGS, and (6) a review of information related to 3 severe accident mitigation. 4 The NRC also has a process for identifying new and significant information, which is described 5 in NUREG-1555, Supplement 1, "Standard Review Plans for Environmental Reviews for 6 Nuclear Power Plants, Supplem e nt 1; Operating License Renewal" (NRC 19 9 9b). The search 7 for new information includes: (1) review of an applicant's ER and the process for discovering 8 and evaluating the significance for new information, (2) review of records for public comments, 9 (3) review of environmental quality standards and regulations, (4) coordination with Federal, 10 state, and local environmental protection and resource agencies, and (5) review of the technical 11 literature. New information discovered by the NRC staff is evaluated for significance using 12 criteria set forth in the GEIS. For Category 1 issues in which new and significant information is 13 identified, reconsideration of the conclusions for those issues is limited in scope to the 14 assessment for the relevant new and significant information; the scope of the assessment does 15 not include other facets of an issue that are not affected by the new information. 16 Exelon reported in its ER (Exelon 2011a) that it was aware of one new radiological issue 17 associated with the renewal of the LGS operating license -tritium in groundwater. In 2006, 18 Exelon implemented a fleet -wide program to proactively review the environmental status of its 19 nuclear power generating stations, specifically to identify the potential for releases of 20 radionuclides. The program is consistent with the guidance provided in NEI 07 -07, "Industry 21 Ground Water Protection Initiative -Final Guidance Document ." As part of this program, Exelon 22 commissioned a hydrogeologic investigation of LGS to evaluate any groundwater impact from 23 radionuclides that may have been released from the plant. Exelon also developed its RGPP 24 during this time. 25 A groundwater monitoring well network for LGS's groundwater protection program was 26 designed and installed to gather any radionuclide release data. Monitoring was initiated in 2006 27 and performed at least semi -annually on each monitoring well. The results of the program , 28 including trending data, program modifications, reporting protocols, and other information are 29 included in the annual LGS radiological environmental operating reports. Neither Sr -90 nor any 30 LGS-related gamma -emitting radionuclides have been identified in any groundwater sample. 31 The reporting level for tritium in groundwater specified in the Exelon Offsite Dose Calculation 32 Manual (ODCM) is equal to the EPA drinking water standard of 20,000 picocuries per liter 33 (pCi/L). The ODCM specifies a detection capability of 200 pCi/L for analyzing tritium 34 concentrations in groundwater samples. 35 The groundwater monitoring data are reported in the annual LGS REMP reports. Sampling of 36 the monitoring well network at LGS has not identified any tritium concentration greater than 37 20,000 pCi/L. Tritium was detected during a 2006 site investigation at a concentration of 2,020 38 +/- 154 pCi/L in a sample collected from the power block foundation sump, which accumulates 39 water from the drain system around the power block. This water is not in direct contact with 40 groundwater and, therefore, also is not reflective of groundwater quality beneath LGS. Tritium 41 concentrations greater than 2,000 pCi/L, but below the reporting level of 20,000 pCi/L, have 42 been detected in power block foundation sump samples on other occasions since 2006. 43 Exelon's evaluation of the groundwater monitoring data concluded that there are no significant 44 impacts associated with tritium in groundwater down gradient of LGS. This conclusion is based 45 on the following information. Sampling of the monitoring well network at LGS has not identified 46 tritium concentration s greater than the reporting level of 20,000 pCi/L. There is no groundwater 47 connectivity with the monitoring points that have shown tritium concentrations greater than 48 Environmental Impacts of Operation 4-41 2, 000 pCi/L. None of the wells that ha ve detectable tritium are used by workers or members of 1 the public for drinking water. The applicant's groundwater protection monitoring program and 2 REMP will continue to monitor the groundwater and report the results in the annual radioactive 3 effluent operating reports. Also, NRC inspectors will periodically review the REMP data for 4 compliance with NRC radiation protection standards. Based on the above, the NRC staff 5 concludes that the issue of tritium contamination of the groundwater on the LGS site is not 6 significant. 7 4.12. Cumulative Impacts 8 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 9 protection regulation, 10 CFR Part 51. With respect to cumulative impacts , the revised rule 10 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 11 Category 2 issue, "Cumulative impacts," to evaluate the potential cumulative impacts of license 12 renewal. 13 The NRC staff considered potential cumulative impacts in the environmental analysis of 14 continued operation of the LGS nuclear plant during the 20 -year license renewal period. 15 Cumulative impacts may result when the environmental effects associated with the proposed 16 action are overlaid or added to temporary or permanent effects associated with other past, 17 present, and reasonably foreseeable actions. Cumulative impacts can result from individually 18 minor, but collectively significant, actions taking place over a period of time. It is possible that 19 an impact that may be SMALL by itself could result in a MODERATE or LARGE cumulative 20 impact when considered in combination with the impacts of other actions on the affected 21 resource. Likewise, if a resource is regionally declining or imperiled, even a SMALL individual 22 impact could be important if it contributes to or accelerates the overall resource decline. 23 For the purposes of this cumulative analysis, past actions are those before the receipt of the 24 license renewal application. Present actions are those related to the resources at the time of 25 current operation of the power plant, and future actions are those that are reasonably 26 foreseeable through the end of plant operation, including the period of extended operation. 27 Therefore, the analysis considers potential impacts through the end of the current license terms 28 as well as the 20 -year renewal license term. The geographic area over which past, present, 29 and reasonably foreseeable actions would occur depend s on the type of action considered and 30 is described below for each resource area. 31 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 32 in Sections 4.1 to 4.10, are combined with other past, present, and reasonably foreseeable 33 future actions regardless of what agency (Federal or non -Federal) or person undertakes such 34 actions. The NRC staff used the information provided in the ER; responses to requests for 35 additional information; information from other Federal, state, and local agencies; scoping 36 comments; and information gathered during the visits to the LGS site to identify other past, 37 present, and reasonably foreseeable actions. To be considered in the cumulative analysis, the 38 NRC staff determined if the project would occur within the noted geographic areas of interest 39 and within the period of extended operation, was reasonably foreseeable, and if there would be 40 potential overlapping effect with the proposed project. For past actions, consideration within the 41 cumulative impacts assessment is resource and project -specific. In general, the effects of past 42 actions are included in the description of the affected environment in Chapter 2, which serves as 43 the baseline for the cumulative impacts analysis. However, past actions that continue to have 44 an overlapping effect on a resource potentially affected by the proposed action are considered 45 in the cumulative analysis. 46 Environmental Impacts of Operation 4-42 Other actions and projects identified during this review and considered in the NRC staff's 1 independent analysis of the potential cumulative effects are described in Appendix F. Examples 2 of other actions that were considered in this analysis include the following: 3 Cromby Generating Station, 4 Titus coal plant, 5 independent spent fuel storage installation, 6 transmission lines 7 future urbanization, and 8 Schuylkill River greenway. 9 4.12.1. Air Quality 10 This section addresses the direct and indirect effects of license renewal on air quality resources 11 when added to the aggregate effects of other past, present, and reasonably foreseeable future 12 actions. As described in Section 4.2, the incremental impacts on air quality from the proposed 13 license renewal would be SMALL, as there is no planned refurbishment associated with the 14 LGS license renewal. The geographic area considered in the cumulative air quality analysis is 15 the county of the proposed action because air quality designations for criteria air pollutants are 16 generally made at the county level. Counties are further grouped together based on a common 17 air shed-known as an air quality control region (AQCR) -to provide for the attainment and 18 maintenance of the National Ambient Air Quality Standards (NAAQS). The LGS site is located 19 in Montgomery and Chester Counties, Pennsylvania , and is part of the Metropolitan 20 Philadelphia Intrastate AQCR (40 CFR 81.15). Additional counties in this AQCR include Bucks, 21 Delaware, and Philadelphia Counties. 22 Section 2.2.2 presents a summary of the air quality designation status for Montgomery and 23 Chester Counties. As noted in Section 2.2.2, EPA regulates six criteria pollutants under the 24 NAAQS, including carbon monoxide, lead, nitrogen dioxide, ozone, sulfur dioxide, an d 25 particulate matter. Montgomery and Chester Counties are designated unclassified or in 26 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM 10; and nonattainment 27 with respect to ozone and PM2.5 (40 CFR 81.339). All other counties in this AQCR are similarly 28 designated with respect to the NAAQS criteria pollutants. 29 Criteria pollutant air emissions from the LGS site are presented in Section 2.2.2.1; these 30 emissions are principally from standby diesel generators, boilers, two cooling towers, and a 31 spray pond. Air pollutants from these sources are permitted under a Title V operating permit 32 (TVOP-46-00038) (Exelon 2011a). In Section 4.2, it was noted that there would be no new air 33 emissions associated with the LGS license renewal because there is no planned site 34 refurbishment. Therefore, cumulative changes to air quality in Montgomery and Chester 35 Counties would be the result of changes to present -day emissions from other existing facilities 36 as well as future projects and actions within the county. 37 Appendix F provides a list of present and reasonably foreseeable projects that could contribute 38 to cumulative impacts to air quality. Continued air emissions from existing projects and actions 39 listed in Appendix F as well as proposed new source activities would contribute to air emissions 40 in Montgomery and Chester Counties and will affect air quality within the region. Development 41 and construction activities associated with regional growth of housing, business, and industry, 42 as well as associated vehicular traffic, also will result in additional air emissions. Project timings 43 and locations, which are difficult to predict, affect cumulative impacts to air quality. However, 44 permitting and licensing requirements, efficiencies in equipment, cleaner fuels, and various 45 mitigation measures can be used to minimize cumulative air quality impacts. 46 Environmental Impacts of Operation 4-43 The effects of global climate change are already being felt in the northeastern United States , 1 including an increase in annual average temperatures since 1970. This warming has resulted in 2 many other climate -related changes, such as more frequent days over 90 °F (32 °C), increased 3 heavy precipitation, less snow and more rain in winter, reduced snowpack, earlier spring 4 snowmelt, and rising sea temperatures and sea level. The Northeast is projected to face 5 continued warming and more extensive climate -related changes. Extreme heat and declining 6 air quality (notably ozone) could affect human health. States, however, must continue to comply 7 with the Clean Air A ct, so it is likely that additional limitations on ozone precursors could help 8 counteract this effect. 9 The overall warming trend also affects patterns of agricultural production and fisheries in the 10 region, and the projected reduction in snow cover would adversely affect winter recreation and 11 its related industries. Above all, more frequent flooding due to the sea -level rise and heavy 12 downpours would have severe impacts on densely populated coastal areas, resulting in storm 13 surges, coastal flooding, erosion, losses of life, property damage, and loss of wetlands 14 (Karl et al. 2009). While these impacts are the result of changing atmospheric conditions, most 15 of them are not, in and of themselves, air quality impacts. 16 Given that there is no planned plant refurbishment associated with the LGS license renewal, 17 and therefore no expected changes in air emissions, cumulative air quality impacts in 18 Montgomery and Chester Counties would be the result of changes to present -day emissions 19 and emissions from reasonably foreseeable projects and actions. As NRC staff noted above, 20 project timings and locations, which are difficult to predict, affect cumulative impacts to air 21 quality. However, various strategies and techniques are available to limit air quality impacts. 22 Therefore, the NRC staff concludes that the cumulative air quality impacts from the proposed 23 license renewal and other past, present, and reasonably foreseeable projects would be SMALL. 24 4.12.2. Water Resources 25 This section addresses the direct and indirect effects of license renewal on water resources 26 when added to the aggregate effects of other past, present, and reasonably foreseeable future 27 actions. As described in Sections 4.4 and 4.5, the incremental impacts on water resources from 28 continued operations of LGS, Units 1 and 2 during the license renewal term would be SMALL. 29 NRC staff also conducted an assessment of other projects and actions for consideration in 30 determining their cumulative impacts on water resources (see Appendix F). The geographi c 31 area considered for the surface water resources component of the cumulative impacts analysis 32 spans the Delaware River Basin. For groundwater, the area considered encompasses the local 33 groundwater basin relative to LGS in which groundwater is recharged and flows to discharge 34 points, or is withdrawn through wells. As such, this review focused on those projects and 35 activities that would (1) withdraw water from or discharge wastewater to the Delaware River or 36 its tributaries (i.e., the Schuylkill River) and/or (2) would use groundwater or could otherwise 37 affect the bedrock aquifer beneath the LGS site. 38 4.12.2.1. Cumulative Impacts on Surface Water Resources 39 Water resource managers must balance multiple conflicting water management objectives. 40 Within the Delaware River Basin, this includes demands for power generation, municipal water, 41 industrial water, agricultural water, mining, recreation, flood protection, and instream flow 42 requirements to sustain aquatic life (see Section 4.12.2). The Delaware River Basin 43 Commission (DBRC) was formed to balance these objectives. These tradeoff decisions reflect 44 an understanding of the inevitable uncertainty in regulated flows that result from inter -annual 45 and intra-annual variability. Based on the USGS gage on the Schuylkill River at Pottstown, 46 Pennsylvania, for water years 1928 to 2010, the highest annual mean flow and lowest annual 47 Environmental Impacts of Operation 4-44 mean flow recorded are 3,211cfs (90.7 m 3/s) and 843 cfs (23.8 m 3/s), respectively. The highest 1 daily mean flow and the lowest daily mean flow recorded are 71,200 cfs (2,011 m 3/s) and 2 175 cfs (4.9 m 3/s), respectively (USGS 2010). This magnitude of variability reflects climate 3 variability and no other projects within the basin. 4 To support full operations of LGS, Units 1 and 2, Exelon must withdraw up to 4 2 mgd or 5 29,200 gpm (65 cfs or 1.8 m 3/s) of water from either the Schuylkill River or other sources for 6 consumptive cooling water use, as further described in Section 2.1.7.1 of this SEIS. Surface 7 water withdrawals by LGS, like other similar surface water users in the basin, are subject to 8 limits and conditions imposed by DRBC dockets. Relative to the cited magnitude of variability of 9 flows in the Schuylkill River, the hydrologic impacts of surface water withdrawals associated 10 with LGS operations are very small. 11 In general, water quality across the Delaware River Basin has dramatically improved over the 12 past several decades. The water quality of the Delaware River and its main tributaries, such as 13 the Schuylkill River, was profoundly impaired by municipal and industrial waste discharges and 14 mining activities. Regulatory changes, including implementation of the Clean Water Act, have 15 eliminated many of the largest point and nonpoint sources of water quality degradation. Still, 16 within this context, the trend in urban and suburban development in the immediate LGS region 17 (see Sections 4.12.3 and 4.12.4) and associated corridor -type development (e.g., roads) to 18 keep pace with overall population growth in the Delaware River Basin has introduced a different 19 impact dynamic. From the perspective of water quality, these types of development generally 20 substitute more diffuse sources of pollution (i.e., nonpoint) and their impacts for point sources 21 traditionally associated with industry. 22 Nevertheless, the segment of the Schuylkill River near LGS meets all established water quality 23 standards at present, as further described in Section 2.2.4.1. The DRBC is responsible for 24 classifying all waters in the basin as to use, setting basin -wide water quality standards, 25 establishing pollutant treatment and control regulations, and reviewing projects or other 26 undertakings with the potential to affect basin water resources for conformance with the DRBC 27 Comprehensive Plan (DRBC 2001). DRBC acts in coordination with the states and other 28 parties that are signatories to the DRBC Compact (DRBC 1961) to include the imposition of 29 necessary effluent limitations on industrial wastewater discharges to surface water. 30 In addition, the NRC staff considered the U.S. Global Change Research Program's (USGCRP 's) 31 most recent compilation of the state of knowledge relative to global climate change effects 32 (Karl 2009). Temperatures in the Northeastern United States are projected to rise an additional 33 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 34 2050. This would be in addition to the 2 °F (1.1 °C) increase in annual average temperature 35 that has occurred since 1970. Sea level is expected to continue to rise. While there is great 36 uncertainty, sea levels are expected to rise between 3 and 4 ft (0.9 to 1.2 m) by the end of this 37 century. Meanwhile, precipitation and runoff are projected to increase in the winter and spring 38 across the Northeast. Increased runoff generally equates to increased streamflow 39 (Karl et al. 2009). 40 Without an offsetting increase in discharge in the Delaware River, any sea level rise associated 41 with climate change will cause increased upstream saltwater migration and potentially affect 42 fresh water withdrawals upstream of the salt line (see Section 2.2.4.1). This could lead to fresh 43 water availability and water use conflicts. Moreover, permitting agencies, principally the PADEP 44 and the DRBC, could have to consider imposing more stringent effluent limits on power plant 45 discharges, should water temperatures rise. These predictions, if borne out, have important 46 implications for the Delaware River Basin as a whole, but the overall interaction of predicted 47 Environmental Impacts of Operation 4-45 hydrologic changes and their effect on water users in the Delaware River Basin is highly 1 speculative at the present time. 2 Surface water withdrawals for LGS operations are a small fraction of the mean annual flow of 3 the Schuylkill River, and the discharge of cooling tower blowdown has not significantly affected 4 ambient surface water quality. The NRC staff did not identify any exceptional limitations to 5 water resources. The NRC staff concludes that the cumulative impacts from past, present, and 6 reasonably foreseeable future actions on surface water resources during the license renewal 7 term would be SMALL. This conclusion is based on the regulatory framework established by 8 the DBRC and PADEP in managing surface water use and quality and the generally improving 9 trend in conditions in the Schuylkill River and within the Delaware River Basin. 10 4.12.2.2. Cumulative Impacts on Groundwater Resources 11 The Brunswick bedrock aquifer is the most widespread source of groundwater in the plant 12 region and across the Triassic lowlands of the Newark Basin. LGS's four groundwater 13 production wells are completed in the Brunswick aquifer system along with over 50 domestic 14 and several other commercial/industrial supply wells within a 1 -mi (1.6-km) radius of LGS (see 15 Section 2.2.5.1). 16 The DRBC promulgated its Ground Water Protected Area Regulations (DRBC 1999; 17 18 CFR 430) to manage groundwater resources in the Triassic lowland and adjacent areas in 18 southeastern Pennsylvania. LGS and its regulated production wells are located in the 19 Schuylkill -Sprogels Run Subbasin, as delineated by the DRBC (DRBC 1999; Exelon 2011a). 20 The DRBC has established a total maximum withdrawal limit of 1,455 million gal/yr (mgy) 21 (5.49 million m 3/yr) for the subbasin. It has also set a withdrawal level of 1,091 mgy 22 (4.12 million m 3/yr) as that level where groundwater resources of the subbasin would be 23 "potentially stressed" (DRBC 1999; 18 CFR 430). Nonetheless, total net annual groundwater 24 withdrawals in the subbasin are currently well below the DRBC limits at 174.89 mgy 25 (0.66 million m 3/yr) (DRBC 2011). As described in Section 2.1.7.2, total LGS site groundwater 26 withdrawals have averaged about 31,500 gpd or 11.5 mgy (0.04 million m 3/yr). This withdrawal 27 is about 0.8 and 1.1 percent, respectively, of the DRBC established thresholds for groundwater 28 withdrawals in the Schuylkill -Sprogels Run Subbasin. 29 LGS operations have resulted in inadvertent releases of liquids containing tritium to the bedrock 30 aquifer, as described in Sections 4.5.2 and 2.2.5.2 of this SEIS. However, there has been no 31 migration of tritium in groundwater exceeding 2,000 pCi/L, and tritium levels have been we ll 32 below the EPA primary drinking water standard (i.e., 20,000 pCi/L) at all onsite monitoring wells. 33 In addition, there are no potable water users downgradient of the LGS power block that have 34 been affected by the inadvertent releases. As site groundwater locally discharges to the 35 Schuylkill River and Possum Hollow Run where rapid mixing and dilution occurs, there is no 36 drinking water pathway to other groundwater users. Meanwhile, Exelon maintains an ongoing 37 RGPP at LGS to detect and correct the source of inadvertent releases of 38 radionuclide -containing liquids. 39 In summary, the DRBC has established limits on total groundwater withdrawals in the local 40 groundwater subbasin, and current total withdrawals for all projects identified in this review are a 41 small percentage of the established thresholds for the subbasin. LGS groundwater withdrawals 42 are not expected to increase during the license renewal term. Further, inadvertent releases of 43 liquids containing tritium have not impacted groundwater quality beyond the site boundary, and 44 there is no pathway to other drinking water users. Tritium levels as measured in groundwater 45 on site are well below the EPA drinking water standard and a program is in place to safeguard 46 groundwater quality. Based on the above considerations, the NRC staff concludes that the 47 Environmental Impacts of Operation 4-46 cumulative impacts from past, present, and reasonably foreseeable future actions on 1 groundwater use and quality during the license renewal term would be SMALL. 2 4.12.3. Aquatic Resources 3 This section addresses the direct and indirect effects of license renewal on aquatic resources 4 when added to the aggregate effects of other past, present, and reasonably foreseeable future 5 actions. As described in Section 4. 6, the incremental impacts on aquatic biota from the 6 proposed license renewal would be SMALL. The geographic area considered in the cumulative 7 aquatic resources analysis includes the LGS cooling water sources in the vicinity of intake and 8 discharge structures on the Schuylkill River, the Perkiomen Creek, the Delaware River, and 9 along the East Branch Perkiomen Creek and Perkiomen Creek where water from the Delaware 10 River is discharged to augment flows to the Perkiomen Creek. 11 The benchmark for assessing cumulative impacts on aquatic resources takes into account the 12 preoperational environment as recommended by the EPA (1999), for its review of NEPA 13 documents, as follows: 14 Designating existing environmental conditions as a benchmark may focus the 15 environmental impact assessment too narrowly, overlooking cumulative impacts 16 of past and present actions or limiting assessment to the proposed action and 17 future actions. For example, if the current environmental condition were to serve 18 as the condition for assessing the impacts of relicensing a dam, the analysis 19 would only identify the marginal environmental changes between the continued 20 operation of the dam and the existing degraded state of the environment. In this 21 hypothetical case, the affected environment has been seriously degraded for 22 more than 50 years with accompanying declines in flows, reductions in fish 23 stocks, habitat loss, and disruption of hydrologic functions. If the assessment 24 took into account the full extent of continued impacts, the significance of the 25 continued operation would more accurately express the state of the environment 26 and thereby better predict the consequences of relicensing the dam. 27 Sections 2.2.4 and 2.2.6 present an overview of the condition of the Schuylkill River, Perkiomen 28 Creek, East Branch Perkiomen Creek, and the Delaware River at the Point Pleasant Pumping 29 Station, and the history and factors that led to current conditions. The direct and indirect 30 impacts from water use and industrial discharge, such as mining waste water, are some of the 31 most influential human activities on the Delaware River Basin (DRBC 2010a). Within the 32 Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek, increased urbanization 33 over the past 100 years has also led to increased runoff and elevated levels of pollutants within 34 (Rhoads and Block 2008). On the Schuylkill River, the construction of dams beginning in the 35 early 1800s blocked anadromous fish migrations and resulted in the decline of American shad, 36 river herring, and blueback herring, which require movement between freshwater and marine 37 waters to complete their life cycles (Perillo and Butler 2009). 38 Many natural and anthropogenic activities can influence the current and future aquatic biota in 39 the area surrounding the LGS site and the Delaware River Basin. Potential biological stressors 40 include operational impacts from LGS (as described in Section 4. 6), increasing urbanization, 41 energy development, and climate change. 42 4.12.3.1. Urbanization and Water Quality 43 Interlandi and Crockett (2003) reported an increase in residential and commercial development 44 for the area surrounding LGS along the Schuylkill River, Perkiomen Creek, and East Branch 45 Perkiomen Creek, and a decrease in population near Philadelphia. Increased urbanization has 46 led to increases in dissolved nitrate and chloride levels in the Schuylkill River. Urbanization will 47 Environmental Impacts of Operation 4-47 likely continue to contribute significant organic and metal pollutants to the river through runoff 1 (Interlandi and Crockett 2003). The DRBC and EPA manage and set total maximum daily load 2 (TMDL) limits for contaminants, such as polychlorinated biphenyl (PCBs), to help control future 3 pollution of waters within the Delaware River Basin (DRBC 2008, EPA 2007). 4 Several other facilities within 10 miles (16 km) of LGS have NPDES permits to discharge into 5 the Schuylkill River, which contributes to the cumulative impacts to aquatic habitats 6 (EPA 2012 a). For example, six municipal wastewater treatment facilities discharge treated 7 wastewater to the Schuylkill River for a total discharge of less than 9 mgd (Appendix F). In 8 addition, at least seven major industrial facilities, such as industrial laundry facilities, chemical 9 production facilities, and aluminum die casting facilities, discharge into the Schuylkill River. Two 10 municipal and one industrial treatment facilities discharge to Perkiomen Creek with a maximum 11 total discharge of 2.0 mgd (Appendix F). Three major industrial facility NPDES permits for water 12 discharge to Perkiomen Creek exist within a 10 -mi (16-km) radius of LGS. Little effect to 13 aquatic habitats from industrial and wastewater discharges is expected assuming that facilities 14 comply with NPDES permit limitations. 15 4.12.3.2. Energy Development 16 A number of energy plants withdraw water from the Schuylkill and Delaware Rivers. Within 17 30 miles (48 km) of LGS, one oil plant and one natural -gas plant also withdraw and discharge to 18 the Schuylkill River. In 2011, Exelon decommissioned two coal -fired units on the Schuylkill 19 River at Cromby Generating Station (Appendix F). Two coal and two natural -gas plants operate 20 near the confluence of the Delaware and Schuylkill Rivers, and use tidal Delaware River water 21 as the main water source. In 2005, DRBC annual consumptive surface water use records show 22 Eddystone Generating Station Coal Plant at 897 million gallons per year (MGY) (3.4 million m 3), 23 Florida Power & Light Energy Marcus Hook gas plant at 1,018 MGY (3.85 million m 3), and 24 Fairless Energy at 495 MGY (1.87 million m
- 3) (DRBC 2012a). These energy plants use water 25 resources shared by LGS, but do not affect habitats or aquatic biota directly associated with the 26 LGS cooling system.
27 Marcellus shale formation underlies approximately 36 percent of the Delaware River Basin and 28 energy companies are actively seeking to mine the natural gas deposits within the Marcellus 29 Shale (DRBC 2012b). Several impacts to aquatic habitat could occur during the mining 30 process, including physical habitat disturbance at the drill site; the potential to add, discharge, or 31 cause the release of pollutants into waterbodies near the drill site; reduced water flow where 32 water is withdrawn to support mining operations; and degradation of aquatic habitat if recovered 33 "frac water" is not properly treated before discharge into waterbodies (DRBC 2012b). Direct 34 impacts to aquatic biota could occur if aquatic organisms are immobile or unable to avoid the 35 drill site. On May 5, 2010, DRBC voted to postpone its consideration of well pad dockets 36 until DRBC has developed and implemented regulations for natural gas development within 37 Marcellus Shale. As of May 2012, DRBC was in the process of developing these regulations, 38 which would likely provide protection of aquatic resources during drilling activities 39 (DRBC 2012b). 40 4.1 2.3.3. Climate Change 41 Within the northeast region, climate models predict increasing average annual temperatures 42 that foster rising sea surface temperatures and sea levels, increased heavy precipitation, 43 reduced snowpack, and earlier spring peak river flows (Karl et al. 2009). The impacts of climate 44 change on aquatic communities within the Delaware River Basin may be substantial and 45 subsequently affect aquatic resources in the region. For example, seasonal spawning may shift 46 earlier to coincide with earlier spring flows from higher temperatures melting snowpack earlier in 47 the season. Increased water temperatures and higher sea levels may result in anadromous fish 48 Environmental Impacts of Operation 4-48 migrations further up the Delaware or Schuylkill Rivers. Further degradation of water quality 1 from increased runoff following heavy precipitation events may compromise sensitive life stages 2 of aquatic species in associated watersheds and have noticeable effects on aquatic populations. 3 Interlandi and Crockett (2003) examined the relative influences of climate change and 4 stormwater discharge on the Schuylkill River Basin from 1895 to 1999 using temperature, 5 precipitation, and river discharge data. While seasonal variations exist, the overall influence of 6 long-term climate change showed marginal influence as increasing urbanization and increased 7 stormwater discharge had a larger direct effect on water quality (Interlandi and Crockett 2003). 8 Therefore, stormwater discharges may play a larger role than climate change in cumulative 9 changes to aquatic biota in the future. 10 4.12.3.4. Conclusion 11 The stresses from past river flow alterations, increasing urbanization, and demand for water 12 resources across the geographic area of interest depend on many factors that the NRC staff 13 cannot quantify, but they are likely to noticeably alter aquatic resources when all stresses on the 14 aquatic communities are assessed cumulatively. Therefore, the NRC staff concludes that the 15 cumulative impacts from the proposed license renewal and other past, present, and reasonably 16 foreseeable projects would be SMALL to MODERATE. 17 4.12.4. Terrestrial Resources 18 This section addresses past, present, and future actions that could result in cumulative impacts 19 on the terrestrial species and habitats described in Section 2.2.7. For purposes of this analysis, 20 the geographic area considered in the evaluation includes the LGS site, the in -scope 21 transmission line corridors, and the offsite facilities associated with the LGS makeup water 22 system. See Section 2.2.8.1 for a description of these areas. 23 Historic Conditions 24 Section 2.2.7 discusses the ecoregion in which the LGS site is located -the Triassic Lowlands 25 portion of the Northern Piedmont ecoregion -which is dominated by Appalachian oak forest. In 26 the region surrounding the LGS site, much of what would be forest has been cleared and 27 cultivated for crops, hayfields, and pastureland. Forest remains on marginal land, such as steep 28 slopes and land with poorer quality soils. From 1973 to 2000, about 6.2 percent of land in the 29 Northern Piedmont ecoregion changed in land use type. New development surrounding urban 30 areas accounted for about 70 percent of this change. This rate of land development is one of 31 the highest in the Eastern ecoregions over the time period (Auch 2003). 32 On the immediate site, PECO cleared about 270 ac (110 ha; 42 percent of the current LGS site) 33 for construction of the facility's buildings, parking lots, roads, and other infrastructure 34 (AEC 1973). The terrestrial habitats on the undeveloped portions of the site have not changed 35 significantly since LGS's construction (Exelon 2011a). 36 Energy-Producing Facilities 37 A number of operating energy -producing facilities within the vicinity of the LGS site could affect 38 the terrestrial environment now and in the future. 39 Two bituminous coal plants operate near LGS: the Cromby Generating Station (6 mi [10 km] 40 southeast) and the Titus Coal Plant (18 mi [29 km] northwest). Coal-fired plants are a major 41 source of air pollution in the United States because they release sulfur dioxide, nitrogen oxides, 42 mercury, carbon dioxide, and particulates. Nitrous oxides and sulfur dioxides combine with 43 water to form acid rain, which can lead to erosion and changes in soil pH levels. Mercury 44 Environmental Impacts of Operation 4-49 deposits onto soil and surface water, which may then be taken up by terrestrial and aquatic 1 plant or animal species and poses the risk of bioaccumulation. 2 Several natural gas plants operate in the region as well, including Linfield Energy Center, which 3 lies 3 mi (5 km) northwest of LGS. Natural gas plants emit nitrous oxides and sulfur dioxides, 4 though at much lower levels than coal plants. Methane, a primary component of natural gas 5 and also a greenhouse gas, can be released when natural gas is not burned completely or as a 6 result of leaks or losses during transportation. The release of methane contributes to climate 7 change, the terrestrial resource impacts of which are discussed below. 8 Additionally, a number of distillate oil facilities in the area contribute to air emissions, which can 9 result in bioaccumulation of chemicals and contribute to climate change, as discussed above. 10 Urbanization and Habitat Fragmentation 11 As the region surrounding the LGS site becomes more developed, habitat fragmentation will 12 increase. Species that require larger ranges, especially predators, will likely suffer reductions in 13 their populations. In contrast, herbivores will experience less predation pressure and their 14 populations are likely to increase. Edge species will benefit from the fragmentation, while 15 species that require interior forest or swamp habitat will likely suffer. The transmission line 16 corridors established for LGS's transmission lines represent habitat fragmentation, though all of 17 the LGS transmission lines were constructed along existing utility or railroad corridors; therefore, 18 these lines likely did not contribute measurable cumulative impacts. 19 Agricultural Runoff 20 As of 2000, agriculture accounted for about 20 percent of Montgomery County's land acreage 21 (MCPCB 2005). As development continues, the county's agricultural lands are being converted 22 to residential and commercial uses; however, a significant portion of the county continues to be 23 used for agriculture. The 2000 National Water Quality Inventory reported that agricultural 24 nonpoint source pollution accounted for the second largest source of impairments to wetlands 25 (EPA 2012b). Fertilizers and pesticides can affect wetlands in a variety of ways. Because 26 wetlands are often at lower elevation than surrounding land, they receive much of the runo ff 27 first, and that runoff persists because it is unable to drain to lower ground. This can result in 28 pollutant loadings and bioaccumulation and changes to species composition and abundance 29 and increases. Species that rely on wetlands, such as birds and amphibians, are more 30 sensitive to environmental stressors, which exacerbate these effects. 31 Parks and Conservation Areas 32 Eleven National and state parks occur within 30 mi (50 km) of the LGS site (see Appendix F). 33 These areas will continue to provide valuable habitat to native wildlife and migratory birds. As 34 habitat fragmentation resulting from various types of development occurs, these areas will 35 become ecologically more important because they will provide large areas of natural habitat. 36 The Montgomery County Planning Commission (MCPC) has designated about 24 percent of the 37 county as conservation landscapes. Conservation landscapes provide a focus for the county's 38 restoration and native habitat management efforts. The MCPC has designated 13 of these 39 landscapes, which total about 75,000 ac (30,000 ha). These conservation landscapes include 40 relatively large forested tracts, stream corridors, wetlands, known sites of rare plant and animal 41 species, and areas of high natural biodiversity. The large tracts of forest support native bird and 42 wildlife diversity throughout the county, and the wetland habitats are critical to maintaining 43 native amphibian and reptile populations (Rhoads and Block 2008). In addition, terrestrial 44 habitats within the Schuylkill River corridor are protected by the Schuylkill River National and 45 State Heritage Area. 46 Environmental Impacts of Operation 4-50 Climate Change 1 Over the next several decades, the U.S. Global Change Research Program (Karl et al. 2009) 2 estimates that summer temperatures within the Northeast will rise 1.5 to 3.5 °F (0.8 to 1.9 °C) 3 and winter temperatures will rise 2.5 to 4 °F (1.4 to 2.2 °C). By late this century, the Northeast 4 is likely to experience shorter winters with more precipitation; short -term droughts in the summer 5 months; longer, hotter summers; and sea -level rise, among other effects. Changes in the 6 climate will shift many wildlife population ranges and alter migratory patterns. Such changes 7 could favor non -native invasive species and promote the population increases of insect pests 8 and plant pathogens. Climate change will likely alter disturbance regimes as the severity or 9 frequency of precipitation, flooding, and fire change. Climate change may also exacerbate the 10 effects of existing stresses in the natural environment, such as those caused by habitat 11 fragmentation, invasive species, nitrogen deposition and runoff from agriculture, and air 12 emissions. 13 Conclusion 14 The NRC staff examined the cumulative effects of the construction of LGS , neighboring 15 energy-producing facilities, continued urbanization and habitat fragmentation, agricultural runoff, 16 nearby parks and conservation areas, and climate change. The NRC staff concludes that the 17 minimal terrestrial impacts from the continued LGS operations would not contribute to the 18 overall decline in the condition of terrestrial resources. The NRC staff believes that the 19 cumulative impacts of other and future actions during the term of license renewal on terrestrial 20 habitat and associated species, when added to past, present, and reasonably foreseeable 21 future actions, would be MODERATE. 22 4.12.5. Human Health 23 The radiological dose limits for protection of the public and workers have been developed by the 24 NRC and EPA to address the cumulative impact of acute and long -term exposure to radiation 25 and radioactive material. These dose limits are codified in 10 CFR Part 20 and 26 40 CFR Part 190. For the purpose of this analysis, the area within a 50 -mi (80-km) radius of 27 LGS was included. The REMP conducted by Exelon in the vicinity of the LGS site measures 28 radiation and radioactive materials from all sources (i.e., hospitals and other licensed users of 29 radioactive material); therefore, the monitoring program measures cumulative radiological 30 impacts. Within the 50 -mi (80-km) radius of the LGS site there are currently no other nuclear 31 power reactors or uranium fuel cycle facilities. 32 Radioactive effluent and environmental monitoring data for the 5 -year period from 2006 to 2010 33 were reviewed as part of the cumulative impacts assessment. In Section 4.9.2 of this SEIS, the 34 NRC staff concluded that impacts of radiation exposure to the public and workers (occupational) 35 from operation of LGS during the renewal term are SMALL. The NRC and the State of 36 Pennsylvania would regulate any future actions in the vicinity of the LGS site that could 37 contribute to cumulative radiological impacts. 38 Exelon constructed an Independent Spent Fuel Storage Installation (ISFSI) on the LGS site 39 in 2008 for the storage of its spent fuel. The installation and monitoring of this facility is 40 governed by NRC requirements in 10 CFR Part 72, "Licensing Requirements for the 41 Independent Storage of Spent Nuclear Fuel, High -Level Radioactive Waste, and 42 Reactor-Related Greater Than Class C Waste." Radiation from this facility, as well as from the 43 operation of LGS, is required to be within the radiation dose limits in 10 CFR Part 20, 44 40 CFR Part 190, and 10 CFR Part 72. The NRC carries out periodic inspections of the ISFSI 45 to verify its compliance with its licensing and regulatory requirement
- s. 46 Environmental Impacts of Operation 4-51 The cumulative radiological impacts from LGS, Units 1 and 2 and the ISFSI are required to meet 1 the radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. Therefore, the NRC staff 2 concludes that cumulative radiological impacts would be SMALL.
3 4.12.6. Socioeconomics 4 Socioeconomics 5 This section addresses socioeconomic factors that have the potential to be directly or indirectly 6 affected by changes in operations at LGS, Units 1 and 2 in addition to the aggregate effects of 7 other past, present, and reasonably foreseeable future actions. The primary geographic area s 8 of interest considered in this cumulative analysis include Montgomery, Berks, and Chester 9 Counties where approximately 84 percent of LGS, Units 1 and 2 employees reside (see 10 Section 2.2.9). This is where the economy, tax base, and infrastructure would most likely be 11 affected since LGS workers and their families reside, spend their income, and use their benefits 12 within these counties. As previously discussed in Section 4.1, onsite land use conditions at 13 LGS are expected to remain unchanged during the license renewal term. Therefore, activities 14 associated with continued reactor operations during the license renewal term are not expected 15 to affect the use and management of LGS lands identified as part of the Schuylkill River 16 Greenway. 17 As discussed in Section 4.10 of this SEIS, continued operation of LGS would have no impact on 18 socioeconomic conditions in the region during the license renewal term beyond what is already 19 being experienced. Since Exelon has no plans to hire additional workers during the license 20 renewal term, overall expenditures and employment levels at LGS, Units 1 and 2 would remain 21 relatively unchanged with no new, additional, or increased demand for permanent housing and 22 public services. In addition, since employment levels and tax payments would not change, 23 there would be no population or tax revenue -related land use impacts. Based on this and other 24 information presented in Chapter 4 of this SEIS, there would be no contributory effect from 25 continued operations of LGS, Units 1 and 2 on socioeconomic conditions in the region beyond 26 what is currently being experienced. Therefore, the only cumulative contributory effects would 27 come from the other planned activities in the region independent of LGS, Units 1 and 2 28 operations. 29 Environmental Justice 30 The environmental justice cumulative impact analysis assesses the potential for 31 disproportionately high and adverse human health and environmental effects on minority and 32 low-income populations that could result from past, present, and reasonably foreseeable future 33 actions including LGS, Units 1 and 2 operations during the renewal term. Adverse health 34 effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human 35 health. Disproportionately high and adverse human health effects occur when the risk or rate of 36 exposure to an environmental hazard for a minority or low -income population is significant and 37 exceeds the risk or exposure rate for the general population or for another appropriate 38 comparison group. Disproportionately high environmental effects refer to impacts or risk of 39 impact on the natural or physical environment in a minority or low -income community that are 40 significant and appreciably exceeds the environmental impact on the larger community. Such 41 effects may include biological, cultural, economic, or social impacts. Some of these potential 42 effects have been identified in resource areas presented in Chapter 4 of this SEIS. Minority and 43 low-income populations are subsets of the general public residing in the area and all would be 44 exposed to the same hazards generated from LGS operations. As previously discussed in this 45 chapter, the impact from license renewal for all resource areas (e.g., land, air, water, ecology, 46 and human health) would be SMALL. 47 Environmental Impacts of Operation 4-52 As discussed in Section 4. 10.7 of this SEIS, there would be no disproportionately high and 1 adverse impacts to minority and low -income populations from the continued operation of LGS, 2 Units 1 and 2 during the license renewal term. Since Exelon has no plans to hire additional 3 workers during the license renewal term, employment levels at LGS, Units 1 and 2 would 4 remain relatively constant with no new, additional, or increased demand for housing or 5 increased traffic. Based on this information and the analysis of human health and 6 environmental impacts presented in Chapters 4 and 5, it is not likely there would be any 7 disproportionately high and adverse contributory effect on minority and low -income populations 8 from the continued operation of LGS during the license renewal term. 9 4.12.7. Cultural Resources 10 This section addresses the direct and indirect effects of license renewal on historic and cultural 11 resources when added to the aggregate effects of other past, prese nt, and reasonably 12 foreseeable future actions. The geographic area considered in this analysis is the Area of 13 Potential Effect (APE) associated with the proposed undertaking, as described in 14 Section 2.2.10. 15 Substantial archeological records indicate that there was historic occupation of the LGS area. 16 Surveys were performed in the 1970s and 1980s. Section 2.2.10 presents an overview of the 17 existing historic and archaeological resources located on the LGS site. Past land development 18 has resulted in impacts on and the loss of cultural resources near and at the LGS site. As 19 described in Section 4. 10.6, no cultural resources would be affected by relicensing activities 20 associated with the LGS site because there will be no changes or ground -disturbing activities 21 that will occur as part of the relicensing of LGS, Units 1 and 2 (Exelon 2011a). Cultural 22 resources are being managed through Exelon's Cultural Resources Management Plan and the 23 Fricks Lock rehabilitation and mothball project (Exelon 2012 a). 24 The present and reasonably foreseeable projects reviewed in conjunction with license renewal 25 are noted in Appendix F of this document. Direct impacts would occur if archaeological sites in 26 the APE are physically removed or disturbed. The following projects are located within the 27 geographic area considered for cumulative impacts: 28 decommissioning of LGS Units 1 and 2, 29 transmission lines, and 30 future urbanization. 31 Decommissioning of LGS Units 1 and 2, transmission lines, and future urbanization have the 32 potential to result in impacts on cultural resources through inadvertent discovery during 33 ground-disturbing activities. However, as discussed above in Section 4.10.6, the contribution 34 from the proposed license renewal action would not incrementally affect historic or cultural 35 resources. Therefore, the NRC staff concludes that the cumulative impacts of the proposed 36 license renewal plus other past, present, and reasonable foreseeable future activities on historic 37 and cultural resources would be SMALL. 38 4.12.8. Summary of Cumulative Impacts 39 The NRC staff considered the potential impacts resulting from the operation of LGS during the 40 period of extended operation and other past, present, and reasonably foreseeable future actions 41 near LGS. The preliminary determination is that the potential cumulative impacts would range 42 from SMALL to MODERATE, depending on the resource. Table 4-10 summarizes the 43 cumulative impacts on resources areas. 44 Environmental Impacts of Operation 4-53 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 prese nt-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. Water Resources 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 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. Aquatic Ecology 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 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. Socioeconomics 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 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. Environmental Impacts of Operation 4-54 4.13. References 1 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 2 protection against radiation." 3 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 4 production and utilization facilities." 5 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 6 protection regulations for domestic licensing and related regulatory functions." 7 10 CFR Part 72. Code of Federal Regulations. Title 10, Energy, Part 72, "Licensing 8 requirements for the independent storage of spent nuclear fuel, high -level radioactive waste, 9 and reactor -related greater than Class C waste." 10 18 CFR Part 430, Code of Federal Regulations, Title 18, Conservation of Power and Water 11 Sources, Part 430, "Ground water protected area: Pennsylvania." 12 36 CFR Part 60. Code of Federal Regulations, Title 36, "Parks, Forests, and Public Property," 13 Part 60, "National Register of Historic Places." 14 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property , 15 Part 800, "Protection of historic properties." 16 40 CFR Part 81. Code of Federal Regulations. Title 40, Protection of Environment, Part 81, 17 "Designation of areas for air quality planning purposes." 18 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 19 "Environmental radiation protection standards for nuclear power operations." 20 50 CFR Part 402. Code of Federal Regulations. Title 50, Wildlife and Fisheries, Part 402, 21 "Interagency cooperation-Endangered Species Act of 1973, as amended. 22 59 FR 7629. Executive Order 12898. Federal actions to address environmental justice in 23 minority populations and low -income populations. Federal Register 59(32):7629 -7634, 24 February 16, 1994. 25 69 FR 41576. Environmental Protection Agency. "National Pollutant Discharge Elimination 26 System-Final Regulations to Establish Requirements for Cooling Water Intake Structures at 27 Phase II Existing Facilities." Federal Register 69(131):41576 -41593. July 9, 2004. 28 69 FR 52040. U.S. Nuclear Regulatory Commission. Policy statement on the treatment of 29 environmental justice matters in NRC regulatory and licensing actions. Federal 30 Register 69(163):52040 -52048. August 24, 2004. 31 [AEC] U.S. Atomic Energy Commission. 1973. Final Environmental Statement Related to the 32 Proposed Limerick Generating Station Units 1 and 2. Washington, DC: AEC. June 1973. 700
- p. 33 Agencywide Documents Access and Management System (ADAMS) Accession 34 No. ML11313A215.
35 Auch RF. 2003. "Northern Piedmont." Available at 36 <http://landcovertrends.usgs.gov/east/eco64Report.html> (accessed 12 May 2012). 37 [BHP] Bureau of Historic Preservation. 2011. Letter from D.C. McLearen, Pennsylvania 38 Historical and Museum Commission Bureau for Historic Preservation, to D.H. Frens, Frens and 39 Frens.
Subject:
NRC: Limerick Generating Station Relicensing Project, Fricks Lock Village 40 Rehabilitation and Mothballing, E. Coventry Twp., Chester Co. October 19, 2011. ADAMS 41 Accession No. ML11318A295. 42 Environmental Impacts of Operation 4-55 [CAPS] Missouri Census Data Center Circular Area Profiling System. Version 10C. Using Data 1 from Summary File 1, 2010 Census Summary of Census Tracts in a 50 -mile radius around the 2 South Texas Project (40.22 Lat., -75.58 Long.). March 201
- 2. 3 [CEQ] Council on Environmental Quality. 1997. Environmental Justice: Guidance Under the 4 National Environmental Policy Act. Available at
<http://www.epa.gov/compliance/ej/ 5 resources/policy/ej_guidance_nepa_ceq1297.pdf > (accessed 22 May 2012). ADAMS Accession 6 No. ML082520150. 7 [CRA] Conestoga -Rovers & Associates. 2006. Hydrogeologic Investigation Report, Fleetwide 8 Assessment Limerick Generating Stations, Pottstown, Pennsylvania. September 2006. ADAMS 9 No. ML12110A228. 10 [DRBC] Delaware River Basin Commission. 1961. Delaware River Basin Compact. Available at 11 <http://www.state.nj.us/drbc/about/regulations/> (accessed 11 May 2012). 12 [DRBC] Delaware River Basin Commission. 1999. Ground Water Protected Area Regulations, 13 Southeastern Pennsylvania. June 23, 1999. Available at 14 <http://www.state.nj.us/drbc/about/regulations/> (accessed 11 May 2012). 15 [DRBC] Delaware River Basin Commission. 2001. Comprehensive Plan. West Trenton, NJ: 16 DRBC. July 2001. Available at 17 <http://www.nj.gov/drbc/library/documents/comprehensive_plan.pdf> (accessed 22 May 2012). 18 [DRBC] Delaware River Basin Commission. 2008. Delaware River State of the Basin Report 19 2008. West Trenton, NJ: DRBC. Available at 20 <http://www.state.nj.us/drbc/programs/basinwide/report/ > (accessed 30 April 2012). 21 [DRBC] Delaware River Basin Commission. 2010a. 2010 Delaware River and Bay Integrated 22 List Water Quality Assessment. West Trenton, NJ: DRBC. June 2010. Available at 23 <http://www.nj.gov/drbc/library/documents/10IntegratedList/FinalReport.pdf > (accessed 24 12 April 2012). 25 [DRBC] Delaware River Basin Commission. 2010b. "Water Resources Program FY 2010 -2015" 26 (accessed 12 April 2012). 27 [DRBC] Delaware River Basin Commission. 2011. DOCKET NO. D -1999-041-2, Southeastern 28 Pennsylvania Ground Water Protected Area, TPT Partners, L.P., Bellewood Golf Club 29 Groundwater Withdrawal, North Coventry Township, Chester County, Pennsylvania. 30 8 December 2011. Available at <http://www.nj.gov/drbc/library/documents/dockets/ 31 1999-041-2.pdf> (accessed 30 May 2012). 32 [DRBC] Delaware River Basin Commission. 2012a. "Year 2005 Water Withdrawal and 33 Consumptive Use by Large Users on the Tidal Delaware River." December 7, 2011. Available at 34 <http://www.nj.gov/drbc/programs/supply/policies/largeusers_05.htm l> (accessed 35 12 April 2012). 36 [DRBC] Delaware River Basin Commission. 2012b. "Natural Gas Drilling Index Page." Available 37 at <http://www.state.nj.us/drbc/programs/natural/> (accessed 17 May 2012). 38 [EPA] U.S. Environmental Protection Agency. 1999. Consideration of Cumulative Impacts in 39 EPA Review of NEPA Documents. May 1999. Washington, DC: Office of Federal Activities. 40 EPA-315-R-99-002. ADAMS Accession No. ML040081036. 41 [EPA] U.S. Environmental Protection Agency. 2007. "PCB Total Maximum Daily Load for the 42 Schuylkill River." April 7, 2007. Available at 43 <http://www.epa.gov/reg3wapd/tmdl/pa_tmdl/SchuylkillRiverPCB/SchuylkillPCBReport.pdf >. 44 Environmental Impacts of Operation 4-56 [EPA] Environmental Protection Agency. 2012a. Envirofacts Multisystem Search. Available at 1 <http://www.epa.gov/enviro/facts/multisystem.html > (accessed 12 April 2012). 2 [EPA] U.S. Environmental Protection Agency. 2012b. "Agriculture." Available at 3 <http://water.epa.gov/polwaste/nps/agriculture.cfm> (accessed 11 May 2012). 4 [EPA] U.S. Environmental Protection Agency. 2012c. Multisystem Search. February 24, 2012. 5 Available at <http://www.epa.gov/enviro/facts/multisystem.html> (accessed 12 April 2012). 6 [Exelon] Exelon Generation Company, LLC. 2008a. Limerick Generating Station, Units 1 and 2. 7 2007 Annual Radiological Environmental Operating Report. Sanatoga, PA. ADAMS No. 8 ML0812606810. 9 [Exelon] Exelon Generation Company, LLC. 2008b. Limerick Generating Station, Units 1 and 2. 10 Annual Radioactive Effluent Release Report No 33. Sanatoga, PA. ADAMS No. 11 ML0812606830. 12 [Exelon] Exelon Generation Company, LLC. 2009a. Limerick Generating Station, Units 1 and 2. 13 2008 Annual Radiological Environmental Operating Report. Sanatoga, PA. ADAMS No. 14 ML0912800600. 15 [Exelon] Exelon Generation Company, LLC. 2009b. Limerick Generating Station, Units 1 and 2. 16 Annual Radioactive Effluent Release Report No 34. Sanatoga, PA. ADAMS No. 17 ML0912804310. 18 [Exelon] Exelon Generation Company, LLC. 2010a. Limerick Generating Station, Units 1 and 2, 19 Annual Radiological Environmental Operating Report, Report No. 25, 1 January through 31 20 December 2009. Sanatoga, PA: Exelon Nuclear. April 2010. ADAMS Accession 21 No. ML101250333. 22 [Exelon] Exelon Generation Company, LLC. 2010b. Limerick Generating Station, Units 1 and 2. 23 Annual Radioactive Effluent Release Report No 35. Sanatoga, PA. ADAMS No. 24 ML1012503240. 25 [Exelon] Exelon Generation Company, LLC. 2011a. License Renewal Application, Limerick 26 Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating 27 License Renewal Stage. ADAMS Accession No. ML11179A104. 28 [Exelon] Exelon Generation Company, LLC. 2011b. Limerick Generating Station, Units 1 and 2. 29 2010 Annual Radiological Environmental Operating Report. Sanatoga, PA. ADAMS 30 No. ML11157A0350. 31 [Exelon] Exelon Generation Company, LLC. 2011c. Limerick Generating Station, Units 1 and 2. 32 Annual Radioactive Effluent Release Report No 36. Sanatoga, PA. ADAMS No. 33 ML11126A1680. 34 [Exelon] Exelon Generation Company, LLC. 2012a. Letter from M.P. Gallagher, Exelon 35 Generation, to NRC, dated March 27, 2012, "Responses to NRC request for additional 36 information, dated February 28, 2012, related to the Limerick Generating Station license 37 renewal application." ADAMS Accession No. ML12088A366. 38 [Exelon] Exelon Generation Company, LLC. 2012b. Limerick Generating Station, Units 1 and 2, 39 Annual Radiological Environmental Operating Report, 1 January Through 31 December 2011. 40 Sanatoga, PA: Exelon Nuclear. April 2012. ADAMS No. ML12121A620. 41 [Exelon] Exelon Generation Company, LLC. 2012c. Limerick Generating Station, Units 1 and 2. 42 Annual Radioactive Effluent Release Report No 37. Sanatoga, PA. ADAMS No. ML12129A391 43 Environmental Impacts of Operation 4-57 [Exelon Nuclear]. Exelon Nuclear. 2001. Letter from J. Doering, Vice President, to NRC. 1
Subject:
Annual Environmental Operating Report (Non -Radiological) January 1, 2000 through 2 December 31, 2000. April 16, 2001. 3 [Exelon Nuclear]. Exelon Nuclear. 2002. Letter from R. Braun, Plant Manager, to NRC.
Subject:
4 2001 Annual Environmental Operating Report (Non -Radiological). April 9, 2002. 5 [Exelon Nuclear]. Exelon Nuclear. 2003. Letter from R. Braun, Vice President -LGS (acting), to 6 NRC: 2002 Annual Environmental Operating Report (Non -Radiological). April 30, 2003. 7 [Exelon Nuclear]. Exelon Nuclear. 2004. Letter from R. DeGregorio, Vice President -LGS, to 8 NRC.
Subject:
2003 Annual Environmental Operating Report (Non -Radiological). April 26, 2004. 9 [Exelon Nuclear]. Exelon Nuclear. 2005. Letter from R. DeGregorio, Vice President -LGS, to 10 NRC.
Subject:
2004 Annual Environmental Operating Report (Non -Radiological). April 29, 2005. 11 [Exelon Nuclear]. Exelon Nuclear. 2010a. Exelon Corporation Limerick Generating Station 12 Wildlife Management Plan. 66 p. ADAMS No. ML12110A289 (p. 85 -150). 13 [FWS] U.S. Fish and Wildlife Service. 2011a. Letter from C. Riley, Pennsylvania Field Office 14 Supervisor, FWS, to M. Gallagher, Exelon Nuclear.
Subject:
PNDI Internet Database query for 15 potential conflict with a Federally listed, proposed, or candidate species. USFWS Project 16 #2011-0365. March 22, 2011. ADAMS Accession No. ML11179A104. 17 [FWS] U.S. Fish and Wildlife Service. 2011b. Letter from C. Riley, Pennsylvania Field Office 18 Supervisor, FWS, to D. Wrona, RPB2 Branch Chief, NRC.
Subject:
Reply to request for 19 protected species information. USFWS Project #2011 -0365. November 22, 2011. ADAMS 20 Accession No. ML11339A043. 21 [FWS] U.S. Fish and Wildlife Service. 2012a. Draft Rangewide Indiana Bat Summery Survey 22 Guidance. February 3, 2012. 42 p. Available at 23 <http://www.fws.gov/midwest/Endangered/mammals/inba/pdf/DraftINBASurveyGuidance.pdf > 24 (accessed 14 May 2012). 25 [FWS] U.S. Fish and Wildlife Service. 2012b. "Species profile Dwarf wedgemussel (Alamidonta 26 heterodon)." April 26, 2012. Available at 27 <http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=F029> (accessed 28 10 April 2012) 29 Hastings RW, O'Herron JC, Schick K, Lazzari MA. 1987. Occurrence and Distribution of 30 Shortnose Sturgeon, Acipenser brevirostrum, in the Upper Tidal Delaware River. Estuaries 31 10(4):337-341. 32 [IEEE] Institute of Electrical and Electronics Engineers, Inc. 2002. National Electrical Safety 33 Code. 34 Interlandi S, Crockett CS. 2003. Recent water quality trends in the Schuylkill River, 35 Pennsylvania, USA: A preliminary assessment of the relative influences of climate, river 36 discharge, and suburban development. Water Research 37:1737-1748. 37 Joklik WK, Smith, DT. 1972. Zinsser Microbiology. Addleton -Century-Croft, NY. 38 Karl TR, Melillo JM, Peterson TC, editors. 2009. Global Climate Change Impacts in the United 39 States. U.S. Global Change Research Program. Cambridge University Press, New York. 40 Available at <http://downloads.globalchange.gov/usimpacts/pdfs/climate -impacts-report.pdf>. 41 ADAMS Accession No. ML100 580077. 42 Environmental Impacts of Operation 4-58 [MCPCB] Montgomery County Planning Commission Board. 2005. Land Use Plan: Shaping Our 1 Future-A Comprehensive Plan for Montgomery County. 20 p. Available at 2 <http://planning.montcopa.org/planning/cwp/fileserver,Path,PLANNING/pdf_files/montcolanduse3 plan2005intro -ch1.pdf,assetguid,b62e6e8a -705b-44b2-966e066f9537e26b.pdf> (accessed 4 11 May 2012). 5 [MCPCB] Montgomery County Planning Commission. 2005. Land Use Plan Summary, Shaping 6 our Future: a Comprehensive Plan for Montgomery County. Norristown, PA: MCPL. Available at 7 <http://planning.montcopa.org/planning/cwp/fileserver,Path,PLANNING/pdf_files/landuseplansu8 mmaryweb.pdf,assetguid,a98189c3 -5c3a-4e19-b218ec91ad3f6f50.pdf> (accessed 9 16 April 2012). 10 Morrow, JL, Howard, JH, Smith, SA, Poppel, DK. 2001. Home range and movements of the bog 11 turtle (Clemmys mahlenbergii) in Maryland. Journal of Herpetology 35(1):68-73. 12 [NAI] Normandeau Associates, Inc. 2010a. East Branch Perkiomen Creek aquatic biology 13 assessment XIII, 2008 monitoring period. May 2010. 14 [NAI] Normandeau Associates, Inc. 2010b. Fish and benthic macroinvertebrate community 15 composition in the Schuylkill River in the vicinity of Limerick Generating Station during 2009. 16 February 2010. 17 [NAI] Normandeau Associates, Inc. 2010c. East Branch Perkiomen Creek aquatic biology 18 assessment XIV, 2009 monitoring period. July 2010. 19 [NAI and URS] Normandeau Associates, Inc. and URS Corporation. 2004. Year one (2003) 20 interim report for the Wadesville mine water demonstration project. Available at 21 <http://www.nj.gov/drbc/library/documents/wadesville/2003_interim -report.pdf > (accessed 22 9 April 2012). 23 [NAI and URS] Normandeau Associates, Inc. and URS Corporation. 2011. 2011 Interim report 24 for the Limerick Generating Station water supply modification demonstration project and 25 Wadesville Mine Pool withdrawal and streamflow augmentation demonstration project. Kennett 26 Square, PA: Exelon Generation Company, LLC. December 2011. Available at 27 <http://www.nj.gov/drbc/library/documents/wadesville/2011_interim -report.pdf> (accessed 28 9 April 2012). 29 National Environmental Policy Act of 1969, as amended. 42 USC 4321, et seq. 30 National Historic Preservation Act of 1966, as amended. 16 USC 470, et seq. 31 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative -Final 32 Guidance Document. NEI 07-07. Washington DC. August, 2007. ADAMS Accession 33 No. ML072610036. 34 [NHDES] New Hampshire Department of Environmental Services. 2010. Environmental Fact 35 Sheet, Variable milfoil (Myriophyllum heterophyllum). Available at 36 <http://www.tuftonboro.org/Pages/TuftonboroNH_boards/facts > (accessed 10 April 2012). 37 [NIEHS] National Institute of Environmental Health Sciences. 1999. NIEHS Report on Health 38 Effects from Exposure to Power -Line Frequency Electric and Magnetic Fields. Publication 39 No. 99-4493. Triangle Park, NC: NIEHS. 80 p. Available at <http://www.niehs.nih.gov/about/ 40 materials/niehsreport.pdf> (accessed 22 May 2012). 41 [NMFS] National Marine Fisheries Service. 2012a. "Marine/Anadromous Fish Species under the 42 Endangered Species Act (ESA)." March 9, 2012 . Available at 43 <http://www.nmfs.noaa.gov/pr/species/esa/fish.htm> (accessed 9 April 2012). 44 Environmental Impacts of Operation 4-59 [NMFS] National Marine Fisheries Service. 2012b. "Shortnose Sturgeon (Acipenser 1 brevirostrum )." March 14, 2012. Available at 2 <http://www.nmfs.noaa.gov/pr/species/fish/shortnosesturgeon.htm> (accessed 9 April 2012). 3 [NMFS] National Marine Fisheries Service. 2012c. Letter from Mary A. Colligan, Assistant 4 Regional Administrator for Protected Resources, NMFS, to J. Susco, Acting Branch Chief, NRC. 5 June 2, 2012. ADAMS Accession No. ML12226A163 6 [NRC] U.S. Nuclear Regulatory Commission. 1984. Final Environmental Statement Related to 7 the Operation of Limerick Generating Station, Units 1 and 2. Washington, DC: NRC. 8 NUREG-0974. April 30, 1984. ADAMS Accession No. ML11221A206. 9 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 10 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 11 ADAMS Accession Nos. ML040690705 and ML040690738. 12 [NRC] U.S. Nuclear Regulatory Commission. 1999a. Section 6.3 -Transportation, Table 9.1, 13 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 14 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 15 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 16 No. ML04069720. 17 [NRC] U.S. Nuclear Regulatory Commission. 1999b. Standard Review Plans for Environmental 18 Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. Washington, 19 DC: NRC. NUREG -1555, Supplement 1. October 1999. ADAMS Accession No. ML003702019. 20 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Letter from D.J. Wrona, NRC, to J. Cutler, 21 Bureau of Historic Preservation, dated September 15, 2011, "Limerick Generating Station 22 License Renewal Environmental Review (SHPO File No. ER 2004-2024-091-B)." ADAMS 23 Accession No. ML1121A265. 24 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from D.J. Wrona, NRC, to T. 25 McCulloch, Advisory Council on Historic Preservation, dated September 16, 2011, "Limerick 26 Generating Station License Renewal Environmental Review (SHPO File 27 No. ER 2004-2024-091-B)." ADAMS Accession No. ML11245A083. 28 [NRC] U.S. Nuclear Regulatory Commission. 2011c. E -mail from Ann, BHP, to T.K. O'Neil, 29 PNNL, dated November 1, 2012. "LGS License Renewal -SHPO Meeting." ADAMS Accession 30 No. ML12255A291. 31 [NRC] U.S. Nuclear Regulatory Commission. 2011d. Letter from D. Wrona, RPB2 Branch Chief, 32 NRC, to M. Roberts, Pennsylvania Field Office, U.S. Fish and Wildlife Service.
Subject:
Reques t 33 for list of protected species within the area under evaluation for the Limerick Generating Station, 34 Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession No. 35 ML11258A248. 36 [NRC] U.S. Nuclear Regulatory Commission. 2011e. Letter from D. Wrona, RPB2 Branch Chief, 37 NRC, to C. Urban, Division of Environmental Services, Pennsylvania Fish and Boat 38 Commission.
Subject:
Request for list of protected species within the area under evaluation for 39 the Limerick Generating Station, Units 1 and 2, license renewal application review. 40 September 8, 2011. ADAMS Accession No. ML11234A024. 41 [NRC] U.S. Nuclear Regulatory Commission. 2011f. Letter from D. Wrona, RPB2 Branch Chief, 42 NRC, to C. Firestone, Bureau of Forestry Plant Program, Pennsylvania Department of 43 Conservation and Natural Resources.
Subject:
Request for list of protected species within the 44 area under evaluation for the Limerick Generating Station, Units 1 and 2, license renewal 45 application review. September 16, 2011. ADAMS Accession No. ML11230B346. 46 Environmental Impacts of Operation 4-60 [NRC] U.S. Nuclear Regulatory Commission. 2011g. Letter from D. Wrona, RPB2 Branch Chief, 1 NRC, to O. Braun, Environmental Planner, Pennsylvania Game Commission.
Subject:
Request 2 for list of protected species within the area under evaluation for the Limerick Generating Station, 3 Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession 4 No. ML11234A065. 5 [NRC] U.S. Nuclear Regulatory Commission. 2012
- a. Letter from J. Susco, RERB Acting Branch 6 Chief, NRC, to D. Morris, Acting Regional Administrator, National Marine Fisheries Service. 7
Subject:
Request for list of Federal protected species within the area under evaluation for the 8 Limerick Generating Station, Units 1 and 2, license renewal application review. May 30, 2012. 9 ADAMS Accession No. ML12138A347. 10 [NRC] U.S. Nuclear Regulatory Commission. 2012
- b. Staff Requirements, SECY-12-0063 , "Final 11 Rule: Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating 12 Licenses (10 CFR Part 51; RIN 3150
-AI42)." Decemb er 6, 2012. ADAMS No. ML12341A134. 13 O'Herron, JC, Able, KW, Hastings, RW. 1993. Movements of shortnose sturgeon (Acipenser 14 brevirostrum) in the Delaware River. Estuaries 16(2):235-240. 15 [PADEP] Pennsylvania Department of Environmental Protection Bureau of Radiation Protection 16 (BRP). Environmental Radiation in Pennsylvania 2003 and 2004 Annual Reports. Available at 17 <http://www.elibrary.dep.state.pa.us/dsweb/Get/Document -66310/2900 -BK-DEP4006% 18 20%20%202003 -2004%20Annual%20Report.pdf> (accessed 18 April 2012). 19 [PADEP] Pennsylvania Department of Environmental Protection. 2006c. General Permit 20 BWM-GP-11, Maintenance, Testing, Repair, Rehabilitation, or Replacement of Water 21 Obstructions or Encroachments. Revision 12/2006. Harrisburg, PA: P ADEP. Available at 22 <http://www.elibrary.dep.state.pa.us/dsweb/Get/Document -85002/3930 -PM-WM0511-Entire% 23 20Package.pdf> (accessed 18 April 2012). 24 [PDCNR] Pennsylvania Department of Conservation and Natural Resources. 2011. Letter from 25 R. Bowen, Environmental Review Manager, for C. Firestone, Wild Plant Program Manager, 26 Bureau of Forestry, PDCNR, to M. Gallagher, Exelon Nuclear.
Subject:
Pennsylvania Natural 27 Diversity Inventory review for renewal of operating licenses for Limerick Generating Station, 28 Units 1 and 2, Chester, Montgomery & Bucks Counties. March 9, 2011. In Appendix C to 29 Applicant's Environmental Report -Operating License Renewal Stage, Limerick Generating 30 Station, Units 1 and 2. ADAMS Accession No. ML11179A104. 31 [PECO] Philadelphia Electric Company. 1984. Environmental Report Operating License Stage 32 Limerick Generating Station Units 1 & 2, Vol. 1. Philadelphia, PA: PECO. September 30, 1984. 33 ADAMS Accession No. ML11299A113. 34 Perillo J.A. and Butler L.H. 2009. "Evaluating the use of Fairmount Dam fish passage facility 35 with application to anadromous fish restoration in the Schuylkill River, Pennsylvania." Journal of 36 the Pennsylvania Academy of Science 83(1):24-33. 37 [PFBC] Pennsylvania Fish and Boat Commission. 2011a. Letter from C.A. Urban, Natural 38 Diversity Section Chief, PFBC, to N. Ranek, Exelon Nuclear.
Subject:
Species impact review for 39 renewal of operating licenses for Limerick Generating Station, Units 1 and 2, Montgomery and 40 Chester County, Pennsylvania. February 11, 2011. In Appendix C of "Exelon 2011a." ADAMS 41 Accession No. ML11179A104. 42 Environmental Impacts of Operation 4-61 [PFBC] Pennsylvania Fish and Boat Commission. 2011b. Letter from C.A. Urban, Natural 1 Diversity Section Chief, PFBC, to D. Wrona, RPB2 Branch Chief, NRC.
Subject:
Species impact 2 review for renewal of operating licenses for Limerick Generating Station, Units 1 and 2, 3 Montgomery and Chester County, Pennsylvania. October 5, 2011. ADAMS Accession 4 No. ML11291A077. 5 [PGC] Pennsylvania Game Commission. 2011. Letter from O.A. Mowery, Environmental 6 Planner, Division of Environmental Planning and Habitat Protection, PGC, to D. Wrona, RPB2 7 Chief, NRC.
Subject:
Re: Limerick Generating Station and transmission lines -license renewal, 8 Montgomery and Chester Counties, Pennsylvania. November 17, 2011. ADAMS Accession No. 9 ML11329A060. 10 [PNHP] Pennsylvania Natural Heritage Program. 2012a. "State Species List Database -Bucks, 11 Chester, and Montgomery Counties." Available at <http://www.naturalheritage.state.pa.us/ > 12 (accessed 10 April 2012). 13 [PNHP] Pennsylvania Natural Heritage Program. 2012b. "Species Fact Sheet, Farwell's 14 Water-milfoil (Myriophyllum farwellii)." Available at 15 <http://www.naturalheritage.state.pa.us/factsheets/13979.pdf> (accessed 10 April 2012). 16 [PNHP] Pennsylvania Natural Heritage Program. 2012c. "Species Fact Sheet, Floating -heart 17 (Nymphoides cordata)." Available at 18 <http://www.naturalheritage.state.pa.us/factsheets/14174.pdf > (accessed 10 April 2012). 19 [PNHP] Pennsylvania Natural Heritage Program. 2012d. "Species Fact Sheet, Spotted 20 Pondweed (Potamogeton pulcher)." Available at 21 <http://www.naturalheritage.state.pa.us/factsheets/15786.pdf > (accessed 10 April 2012). 22 Rhoads AF, Block TA. 2008. Montgomery County, Pennsylvania: Natural Areas Inventory 23 Update. Philadelphia, PA: Morris Arboretum of the University of Pennsylvania. Submitted to the 24 Montgomery County Planning Commission. June 30, 2007. 401 p. Available at 25 <http://planning.montcopa.org/planning/cwp/view,a,3,q,66753.asp> (accessed 8 May 2012). 26 [RMC] RMC-Environmental Services. 1984. Progress Report, Non -radiological Environmental 27 Monitoring for Limerick Generating Station 1979 -1983. Pottstown, PA: RMC. October 1984. 28 [RMC] RMC-Environmental Services. 1985. Progress Report, Non -radiological Environmental 29 Monitoring for Limerick Generating Station 1984. Pottstown, PA: RMC. December 1985. 30 [RMC] RMC-Environmental Services. 1986. Progress Report, Non -radiological Environmental 31 Monitoring for Limerick Generating Station 1985. Pottstown, PA: RMC. September 1986. 32 [RMC] RMC-Environmental Services. 1987. Progress Report, Non-radiological Environmental 33 Monitoring for Limerick Generating Station 1986. Pottstown, PA: RMC. November 1987. 34 [RMC] RMC-Environmental Services. 1988. Progress Report, Non -radiological Environmental 35 Monitoring for Limerick Generating Station 1987. Pottstown, PA: RMC. September 1988. 36 [RMC] RMC-Environmental Services. 1989. Progress Report, Non -radiological Environmental 37 Monitoring for Limerick Generating Station 1988. Pottstown, PA: RMC. December 1989. 38 Simpson, PC, Fox, DA. undated. Atlantic sturgeon in the Delaware River: contemporary 39 population status and identification of spawning areas. Dover, DE: Delaware State University. 40 Available at 41 <http://www.nero.noaa.gov/StateFedOff/grantfactsheets/DE/FINAL%20REPORTS/FINAL%20N 42 A05NMF4051093.pdf > (accessed 6 August 2012). 43 Environmental Impacts of Operation 4-62 Todar, K. 2012. "Todar's Online Textbook of Bacteriology." Available at 1 <http://www.textbookofbacteriology.net > (accessed August 2012). 2 [USCB] U.S. Census Bureau. 2011. American FactFinder, 2010 American Community Survey 3 and Data Profile Highlights Information on New Castle, Cecil, Burlington, Camden, Gloucester, 4 Hunterdon, Mercer, Salem, Somerset, Warren, Berks, Bucks, Carbon, Chester, Delaware, 5 Lancaster, Lebanon, Lehigh, Monroe, Montgomery, Northhampton, Philadelphia, and Schuylkill 6 Counties and State of Pennsylvania. Available at <http://factfinder.census.gov > and 7 <http://quickfacts.census.gov> (accessed March 2012). 8 [USGS] U.S. Geological Survey. 2010. Water-Data Report 2010, 01472000 SCHUYLKILL 9 RIVER AT POTTSTOWN, PA, Lower Delaware Basin Schuylkill Subbasin. Available at 10 <http://wdr.water.usgs.gov/wy2010/pdfs/01472000.2010.pdf> (accessed 16 May 2011). 11 Wallace Roberts & Todd, LLC. 2003. Living with the River, Schuylkill River National and State 12 Heritage Area, Final Management Plan and Environmental Impact Statement. Pottstown, PA: 13 Schuylkill River Greenway Association. Available at 14 <http://www.schuylkillriver.org/pdf/0.0__table_of_contents.pdf> (accessed 19 April 2012). 15 5-1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 1 This chapter describes the environmental impacts from postulated accidents that Limerick 2 Generating Station, Units 1 and 2 (LGS) might experience during the period of extended 3 operation. The term "accident" refers to any unintentional event outside the normal plant 4 operational envelope that results in a release or the potential for release of radioactive materials 5 into the environment. The two classes of postulated accidents listed in Table 5-1 are evaluated 6 in detail in the generic environmental impact statement (GEIS). These two classes of accidents 7 are: 8 design-basis accidents (DBAs), and 9 severe accidents. 10 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 5.1. Design-Basis Accidents 12 In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 13 power plant, an applicant for an initial operating license must submit a safety analysis report 14 (SAR) as part of its application. The SAR presents the design criteria and design information for 15 the proposed reactor and comprehensive data on the proposed site. The SAR also discusses 16 various hypothetical accident situations and the safety features that prevent and mitigate 17 accidents. The NRC staff (the staff) reviews the application to determine if the plant design 18 meets the NRC's regulations and requirements and includes, in part, the nuclear plant design 19 and its anticipated response to an accident. 20 DBAs are those accidents that both the licensee and the staff evaluate to ensure that the plant 21 can withstand normal and abnormal transients and a broad spectrum of postulated accidents, 22 without undue hazard to the health and safety of the public. Many of these postulated accidents 23 are not expected to occur during the life of the plant but are evaluated to establish the design 24 basis for the preventive and mitigative safety systems of the nuclear power plant. Title 10 of the 25 Code of Federal Regulations (10 CFR) Part 50 and 10 CFR Part 100 describe the acceptance 26 criteria for DBAs. 27 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 28 ability of the nuclear power plant to withstand these accidents is demonstrated to be acceptable 29 before issuance of the operating license. The results of these evaluations are found in license 30 documentation such as the applicant 's final safety analysis report (FSAR), the staff's safety 31 evaluation report (SER), the final environmental statement (FES), and Section 5.1 of this 32 supplemental environmental impact statement (SEIS). A licensee is required to maintain the 33 acceptable design and performance criteria throughout the life of the nuclear power plant, 34 including any period of extended operation. The consequences for these events are evaluated 35 for the hypothetical maximum exposed individual. Because of the requirements that continuou s 36 acceptability of the consequences and aging management programs be in effect for license 37 renewal, the environmental impacts, as calculated for DBAs, should not differ significantly from 38 initial licensing assessments over the life of the nuclear power plant, including the license 39 Environmental Impact s of Postulated Accidents 5-2 renewal period. Accordingly, the design of the nuclear power plant, relative to DBAs during the 1 extended period, is considered to remain acceptable; therefore, the environmental impacts of 2 those accidents were not examined further in the GEIS. 3 The NRC has determined in the GEIS that the environmental impacts of DBAs are of SMALL 4 significance for all nuclear power plants because the plants were designed to successfully 5 withstand these accidents. Therefore, for the purposes of license renewal, DBAs are 6 designated as a Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The 7 early resolution of the DBAs makes them a part of the current licensing basis (CLB) of the plant; 8 the CLB of the plant is to be maintained by the licensee under its current license and, therefore, 9 under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This 10 issue is applicable to LGS. 11 Exelon Generation Company, LLC (Exelon) stated in its environmental report (ER) 12 (Exelon 2011c) that it is not aware of any new and significant information related to DBAs 13 associated with the renewal of the LGS. The staff has not noted any new and significant 14 information during its independent review of Exelon's ER, the scoping process, or its evaluation 15 of other available information. Therefore, the staff concludes that there are no impacts related 16 to DBAs beyond those discussed in the GEIS (NRC 1996). 17 5.2. Severe Accidents 18 Severe nuclear accidents are those that are more severe than DBAs because they could result 19 in substantial damage to the reactor core, whether or not there are serious offsite 20 consequences. In the GEIS, the staff assessed the effects of severe accidents during the 21 period of extended operation, using the results of existing analyses and site -specific information 22 to conservatively predict the environmental impacts of severe accidents for each plant during 23 the period of extended operation. 24 The impacts from severe accidents initiated by external phenomena such as tornadoes, floods, 25 earthquakes, fires, and sabotage were specifically considered in the GEIS. The GEIS evaluated 26 existing impact assessments -performed by the staff and by the industry at 44 nuclear power 27 plants (including LGS) in the United States -and concluded that the risk from beyond 28 design-basis earthquakes at existing nuclear power plants is SMALL. The GEIS also performed 29 a discretionary analysis of sabotage, in connection with license renewal, and concluded that the 30 core damage and radiological release from such acts would be no worse than the damage and 31 release expected from internally initiated events. In the GEIS, the NRC concludes that the risk 32 from sabotage at existing nuclear power plants is SMALL and, additionally, that the risks from 33 other external events are adequately addressed by a generic consideration of internally initiated 34 severe accidents (NRC 1996). 35 Based on information in the GEIS, the NRC determined in its regulations that: 36 The probability weighted consequences of atmospheric releases, fallout onto open bodies of 37 water, releases to ground water, and societal and economic impacts from severe accidents are 38 small for all plants. However, alternatives to mitigate severe accidents must be considered for 39 all plants that have not considered such alternatives. 40 The staff found no new and significant information related to postulated accidents during the 41 review of Exelon's ER (Exelon 2011c), the scoping process, or evaluation of other available 42 information. Therefore, there are no impacts related to these issues, beyond those already 43 discussed in the GEIS. 44 Environmental Impacts of Postulated Accidents 5-3 5.3. Severe Accident Mitigation Alternatives 1 The purpose of the evaluation of severe accident mitigation alternatives (SAMAs) is to identify 2 design alternatives, procedural modifications, or training activities that are cost-beneficial and 3 further reduce the risks of severe accidents (NRC 1999a). The analysis of SAMAs includes the 4 identification and evaluation of alternatives that reduce the radiological risk from a severe 5 accident by preventing substantial core damage (i.e., preventing a severe accident) or by 6 limiting releases from containment in the event that substantial core damage occurs (i.e., 7 mitigating the impacts of a severe accident) (NRC 1999b). In accordance with 10 CFR 8 51.53(c)(3)(ii)(L) and Table B -1 of Part 51, license renewal ERs must provide a consideration of 9 alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the 10 applicant's plant in an environmental impact statement (EIS) or related supplement or in an 11 environmental assessment. 12 The staff has previously performed a site -specific analysis of severe accident mitigation in a 13 NEPA document for LGS in the Final Environmental Statement Related to Operation of LGS, 14 Units 1 and 2 in NUREG -0974, Supplement 1 (NRC 1989) ("1989 SAMDA Analysis"). 15 Therefore, no analysis of SAMAs for LGS is required in Exelon's ER or the staff's SEIS. The 16 NRC Staff uses the term SAMA to refer to severe accident mitigation alternatives at the license 17 renewal phase. In contrast, the term severe accident mitigation design alternatives (SAMDA) 18 refers to severe accident mitigation alternatives at the initial licensing phase. The site -specific 19 SAMDAs reviewed for applicability to LGS were evaluated in the 1989 SAMDA Analysis and 20 also documented in GEIS Table 5.35. The staff examined each SAMDA (individually and, in 21 some cases, in combination) to determine the potential SAMDA individual risk reduction 22 potential. This risk reduction was then compared with the cost of implementing the SAMDA to 23 provide cost -benefit evidence of its value. The staff concluded that: 24 The risks of early fatality from potential accidents at the site are small in 25 comparison with risks of early fatality from other human activities in a comparably 26 sized population, and the accident risk will not add significantly to population 27 exposure and cancer risks. Accident risks from Limerick are expected to be a 28 small fraction of the risks the general public incurs from other sources. Further, 29 the best estimates show that the risks of potential reactor accidents at Limerick 30 are within the range of such risks from other nuclear power plants. 31 However, in the LGS specific 1989 SAMDA Analysis, the staff acknowledged: 32 In the longer term, these same severe accident issues are currently being 33 pursued by the NRC in a systematic way for all utilities through the Severe 34 Accident Program described in SECY 147, "Integration Plan for Closure of 35 Severe Accident Issues" (NRC 1988c). The plan includes provisions for an 36 Individual Plant Examination (IPE) for each operating reactor, a Containment 37 Performance Improvement (CPI) program, and an Accident Management (AM) 38 program. These programs will produce a more complete picture of the risks of 39 operating plants and the benefits of potential design improvements, including 40 SAMDAs. The staff believes that the severe accident program is the proper 41 vehicle for further review of severe accidents at nuclear power plants, including 42 Limerick. 43 Therefore, the Commission considers ways to mitigate severe accidents at a given site more 44 than once. The Commission has considered alternatives for mitigating severe accidents at 45 many sites, including LGS, multiple times through a variety of NRC programs. When it 46 promulgated Table B-1 of 10 CFR Part 51, the Commission explained, 47 The Commission has considered containment improvements for all plants 48 pursuant to its Containment Performance Improvement (CPI) program -and the 49 Environmental Impact s of Postulated Accidents 5-4 Commission has additional ongoing regulatory programs whereby licensees 1 search for individual plant vulnerabilities to severe accidents and consider cost -2 beneficial improvements [(the individual plant examination "IPE" and individual 3 plant examination of external events "IPEEE" programs )] (61 Fed. Reg. 28,467 ). 4 In light of these studies, the Commission believed it was "unlikely that any site -specific 5 consideration of SAMAs for license renewal will identify major plant design changes or 6 modifications that will prove to be cost -beneficial for reducing severe accident frequency or 7 consequences" (61 FR 28467). Given the significant costs of a major plant design change, 8 such an improvement must result in a substantial reduction in risk to be cost -beneficial. As 9 discussed below, these studies already thoroughly considered severe accidents and ways to 10 mitigate their impacts and did not identify cost -beneficial major plant design changes or 11 modifications for mitigating the impacts of severe accidents. Regulations in 10 CFR 12 51.53(c)(3)(ii)(L) and Table B -1 reflect the Commission's judgment that in light of these ongoing 13 studies, reconsideration of SAMAs at license renewal would be unlikely to uncover major cost -14 beneficial plant modifications and is unnecessary. 15 Containment Performance Improvement Program 16 One of the programs the Commission relied on in determining that SAMAs need not be 17 performed at license renewal if the staff had already performed a SAMA review in an earlier 18 NEPA document is the CPI program. With this program, the NRC examined each of five U.S. 19 reactor containment types (BWR Mark I, II, and III; PWR Ice Condenser; and PWR Dry) with the 20 purpose of examining the potential failure modes, potential fixes, and the cost benefit of such 21 fixes. Tables 5.32 through 5.34 in the GEIS summarize the results of this program. As can be 22 seen from these tables, many potential changes were evaluated but only a few containment 23 improvements were identified for site -specific review. The items evaluated in the CPI program 24 were also included in the list of plant -specific SAMDAs examined in the LGS FES supplement 25 (NRC 1996). 26 Individual Plant Examination 27 Another program the Commission relied on in determining that SAMAs need not be performed 28 at license renewal if the staff had already performed a SAMA review in an earlier NEPA 29 document is the Individual Plant Examination (IPE). The IPE's specific objective was to develop 30 an appreciation of severe accident behavior, and to identify ways in which the overall 31 probabilities of core damage and fission product releases could be reduced if deemed 32 necessary. In general, the IPEs have resulted in plant procedural and programmatic 33 improvements (i.e., accident management) and, in only a few cases, minor plant modifications, 34 to further reduce the risk and consequences of severe accidents (NRC 1996). 35 In accordance with NRC's policy statement on severe accidents, the licensee performed an IPE 36 to look for vulnerabilities to both internal and external initiating events (NRC 1988a ). This 37 examination considered potential improvements on a plant -specific basis. The CDF was found 38 to be considerably less in the LGS IPE (4.3x10-6) than in the original CDF value provided in 39 NUREG-1068 (1.0x10-5) for LGS and the 1989 PRA Update (1.0x10-5) used in the 1989 SAMDA 40 Analysis review. The staff further notes that the 2009 PRA Update (3.2x10-6) is approximately 41 an order of magnitude less than the 1989 PRA Update (Exelon ER). Plant improvements 42 identified and implemented for LGS as a result of the IPE included: (1) relaxing restrictions on 43 the drywell spray initiation curve in the Emergency Operating Procedures; (2) creating a 44 procedure to cross -tie the 4 kV safeguards electrical buses; (3) creating a procedure to power 45 Unit 2 emergency service water pumps from Unit 1; and (4) creating a cross -connection 46 between the fire water and residual heat removal systems (PECO 1992). 47 Environmental Impacts of Postulated Accidents 5-5 Individual Plant Examination of External Events 1 Another program the Commission relied on in determining that SAMAs need not be performed 2 at license renewal if the staff had already performed a SAMA review in an earlier NEPA 3 document is the Individual Plant Examination of External Events (IPEEE) program. The IPEEE 4 program was initiated in the early 1990s. All operating plants in the United States (including 5 LGS) performed an assessment to identify vulnerabilities to severe accidents initiated by 6 external events and reported the results to the NRC, along with any identified improvements 7 and/or corrective actions. Perspectives Gained from the Individual Plant Examination of 8 External Events (IPEEE) Progra m, NUREG-1742 documents the perspectives derived from the 9 technical reviews of the IPEEE results (NRC 2002). As a result of conducting the LGS IPEEE, 10 PECO Energy identified seismic event and fire event findings. Actions were taken to address 11 minor housekeeping and maintenance issues related to the seismic analysis such as 12 unrestrained tools, lockers, hoist controllers and lifting devices for low voltage switchgear. In 13 addition, Fire brigade drill activities and fire brigade awareness were increased for 3 areas in the 14 common control structure. Furthermore, actions credited in the fire analysis such as improved 15 transient combustible controls, creation of transient combustible free zones and formal 16 designation of certain fire rated doors as "fire" doors were implemented at LGS (PECO 1995). 17 Accident Management Program 18 The staff specifically relied on the Accident Management Program as the proper avenue for 19 addressing the improvements considered in the 1989 SAMDA Analysis. Accident management 20 involves the development of procedures that promote the most effective use of available plant 21 equipment and staff in the event of an accident. The staff indicated its intent (NRC 1988a) that 22 licensees develop an accident management framework that will include implementation of 23 accident management procedures, training, and technical guidance. Insights gained as a result 24 of the IPE were factored into the accident management program at LGS. As discussed earlier, 25 the majority of improvements identified from the completed IPEs to date have been in the area 26 of accident management or other procedural and programmatic improvements (NRC 1996 and 27 NRC 1997). 28 NRC Efforts to Address Severe Accident-Related Issues since the Publication of the 1996 GEIS 29 The NRC has continued to address accident -related issues since the GEIS was published and 30 10 CFR Part 51 changes related to license renewal were promulgated. The NRC's efforts have 31 reduced risks from accidents beyond that considered in the 1996 GEIS. As discussed below, i n 32 some cases, such as the agency response to Fukushima, these activities are ongoing. Each of 33 the activities applied or continues to apply to all reactors, including LGS. The specific 34 requirement for any given reactor was based either on a site -specific evaluation or a 35 design-specific requirement. 36 10 CFR 50.54(hh) Conditions of License Regarding Loss of Large Areas of the Plant Due to Fire 37 or Explosions 38 Following September 11, 2001, the Commission issued Order EA-02-026 and ultimately a new 39 regulation (10 CFR 50.54(hh)), which required commercial power reactor licensees to, among 40 other things, adopt mitigation strategies using readily available resources to maintain or restore 41 core cooling, containment, and spent fuel pool cooling capabilities to cope with the loss of large 42 areas of the facility due to large fires and explosions from any cause, including 43 beyond-design-basis aircraft impacts (See 74 FR 13926). The final rule also added several new 44 requirements developed as a result of insights gained from implementation of the security 45 orders, reviews of site security plans, and implementation of the enhanced baseline inspection 46 program, and updated the NRC's security regulatory framework for the licensing of new nuclear 47 Environmental Impact s of Postulated Accidents 5-6 power plants. Compliance with the final rule was required by March 31, 2010, for licensees, 1 including Exelon, currently licensed to operate under 10 CFR Part 50. Exelon has updated its 2 plant and procedures accordingly, and the NRC has inspected the guidelines and strategies that 3 Exelon has implemented to meet the requirements of 10 CFR 50.54(hh)(2). The specifics of the 4 enhancements are security related and not publicly available but in general include: 5 (1) significant reinforcement of the defense capabilities for nuclear facilities, (2) better control of 6 sensitive information, (3) enhancements in emergency preparedness to further strengthen the 7 NRC's nuclear facility security program, and (4) implementation of mitigating strategies to deal 8 with postulated events potentially causing loss of large areas of the plant due to explosions or 9 fires, including those that an aircraft impact might create. These measures are outlined in 10 greater detail in NUREG/BR -0314 (NRC 2004), NUREG -1850 (NRC 2006a), and Sandia 11 National Laboratory's "Mitigation of Spent Fuel Loss-of-Coolant Inventory Accidents and 12 Extension of Reference Plant Analyses to Other Spent Fuel Pools" (NRC 2006b). 13 Severe Accident Mitigation Guidelines 14 Exelon has also developed and implemented severe accident mitigation guidelines (SAMGs) at 15 LGS, which further reduce risk at the facility. SAMGs were developed by the industry during the 16 1980s and 1990s in response to the Three Mile Island (TMI) Nuclear Station accident and 17 follow-up activities. SAMGs are meant to "enhance the ability of the operators to manage 18 accident sequences that progress beyond the point where emergency operating procedures 19 (EOPs) and other plant procedures are applicable and useful" (NRC 2011a). 20 Fukushima-Related Activities 21 The Commission also considered additional measures to enhance plant severe accident 22 performance throughout the nuclear fleet, including LGS, following the March 11, 2011, 23 Fukushima Dai -ichi accident. The Commission established a Task Force to "conduct a 24 methodical and systematic review of the NRC's process and regulations to determine whether 25 the agency should make additional improvements to its regulatory system and to make 26 recommendations to the Commission for its policy direction." 27 As a result of this review, the Task Force issued SECY 0093 (NRC 2011c), "Near-Term 28 Report and Recommendations for Agency Actions Following the Events in Japan
- " 29 SECY-11-0124 (NRC 2011d), "Recommended Actions to be Taken Without Delay from the 30 Near-Term Task Force Report;" and SECY-11-0137 (NRC 2011f), "Prioritization of 31 Recommended Actions to be Taken in Response to Fukushima Lessons Learned," to establish 32 the staff's prioritization of the recommendations.
The Commission's direction is provided in 33 SRM-SECY-11-0124 (NRC 2011e) and SRM -SECY-11-0137 (NRC 2011g). In March 2012 , 34 three Orders were issued to U.S. nuclear power plants. The first Order requires all U.S. plants 35 to better protect portable safety equipment put into place after the 9/11 terrorist attacks and to 36 obtain sufficient equipment to support all reactors at a given site simultaneously (NRC 2012a). 37 The second Order applies only to U.S. boiling water reactors that have "Mark I" or "Mark II" 38 (such as LGS) containment structures. Mark I reactors must improve installed venting systems 39 that help prevent or mitigate core damage in the event of a serious accident; Mark II reactors 40 must install these venting systems (NRC 2012b). The third Order requires all plants to install 41 enhanced equipment for monitoring water levels in each plant's spent fuel pool (NRC 2012c). 42 The NRC also issued an information request in March 2012, including earthquake and flooding 43 hazard "walkdowns," during which skilled engineers verify that the plants conform to their 44 current license requirements (NRC 2012d). 45 Under 10 CFR 51.53(c)(3)(ii)(L) and 10 CFR Part 51 Table B-1, the NRC does not need to 46 reconsider SAMAs for LGS at the license renewal phase. As provided above, those regulations 47 rely on more than just the prior 1989 SAMDA Analysis; they also rest on the IPE, IPEEE, and 48 Environmental Impacts of Postulated Accidents 5-7 CPI programs, to consider SAMAs in cases like LGS in which the NRC has already analyzed 1 SAMAs. These studies did not identify major cost -beneficial mitigation measures that could 2 substantially reduce offsite risk. Rather, they mostly uncovered minor improvements and 3 programmatic fixes. The volume of studies cited by the Commission, and their ongoing nature, 4 provide the type of "hard look" the Commission understood it must apply to the issue of severe 5 accident mitigation alternatives in its NEPA review for every license renewal proceeding 6 (61 FR 28481). This approach is all the more reasonable in light of the Commission's finding 7 that the probability -weighted environmental impacts of severe accidents are small. 8 Evaluation of New Information 9 Additionally, both the applicant and the NRC must consider whether new and significant 10 information affects environmental determinations in the NRC's regulations, including the 11 determination in 10 CFR 51.53(c)(3)(ii)(L) and Table B-1 that the agency need not reconsider 12 SAMAs at license renewal if it has already done so in a NEPA document for the plant. New 13 information is significant if it provides a seriously different picture of the impacts of the Federal 14 action under consideration. Thus, for mitigation alternatives such as SAMAs, new information is 15 significant if it indicates that a mitigation alternative would substantially reduce an impact of the 16 Federal action on the environment. Consequently, with respect to SAMAs, new information may 17 be significant if it indicated a given cost -beneficial SAMA would substantially reduce the impacts 18 of a severe accident, the probability or consequences (risk) of a severe accident occurring. As 19 discussed below, none of the information identified by the applicant or the staff indicates that 20 any SAMAs would be cost beneficial and likely to result in such a reduction of risk. Rather, new 21 information indicates that further SAMA analyses are unlikely to identify a SAMA that 22 substantially reduces the risk of a severe accident, such as major, cost -beneficial plant 23 improvements, and that the overall probability of a severe accident has decreased at LGS. The 24 following evaluation for new and significant information is to determine whether any new and 25 significant information exists that provides a "seriously different picture of the environmental 26 impacts than what was previously envisioned" regarding the determination in 27 10 CFR 51.53(c)(3)(ii)(L), Table B-1, and the clarifications in the statement of considerations. 28 As explained above, the Commission determined that no new SAMA analysis is required for 29 plants such as LGS at the license renewal stage. 30 The applicant relied on this and did not submit a SAMA analysis for license renewal. 31 Specifically, the applicant cited 10 CFR 51.53(c)(3)(ii)(L) and stated that no SAMA was 32 submitted as none was required as a matter of law (Entergy 2011c). Thus, the applicant's 33 treatment of SAMA in its ER is in accordance with the Commission's regulations, and the 34 applicant evaluated the new and significant information evaluation with respect to the 35 Commission's regulation (Exelon 2011c). The applicant analyzed whether potentially new and 36 significant information would change the results of its 1989 SAMDA Analysis review. The 37 Commission had indicated that if the Staff identifies information that could invalidate the 1989 38 SAMDS Analysis, it should determine if that information is significant. The staff reviewed the 39 applicant's submitted information and also assessed if any new and significant information has 40 been found that would change the generic conclusion codified by the NRC that Exelon need not 41 reassess SAMAs at LGS for license renewal (10 CFR 51.53(c)(3)(ii)(L)) and the staff need not 42 reconsider SAMAS at this stage (10 CFR 51, Table B-1). The following summarizes Exelon's 43 evaluation and the staff's review of this information. In addition, the staff's independent 44 assessment did not identify any other new and significant information with respect to those 45 regulations. Hence, no new and significant information has been found with respect to the 46 generic conclusion codified by the NRC that LGS need not reassess SAMAs for license renewal 47 (10 CFR 51.53(c)(3)(ii)(L)) because neither the Staff nor applicant uncovered any new and 48 Environmental Impact s of Postulated Accidents 5-8 significant information that suggested another cost beneficial SAMA that could substantially 1 reduce the risk of a severe accident at Limerick. 2 The Applicant's Evaluation of New and Significant Information 3 The applicant explained the process it used to identify any potentially new and significant 4 information related to its existing 1989 SAMA review in Section 5.3.1 of the ER (Exelon 2011c). 5 As provided in Section 5.1 of Appendix E of the ER (Exelon 2011c), the new and significant 6 assessment that Exelon conducted during preparation of this license renewal application 7 included: (1) interviews with Exelon Generation subject -matter experts on the validity of the 8 conclusions in the GEIS as they relate to LGS, (2) an extensive review of documents related to 9 environmental issues at LGS, (3) a review of correspondence with State and Federal agencies 10 to determine if the agencies had concerns relevant to their resource areas that had not been 11 addressed in the GEIS, (4) a review of the results of LGS environmental monitoring and 12 reporting, as required by regulations and oversight of plant facilities and operations by State and 13 Federal regulatory agencies (i.e., the results of ongoing routine activities that could bring 14 significant issues to Exelon Generation's attention), (5) a review for issues relevant to the LGS 15 application of certain license renewal applications that have previously been submitted to the 16 NRC by the operators of other nuclear plants, and (6) a review of information related to severe 17 accident mitigation. The significance and materiality of the new information identified through 18 this process was discussed further in ER Section 5.3.2, "Significance of New Information." 19 Exelon used a methodical approach to identify new and significant information and the staff 20 finds Exelon's process adequate to ensure a reasonable likelihood that the applicant would be 21 aware of any new and significant information. 22 The following four items of new information were identified and evaluated by the applicant by 23 comparing assumptions for the 1989 SAMDA Analysis with assumptions used for current -day 24 assessments of SAMAs: 25 (1) population increase 26 (2) consideration of offsite economic cost risk 27 (3) changed criteria for assigning cost per person -rem averted 28 (4) changed seismic hazard proposed by GI -199 29 Each item of new information wa s evaluated by the applicant and reviewed by the staff to 30 determine whether it would materially alter the NRC 's conclusions, as documented in the 31 1989 SAMDA Analysis, which is one of the documents that supports the determination in 32 10 CFR 51.53(c)(3)(ii)(L ). None of the items of new information led to the identification of a 33 SAMA that was cost -beneficial. Consequently, the applicant's and staff's review of new and 34 significant information with respect to the 1989 SAMA review did not uncover any cost beneficial 35 plant improvements or SAMAs that would substantially decrease the risk of a severe accident. 36 Instead, it confirmed that no plant improvements that led to a substantial reduction in risk would 37 be cost-beneficial. Therefore, the staff finds that none of the new information identified by the 38 applicant significantly affects the generic conclusion codified by the NRC that applicants need 39 not reassess SAMAs for license renewal at facilities like LGS (10 CFR 51.53(c)(3)(ii)(L)). 40 Risk 41 As provided in the discussion earlier regarding LGS's IPE, the CDF in the 2009 PRA Update 42 (3.2x10-6) is more than an order of magnitude less than the 1989 PRA Update (Exelon ER). 43 Any change in the likelihood of accidents that release substantial amounts of radioactive 44 material to the environment not only affects the human impact but also any environmental 45 impact. For LGS, this decrease in CDF would demonstrate less impact to dose, economic, and 46 environmental impact. The overall reduction in risk indicates that further SAMA analyses for 47 Environmental Impacts of Postulated Accidents 5-9 LGS would be unlikely to uncover cost -beneficial major plant improvements or plant 1 improvements that could substantially reduce risk. In light of the significant reduction in CDF, 2 no new information is likely to significantly affect the Commission's generic determination that 3 the NRC need not reanalyze SAMAs at LGS for license renewal. 4 Population Increase 5 A summary of Exelon's evaluation of population increase provided in the ER is as follows. 6 Exelon provided population values within 50 miles growing from 6,819,505 in 1980 to 9,499,925 7 in 2030. They further assumed that this 39 percent increase in population would yield an 8 approximate 39 percent increase in dose values. Hence, even assuming 2030 population 9 numbers, the highest benefit/cost ratio SAMDA (ATWS Vent) based on cost per person -rem 10 averted would still not be cost beneficial in the 1989 SAMDA Analysis. 11 The staff reviewed the calculation provided by the applicant and agrees that the population 12 increase would not make any of the 1989 SAM DA's cost effective. The staff acknowledges that 13 a more precise estimate of this relationship could be obtained by using the MACCS2 code, 14 performing a level III PRA, and completing a SAMA analysis. However, NEPA does not require 15 the NRC to completely reanalyze issues it has resolved generically, only look for information 16 that provides a "seriously different picture" of those considered generically. Notably, additional 17 conservatisms not mentioned by the applicant include that converting the $3,000,000 cost of the 18 anticipated transient without scram (ATWS) Vent SAM DA to 2012 dollars would increase the 19 cost of the SAMDA to over
$5,000,000(assuming similar construction and engineering 20 practices) and the current CDF for LGS is nearly an order of magnitude smaller than the one 21 used in the 1989 SAMDA Analysis. Considering the large conservatisms in the analysis with 22 respect to CDF , the applicant's analysis is reasonable. Moreover, even if population increase 23 led to another SAMA becoming cost beneficial, that SAMA would still not likely result in a 24 substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick since the 25 1989 SAMDA analysis. Consequently, the population increase within 50 miles of LGS does not 26 suggest that additional cost beneficial SAMAs could substantially reduce the risk of severe 27 accidents and therefore does not constitute new and significant information with respect to the 28 generic conclusion codified by the NRC that SAMAs need not be reassessed at facilities like 29 LGS for license renewal (10 CFR 51.53(c)(3)(ii)(L)). 30 Consideration of Offsite Economic Cost Risk 31 The applicant indicated that the 1989 SAM D A Analysis did not consider o ff site economic cost 32 risk. To account for the offsite economic cost risk, the applicant estimated these impacts by 33 using data from the Three Mile Island (TMI) license renewal application (Amergen 2008). Using 34 TMI data, the offsite economic cost risk was approximately 70 percent larger than the of fsite 35 exposure cost risk at TMI. In order to apply the TMI data to LGS, the applicant applied a factor 36 of 3 (300 percent) to analyze the impact on the 1989 SAM D A Analysis for LGS. Applying a 37 factor of 3 reduction to the closest potential cost beneficial SAMDA (ATWS Vent) would not 38 result in a cost beneficial SAMDA (Exelon 2011c). 39 The staff assessed the calculation provided by the applicant. The staff also used similar ratios 40 to evaluate the cost impact of onsite exposure and economic costs for LGS ($2 ,000 and 41 $400,000, respective ly) to obtain the total offsite and onsite economic and exposure cost.
The 42 net value was -$284,000, indicating the ATWS Vent SAMDA was still not cost effective. Since 43 this was applied to the SAMDA (ATWS Vent) that was closest to being cost effective, none of 44 the SAMDAs identified in the 1989 SAMDA Analysis would be cost effective. Additional 45 conservatisms not mentioned by the applicant include converting the $3,000,000 cost of the 46 ATWS Vent SAMA to 2012 dollars that would increase the cost of the SAMDA to over 47 $5,000,000 (assuming similar engineering and construction practices). Considering the large 48 Environmental Impact s of Postulated Accidents 5-10 conservatisms in the Exelon analysis, it is reasonable. Moreover, even if consideration of offsite 1 economic risk increase led to another SAMA becoming cost beneficial, that SAMA would still not 2 likely result in a substantial reduction in offsite risk, given the substantial reduction in CDF at 3 Limerick since the 1989 SAMDA analysis. Therefore, consideration of offsite costs would not 4 likely lead to discovery of a cost beneficial SAMA that would substantially reduce risk of severe 5 accidents and, therefore, does not constitute new and significant information with respect to the 6 generic conclusion codified by the NRC that applicants need not reassess SAMAs for facilities 7 such as LGS for license renewal. 8 Changed Criterion for Assigning Cost per Person-Rem Averted 9 The 1989 SAMDA Analysis calculated the benefit of each proposed SAMDA based on a 10 criterion of $1,000 per person -rem averted. Using a value of $2,000 per person -rem averted 11 would increase the threshold and potentially result in new cost beneficial SAMDAs. As 12 described in 1989 SAMDA Analysis, changing the cost/benefit threshold using the $2,000 per 13 person-rem averted conversion would still not result in this or any other of the SAMDAs 14 becoming cost beneficial. Therefore, Exelon concludes that changing the criterion for assigning 15 benefit (i.e., cost per person -rem averted) from $1,000 per person -rem averted to $2,000 per 16 person-rem averted would not change the conclusions in the 1989 SAMDA Analysis. Hence, 17 the new information represented by the changed criterion for assigning cost per person -rem 18 averted was judged not to be significant by Exelon. 19 The staff reviewed the LGS analysis provided in the License Renewal ER and agrees that 20 changing the criterion for assigning cost per person -rem averted would not result in a cost 21 beneficial SAMA. As provided above, the ATWS Vent has the lowest cost/benefit ratio for the 22 set, and it represents the SAMDA with the largest benefit potential. Even for this limiting 23 SAMDA, changing the cost/benefit threshold to $2,000 per person -rem averted would still not 24 result in this or any other of the SAMDAs becoming cost beneficial. Since this was applied to 25 the SAMDA (ATWS Vent) closest to being cost effective, none of the SAMDAs are cost 26 effective. Additional conservatisms not mentioned by the applicant include that converting the 27 $3,000,000 cost of the ATWS Vent SAMA to 2012 dollars would increase the cost of the 28 SAMDA to over $5,000,000 (assuming similar engineering and construction practices). 29 Considering all of the large conservatisms in the analysis, the applicant's analysis is reasonable. 30 Moreover, even if the increase in cost per person -rem averted led to another SAMA becoming 31 cost beneficial, that SAMA would still not likely result in a substantial reduction in offsite risk, 32 given the substantial reduction in CDF at Limerick since the 1989 SAMDA analysis. Therefore, 33 consideration of offsite costs would not likely lead to discovery of a cost-beneficial SAMA, let 34 alone one that would substantially reduce offsite risk and therefore does not constitute new and 35 significant information with respect to the generic conclusion codified by the NRC that Exelon 36 need not reassess LGS SAMAs for license renewal. 37 Changed Seismic Hazard Proposed in GI -199 38 The staff is investigating the implication of Updated Probabilistic Seismic Hazard Estimates in 39 Central and Eastern United States in GI -199. 40 The applicant indicated that GI -199 issues related to the seismic hazard will not result in 41 postulated accident scenarios not already considered for LGS. Seismologists are frequently 42 refining seismic methodologies and results, which may increase the estimated frequency of 43 seismic events with very low probability. Results from the LGS June 1989 PRA Update indicate 44 that the contribution from seismic risk to the total CDF is approximately 25 percent, with fire risk 45 contributing 31 percent to the total risk (Exelon 2011c). Therefore, based on the June 1989 46 Update, the major risk contributors for external hazards are approximately equal to the CDF 47 computed for internal events only. Based on the ER, total CDF for internal and external events 48 Environmental Impacts of Postulated Accidents 5-11 can generally be approximated by multiplying the CDF for internal events by a factor of 2. With 1 a multiplication factor of 2 applied to the CDF estimated by the current model of record 2 (CDF=3.2 x10-6), the revised CDF that accounts for both internal and external hazards 3 (CDF=6.4 x10-6) would still be a factor of 6.5 below the value used in the 1989 SAMDA Analysis 4 (CDF=4.2 x10-5 ). This demonstrates the excess margin in the 1989 SAMDA Analysis. A 5 possible increase in risk beyond this assumption due to an even larger seismic CDF would be 6 more than offset by the factor of 6.5 reduction in the current CDF. Therefore, Exelon concludes 7 that the new information represented by the changed seismic hazard proposed in GI -199 is not 8 significant because it would not materially alter the SAMDA conclusions in the 1989 SAMDA 9 (Exelon 2011c). 10 The staff reviewed the method the applicant used in determining the external events multiplier 11 and its use and determined that it was consistent with the guidance provided in NEI 05 -01. The 12 staff also confirmed that the risk has decreased since the 1989 SAMDA and agrees with 13 Exelon's analysis that the new information represented by the changed seismic hazard 14 proposed in GI -199 is not significant because it would not materially alter the SAMDA 15 conclusions in the 1989 SAMDA Analysis. Considering the large conservatism in the 16 1989 SAMDA Analysis, the applicant's approach is reasonable. Moreover, even if the change in 17 seismic hazard led to another SAMA becoming cost beneficial, that SAMA would still not likely 18 result in a substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick 19 since the 1989 SAMDA analysis. Therefore, consideration of GI -199 is not likely to lead to the 20 discovery of a cost -beneficial SAMA that would substantially reduce offsite risk and, therefore, 21 does not constitute new and significant information with respect to the generic conclusion 22 codified by the NRC that SAMAs need not be reassessed at LGS for license renewal. 23 Additional staff evaluation for new and significant information 24 The staff reviewed records of public meetings and correspondence related to the application 25 and compared information presented by the public with information considered in NUREG -1437 26 to determine if there was any new and significant information with respect to the generic 27 conclusion codified by the NRC, which indicates that SAMAs need not be reassessed at LGS 28 for license renewal (10 CFR 51.53(c)(3)(ii)(L)). 29 Cost-effective SAMAs Identified at Other Plants 30 From the scoping comments (NRDC 2011), there was a recommendation that potential 31 cost-effective SAMAs identified at other similar plants be addressed at LGS. Many of the SAMA 32 recommendations identified from other plants are compiled in an NRC published paper 33 (NRC 2009). The paper concludes that, "SAMAs that are found to be potentially cost -beneficial 34 tend to be low -cost improvements such as modifications to plant procedures or training, minimal 35 hardware changes, and use of portable equipment." These potential cost -beneficial SAMAs are 36 further evaluated and many times not found cost beneficial because sufficient risk is not 37 eliminated by the modification (which was assumed) or other factors. Furthermore, the staff 38 found that SAMA analyses that have been performed to date have found SAMAs that were 39 cost-beneficial, or at least possibly cost -beneficial subject to further analysis, in approximately 40 half of the plants. In general, the cost -beneficial SAMAs were identified and considered by the 41 licensee under the current operating license. In several cases, SAMA -related modifications 42 were implemented at LGS, further reducing that probability of an additional SAMA substantially 43 reducing severe accident risk. (PECO 1992)(Exelon 2011c) 44 As provided in the statement of considerations for 10 CFR 51.53(c)(3)(ii)(L), in forming its basis 45 for determining whic h plants needed to submit a SAMA, the Commission noted that all licensees 46 had undergone, or were in the process of undergoing, more detailed site -specific severe 47 accident mitigation analyses through processes separate from license renewal, specifically the 48 Environmental Impact s of Postulated Accidents 5-12 CPI, IPE, and IPEEE programs (61 FR 28467). These programs for LGS were discussed 1 earlier. In light of these studies, the Commission stated that it did not expect future SAMA 2 analyses in the license renewal stage to uncover "major plant design changes or modifications 3 that will prove to be cost -beneficial" (61 FR 28467). As discussed above, the NRC's experience 4 in completed license renewal proceedings has confirmed this assumption (NRC 2009) . As a 5 result, potentially cost -beneficial SAMAs at other facilities do not constitute new and significant 6 information with respect to the NRC's determination not to perform a second SAMA analysis at 7 license renewal in the event the agency has previously considered the issue because even if 8 cost beneficial the NRC staff's experience show that they will not likely yield a major reduction of 9 risk, particularly in light of the many improvements already implemented at Limerick. 10 Current State of the Art Knowledge for Performing SAMA Analysis 11 A current detailed SAMA analysis has the ability to analyze numerous plant -specific variables 12 and the sensitivity of a SAMA analysis to these variables. In the scoping comments, numerous 13 variables were identified that might cast doubt on the results of the initial 1989 SAM D A Analysis. 14 To thoroughly evaluate all of these variables would require a de novo SAMA analysis, which is 15 not required by 51.53(c)(3)(ii)(L) and Table B-1. However, the applicant evaluated some of the 16 changes at LGS that could have a significant impact on the SAMA evaluation such as 17 population increase, consideration of offsite economic cost risk, changed criteria for assigning 18 cost per person -rem averted, and changed seismic hazard proposed by GI -199 and concluded 19 that the changes or new information did not have a significant effect on the analysis. As 20 provided earlier, the staff independently confirmed this information to be reasonable and 21 moreover determine that they would not lead to identification of a SAMA that would substantially 22 reduce offsite risks but acknowledges that a more precise answer could be found with a detailed 23 SAMA analysis. However, the staff believes that this more precise answer would still not 24 identify significant cost beneficial SAMAs . As explained above, new and significant information 25 must provide a seriously different picture of the consequences of the Federal action under 26 consideration. With respect to SAMAs, new information may be significant if it indicated a given 27 SAMA would substantially reduce the probability or consequences of a severe accident. None 28 of the information identified by the applicant or the staff indicates that any SAMAs would be 29 likely to result in such a reduction of risk. Instead, as discussed above, new information 30 indicates that further SAMA analyses are unlikely to identify such major, cost -beneficial plant 31 improvements particularly in light of the substantial reduction in the CDF for Limerick since the 32 1989 SAMDA analysis. Nonetheless, the staff discusses another significant variable in 33 contemporary SAMA analyses, fuel enrichment, further below. 34 Enrichment of Fuel (Power Uprates) 35 Another potentially new and significant item that could impact the 1989 SAMA analysis is 36 increases in the enrichment of the fuel in the core. The following is the staff's review for any 37 significant changes to the fuel enrichment design basis at LGS by reviewing LGS docketed 38 information regarding power uprates. Extended power uprates require using fuel with a higher 39 percentage of uranium -235 or additional fresh fuel to derive more energy from the operation of 40 the reactor. This results in a larger radionuclide inventory (particularly short -lived isotopes, 41 assuming no change in burnup limits) in the core, than the same core at a lower power level. 42 The larger radionuclide inventory represents a larger source term for accidents and can result in 43 higher doses to offsite populations in the event of a severe accident. Typically, short -lived 44 isotopes are the main contributor to early fatalities. As stated in NUREG -1449 (NRC 1993), 45 short-lived isotopes make up 80 percent of the dose following early release. The staff found 46 that LGS had received two power uprate approvals since 1989. One uprate occurred in 1995. 47 In 1993, an amendment request was submitted to the NRC that would increase the licensed 48 thermal power level of the reactor from 3 ,293 megawatts thermal (MWt) to 3 ,458 MWt, primarily 49 Environmental Impacts of Postulated Accidents 5-13 by increasing the licensed core flow. In the staff's Environmental Assessment and Finding of 1 No Significant Impact related to the LGS application for the amendment, the staff f ound, "the 2 radiological and nonradiological environmental impacts associated with the proposed small 3 increase in power are very small and do not change the conclusion in the FES that the 4 operation of LGS, Units 1 and 2, would cause no significant adverse impact upon the quality of 5 the human environment." Furthermore, in the January 23, 1995 submittal relating to increasing 6 core flow, the licensee indicated that while fuel burnup and enrichment levels may increase as a 7 result of operation at uprated power, the burnup and enrichment will remain within the 5 percent 8 enrichment and 60,000 MWd/MT value previously evaluated by the staff. Thus, the fuel 9 enrichment did not exceed the previously licensed value (NRC 1995). 10 By application dated March 25, 2010 (Exelon 2010), Exelon submitted a license amendment 11 request for the LGS Units 1 and 2 Facility Operating Licenses and Technical Specifications. 12 The proposed amendment consisted of a 1.65 percent measurement uncertainty recapture 13 (MUR) p ower uprate that will increase each unit's rated thermal power from 3,458 megawatts 14 (MWt) to 3,515 MWt. The proposed amendment was characterized as a MUR power uprate, 15 which uses a Cameron International (formerly Caldon) CheckPlus TM Leading Edge Flow Meter 16 (LEFM) system to improve plant calorimetric heat balance measurement accuracy. This 17 flowmeter provides a more accurate measurement of feedwater (FW) flow and thus reduces the 18 uncertainty in the FW flow measurement. This submittal did not change the fuel enrichment 19 design basis. 20 Neither of these power uprates increased the fuel enrichment any higher than was previously 21 evaluated by the staff before the 1989 SAMDA Analysis was completed. Since the fuel 22 enrichment was not increased, further SAMA analyses for LGS would be unlikely to uncover 23 cost-beneficial major plant improvements or plant improvements that could substantially result in 24 lower doses to offsite populations in the event of a severe accident. Also, it reinforces the 25 Commission's generic determination that the NRC need not reanalyze SAMAs at LGS for 26 license renewal. 27 Conclusion 28 In conclusion, 10 CFR 51.53(c)(3)(ii)(L) states that, "[i]f the staff has not previously considered 29 SAMAs for the applicant's plant, in an environmental impact statement or related supplement or 30 in an environmental assessment, a consideration of alternatives to mitigate severe accidents 31 must be provided." Table B-1 in 10 CFR Part 51, which governs the scope of the staff's 32 environmental review for license renewal, echoes this regulation. Applicants for plants that 33 have already had a SAMA analysis considered by the NRC as part of an EIS, supplement to an 34 EIS, or EA, do not need to have a SAMA analysis reconsidered for license renewal. In forming 35 its basis for determining which plants needed to submit a SAMA at license renewal, the 36 Commission noted that all licensees had undergone, or were in the process of undergoing, 37 more detailed site -specific severe accident mitigation analyses through processes separate 38 from license renewal, specifically the CPI, IPE, and IPEEE programs (61 FR 28467). In light of 39 these studies, the Commission stated that it did not expect future SAMA analyses to uncover 40 "major plant design changes or modifications that will prove to be cost -beneficial" 41 (61 FR 28467). The NRC's experience in completed license renewal proceedings has 42 confirmed this assumption. 43 LGS is a plant that had a previous SAMA documented in a NEPA document. Therefore, Exelon 44 was not required to, and did not, submit a SAMA in its license renewal ER. Exelon did evaluate 45 whether there was new and significant information with respect to the Commission's prior 46 determination not to require a SAMA analysis at license renewal for those plants that were 47 already the subject of a SAMA analysis by the staff. 48 Environmental Impact s of Postulated Accidents 5-14 The staff analyzed information in the applicant's ER with respect to the 1989 SAMDA Analysis 1 for LGS, public comments, and its own review of information relevant to LGS to search for new 2 and significant information with respect to the NRC's determination not to conduct a second 3 SAMA analysis at LGS for license renewal and the studies and assumptions underlying that 4 determination. In conducting that search, the staff considered whether new information 5 provided a seriously different view of the consequences of renewing the LGS operating license 6 than previously contemplated. For a mitigation analysis, such as a SAMA analysis, such 7 information would need to demonstrate a substantial change in the environmental impact sought 8 to be mitigated, in this case severe accidents. Given the discussion above, it is unlikely that 9 further SAMA analyses for LGS could uncover cost beneficial SAMAs that would substantially 10 reduce the risk of severe accidents because the reduction in severe accident risk at Limerick 11 from the use of new information outweighs any increases resulting from new considerations. 12 The staff also did not identify any new and significant information that rises to a level that 13 requires staff to seek Commission approval to conduct a new SAMA analysis (similar to the 14 waiver requirement that applies for Category 1 issues when staff identifies new and significant 15 information). The impacts of all other new information do not contribute sufficiently to the 16 environmental impacts to warrant their inclusion in a SAMA analysis, since the likelihood of 17 finding cost-effective plant improvements that substantially reduce risk is small. Additionally, the 18 staff did not identify a significant environmental issue not covered in the GEIS, or that was not 19 considered in the analysis in the GEIS and leads to an impact finding that is different from the 20 finding presented in the GEIS. 21 The staff identified no new and significant information related to postulated accidents during the 22 review of LGS's ER (Exelon 201 1c) or evaluation of other available information. Therefore, 23 there are no impacts related to these issues beyond those discussed in the GEIS. In 24 accordance with 10 CFR 51.53(c)(3)(ii)(L), the staff did not repeat the review of SAMAs for LGS. 25 While another SAMA is not required, the applicant provided and the staff reviewed 26 considerations of new and significant information. 27 5.4. References 28 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 29 production and utilization facilities." 30 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 31 protection regulations for domestic licensing and related regulatory functions." 32 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 33 renewal of operating licenses for nuclear power plants." 34 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor site 35 criteria." 36 61 FR 28467. U.S. Nuclear Regulatory Commission. Environmental review for renewal of 37 nuclear power plant operating licenses. Federal Register 61(109):28467 -28481. June 5, 1996. 38 74 FR 13926. U.S. Nuclear Regulatory Commission. Power reactor security requirements. 39 Federal Register 74(58): 13926 -13993. March 27, 2009. 40 [Amergen] Amergen Energy Company, LLC. 2008. "Three Mile Island Nuclear Station, 41 Applicant's Environmental Report, License Renewal Operating Stage." Kennett Square, PA: 42 Amergen. Agencywide Documents Access and Management System (ADAMS) Accession Nos. 43 ML080220255, ML080220257, ML080220261, and ML080220282. 44 Environmental Impacts of Postulated Accidents 5-15 Energy Northwest. 2011. Letter from A. Javorik, Vice President, to NRC Document Control 1 Desk.
Subject:
Columbia Generating Station, Docket No. 50 -397, Response to request for 2 additional information, license renewal application. November 17, 2011. ADAMS Accession 3 No. ML11325A067. 4 [Exelon] Exelon Generation Company, LLC. 2010. Letter from M. Jesse, Manager, 5 Licensing-Power Uprate, to NRC Document Control Desk. Limerick Generating Station, Units 1 6 and 2: Request for license amendment regarding measurement uncertainty recapture power 7 uprate. March 25, 2010. ADAMS Accession No. ML100850380. 8 [Exelon] Exelon Generation Company, LLC. 2011a. Letter from M.P. Gallagher, Vice President, 9 License Renewal Projects, to NRC Document Control Desk. Limerick Generating Station, Units 10 1 and 2: Application for renewed operating licenses. June 22, 2011. ADAMS Accession No. 11 ML11179A096. 12 [Exelon] Exelon Generation Company, LLC. 2011b. License Renewal Application [LRA], 13 Limerick Generating Station, Units 1 and 2. June 22, 2011. ADAMS Accession 14 No. ML11179A101. 15 [Exelon] Exelon Generation Company, LLC. 2011c. Environmental Report -Operating License 16 Renewal Stage, Limerick Generating Station, Units 1 and 2. June 22, 2011. ADAMS Accession 17 No. ML11179A104. 18 Ghosh T, Palla R, Helton D. 2009. Perspectives on Severe Accident Mitigation Alternatives for 19 U.S. Plant License Renewal. U.S. Nuclear Regulatory Commission. September 2009. ADAMS 20 Accession No. ML092750488. 21 [NRC] U.S. Nuclear Regulatory Commission. 1988a. Generic Letter No. 88 -20, "Individual Plant 22 Examination for Severe Accident Vulnerabilities." November 23, 1988. ADAMS Accession 23 No. ML031150465. 24 [NRC] U.S. Nuclear Regulatory Commission. 1988b. Generic Letter No. 88 -20, Supplement 25 No. 4, "Individual Plant Examination of External Events (IPEEE) for Severe Accident 26 Vulnerabilities -10 CFR 50.54(f)." June 28, 1991. ADAMS Accession No. ML031150485. 27 [NRC] U.S. Nuclear Regulatory Commission. 1988c. SECY 147, "Integration Plan for 28 Closure of Severe Accident Issue." May 25, 1988. 29 [NRC] U.S. Nuclear Regulatory Commission. 1989. Final Environmental Statement Related to 30 Operation of LGS, Units 1 and 2. Washington, DC: NRC. NUREG -0974, Supplement 1. 31 August 1989. ADAMS Accession No. ML112221A204. 32 [NRC] U.S. Nuclear Regulatory Commission. 1991. Procedural and Submittal Guidance for the 33 Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. 34 Washington, DC: NRC. NUREG -1407. June, 1991. ADAMS Accession No. ML063550238. 35 [NRC] U.S. Nuclear Regulatory Commission. 1993. Shutdown and Low -Power Operation at 36 Commercial Nuclear Power Plants in the United States. Washington, DC: NRC. NUREG -1449. 37 September 1993. ADAMS Accession No. ML063470582. 38 [NRC] U.S. Nuclear Regulatory Commission. 1995. Letter from F. Rinaldi, Project Director, 39 Division of Reactor Projects, to G. Hunger, Director -Licensing, PECO Energy Company. 40 Environmental assessment and finding of no significant impact, power uprate with increased 41 core flow, Limerick Generating Station, Unit Nos. 1 and 2 (TAC Nos. M88392 and M88393). 42 February 7, 1995. ADAMS Accession No. ML011560483. 43 Environmental Impact s of Postulated Accidents 5-16 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 1 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 2 ADAMS Accession Nos. ML040690705 and ML040690738. 3 [NRC] U.S. Nuclear Regulatory Commission. 199
- 7. Status of the Integration Plan for Closure of 4 Severe Accident Issues and the Status of Severe Accident Research. Washington, DC: NRC.
5 SECY 97-132. June 1997. ADAMS Accession No. ML 992930144 6 [NRC] U.S. Nuclear Regulatory Commission. 1999a. Standard Review Plans For Environmental 7 Reviews for Nuclear Power Plants, Supplement 1 . Washington, DC: NRC. NUREG-1555. 8 October 1999. ADAMS Accession No. ML003702019. 9 [NRC] U.S. Nuclear Regulatory Commission. 1999b. Section 6.3 - Transportation, Table 9.1, 10 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 11 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 12 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 13 No. ML04069720. 14 [NRC] U.S. Nuclear Regulatory Commission. 2002. Perspectives Gained from the Individual 15 Plant Examination of External Events (IPEEE) Program. Washington, DC: NRC. NUREG -1742. 16 April 2002. ADAMS Accession No. ML021270070. 17 [NRC] U.S. Nuclear Regulatory Commission. 2004. Protecting Our Nation -Since 9-11-01. 18 Washington, DC: NRC. NUREG/BR -0314. September 2004. 19 [NRC] U.S. Nuclear Regulatory Commission. 2006a. Frequently Asked Questions on License 20 Renewal of Nuclear Power Reactors. Washington, DC: NRC. NUREG -1850. March 2006. 21 [NRC] U.S. Nuclear Regulatory Commission. 2006b. Mitigation of Spent Fuel Loss -of-Coolant 22 Inventory Accidents and Extension of Reference Plant Analyses to Other Spent Fuel Pools. 23 Sandia Letter Report, Revision. November 2, 2006. 24 [NRC] U.S. Nuclear Regulatory Commission. 2011a. "Recommendations for Enhancing Reactor 25 Safety in the 21st Century: The Near -Term Task Force Review of Insights from the Fukushima 26 Dai-ichi Accident." July 12, 2011. ADAMS Accession No. ML111861807 27 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from P. Bamford, Project Manager, 28 Division of Operating Reactor Licensing, to MJ Pacilio, President and Chief Nuclear Officer, 29 Exelon Nuclear. Limerick Generating Station, Units 1 and 2 - Issuance of amendments re: 30 measurement uncertainty recapture power uprate and standby liquid control system changes 31 (Tac Nos. ME3589, ME3590, ME3591, and ME3592). April 8, 2011. ADAMS Accession No. 32 ML110691095. 33 [NRC] U.S. Nuclear Regulatory Commission. 2011c. SECY 0093, "Near -Term Report and 34 Recommendations for Agency Actions Following the Events in Japan." ADAMS Accession 35 No. ML 11186A950. 36 [NRC] U.S. Nuclear Regulatory Commission. 2011d. SECY-11-0124, "Recommended Actions to 37 be taken Without Delay from the Near -Term Task Force Report." ADAMS Accession 38 No. ML112911571.[NRC] U.S. Nuclear Regulatory Commission. 2011e. SRM -SECY-11-0124, 39 "Staff Requirements -SECY-11-0124: Recommended Actions to Be Taken Without Delay from 40 the Near-Term Task Force Report." October 18, 2011. 41 [NRC] U.S. Nuclear Regulatory Commission. 2011f. SECY 0137, "Prioritization of 42 Recommended Actions to be Taken in Response to Fukushima Lessons Learned." 43 October 3, 2011. ADAMS Accession No. ML11272A111. 44 Environmental Impacts of Postulated Accidents 5-17 [NRC] U.S. Nuclear Regulatory Commission. 2011g. Staff Requirements- Secy-11-0137 - 1 "Prioritization of Recommended Actions to Be Taken in Response to Fukushima Lessons 2 Learned." December 15, 2011. 3 [NRC] U.S. Nuclear Regulatory Commission. 2012a. Order EA 049, Issuance of Order to 4 Modify Licenses With Regard to Requirements for Mitigation Strategies for 5 Beyond-Design-Basis External Events. March 12, 2012. ADAMS Accession No. ML012054A735 6 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Order EA 050, "Issuance of Order to 7 Modify Licenses with Regard to Reliable Hardened Containment Vents." March 12, 2012. 8 ADAMS Accession No. ML012054A694. 9 [NRC] U.S. Nuclear Regulatory Commission. 2012c. Order EA 051, "
Subject:
Issuance of 10 Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation." 11 March 12, 2012. ADAMS Accession No.ML012054A679. 12 [NRC] U.S. Nuclear Regulatory Commission. 2012d. "Request For Information Pursuant to 13 Title 10 of The Code of Federal Regulations 50.54(F) Regarding Recommendations 2.1,2.3, and 14 9.3, of The Near -Term Task Force Review of Insights From the Fukushima Dai -Ichi Accident." 15 March 12, 2012. ADAMS Accession No. ML012053A340. 16 [NRC] U.S. Nuclear Regulatory Commission. 2012e. Generic Environmental Impact Statement 17 for License Renewal of Nuclear Plants Regarding Columbia Generating Station (NUREG-1437, 18 Supplement 47) Final Report for Comment. Washington, DC: NRC. NUREG-1437. April 2012. 19 ADAMS Accession No. ML11227A007. 20 [NRDC] Natural Resources Defense Council. 2011. Letter from NRDC to C. Bladey. Natural 21 Resources Defense Council comments on Limerick EIS scoping process." October 28, 2011. 22 ADAMS Accession No. ML11307A456 23 [PECO] Philadelphia Electric Company. 1992. Limerick Generati ng Station, Units 1 and 2: 24 Individual plant examination volume 1. July 1992. ADAMS Accession No. ML080030106 and 25 ML080030104. 26 [PECO] Philadelphia Electric Company. 1995. Limerick Generating Station, Units 1 and 2 27 response to NRC Generic Letter 88 -20, supplement 4, "Individual Plant Examination of External 28 Events (IPEEE) for Severe Accident Vulnerabilities." June 1995. ADAMS Accession 29 No. ML073610238. 30 [PECO] Philadelphia Electric Company. 1996. Letter from G.A. Hungar, Jr., Director -Licensing, 31 to NRC Document Control Desk. Limerick Generating Station, Units 1 and 2: Response to 32 request for additional information regarding review of individual plant examination of external 33 events. June 28, 1996. ADAMS Accession No. ML073610237. 34
6-1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 1 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS 2 This chapter addresses issues related to the uranium fuel cycle, solid waste management, and 3 greenhouse gas emissions during the proposed 20 -year period of extended operation. 4 6.1. The Uranium Fuel Cycle 5 The uranium cycle includes uranium mining and milling, the production of uranium hexafluoride, 6 isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation of radioactive 7 materials, and management of low -level wastes and high -level wastes related to uranium fuel 8 cycle activities. The generic potential impacts of the radiological and nonradiological 9 environmental impacts of the uranium fuel cycle and transportation of nuclear fuel and waste s 10 are described in detail in NUREG -1437, Generic Environmental Impact Statement (GEIS) for 11 License Renewal of Nuclear Plants (NRC 1996, 1999) based, in part, on the generic impacts 12 given in Table S-3, "Table of Uranium Fuel Cycle Environmental Data," located in Title 10 of the 13 Code of Federal Regulations 51.51 (10 CFR 51.51) and in 10 CFR 51.52(c), Table S-4, 14 "Environmental Impact of Transportation of Fuel and Waste to and from One 15 Light-Water-Cooled Nuclear Power Reactor." 16 In the GEIS, the U.S. Nuclear Regulatory Commission staff (the staff) identified nine 17 Category 1 issues related to the fuel cycle and waste management, which appear in Table 6 -1. 18 There are no Category 2 issues related to the fuel cycle and waste management. 19 Table 6-1. Issues Related to the Uranium Fuel Cycle and Waste Management 20 Issues GEIS Sections Category Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high -level waste) 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 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 cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 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 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-2 The NRC staff's evaluation of the environmental impacts associated with spent nuclear fuel is 1 addressed in two issues in Table 6 -1, "Offsite radiological impacts (spent fuel and high -level 2 waste disposal)" and "Onsite spent fuel." However, as explained later in this section, the scope 3 of the evaluation of these two issues in this SEIS has been revised. The issue, "Offsite 4 radiological impacts (spent fuel and high -level waste disposal)," is not evaluated in this SEIS. In 5 addition, the issue, "Onsite spent fuel" only evaluates the environmental impacts during the 6 license renewal term. 7 For the term of license renewal, the staff did not find any new and significant information related 8 to the remaining uranium fuel cycle and solid waste management issues listed in Table 6 -1 9 during its review of the Limerick Generating Station environmental report (ER) (Exelon 2011), 10 the site visit, and the scoping process. Therefore, there are no impacts related to these issues 11 beyond those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the 12 impacts are SMALL, except for the issue, "Offsite radiological impacts (collective effects)," which 13 the NRC concluded are acceptable. 14 However, the offsite radiological impacts resulting from spent fuel and high -level waste disposal 15 and the onsite storage of spent fuel, which will occur after the reactors have been permanently 16 shutdown, are addressed in the Commission's Waste Confidence Decision Rule (WCD), 17 10 CFR 51.23. In 2010, the Commission revised the WCD (i.e., WCD Update) to reflect 18 information gained based on experience in the storage of spent nuclear fuel and the increased 19 uncertainty in the siting and construction of a permanent geologic repository for the disposal of 20 spent nuclear fuel. 21 On June 8, 2012, in response to a legal challenge to the WCD, the U.S. Court of Appeals for the 22 District of Columbia Circuit (New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012)) vacated the 23 NRC's WCD Update (75 Federal Register (FR) 81032 , 75 FR 81037). The court decision was 24 based on grounds relating to aspects of the National Environmental Policy Act (NEPA). The 25 court decision held that the WCD Update is a major Federal action necessitating either an 26 environmental impact statement (EIS) or a finding of no significant environmental impact 27 (FONSI), and the Commission's evaluation of the risks associated with the storage of spent 28 nuclear fuel for at least 60 years beyond the licensed life for reactor operation is deficient. 29 In response to the court's ruling, the Commission, in CLI 1 6 (NRC 2012a), determined that it 30 would not issue licenses dependent upon the WCD, until the issues identified in the court's 31 decision are appropriately addressed. In CLI 16, the Commission also noted that this 32 determination extends only to final license issuance; all current licensing reviews and 33 proceedings should continue to move forward. 34 In addition, the Commission directed in SRM-COMSECY-12-0016 (NRC 2012b) that the NRC 35 staff proceed with a rulemaking that includes the development of an EIS to support an updated 36 WCD within 24 months (by September 2014). The Commission indicated that the EIS used to 37 support the revised rule should build on the information already documented in various NRC 38 studies and reports on the impacts associated with the storage of spent nuclear fuel that were 39 developed as part of the 2010 WCD Update, and should primarily focus additional analyses on 40 the deficiencies identified in the D.C. Circuit's decision. The NRC considers the WCD to be a 41 generic issue that is best addressed through rulemaking, and that the NRC rulemaking process 42 provides an appropriate forum for public review and comment on both the draft EIS and the 43 proposed WCD. 44 The updated rule and supporting EIS will provide the necessary NEPA analyses of waste 45 confidence-related human health and environmental issues. As directed by the Commission, 46 the NRC will not issue a renewed license before the resolution of waste confidence -related 47 issues. This will ensure that there would be no irretrievable or irreversible resource 48 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-3 commitments or potential harm to the environment before waste confidence impacts have been 1 addressed. 2 If the results of the WCD EIS identify information that requires a supplement to this EIS, the 3 NRC staff will perform any appropriate additional NEPA review for those issues before the NRC 4 makes a final licensing decision. 5 6.2. Greenhouse Gas Emissions 6 This section discusses the potential impacts from greenhouse gases (GHGs) emitted from the 7 nuclear fuel cycle. The GEIS does not directly address these emissions, and its discussion is 8 limited to an inference that substantial carbon dioxide (CO
- 2) emissions may occur if coal- or 9 oil-fired alternatives to license renewal are carried out.
10 6.2.1. Existing Studies 11 Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 12 electricity generating methods have been widely studied. However, estimates and projections 13 of the carbon footprint of the nuclear power lifecycle vary depending on the type of study done. 14 Additionally, considerable debate also exists among researchers on the relative effects of 15 nuclear and other forms of electricity generation on GHG emissions. Existing studies on GHG 16 emissions from nuclear power plants generally take two different forms: 17 (1) qualitative discussions of the potential to use nuclear power to reduce GHG 18 emissions and mitigate global warming, and 19 (2) technical analyses and quantitative estimates of the actual amount of GHGs 20 generated by the nuclear fuel cycle or entire nuclear power plant life cycle 21 and comparisons to the operational or life cycle emissions from other energy 22 generation alternatives. 23 6.2.1.1. Qualitative Studies 24 The qualitative studies consist primarily of broad, large -scale public policy, or investment 25 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 26 or politically workable means of achieving global GHG reductions. Studies the staff found 27 during the subsequent literature search include the following: 28 Evaluations to determine if investments in nuclear power in developing 29 countries should be accepted as a flexibility mechanism to assist 30 industrialized nations in achieving their GHG reduction goals under the Kyoto 31 Protocols (IAEA 2000, NEA 2002, Schneider 2000). Ultimately, the parties to 32 the Kyoto Protocol did not approve nuclear power as a component under the 33 clean development mechanism (CDM) because of safety and waste disposal 34 concerns (NEA 2002). 35 Analyses developed to assist governments, including the United States, in 36 making long-term investment and public policy decisions in nuclear power 37 (Hagen et al. 2001, Keepin 1988, MIT 2003). 38 Although the qualitative studies sometimes reference and critique the existing quantitative 39 estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally 40 rely heavily on discussions of other aspects of nuclear policy decisions and investment, such as 41 safety, cost, waste generation, and political acceptability. Therefore, these studies typically are 42 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-4 not directly applicable to an evaluation of GHG emissions associated with the proposed license 1 renewal for a given nuclear power plant. 2 6.2.1.2. Quantitative Studies 3 A large number of technical studies, including calculations and estimates of the amount of 4 GHGs emitted by nuclear and other power generation options, are available in the literature and 5 were useful in the staff's efforts to address relative GHG emission levels. Examples of these 6 studies include -but are not limited to -Mortimer (1990), Andseta et al. (1998), Spadaro (2000), 7 Storm van Leeuwen and Smith (2008), Fritsche (2006), Parliamentary Office of Science and 8 Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), Fthenakis 9 and Kim (2007), and Dones (2007). In addition, Sovacool (2008) provides a review and 10 synthesis of studies in existence through 2008; however, the Sovacool synthesis ultimately uses 11 only 19 of the 103 studies initially considered (the remaining 84 were excluded because they 12 were more than 10 years old, not publicly available, available only in a language other than 13 English, or they presented methodological challenges by relying on inaccessible data, providing 14 overall GHG estimates without allocating relative GHG impacts to different parts of the nuclear 15 lifecycle, or they were otherwise not methodologically explicit). 16 Comparing these studies and others like them is difficult because the assumptions and 17 components of the lifecycles that the authors evaluate vary widely. Examples of areas in which 18 differing assumptions make comparing the studies difficult include the following: 19 energy sources that may be used to mine uranium deposits in the future, 20 reprocessing or disposal of spent nuclear fuel, 21 current and potential future processes to enrich uranium and the energy 22 sources that will power them, 23 estimated grades and quantities of recoverable uranium resources, 24 estimated grades and quantities of recoverable fossil fuel resources, 25 estimated GHG emissions other than CO 2, including the conversion to CO 2 26 equivalents per unit of electric energy produced, 27 performance of future fossil fuel power systems, 28 projected capacity factors for alternatives means of generation, and 29 current and potential future reactor technologies. 30 In addition, studies may vary with respect to whether all or parts of a power plant's lifecycle are 31 analyzed (i.e., a full lifecycle analysis will typically address plant construction, operations, 32 resource extraction -for fuel and construction materials, and decommissioning), whereas a 33 partial lifecycle analysis primarily focuses on operational differences. In addition, as 34 Sovacool (2008) noted, studies vary greatly in terms of age, data availability, and 35 methodological transparency. 36 In the case of license renewal, a GHG analysis for the portion of the plant's lifecycle attributable 37 to license renewal (operation for an additional 20 years) would not involve GHG emissions 38 associated with construction because construction activities already have been completed at the 39 time of relicensing. In addition, the proposed action of license renewal also would not involve 40 additional GHG emissions associated with facility decommissioning because that 41 decommissioning must occur whether the facility is relicensed or not. However, in many 42 studies, the specific contribution of GHG emissions from construction, decommissioning, or 43 other portions of a plant's lifecycle cannot be clearly separated from one another. In such 44 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-5 cases, an analysis of GHG emissions would overestimate the GHG emissions attributed to a 1 specific portion of a plant's lifecycle. As Sovacool (2008) noted, many of the available analyses 2 provide markedly lower GHG emissions per unit of plant output when one assumes that a power 3 plant operates for a longer period of time. Nonetheless, available studies supply some 4 meaningful information on the relative magnitude of the emissions among nuclear power plants 5 and other forms of electric generation, as discussed in the following sections. 6 In Tables 6-2, 6-3, and 6-4, the staff presents the results of the above -mentioned quantitative 7 studies to supply a weight -of-evidence evaluation of the relative GHG emissions that may result 8 from the proposed license renewal compared to the potential alternative use of coal -fired, 9 natural gas -fired, and renewable generation. Most studies from Mortimer (1990) onward 10 (through Sovacool 2008) indicate that uranium ore grades and uranium enrichment processes 11 are leading determinants in the ultimate GHG emissions attributable to nuclear power 12 generation. These studies show that the relatively lower order of magnitude of GHG emissions 13 from nuclear power, when compared to fossil -fueled alternatives (especially natural gas), could 14 potentially disappear if available uranium ore grades drop sufficiently while enrichment 15 processes continued to rely on the same technologies. 16 Sovacool's synthesis of 19 existing studies found that nuclear power generation causes carbon 17 emissions in a range of 1.4 grams of carbon equivalent per kilowatt -hour (g C eq/kWh) to 18 288 g C eq/kWh, with a mean value of 66 g C eq/kWh. The results of his synthesis and the results 19 of others' efforts are included in the tables in this section. 20 6.2.1.3. Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 21 Considering that coal fuels the largest share of electricity generation in the United States and 22 that its burning results in the largest emissions of GHGs for any of the likely alternatives to 23 nuclear power generation, including CGS, many of the available quantitative studies focused on 24 comparing the relative GHG emissions of nuclear to coal-fired generation. The quantitative 25 estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the 26 nuclear lifecycle), as compared to an equivalent coal -fired plant, are presented in Table 6-2. 27 The following table does not include all existing studies, but it gives an illustrative range of 28 estimates that various sources have developed. 29 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-6 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal 1 Source GHG Emission Results Mortimer (1990) Nuclear-230,000 tons CO 2 Coal-5,912,000 tons CO 2 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 (2008) Authors did not evaluate nuclear versus coal. 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 results from other studies) Nuclear-2.8-24 g C eq/kWh 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) 6.2.1.4. Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 2 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 3 some cases, the nuclear lifecycle), as compared to an equivalent natural gas -fired plant, are 4 presented in Table 6-3. The following table does not include all existing studies, but it gives an 5 illustrative range of estimates various sources have developed. 6 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-7 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 C eq/kWh Storm van Leeuwen and Smith (2008) Nuclear fuel cycle produces 20 -33% of the GHG emissions compared to natural gas (at high ore grades). 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/k Wh Cogeneration combined cycle natural gas -150 g C eq/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 results from other studies) Nuclear-2.8-24 g C eq/kWh Natural gas -440-780 g C eq/kWh Fthenakis and Kim (2007) Authors did not evaluate nuclear versus natural gas. Dones (2007) 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) 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 2 Sources 3 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 4 some cases, the nuclear lifecycle), as compared to equivalent renewable energy sources, are 5 presented in Table 6-4. Calculation of GHG emissions associated with these sources is more 6 difficult than the calculations for nuclear energy and fossil fuels because of the large variation in 7 efficiencies and capacity factors because of their different technologies, sources, and locations. 8 For example, the efficiency of solar and wind energy is highly dependent on the wind or solar 9 resource in a particular location. Similarly, the range of GHG emissions estimates for 10 hydropower varies greatly depending on the type of dam or reservoir involved (if used at all). 11 Therefore, the GHG emissions estimates for these energy sources have a greater range of 12 variability than the estimates for nuclear and fossil fuel sources. As noted in Section 6.2.1.2, the 13 following table does not include all existing studies, but it gives an illustrative range of estimates 14 various sources have developed. 15 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-8 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources 1 Source GHG Emission Results Mortimer (1990) Nuclear-230,000 tons CO 2 Hydropower -78,000 tons CO 2 Wind power -54,000 tons CO 2 Tidal power -52,500 tons CO 2 Note: Future GHG emissions from nuclear are expecte d 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 (2008) Author did not evaluate nuclear versus renewable energy sources. 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 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. Weisser (2006) (compilation of results from other studies) Nuclear-2.8-24 g C eq/kWh Solar PV-43-73 g Ceq/kWh Hydroelectric-1-34 g Ceq/kWh 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. Sovacool (2008) (adopted from other studies) Nuclear-66 g Ceq/kWh Wind-9-10 g Ceq/kWh Hydroelectric (small, distributed)-10-13 g Ceq/kWh Biogas digester -11 g C eq/kWh Solar thermal -13 g Ceq/kWh 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)
Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-9 6.2.2.
Conclusions:
Relative Greenhouse Gas Emissions 1 The sampling of data presented in Tables 6-2 , 6-3, and 6-4 demonstrates the challenges of 2 any attempt to determine the specific amount of GHG emission attributable to nuclear energy 3 production sources because different assumptions and calculation methods will yield differing 4 results. The differences and complexities in these assumptions and analyses will further 5 increase when they are used to project future GHG emissions. Nevertheless, several 6 conclusions can be drawn from the information presented. 7 First, the various studies show a general consensus that nuclear power currently produces 8 fewer GHG emissions than fossil -fuel-based electrical generation (e.g., GHG emissions from a 9 complete nuclear fuel cycle currently range from 2.5 -66 grams of carbon equivalent per kilowatt 10 hour (g C eq/kWh), as compared to the use of coal plants (264-1, 250 g C eq/kWh) and natural gas 11 plants (120 -780 g C eq/kWh)). The studies also provide estimates of GHG emissions from five 12 renewable energy sources based on current technology. These estimates included 13 solar-photovoltaic (17 -125 g C eq/kWh), hydroelectric (1 -64.6 g C eq/kWh), biomass 14 (8.4-99 g C eq/kWh), wind (2.5 -30 g C eq/kWh), and tidal (25 -50 g C eq/kWh). The range of these 15 estimates is wide, but the general conclusion is that current GHG emissions from nuclear power 16 generation are of the same order of magnitude as from these renewable energy sources. 17 Second, the studies show no consensus on future relative GHG emissions from nuclear power 18 and other sources of electricity. There is substantial disagreement among the various authors 19 about the GHG emissions associated with declining uranium ore concentrations, future uranium 20 enrichment methods, and other factors, including changes in technology. Similar disagreement 21 exists about future GHG emissions associated with coal and natural gas for electricity 22 generation. Even the most conservative studies conclude that the nuclear fuel cycle currently 23 produces fewer GHG emissions than fossil -fuel-based sources and is expected to continue to 24 do so in the near future. The primary difference between the authors is the projected cross -over 25 date (the time at which GHG emissions from the nuclear fuel cycle exceed those of 26 fossil-fuel-based sources) or whether cross -over will actually occur. 27 Considering current estimates and future uncertainties, it appears that GHG emissions 28 associated with the proposed LGS relicensing action are likely to be lower than those 29 associated with fossil -fuel-based energy sources. The staff bases this conclusion on the 30 following rationale: 31 As shown in Tables 6-2 and 6-3, current estimates of GHG emissions from 32 the nuclear fuel cycle are far below those for fossil -fuel-based energy 33 sources. 34 License renewal of a nuclear power plant such as LGS may involve continued 35 GHG emissions caused by uranium mining, processing, and enrichment, but 36 will not result in increased GHG emissions associated with plant construction 37 or decommissioning (since the plant will have to be decommissioned at some 38 point whether the license is renewed or not). 39 Few studies predict that nuclear fuel cycle emissions will exceed those of 40 fossil fuels within a timeframe that includes the LGS periods of extended 41 operation. Several studies suggest that future extraction and enrichment 42 methods, the potential for higher -grade resource discovery, and technology 43 improvements could extend this timeframe. 44 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-10 With respect to the comparison of GHG emissions among the proposed LGS license renewal 1 action and renewable energy sources: 2 It appears likely that there will be future technology improvements and 3 changes in the type of energy used for mining, processing, manufacturing, 4 and constructing facilities of all types. 5 Currently, the GHG emissions associated with the nuclear fuel cycle and 6 renewable energy sources are within the same order of magnitude. 7 Because nuclear fuel production is the most significant contributor to possible 8 future increases in GHG emissions from nuclear power -a nd since most 9 renewable energy sources lack a fuel component -it is likely that GHG 10 emissions from renewable energy sources w ill be lower than those 11 associated with LGS at some point during the period of extended operation. 12 The staff provides additional discussion on the contribution of GHG to cumulative air quality 13 impacts in Section 4.11.2 of this supplemental EIS. 14 6.3. References 15 75 FR 81032. U.S. Nuclear Regulatory Commission. Consideration of environmental impacts of 16 temporary storage of spent fuel a fte r cessation of reactor operation. Federal Register 17 75(246):81032 -81037. December 23, 2010. 18 75 FR 81037. U.S. Nuclear Regulatory Commission. Waste confidence decision update. 19 Federal Register 75(246):81037 -81076. December 23, 2010. 20 [AEA] AEA Technology. 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note." East 21 Kilbride. UK: British Energy Group. March 2006. Available at <http://www.british -energy.com/ 22 documents/carbon_footprint.pdf> (accessed 21 May 2012 ). 23 Andseta S, Thompson MJ, Jarrell JP, Pendergast DR. 1998. CANDU Reactors and Greenhouse 24 Gas Emissions. Proceedings of the 19 th Annual Conference, Canadian Nuclear Society
- 25 1998 October 18
-21; Toronto, Ontario. Available at <http://www.computare.org/Support% 26 20documents/Publications/Life%20Cycle.htm> (accessed 21 May 2012). 27 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 28 Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating 29 License Renewal St age. ADAMS Accession No. ML11179A104. 30 Dones R. 2007. Critical Note on the Estimation by Storm Van Leeuwen JW and Smith P of the 31 Energy Uses and Corresponding CO 2 Emissions for the Complete Nuclear Energy Chain. 32 Villigen, Switzerland: Paul Sherer Institute. April 2007. Available at 33 <http://gabe.web.psi.ch/pdfs/Critical%20note%20GHG%20PSI.pdf> (accessed 21 May 2012 ). 34 Fritsche UR. 2006. Comparison of Greenhouse -Gas Emissions and Abatement Cost of Nuclear 35 and Alternative Energy Options from a Life -Cycle Perspective. Freiburg, Germany: Oko -Institut. 36 January 2006. Available at <http://www.oeko.de/oekodoc/315/2006 -017-en.pdf> (accessed 37 21 May 2012). 38 Fthenakis VM, Kim HC. 2007. Greenhouse -gas emissions from solar -electric and nuclear 39 power: A life cycle study. Energy Policy 35(4):2549 -2557. 40 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-11 [IAEA] International Atomic Energy Agency. 2000. Nuclear Power for Greenhouse Gas 1 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM). Vienna, 2 Austria: IAEA. November 2000. Available at <http://www.iaea.org/Publications/Booklets/ 3 GreenhouseGas/greenhousegas.pdf> (accessed 22 May 2012 ). 4 Mortimer N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal Dec 89/Jan90. 5 Available at <http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php> (accessed 6 22 May 2012). 7 [NEA and OECD] Nuclear Energy Agency and the Organization for Economic Co -operation and 8 Development. 2002. Nuclear Energy and the Kyoto Protocol. Paris, France: OECD. Available at 9 <http://www.nea.fr/ndd/reports/2002/nea3808 -kyoto.pdf> (accessed 22 May 2012 ). 10 [NRC] U.S. Nuclear Regulatory Commission. Code Manual for MACCS2: Volume 1, User's 11 Guide. Washington, DC. NRC. NUREG/CR -6613. May 1998. Agencywide Documents Access 12 and Management System (ADAMS) Accession No. ML063550020. 13 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 14 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 15 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 16 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 17 No. ML04069720. 18 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Commission, Memorandum and Order 19 CLI-12-16." August 7, 2012. ADAMS Accession No. ML12220A094. 20 [NRC] U.S. Nuclear Regulatory Commission. 2012b. "SRM-COMSECY-12-0016-Approach for 21 Addressing Policy Issues Resulting from Court Decision To Vacate Waste Confidence Decision 22 and Rule." September 6, 2012. ADAMS Accession No. ML12250A032. 23 [POST] Parliamentary Office of Science and Technology. 2006. Carbon footprint of electricity 24 generation. Postnote 268. October 2006. Available at <http://www.parliament.uk/ 25 documents/post/postpn268.pdf> (accessed 22 May 2012 ). 26 Schneider M. 2000. Climate Change and Nuclear Power. Gland, Switzerland: WWF -World 27 Wildlife Fund for Nature. April 2000. Available at <http://assets.panda.org/downloads/ 28 fullnuclearreprotwwf.pdf> (accessed 22 May 2012 ). 29 Sovacool, BK. 2008. "Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical 30 Survey." Energy Policy 36:2940-2953. 31 Spadaro JV, Langlois L, Hamilton B. 2000. "Greenhouse Gas Emissions of Electricity 32 Generation Chains: Assessing the Difference." Vienna, Austria: International Atomic Energy 33 Agency. 34 Storm van Leeuwen JW, Smith P. 2008. Nuclear Power -The Energy Balance. Chaam, 35 Netherlands: Ceedata Consultancy. February 2008. Available at <http://www.stormsmith.nl/> 36 (accessed 22 May 2012 ). 37 Weisser D. 2006. A guide to life -cycle greenhouse gas (GHG) emissions from electric supply 38 technologies. Energy 32(9): 1543 -1559. Available at 39 <http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre -40 print_versionDanielWeisser.pdf> (accessed 22 May 2012). 41
7-1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 1 Environmental impacts from the activities associated with the decommissioning of any reactor 2 before or at the end of an initial or renewed license are evaluated in Supplement 1 of 3 NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear 4 Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The 5 U.S. Nuclear Regulatory Commission (NRC) staff 's evaluation of the environmental impacts of 6 decommissioning -presented in NUREG -0586, Supplement 1-notes a range of impacts for 7 each environmental issue. 8 Additionally, the incremental environmental impacts associated with decommissioning activities 9 resulting from continued plant operation during the renewal term are discussed in 10 NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear 11 Plants (NRC 1996, 1999). The GEIS includes a determination of whether the analysis of the 12 environmental issue could be applied to all plants and whether additional mitigation measures 13 would be warranted. Issues were then assigned a Category 1 or a Category 2 designation. 14 Section 1.4 in Chapter 1 explains the criteria for Category 1 and Category 2 issues and defines 15 the impact designations of SMALL, MODERATE, and LARGE. The NRC staff analyzed 16 site-specific issues (Category
- 2) for Limerick Generating Station, Units 1 and 2 (LGS) and 17 assigned them a significance level of SMALL, MODERATE, or LARGE, or not applicable to LGS 18 because of site characteristics or plant features. There are no Category 2 issues related to 19 decommissioning.
20 7.1. Decommissioning 21 Table 7-1 lists the Category 1 issues in Table B -1 of Title 10 , Part 51 of the Code of Federal 22 Regulations (10 CFR Part 51), Subpart A, Appendix B that are applicable to LGS 23 decommissioning following the renewal term. 24 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 Decommissioning would occur either if LGS were shut down at the end of its current operating 26 license or at the end of the period of extended operation. There are no site -specific issues 27 related to decommissioning. 28 A brief description of the NRC staff's review and the GEIS conclusions, as codified in Table B-1 29 of 10 CFR Part 51, for each of the issues follows: 30 Radiation doses. Based on information in the GEIS, the NRC noted that "[d]oses to the public 31 will be well below applicable regulatory standards regardless of which decommissioning method 32 Environmental Impacts of Decommissioning 7-2 is used. Occupational doses would increase no more than 1 person-rem (1 person-millisievert) 1 caused by buildup of long -lived radionuclides during the license renewal term." 2 Waste management . Based on information in the GEIS, the NRC noted that 3 "[d]ecommissioning at the end of a 20 -year license renewal period would generate no more 4 solid wastes than at the end of the current license term. No increase in the quantities of 5 Class C or greater than Class C wastes would be expected." 6 Air quality . Based on information in the GEIS, the NRC noted that "[a]ir quality impacts of 7 decommissioning are expected to be negligible either at the end of the current operating term or 8 at the end of the license renewal term." 9 Water quality . Based on information in the GEIS, the NRC noted that "[t]he potential for 10 significant water quality impacts from erosion or spills is no greater whether decommissioning 11 occurs after a 20 -year license renewal period or after the original 40-year operation period, and 12 measures are readily available to avoid such impacts." 13 Ecological resources . Based on information in the GEIS, the NRC noted that 14 "[d]ecommissioning after either the initial operating period or after a 20 -year license renewal 15 period is not expected to have any direct ecological impacts." 16 Socioeconomic Impacts . Based on information in the GEIS, the NRC noted that 17 "[d]ecommissioning would have some short -term socioeconomic impacts. The impacts would 18 not be increased by delaying decommissioning until the end of a 20 -year relicense period, but 19 they might be decreased by population and economic growth." 20 Exelon Generation Company, LLC (Exelon) stated in its environmental report (ER) 21 (Exelon 2011) that it is not aware of any new and significant information on the environmental 22 impacts of LGS license renewal. The NRC staff has not found any new and significant 23 information during its independent review of Exelon's ER, the site visit, the scoping process, or 24 its evaluation of other available information. Therefore, the NRC staff concludes that there are 25 no impacts related to these issues, beyond those discussed in the GEIS. For all of these 26 issues, the NRC staff concluded in the GEIS that the impacts are SMALL, and additional 27 plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted. 28 7.2. References 29 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 30 Protection Regulations for Domestic Licensing and Related Regulatory Functions." 31 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 32 Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating 33 License Renewal Stage. ADAMS Accession No. ML11179A104. 34 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 35 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996. 36 Agencywide Documents Access and Management System (ADAMS) Accession 37 Nos. ML040690705 and ML040690738. 38 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 39 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants. In: 40 Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, 41 DC: NRC. NUREG-1437, Volume 1, Addendum
- 1. August 1999. ADAMS Accession 42 No. ML04069720.
43 Environmental Impacts of Decommissioning 7-3 [NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact 1 Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of 2 Nuclear Power Reactors. Washington, DC: NRC. NUREG -0586, Supplement
- 1. 3 November 2002. ADAMS Accession Nos.
ML023470304 and ML023500295. 4
8-1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATI VES 1 The National Environmental Policy Act (NEPA) requires that Federal agencies consider 2 reasonable alternatives to the proposed action in an environmental impact statement (EIS). 3 In this case, the proposed action is the issuance of renewed licenses for the Limerick 4 Generating Station (LGS), which will allow the plant to operate for 20 years beyond its current 5 license expiration dates. 6 An operating license, however, is just one of a number of authorizations that an applicant must 7 obtain to operate a nuclear plant. Energy -planning decisionmakers and owners of the nuclear 8 power plant ultimately decide whether the plant will continue to operate, and economic and 9 environmental considerations play important roles in this decision. In general, the U.S. Nuclear 10 Regulatory Commission's (NRC's) responsibility is to ensure the safe operation of nuclear 11 power facilities and not to formulate energy policy or encourage or discourage the development 12 of alternative power generation. 13 The license renewal review process is designed to ensure safe operation of the nuclear power 14 plant during the license renewal term. Under the NRC's environmental protection regulations in 15 Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51), which implement 16 Section 102(2) of NEPA, renewal of a nuclear power plant operating license also requires the 17 preparation of an EIS. 18 To support the preparation of these EISs, the NRC prepared the Generic Environmental Impact 19 Statement for License Renewal of Nuclear Plants (GEIS), NUREG -1437, in 1996. The license 20 renewal GEIS was prepared to assess the environmental impacts of continued nuclear power 21 plant operations during the license renewal term. The intent was to determine which 22 environmental impacts would result in essentially the same impact at all nuclear power plants 23 and which ones could result in different levels of impacts at different plants and would require a 24 plant-specific analysis to determine the impacts. For those issues that could not be generically 25 addressed, the NRC develops a plant -specific supplemental environmental impact statemen t 26 (SEIS) to the GEIS. 27 NRC regulations in 10 CFR 51.71(d) implementing NEPA for license renewal require that a 28 SEIS must do the following
- 29 -include a preliminary analysis that consider s and weighs the environmental 30 effects of the proposed action [license renewal]; the environmental impacts of 31 alternatives to the proposed action; and alternatives available for reducing or 32 avoiding adverse environmental effects.
33 While the 1996 GEIS reached generic conclusions on many environmental issues associated 34 with license renewal, it did not determine which alternatives are reasonable and did not reach 35 conclusions about site -specific environmental impact levels. As such, the NRC must evaluate 36 the environmental impacts of alternatives on a site -specific basis. 37 Environmental Impacts of Alternatives 8-2 As stated in Chapter 1 of this document, alternatives to renewing the LGS operating licenses 1 must meet the purpose and need for the proposed action; they must do the following: 2 -provide an option that allows for power generation capability beyond the term of a 3 current nuclear power plant operating license to meet other future system generating 4 needs, as such needs may be determined by State, utility, and where authorized, 5 Federal (other than NRC) decision makers. (NRC 1996) 6 The NRC ultimately makes no decision about which alternative (or the proposed action) to carry 7 out because that decision falls to utility, state, or other Federal officials. Comparing the 8 environmental effects of these alternatives, however, will help the NRC decide whether the 9 adverse environmental impacts of license renewal are so great as to deny the option of license 10 renewal for energy -planning decisionmakers 11 (10 CFR 51.95(c)(4)). If the NRC acts to issue 12 a renewed license, then all of the alternatives 13 considered in this SEIS, including the 14 proposed action, will be available to 15 energy-planning decisionmakers. If the NRC 16 decides not to renew the license (or takes no 17 action at all), then energy -planning 18 decisionmakers may no longer elect to 19 continue operating LGS and will have to resort 20 to another alternative (or combination of 21 alternatives) -which may or may not be one of 22 the alternatives considered in this section -to 23 meet the energy needs that LGS now satisfies. 24 In evaluating alternatives to license renewal, 25 the NRC considered energy technologies or 26 options currently in commercial operation, as 27 well as some technologies not currently in 28 commercial operation but likely to be 29 commercially available by the time the current 30 LGS operating licenses expire. The current 31 operating licenses for LGS reactors will expire 32 on October 26, 2024, and June 22, 2029, and 33 reasonable alternatives must be available 34 (constructed, permitted, and connected to the 35 grid) by the time the current LGS licenses 36 expire to be considered likely to becom e 37 available. 38 Alternatives that cannot meet future system needs by providing amounts of baseload power 39 equivalent to LGS's current generating capacity and, in some cases, those alternatives whose 40 costs or benefits do not justify inclusion in the range of reasonable alternatives, were eliminated 41 from detailed study. The staff evaluated the environmental impacts of the remaining 42 alternatives and discusses them in depth in this chapter. Each alternative eliminated from 43 detailed study is briefly discussed, and a basis for its removal is provided at the end of this 44 section. In total, 18 alternatives to the proposed action were considered (see text box) and then 45 narrowed to the 5 alternatives considered in 46 Sections 8.1-8.5. 47 The 1996 GEIS presents an overview of some energy technologies but does not reach any 48 conclusions about which alternatives are most appropriate. Since 1996, many energy 49 Alternatives Evaluated In -Depth: natural-gas-fired combined -cycle (NGCC) supercritical pulverized coal (SCPC) new nuclear wind power purchased power Other Alternatives Considered: 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, oil-fired power, fuel cells, demand-side management (DSM), and delayed retirement.
Environmental Impacts of Alternatives 8-3 technologies have evolved significantly in capability and cost while regulatory structures have 1 changed to either promote or impede development of particular alternatives. 2 As a result, the analyses may include updated information from the following sources: 3 Energy Information Administration (EIA), 4 other offices within the U.S. Department of Energy (DOE), 5 U.S. Environmental Protection Agency (EPA), 6 industry sources and publications, and 7 information submitted by Exelon Generation Company, LLC (Exelon) in its 8 environmental report (ER). 9 The evaluation of each alternative considers the environmental impacts across several impact 10 categories: air quality, groundwater use and quality, surface water use and quality, terrestrial 11 ecology, aquatic ecology, human health, land use, socioeconomics, transportation, aesthetics, 12 historic and archaeological resources, environmental justice, and waste management. 13 A three-level standard of significance -SMALL, MODERATE, or LARGE -is used to indicate 14 the intensity of environmental effects for each alternative undergoing in -depth evaluation. The 15 order of presentation is not meant to imply increasing or decreasing level of impact. Nor does it 16 imply that an energy -planning decisionmaker would be more likely to select any given 17 alternative. 18 In some cases, the NRC considers the environmental effects of locating a replacement power 19 alternative at the existing nuclear plant site. Selecting the existing plant site allows for the 20 maximum use of existing transmission and cooling system infrastructures and minimizes the 21 overall environmental impact. However, LGS does not have a sufficient amount of land 22 available for all the replacement power alternatives because LGS would continue to operate 23 while the replacement alternative is being built to prevent a gap in energy generation during the 24 period of construction, which would take several years. As a result, the NRC evaluated the 25 impacts of locating replacement power facilities at other existing power plant sites within the 26 PJM Interconnection (PJM) . Installing replacement power facilities at existing power plants and 27 connecting to existing transmission and cooling system infrastructure would reduce the overall 28 environmental impact. 29 To ensure that the alternatives analysis is consistent with state or regional energy policies, the 30 NRC reviewed energy -related statutes, regulations, and policies within the Commonwealth of 31 Pennsylvania and PJM, including, for example, state renewable portfolio standards (RPSs). As 32 a result, the staff considers several alternatives that include wind power or solar photovoltaic 33 power, as well as combinations that include them. 34 Exelon is wholly-owned by Exelon Corporation, which also owns companies that provide electric 35 transmission, power marketing, and energy delivery. Exelon Generation does not directly serve 36 any customers, but sells its output through existing markets, and in particular, through PJM. 37 The NRC considered the current generation capacity and electricity production within the 38 Commonwealth of Pennsylvania, as well as, where pertinent, the territory covered by PJM. 39 Pennsylvania is similar to the U.S. average in reliance on coal, natural gas, and nuclear power 40 as its primary electric generation fuels. Pennsylvania is slightly more reliant on coal, less reliant 41 on natural gas, and more reliant on nuclear power than the U.S. average. Pennsylvania 42 diverged most from national averages in renewable generation. Pennsylvania hydropower and 43 other renewables provided 2.8 percent of electricity in the Commonwealth compared to 44 10.4 percent nationwide (EIA 2012). 45 Environmental Impacts of Alternatives 8-4 Pennsylvania is one of the nation's top generators of electricity and a net exporter of power. 1 While the staff generally considers alternatives located within Pennsylvania, it acknowledges 2 that alternatives could also be located elsewhere in PJM. 3 The Commonwealth of Pennsylvania has established an alternative energy portfolio standard 4 (AEPS, similar to a renewable portfolio standard) that requires electricity providers to obtain a 5 minimum percentage of their power through renewable energy resources, energy efficiency 6 measures, or one of several nonconventional coal -fired or natural-gas-fired alternatives, 7 including waste coal, coal -mine methane, coal gasification, and combined -heat-and-power 8 generation. The AEPS also includes a solar -power set-aside. Pennsylvania first adopted the 9 AEPS requirement in 2004. It currently requires 18 percent of all electricity sold in the 10 Commonwealth to come from qualifying sources by 2020 -2021. The standard allows 11 renewable energy credit trading within PJM (DSIRE 2011). Other states in PJM also have 12 similar policies, which typically take the form of binding standards. Some, however, have 13 implemented non -binding goals, as Virginia has done. 14 Sections 8.1-8.7 describe the environmental impacts of alternatives to license renewal. These 15 include a natural gas combined -cycle (NGCC) in Section 8.1; a supercritical pulverized coal 16 (SCPC) alternative in Section 8.2; a new nuclear alternative in Section 8.3; and a wind-power 17 alternative in Section 8.4. A summary of these alternatives considered in depth is provided in 18 Table 8-1. In Section 8.5, the staff discusses purchased power as an alternative, and in 19 Section 8.6, the staff addresses alternatives considered but dismissed. Finally, the 20 environmental effects that may occur if NRC takes no action and does not issue renewed 21 licenses for LGS are described in Section 8.7. Section 8.8 summarizes the impacts of each of 22 the alternatives considered. 23 Environmental Impacts of Alternatives 8-5 Table 8-1. Summary of Alternatives Considered In Depth 1 Natural Gas (NGCC) Alternative Supercritical Pulverized Coal (SCPC) Alternative New Nuclear Alternati ve 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 powe r 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 plant site (other than LGS) in PJM. Some infrastructure upgrades may be required. Spread across multiple sites throughout PJM. 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 natural-draft cooling towers. Consumptive water use would be similar to LGS. N/A 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 t o 5,400 ha), would be directly affected by the wind turbines (Exelon 2011, NREL 2009) Work Force 800 during construction; 45 during operations (Exelon 2011) 2,500 during construction; 141 during operations (Exelon 2011) 3,650 during construction; 820 during operations (Exelon 2011) 200 during construction;
50 during operations (Exelon 2011) 8.1 Natural Gas Combined -Cycle Alternative 2 Natural gas combined -cycle (NGCC) systems represent the large majority of the total number of 3 plants currently under construction or planned in the United States. Factors that contribute to 4 the popularity of NGCC facilities include high capacity factors, low relative construction costs, 5 Environmental Impacts of Alternatives 8-6 low gas prices, and relatively low air emissions. Development of new NGCC plants may be 1 affected by uncertainties about the continued availability and price of natural gas (though less 2 so than in the recent past) and future regulations that may limit greenhouse gas (GHG) 3 emissions. A gas -fired power plant, however, produces markedly fewer GHGs per unit of 4 electrical output than a coal -fired plant of the same electrical output. 5 Combined-cycle power plants differ significantly from most coal fired and all existing nuclear 6 power plants. Combined -cycle plants derive the majority of their electrical output from a gas 7 turbine and then generate additional power -without burning any additional fuel -through a 8 second, steam turbine cycle. The exhaust gas from the gas turbine is still hot enough to boil 9 water to steam. Ducts carry the hot exhaust to a heat recovery steam generator, which 10 produces steam to drive a steam turbine and produce additional electrical power. The 11 combined-cycle approach is significantly more efficient than any one cycle on its own; thermal 12 efficiency can exceed 60 percent versus 38 percent for conventional single -cycle facilities 13 (NETL 2007, Siemens 2007). In addition, because the natural gas-fired alternative derives 14 much of its power from a gas -turbine cycle, and because it wastes less heat than the existing 15 LGS unit, it requires significantly less cooling water. 16 While nuclear reactors, on average, operate with capacity factors above 90 percent 17 (LGS Units 1 and 2 operated at 97 percent and 96 percent capacity factors, respectively, 18 from 2003 to 2010 [NRC 2011]), the staff expects that an NGCC alternative would operate with 19 roughly an 85 percent capacity factor. Nonetheless, the staff assumes that a similar -sized 20 NGCC facility would be capable of providing adequate replacement power for the purposes of 21 this NEPA analysis. 22 Typical power trains for large -scale NGCC power generation would involve one, two, or three 23 combined-cycle units, available in a variety of standard sizes, mated to a heat -recovery steam 24 generator. To complete the assessment of an NGCC alternative, the NRC presumes that 25 appropriately sized units could be assembled to annually produce electrical power in amounts 26 equivalent to LGS. For purposes of this review, the staff evaluated an alternative that consists 27 of four General Electric (GE) Advanced F Class units, 530 MW(e) each, equipped with 28 dry-low-nitrogen-oxide combustors to suppress nitrogen oxide formation and selective catalytic 29 reduction (SCR) of the exhaust with ammonia for post -combustion control of nitrogen oxide 30 emissions. This alternative provides 2,120 MW(e) of capacity, and thus slightly underestimates 31 the potential environmental impacts of replacing the full 2,340 MW(e) produced by LGS. 32 While siting an alternative on the LGS site would allow for the fullest use of existing ancillary 33 infrastructure, such as transmission and support buildings, and minimizes the use of 34 undisturbed land, space constraints on the LGS site preclude that option. In its ER, Exelon 35 proposed that the NGCC alternative could be constructed at another existing power plant site 36 elsewhere in Pennsylvania or PJM, which would mitigate construction impacts in a similar way 37 to building the alternative at the LGS site (Exelon 2011). The staff finds this to be a reasonable 38 approach and adopts it for purposes of this analysis. It is possible that an NGCC alternative 39 constructed at an existing power plant site would require some infrastructure upgrades, such as 40 improved transmission lines or modifications to existing intake or cooling systems, but the staff 41 expects that these impacts would be smaller than those necessary to support an NGCC 42 alternative constructed on an undeveloped site. 43 Wherever the NGCC alternative is constructed, it is likely to require a new or upgraded pipeline 44 to supply natural gas to the facility. Some of the natural gas supplied to this alternative is likely 45 to come from Pennsylvania or neighboring states, but the NGCC alternative is unlikely to 46 directly trigger new natural gas development in Pennsylvania or the region. 47 Environmental Impacts of Alternatives 8-7 NGCC power plants are feasible, commercially available options for providing electric 1 generating capacity beyond the current LGS license expiration dates. Environmental impacts 2 from the NGCC alternative are summarized in Table 8-2 and discussed in depth in 3 Sections 8.1.1-8.1.9. 4 8.1.1. Air Quality 5 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 6 Pennsylvania, which is part of the Metropolitan Philadelphia Int erstate Air Quality Control 7 Region (AQCR, 40 CFR 81.15). With regard to the National Ambient Air Quality Standards 8 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 9 attainment for carbon monoxide (CO), lead, sulfur dioxide (SO 2), and PM 10 (particulate matter 10 10 microns or less in diameter) and nonattainment for ozone and PM2.5 (particulate 11 matter 2.5 microns or less in diameter) (40 CFR 81.339). 12 A new NGCC generating plant would qualify as a new major -emitting industrial facility and 13 would be subject to Prevention of Significant Deterioration (PSD) under requirements of the 14 Clean Air Act (CAA) (EPA 2012a). The Pennsylvania Department of Environmental Protection 15 (PADEP) has adopted 25 Pa. Code Chapter 127, which implements the EPA's PSD review. 16 The NGCC plant would need to comply with the standards of performance for stationary 17 combustion turbines set forth in 40 CFR Part 60 Subpart KKKK. 18 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 19 including review of the new sources that may affect visibility in any Federal Class I area. If a n 20 NGCC alternative was located close to a mandatory Class I area, additional air pollution control 21 requirements would be required. As noted in Section 2.2.2.1, there are no mandatory Class I 22 Federal areas within 50 miles (80 km) of the LGS site. However, there are a total of 23 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: 24 Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 25 A new NGCC plant would have to comply with Title IV of the CAA (42 USC §7651) reduction 26 requirements for sulfur dioxides (SO
- 2) and nitrogen oxides (NO x), which are the main precursors 27 of acid rain and the major causes of reduced visibility. Title IV establishes maximum SO 2 and 28 NO x emission rates from the existing plants and a system of SO 2 emission allowances that can 29 be used, sold, or saved for future use by the new plants.
30 More recently, EPA has promulgated additional rules and requirements that apply to certain 31 fossil-fuel-based power plants, such as NGCC generation. The Cross -State Air Pollution Rule 32 (CSAPR) and the Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) 33 Tailoring Rule impose several additional standards to limit ozone, particulate, and GHG 34 emissions from fossil -fuel based power plants (EPA 2012c). A new NGCC plant would be 35 subject to these additional rules and regulations. 36 The EPA has developed standard emission factors that relate the quantity of released air 37 pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the 38 staff projects the following air emissions for the NGCC alternative: 39 sulfur oxides (SO x) - 167 tons (151 MT) per year, 40 nitrogen oxides (NO x) - 485 tons (440 MT) per year, 41 carbon monoxide (CO) - 735 tons (667 MT) per year, 42 PM 10 and PM2.5- 323 tons (293 MT) per year, and 43 carbon dioxide (CO
- 2) - 5,390,097 tons (4,889,896 MT) per year 44 Environmental Impacts of Alternatives 8-8 Activities associated with the construction of the new NGCC plant on or off the LGS site would 1 cause some additional, temporary air effects as a result of equipment emissions and fugitive 2 dust from operation of the earth
-moving and material -handling equipment. Emissions from 3 workers' vehicles and motorized construction equipment exhaust would be temporary. The 4 construction crews would use dust -control practices to control and reduce fugitive dust. The 5 staff concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of 6 the earth-moving and material -handling equipment would be SMALL. 7 Greenhouse Gas Emissions 8 Combustion of fossil fuels, including natural gas, is the greatest anthropogenic source of GHG 9 emissions in the United States. Greenhouse gas emissions during construction of an NGCC 10 alternative would result primarily from the consumption of fossil fuels in the engines of 11 construction vehicles and equipment, workforce vehicles used in commuting to and from the 12 work site, and delivery vehicles. Analogous impacts would occur in association with offsite 13 pipeline construction. All such impacts, however, would be temporary. 14 Although natural gas combustion in the combustion turbines (CTs) would be the primary source 15 of GHGs during operations, other miscellaneous ancillary sources such as truck and rail 16 deliveries of materials to the site and commuting of the workforce would make minor 17 contributions. 18 The National Energy Technology Laboratory (NETL) estimates that carbon capture and storage 19 (CCS) will capture and remove as much as 90 percent of the CO 2 from the exhausts of CTs, but 20 it will result in a power production capacity decrease of approximately 14 percent, a reduction in 21 net overall thermal efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a 22 potential increase in the levelized cost of electricity produced in NGCC units so equipped by as 23 much as 30 percent (NETL 2007). Further, permanent sequestering of the CO 2 would involve 24 removing impurities (including water) and pressurizing it to meet pipeline specifications and 25 transferring the gas by pipeline to acceptable geologic formations. Even when opportunities 26 exist to use the CO 2 for enhanced oil recovery (rather than simply dispose of the CO 2 in 27 geologic formations), permanent disposal costs could be substantial, especially if the NGCC 28 units are far removed from acceptable geologic formations. With CCS in place, the NGCC 29 alternative would release 539,000 tons per year (489,000 MT) of CO 2. Without CCS in place, 30 the staff's projected CO2 emissions for the NGCC alternative would be 5,390,097 tons 31 (4,889,896 MT) per year. 32 Given the expected relatively small workforce, relatively short construction period for both the 33 NGCC facility and the pipeline, and CO2 emissions of operation for the NGCC alternative, the 34 overall impact from the releases of GHGs of a natural gas -fired alternative would be SMALL to 35 MODERATE. 36 Conclusion 37 Based on the above review, the overall air quality impacts of a new NGCC plant located at the 38 LGS site are SMALL to MODERATE and based largely on operational impacts. 39 8.1.2. Groundwater Resources 40 Construction activities associated with the NGCC alternative could require groundwater 41 dewatering of foundation excavations. This activity might require the use of cofferdams, sumps, 42 wells, or other methods to address high water -table conditions. However, because of the 43 relatively shallower depth of excavation for the NGCC plant as compared to other alternatives, 44 any impacts would be expected to be minor at most sites; however, dewatering needs could be 45 greater at some sites. Facility construction would increase the amount of imper vious surface at 46 Environmental Impacts of Alternatives 8-9 the site location as well as alter the subsurface strata because of excavation work and the 1 placement of backfill following facility completion. While an increase in impervious surface 2 would reduce infiltration and reduce groundwater recharge, the effects on water-table elevations 3 at most sites would likely be very small. Below -grade portions of the new NGCC plant could 4 also alter the direction of groundwater flow beneath a site. Such effects would likely be very 5 localized at most site locations and would not be expected to affect offsite wells. Application of 6 best management practices (BMPs) in accordance with a state -issued NPDES general permit, 7 including appropriate waste management, water discharge, and spill prevention practices, would 8 prevent or minimize any groundwater quality impacts during construction. 9 For the construction period, the NRC has conservatively assumed that groundwater would be 10 used. However, it is more likely that water would be supplied via a temporary utility connection, 11 if available, or trucked to the point of use from offsite sources. Regardless, groundwater use for 12 construction of a new NGCC plant would be substantially less than the volume required for the 13 coal-fired or nuclear alternatives because of the smaller footprint involved for excavation, 14 earthwork, and structural work. This would encompass such uses as potable and sanitary uses, 15 concrete production, dust suppression, and soil compaction. The workforce at the NGCC would 16 be slightly smaller than the existing LGS workforce, which uses substantially less than 100 gpm 17 (380 L/min) for both potable water supply and fire suppression uses. The GEIS has found that 18 pumping rates of less than 100 gpm (380 L/min) have not been shown to adversely affect 19 groundwater availability (NRC 1996). 20 For NGCC plant operations, the NRC assumed that the NGCC alternative would entail the same 21 relative ratio of groundwater use to surface water use as that used at LGS Units 1 and 2. This 22 includes the use of groundwater for service water makeup and potable and sanitary uses. 23 Consequently, the staff expects that total groundwater usage and associated aquifer effects 24 would be much less under this alternative than those under current LGS operations because of 25 the smaller number of auxiliary systems requiring groundwater and the much smaller 26 operational workforce under the NGCC alternative. Based on this assessment, the impacts on 27 groundwater use and quality under the NGCC alternative would be SMALL. 28 8.1.3. Surface Water Resources 29 Construction activities associated with the NGCC alternative would be similar to construction 30 activities for most large industrial facilities. A new NGCC plant would occupy a much smaller 31 footprint (about 35 ac [14 ha]) than the current LGS or the proposed coal -fired or new nuclear 32 alternatives. This would also result in less extensive excavation and earthwork than under 33 either of the other conventional replacement power facility alternatives. The staff assumes that 34 no surface water would be used during construction for the NGCC alternative because the staff 35 assumed groundwater would be used or water would be supplied by a water utility or trucked in, 36 as explained above in Section 8.1.2. 37 Some temporary impacts to surface water quality may result from increased sediment loading 38 and from any pollutants in stormwater runoff from disturbed areas and from dredging activities. 39 During facility construction, runoff from disturbed areas in the plant footprint would be controlled 40 under a state -issued NPDES general permit that would require implementation of a stormwater 41 pollution prevention plan and associated BMPs to prevent or significantly mitigate soil erosion 42 and contamination of stormwater runoff. Depending on the path of the gas pipeline to supply 43 the NGCC plant, some creeks and streams would likely be crossed. However, because of the 44 short-term nature of the dredging activities, the hydrologic alterations and sedimentation would 45 be localized and temporary. In addition, modern pipeline construction techniques, such as 46 horizontal directional drilling, would further minimize the potential for water quality impacts in the 47 Environmental Impacts of Alternatives 8-10 affected streams. Dredging would be conducted under a permit from the U.S. Army Corps of 1 Engineers (COE) requiring the implementation of BMPs to minimize impacts. 2 For facility operations, the NGCC alternative would require much less cooling water than LGS 3 Units 1 and 2, and consumptive water use would be much less. Assuming a typical ratio of 4 2 to 1 for electrical generation from gas turbine (Brayton cycle) to electrical generation from 5 steam turbine (Rankine cycle) for a combined -cycle plant, the staff estimated that the 6 consumptive water loss for an equivalent -sized combined -cycle plant would be about one -third 7 the LGS water use. For the purposes of comparison, and as described in Section 2.2.4.1, the 8 mean annual flow and 90 percent exceedance flows of the Schuylkill River are 1,935 cfs 9 (54.8 m 3/s) and 482 cfs (13.6 m 3/s), respectively. At the mean annual flow and the 90 percent 10 exceedance flow, the projected rate of consumptive water use for the NGCC plant (i.e., 22 cfs 11 [0.62 m 3/s]) represents a 1 percent and a 4 percent reduction in the streamflow in the Schuylkill 12 River downstream of the NGCC alternative location, if sited at or near the LGS site. This 13 reduced demand for water would substantially reduce the need for low -flow augmentation from 14 either the Delaware River or the Wadesville Mine Pool. Effects may vary at other sites, but the 15 net consumption of water would be less than that associated with existing LGS operations. 16 The NRC assumed that water treatment additives for the NGCC alternative would be essentially 17 identical to LGS because similar additives are required for water conditioning to operate NGCC 18 and nuclear plants. The NRC also assumed that the proposed site's existing intake and 19 discharge infrastructure would be used, as described above. While the quality would be 20 chemically similar, the discharge volume would be about one -third less than current LGS 21 operations. Surface water withdrawals would be subject to applicable water allocation 22 requirements in Pennsylvania and other states, and effluent discharges and stormwater 23 discharges associated with industrial activity would be subject to a state -issued NPDES permit 24 under this alternative. The NRC also assumes that facility operations would be subject to and 25 would be conducted in accordance with a spill prevention, control, and countermeasures 26 (SPCC) plan, stormwater pollution prevention plan, or equivalent plans and associated BMPs 27 and procedures to prevent and respond to accidental releases of non-nuclear fuels, chemicals, 28 and other materials to soil, surface water, and groundwater. 29 Therefore, based on the above assessment, the impacts on surface water use and quality under 30 the NGCC alternative would be SMALL. 31 8.1.4. Aquatic Resources 32 Construction activities for the NGCC alternative (such as construction of heavy -haul roads, a 33 new pipeline, and the power block) could affect drainage areas or other onsite aquatic features. 34 Minimal impacts on aquatic ecology resources are expected because the plant operator would 35 likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, 36 which would be required to comply with Pennsylvania NPDES permitting, would minimize the 37 flow of disturbed soils into aquatic features. Depending on the available infrastructure at the 38 selected site, the NGCC alternative may require modification or expansion of the existing intake 39 or discharge structures. Because of the relatively low withdrawal rates compared to the SCPC 40 or new nuclear alternatives, it is unlikely that the operators would need to construct new intake 41 and discharge structures for the NGCC alternative at an existing power plant site. Dredging 42 activities that result from infrastructure construction would require BMPs for in -water work to 43 minimize sedimentation and erosion. Because of the short -term nature of the dredging 44 activities, the hydrological alterations to aquatic habitats likely would be localized and 45 temporary. 46 Environmental Impacts of Alternatives 8-11 During operations, the NGCC alternative would require approximately one -third less cooling 1 water to be withdrawn from the Schuylkill River, or other similar water body, than required for 2 LGS Units 1 and 2. Because of the lower withdrawal rates, the number of fish and other aquatic 3 resources affected by cooling -water intake and discharge operations, such as entrainment, 4 impingement, and thermal stress, would be less for an NGCC alternative than for those 5 associated with license renewal. The cooling system for a new NGCC plant would have similar 6 chemical discharges as LGS, but the air emissions from the NGCC plant would emit particulates 7 that could settle onto the river surface and introduce a new source of pollutants as described in 8 Section 8.1.1. However, the flow of the Schuylkill River (or other water source) would likely 9 dissipate and dilute the concentration of pollutants, resulting in minimal exposure to aquatic 10 biota. 11 The impacts on aquatic ecology would be minor because construction activities would require 12 BMPs and stormwater management permits, and because surface water withdrawal and 13 discharge for this alternative would be less than for LGS Units 1 and 2. Deposition of pollutants 14 into aquatic habitats from the plant's air emissions would be minimal because the concentration 15 of pollutants would be diluted with the river flow. Therefore, the staff concluded that impacts on 16 aquatic ecology would be SMALL. 17 Consultation with National Marine Fisheries Service (NMFS), and the U.S. Fish and Wildlife 18 Service (FWS) under the Endangered Species Act (ESA) would ensure that the construction 19 and operation of an NGCC plant would not adversely affect any Federally listed species or 20 adversely modify or destroy designated critical habitat. Consultation with NMFS under the 21 Magnuson-Stevens Act would require the NRC to evaluate impacts to essential fish habitat 22 (EFH). NMFS would provide conservation recommendations if there would be adverse impacts 23 to EFH. Coordination with state natural resource agencies would further ensure that the plant 24 operator would take appropriate steps to avoid or mitigate impacts to state -listed species, 25 habitats of conservation concern, and other protected species and habitats. Consequently, the 26 impacts of construction and operation of an NGCC plant on protected species and habitats 27 would be SMALL. 28 8.1.5. Terrestrial Resources 29 Construction of an NGCC plant would occur at the site of an existing power station other than 30 LGS and would require about 35 ac (14 ha) of land for the plant itself and about 7,630 ac 31 (3,090 ha) of additional land off site for wells, collection stations, and pipelines to bring the gas 32 to the plant (see Section 8.1.7). Because the onsite land requirement is relatively small, Exelon 33 would likely be able to site most of the construction footprint in previously disturbed, degraded 34 habitat, which would minimize impacts to terrestrial habitats and species. Offsite construction 35 would occur mostly on land where gas extraction is occurring already. To the extent 36 practicable, Exelon would route gas pipelines along existing, previously disturbed utility 37 corridors (Exelon 2011). Erosion and sedimentation, fugitive dust, and construction debris 38 impacts would be minor with implementation of appropriate BMPs (Exelon 2011). Impacts to 39 terrestrial habitats and species from transmission line operation and corridor vegetation 40 maintenance, and operation of the mechanical draft cooling towers would be similar in 41 magnitude and intensity as those resulting from operating nuclear reactors and would, therefore, 42 be SMALL (NRC 1996). Overall, the impacts of construction and operation of an NGCC plant to 43 terrestrial habitats and species would be SMALL. 44 Consultation with FWS under the ESA would ensure that the construction and operation of an 45 NGCC plant would not adversely affect any Federally listed terrestrial species or adversely 46 modify or destroy designated critical habitat. Coordination with state natural resource agencies 47 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 48 Environmental Impacts of Alternatives 8-12 state-listed species, habitats of conservation concern, and other protected species and habitats. 1 Consequently, the impacts of construction and operation of an NGCC plant on protected 2 species and habitats would be SMALL. 3 8.1.6. Human Health 4 Impacts on human health from construction of the NGCC alternative would be similar to effects 5 associated with the construction of any major industrial facility. Compliance with worker 6 protection rules would control those impacts on workers at acceptable levels. Impacts from 7 construction on the general public would be minimal since crews would limit active construction 8 area access to authorized individuals. Impacts on human health from the construction of the 9 NGCC alternative would be SMALL. 10 Human health effects of gas -fired generation are generally low, although in Table 8-2 of the 11 GEIS (NRC 1996), the staff identified cancer and emphysema as potential health risks from 12 gas-fired plants. Nitrogen oxide emissions contribute to ozone formation, which in turn 13 contributes to human health risks. Emission controls for the NGCC alternative can be expected 14 to maintain NO x emissions well below air quality standards established for the purposes of 15 protecting human health, and emissions trading or offset requirements mean that overa ll NO x 16 releases in the region will not increase. Health risks for workers may also result from handling 17 spent catalysts used for NO x control that may contain heavy metals. Impacts on human health 18 from the operation of the NGCC alternative would be SMALL. 19 8.1.7. Land Use 20 The GEIS generically evaluates the impacts of constructing and operating various replacement 21 power plant alternatives on land use, both on and off each power plant site. The analysis of 22 land use impacts focuses on the amount of land area that would be affected by the construction 23 and operation of a four-unit NGCC plant at the LGS site. Locating the new NGCC power plant 24 near an existing power plant site would maximize the availability of support infrastructure and 25 reduce the need for additional l and. 26 Exelon estimated 35 ac (14 ha) for new unit construction (Exelon 2011). Based on GEIS 27 estimates, approximately 243 ac (98.3 ha) of land would be needed to support an NGCC 28 alternative to replace the LGS (NRC 1996). This amount of land use would include other plant 29 structures and associated infrastructure and is unlikely to exceed the 243 ac (98.3 ha) estimate, 30 excluding land for natural -gas wells and collection stations. Exelon's estimate appears 31 reasonable and is a more site -specific estimate than the GEIS estimate. Depending on the site 32 location and availability of existing natural gas pipelines, a 100 -feet (ft)-wide (30.5 -meter 33 [m]-wide) right -of-way would be needed for a new pipeline. Land -use impacts from NGCC 34 construction would be SMALL to MODERATE depending on location. 35 In addition to onsite land requirements, land would be required off site for natural -gas wells and 36 collection stations. Scaling from GEIS (NRC 1996) estimates, approximately 7,630 ac 37 (3,090 ha) would be required for wells, collection stations, and pipelines to bring the gas to the 38 plant. Most of this land requirement would occur on land where gas extraction already occurs. 39 Some natural gas could come from within Pennsylvania or nearby states. 40 The elimination of uranium fuel for LGS could partially offset some, but not all, of the land 41 requirements for the NGCC. Scaling from GEIS (NRC 1996) estimates, approximately 1,640 ac 42 (664 ha) would no longer be needed for mining and processing uranium during the operating life 43 of the plant. Operational land -use impacts from a NGCC power plant would be SMALL. 44 Environmental Impacts of Alternatives 8-13 8.1.8. Socioeconomics 1 Socioeconomic impacts are defined in terms of changes to the demographic and economic 2 characteristics and social conditions of a region. For example, the number of jobs created by 3 the construction and operation of a power plant could affect regional employment, income, and 4 expenditures. Two types of jobs would be created by this alternative: (1) construction jobs, 5 which are transient, short in duration, and less likely to have a long -term socioeconomic impact; 6 and (2) power plant operations jobs, which have the greater potential for permanent, long -term 7 socioeconomic impacts. Workforce requirements for the construction and operation of the 8 NGCC alternative were evaluated to measure their possible effects on current socioeconomic 9 conditions. 10 Scaling from GEIS estimates, the construction workforce would peak at 2,650 workers. Exelon 11 estimated 800 workers at the peak of construction (Exelon 2011). Exelon's estimate appears to 12 be reasonable and is consistent with trends toward lowering labor costs by reducing the size of 13 plant workforces. Therefore, Exelon's estimate of 800 workers is used throughout this analysis. 14 The relative economic impact of this many workers on the local economy and tax base would 15 vary, with the greatest impacts occurring in the communities where the majority of construction 16 workers would reside and spend their income. As a result, local communities could experience 17 a short-term economic "boom" from increased tax revenue and income generated by 18 construction expenditures and the increased demand for temporary (rental) housing and 19 business services. Some construction workers could relocate in order to be closer to the 20 construction work site. However, given the proximity of many existing power plants to 21 metropolitan areas, workers could commute to the construction site, thereby reducing the need 22 for rental housing. 23 After completing the installation of the four-unit NGCC plant, local communities could 24 experience a return to pre -construction economic conditions. Based on this information and 25 given the number of construction workers, socioeconomic impacts during construction in 26 communities near the new NGCC site could range from SMALL to MODERATE. 27 Scaling from GEIS estimates, the plant operations workforce would be 331 workers. Exelon 28 estimated a plant operations workforce of approximately 45 workers (Exelon 2011). Exelon's 29 estimate appears to be reasonable and is consistent with trends toward lowering labor costs by 30 reducing the size of plant operations workforces. Therefore, Exelon's estimate of 45 workers is 31 used throughout this analysis. The reduction in employment at LGS from operations to 32 decommissioning and shut down could affect property tax revenue and income in local 33 communities and businesses. In addition, the permanent housing market could also experience 34 increased vacancies and decreased prices if operations workers and their families move out of 35 the region. However, the amount of property taxes paid to local jurisdictions under the NGCC 36 alternative may increase if additional land is required to support this alternative. Based on the 37 above discussion, socioeconomic impacts during operations could range from SMALL to 38 MODERATE. 39 Environmental Impacts of Alternatives 8-14 8.1.9. Transportation 1 Transportation impacts associated with construction and operation of a four -unit, NGCC power 2 plant would consist of commuting workers and truck deliveries of construction materials to the 3 power plant site. During periods of peak construction activity, up to 800 workers could be 4 commuting daily to the site (Exelon 2011), as described in Section 8.1.8. Workers commuting 5 to the construction site would arrive by site access roads, and the volume of traffic on nearby 6 roads could increase substantially during shift changes. In addition to commuting workers, 7 trucks would be transporting construction materials and equipment to the worksite, thus 8 increasing the amount of traffic on local roads. The increase in vehicular traffic would peak 9 during shift changes, resulting in temporary levels of service impacts and delays at 10 intersections. Pipeline construction and modification to existing natural gas pipeline systems 11 could also have a temporary impact. Some power plant components and materials could also 12 be delivered by train or barge, depending on location. Train deliveries could cause additional 13 traffic delays at railroad crossings. Based on this information, traffic -related transportation 14 impacts during construction could range from SMALL to MODERATE. 15 Traffic-related transportation impacts would be greatly reduced after completing the installation 16 of the new NGCC units. Transportation impacts would include daily commuting by the operating 17 workforce, equipment and materials deliveries, and the removal of commercial waste material to 18 offsite disposal or recycling facilities by truck. The NGCC alternative is estimated to require an 19 operational workforce of 45 (Exelon 2011), as described in Section 8.1.8. Since fuel is 20 transported by pipeline, the transportation infrastructure would experience little to no increased 21 traffic from plant operations. Overall, transportation impacts would be SMALL during power 22 plant operations. 23 8.1.10. Aesthetics 24 The analysis of aesthetic impacts focuses on the degree of contrast between the NGCC 25 alternative and the surrounding landscape and the visibility of the new NGCC plant at an 26 existing power plant site. During construction, all of the clearing and excavation would occur on 27 the existing power plant site. These activities could be visible from offsite roads. Since the 28 existing power plant site would already appear industrial, construction of the NGCC power plant 29 would appear similar to other ongoing onsite activities. The power block of the NGCC 30 alternative could look similar to the existing power plant. 31 The four NGCC units could be approximately 100 ft (30 m) tall, with two exhaust stacks up to 32 150 ft (46 m) tall with two cooling towers over 500 ft (152 m) high (Exelon 2011). The facility 33 would be visible off site during daylight hours, and some structures may require aircraft warning 34 lights. The addition of mechanical draft cooling towers and associated condensate plumes 35 could add to the visual impact. Noise generated during NGCC power plant operations would be 36 limited to routine industrial processes and communications. Pipelines delivering natural gas fuel 37 could be audible offsite near gas compressor stations. 38 In general, given the industrial appearance of the existing power plant site, the new NGCC 39 power plant would blend in with the surroundings and the NGCC power plant could be similar in 40 appearance to the existing power plant. Aesthetic changes therefore would be limited to the 41 immediate vicinity of the existing power plant site, and any impacts would be SMALL depending 42 on its location and surroundings. 43 Environmental Impacts of Alternatives 8-15 8.1.11. Historic and Archaeological Resources 1 To consider effects on historic and archaeological resources, any areas potentially affected by 2 the construction of the NGCC alternative would need to be surveyed to identify and record 3 historic and archaeological resources. An inventory of a previously disturbed former plant 4 (brownfield) site may still be necessary if the site has not been previously surveyed or to verify 5 the level of disturbance and evaluate the potential for intact subsurface resources. Plant 6 operators would need to survey all areas associated with operation of the alternative 7 (e.g., a new pipeline, roads, transmission corridors, other ROWs). Any resources found in these 8 surveys would need to be evaluated for eligibility on the National Register of Historic Properties 9 (NRHP), and mitigation of adverse effects would need to be addressed if eligible resources 10 were encountered. Areas with the greatest sensitivity should be avoided. Visual impacts on 11 significant cultural resources-such as the viewsheds of historic properties near the site -also 12 should be assessed. 13 The potential for impacts on historic and archaeological resources from the NGCC alternative 14 would vary greatly depending on the location of the proposed site. Given that the preference is 15 to use a previously disturbed former plant site, avoidance of significant historic and 16 archaeological resources should be possible and effectively managed under current laws and 17 regulations. However, historic and archaeological resources could potentially be affected, 18 depending on the resource richness of the land required for a new pipeline. Therefore, the 19 impacts on historic and archaeological resources from the NGCC alternative would range from 20 SMALL to MODERATE. 21 8.1.12. Environmental Justice 22 The environmental justice impact analysis evaluates the potential for disproportionately high and 23 adverse human health, environmental, and socioeconomic effects on minority and low -income 24 populations that could result from the construction and operation of a new power plant. Minority 25 and low-income populations are subsets of the general public living near the proposed power 26 plant site. 27 Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 28 impacts on human health. Disproportionately high and adverse human health effects occur 29 when the risk or rate of exposure to an environmental hazard for a minority or low -income 30 population is significant and exceeds the risk or exposure rate for the general population or for 31 another appropriate comparison group. Disproportionately high environmental effects refer to 32 impacts or risk of impact on the natural or physical environment in a minority or low -income 33 community that are significant and appreciably exceed the environmental impact on the larger 34 community. Such effects may include biological, cultural, economic, or social impacts. For 35 example, increased demand for rental housing during replacement power plant construction 36 could disproportionately affect low -income populations that rely on the previously inexpensive 37 rental housing market. 38 Potential impacts to minority and low -income populations would mostly consist of environmental 39 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 40 housing impacts). Noise and dust impacts during construction would be short term and 41 primarily limited to onsite activities. Minority and low -income populations residing along site 42 access roads would be directly affected by increased commuter vehicle and truck traffic. 43 However, because of the temporary nature of construction, these effects are not likely to be high 44 and adverse and would be contained to a limited time period during certain hours of the day. 45 Increased demand for rental housing during construction could cause rental costs to rise 46 disproportionately affecting low -income populations living near the site who rely on inexpensive 47 Environmental Impacts of Alternatives 8-16 housing. However, given the proximity of some existing power plant sites to metropolitan areas, 1 workers could commute to the construction site, thereby reducing the need for rental housing. 2 Emissions from the operation of a NGCC plant could affect minority and low -income populations 3 as well as the general population living in the vicinity of the new power plant. However, all 4 would be exposed to the same potential effects from NGCC power plant operations, and any 5 impacts would depend on the magnitude of the change in ambient air quality conditions . 6 Permitted air emissions are expected to remain within regulatory standards. 7 Based on this information and the analysis of human health and environmental impacts 8 presented in this SEIS, the construction and operation of a new NGCC power plant would not 9 have disproportionately high and adverse human health and environmental effects on minority 10 and low-income populations. 11 8.1.13. Waste Management 12 During the construction stage of the NGCC generation alternative, land clearing and other 13 construction activities would generate waste that could be recycled, disposed of on site, or 14 shipped to an offsite waste disposal facility. Because the alternative would be constructed at 15 power plant sites with existing infrastructure, the amount of wastes produced during land 16 clearing would be reduced. 17 During the operational stage, spent selective catalytic reduction (SCR) catalysts, which are used 18 to control NO x emissions from natural 19 generated by this alternative (see Air Quality, Section 8.1.1) 20 According to the GEIS (NRC 1996), a natural gas-fired plant would generate minimal waste. 21 Waste impacts therefore would be SMALL for an NGCC alternative. 22 Table 8-2. Summary of Environmental Impacts of the NGCC Alternative Compared to 23 Continued Operation of the Existing LGS 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.
Environmental Impacts of Alternatives 8-17 8.2. Supercritical Pulverized Coal -Fired Alternative 1 In this section, the NRC evaluates the environmental impacts of a supercritical pulverized 2 coal-fired alternative to the continued operation of LGS. In the Commonwealth of Pennsylvania, 3 48 percent of electricity was generated using coal -fired power plants in 2010 (EIA 2012). 4 Throughout PJM, coal -fired units provided 47 percent of electricity in 2011 (Monitoring Analytics 5 2012). As noted by EIA in its Annual Energy Outlook (EIA 2011b), coal -fired generation 6 historically has been the largest source of electricity in the United States and is expected to 7 remain so through 2035. Baseload coal units have proven their reliability and can routinely 8 sustain capacity factors of 85 percent or greater. Among the various boiler designs available, 9 pulverized coal boilers producing supercritical steam (SCPC boilers) are the most likely variant 10 for a coal -fired alternative given their generally high thermal efficiencies and overall reliability. 11 While nuclear reactors, on average, operate with capacity factors above 90 percent, the new 12 SCPC coal-fired power plant would operate with roughly an 85 percent capacity factor. Despite 13 the slightly lower capacity factor, a SCPC plant would be capable of providing adequate 14 replacement power for a nuclear plant for the purposes of this NEPA analysis. 15 A myriad of sizes of pulverized coal boilers and steam turbine generators (STGs) are available; 16 however, the staff presumes that four equal -sized boiler/STG powertrains, operating 17 independently and simultaneously, would likely be used to match the power output of LGS. To 18 complete this analysis, the staff presumes that all powertrains would have the same features, 19 operate at generally the same conditions, have similar impacts on the environment, and be 20 equipped with the same pollution -control devices such that once all parasitic loads are 21 overcome, the net power available would be equal to 2,120 MWe. The staff assumes that 22 6 percent of an SCPC boiler's gross capacity is needed to supply typical parasitic loads (plant 23 operation plus control devices for criteria pollutants to meet New Source Performance 24 Standards). Introducing controls for GHG emissions (i.e., CCS) would cause the parasitic load 25 to increase to 27 percent of the boiler's gross rated capacity (NETL 2010). However, because 26 of uncertainty regarding future GHG regulations and the limited real -world experience in CCS at 27 utility-scale power plants, parasitic loads associated with CCS are not considered. Various 28 bituminous coal sources are available to coal -fired power plants in Pennsylvania. EIA reports 29 that, in 2008, Pennsylvania produced electricity from coal with heating values of 11,549 British 30 thermal units per pound (Btu/lb), sulfur content of 2.07 percent, and ash of 16.29 percent 31 (EIA 2010a). For the purpose of this evaluation, the NRC presumes that coal burned in 2008 32 will be representative of coal that would be burned in a coal -fired alternative regardless of where 33 it was located. Approximately 74 percent of the coal burned in Pennsylvania in 2008 came from 34 mines in Pennsylvania. West Virginia, Wyoming, and Ohio supplied most of the remaining coal 35 (EIA 2010a). Bituminous coals from Appalachian mines have CO 2 emission factors ranging 36 from 202.8 to 210.2 lb per million Btu of heat input (Hong and Slatick 1994). 37 Environmental Impacts of Alternatives 8-18 Exelon determined that the current LGS site 1 was not viable to accommodate a coal -fired 2 alternative with net generating capacity 3 sufficient to meet the power production of 4 LGS because of limited space on the LGS 5 site, as explained in Section 8.0 6 (Exelon 2011). The staff concurs with that 7 assessment and the analysis of the impacts 8 of the coal -fired alternative assumes that the 9 SCPC coal-fired power plant would be sited 10 at an existing power plant site to take 11 advantage of existing infrastructure. The sit e 12 could be located in Pennsylvania or 13 elsewhere in PJM. 14 It is reasonable to assume that a coal -fired 15 alternative would use supercritical steam 16 (see text box). Supercritical steam 17 technologies are increasingly common in 18 new coal-fired plants. They are 19 commercially available and feasible. 20 Supercritical plants operate at higher 21 temperatures and pressures than older 22 subcritical coal -fired plants and, therefore, 23 can attain higher thermal efficiencies. While 24 supercritical facilities are more expensive to 25 construct than subcritical facilities, they consume less fuel for a given output, reducing 26 environmental impacts throughout the fuel life cycle. The staff expects that a new, supercritical 27 coal-fired plant would operate at a heat rate of 8,844 Btu/kWh (EIA 2010b), or approximately 38 28 to 39 percent thermal efficiency. However, heat inputs could be less, depending on the coal 29 source and whether fuel blending is practiced in order to remain compliant with emission 30 limitations. 31 SCPC coal-fired power plants are currently commercially available and currently are feasible 32 alternatives to LGS license renewal. The overall environmental impacts of a coal -fired 33 alternative, as well as the environmental impacts of proposed LGS license renewal, are shown 34 in Table 8-3. Additional details of the impacts on individual resources of the coal -fired 35 alternative are provided in subsequent sections. 36 8.2.1. Air Quality 37 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 38 Pennsylvania, which is part of the Metropolitan Philadelphia Int erstate Air Quality Control 39 Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards 40 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 41 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM 10; and nonattainment 42 with respect to ozone and PM2.5 (40 CFR 81.339). 43 A new SCPC generating plant would qualify as a new major -emitting industrial facility and would 44 be subject to PSD under requirements of the CAA (EPA 2012a). The PADEP has adopted 45 25 Pa. Code Chapter 127, which implements the EPA's PSD review. The SCPC plant would 46 need to comply with the standards of performance for electric utility steam generating units set 47 forth in 40 CFR Part 60 Subpart Da. 48 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 State
- s.
Environmental Impacts of Alternatives 8-19 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 1 including the review of the new sources that may affect visibility in any Federal Class I area. 2 If an SCPC alternative was located close to a mandatory Cla ss I area, additional air pollution 3 control requirements would be required. As noted in Section 2.2.2.1, there are no mandatory 4 Class I Federal areas within 50 miles (80 km) of the LGS site. There are a total of 5 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: 6 Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 7 A new SCPC plant would have to comply with Title IV of the CAA (42 USC §7651) reduction 8 requirements for SO 2 and NO x, which are the main precursors of acid rain and the major cause 9 of reduced visibility. Title IV establishes maximum SO 2 and NO x emission rates from the 10 existing plants and a system of SO 2 emission allowances that can be used, sold, or saved for 11 future use by the new plants. 12 More recently, the EPA has promulgated additional rules and requirements for certain fossil -fuel 13 based power plants, such as coal. The Cross -State Air Pollution Rule (CSAPR), the Prevention 14 of Significant Deterioration and Title V Greenhouse Gas (GHG) Tailoring Rule, and the Mercury 15 and Air Toxics Standards (MATS) for Power Plants impose several additional standards to limit 16 ozone, particulate, mercury, and GHG emissions from fossil -fuel based power plants 17 (EPA 2012c). A new SCPC plant would be subject to these additional rules and regulations. 18 The EPA has developed standard emission factors that relate the quantity of released air 19 pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the 20 staff projects the following air emissions for the SCPC alternative: 21 sulfur oxides (SO x) - 14,876 tons (13,495 MT) per year, 22 nitrogen oxides (NO x) - 1,891 tons (1,716 MT) per year, 23 carbon monoxide (CO) - 1,891 tons (1,716 MT) per year, 24 PM 10 - 1,232 tons (1,118 MT) per yea r, 25 PM2.5 - 616 tons (559 MT) per year 26 carbon dioxide (CO
- 2) - up to 18,363,843 tons (16,659,678 MT) per year, and 27 mercury (Hg) - 0.31 tons (0.28 MT) per year.
28 The above emission estimates assume that the SCPC plant implements certain pollution control 29 devices, including wet calcium carbonate scrubbers for SO 2 control (operating at 95 percent 30 removal efficiency), low -NO x burners with overfire air and selective catalytic reduction for 31 nitrogen oxide controls capable of attaining a NO x removal of 86 percent, and fabric particulate 32 filters with 99.9 percent removal efficiency. 33 Activities associated with the construction of the new SCPC plant would cause some additional, 34 temporary air effects as a result of equipment emissions and fugitive dust from operation of the 35 earth-moving and material -handling equipment. Emissions from workers' vehicles and 36 motorized construction equipment exhaust would be temporary. The construction crews would 37 use dust-control practices to control and reduce fugitive dust. The staff concludes that the 38 impact of vehicle exhaust emissions and fugitive dust from operation of the earth -moving and 39 material-handling equipment would be SMALL. 40 Greenhouse Gas Emissions 41 The largest anthropogenic source of CO 2 emissions is the combustion of fossil fuels, especially 42 coal. After a thorough examination of the scientific evidence and careful consideration of public 43 comments, the EPA announced on December 7, 2009, that GHGs threaten the public health 44 and welfare of the American people and meet the CAA definition of air pollutants. The 45 construction and operation of the coal -fired alternative would emit GHGs that likely contribute to 46 climate change. 47 Environmental Impacts of Alternatives 8-20 Greenhouse gas emissions from the construction of a coal -fired alternative would result 1 primarily from the consumption of fossil fuels in the engines of construction vehicles and 2 equipment, workforce vehicles used in commuting to and from the work site, and delivery 3 vehicles. All such impacts would be temporary. 4 The staff estimates that uncontrolled emissions of CO 2-e (carbon dioxide equivalents) from 5 operation of the coal -fired alternative would amount to 18.36 million tons per year (16.66 million 6 metric tons per year). From a life -cycle perspective, Sovacool (2008) found that coal -burning 7 plants can have GHG footprints as high as 1,050 grams of carbon dioxide equivalent per kWh. 8 For comparison, nuclear facilities and NGCC facilities have life -cycle GHG footprints of 9 66 grams of CO 2-e/kWh and 443 grams of CO 2-e/kWh, respectively. Although coal combustion 10 in the boilers would be the primary source, other miscellaneous ancillary sources, such as truck 11 and rail deliveries of materials to the site, commuting of the workforce, and deliveries of wastes 12 to offsite disposal or recycling facilities, would contribu te to the CO 2-e emissions from continued 13 operations. 14 NETL estimates that further development could yield technologies that could capture and 15 remove as much as 90 percent of the CO 2 from the exhausts of SCPC boilers. However, NETL 16 also estimates that such equipment imposes a significant parasitic load that would result in 17 a power production capacity decrease of approximately 27 percent (NETL 2010). In addition, 18 permanent sequestering of the CO 2 would involve removing impurities (including water) and 19 pressurizing it to meet pipeline specifications to transfer the gas, by pipeline, to acceptable 20 geologic formations. Even when opportunities exist to use the CO 2 for enhanced oil recovery 21 (rather than simply disposing of the CO 2 in geologic formations), permanent disposal costs 22 could be substantial, especially if the SCPC units are far removed from acceptable geologic 23 formations. With CCS in place, the coal -fired alternative would release 1.84 million tons of 24 CO 2 per year (1.67 million metric tons per year). Without CCS in place, the staff's projected CO2 25 emissions for the SCPC alternative would be 18,363,843 tons (16,659,678 MT) per year 26 The overall impact from the releases of GHGs of a coal-fired alternative would be MODERATE. 27 Construction impacts would be temporary, but GHG emissions during operation would be 28 noticeable. 29 Conclusion 30 Based on the above discussion, the overall air emissions and associated quality impacts from a 31 new SCPC plant located at the LGS site would be MODERATE, primarily because of the 32 noticeable impact during operations. 33 8.2.2. Groundwater Resources 34 Construction activities associated with the SCPC alternative could require more extensive 35 groundwater dewatering as compared to the NGCC alternative, depending on the hydrogeologic 36 conditions of the selected site. This is because of the more extensive excavation that would be 37 required for the SCPC power block and the onsite disposal facility . Nevertheless, engineering 38 measures, as described in Section 8.1.2, can be used to minimize impacts to facilitate 39 construction. Facility construction would increase the amount of imper vious surface at the site 40 location and alter the subsurface strata because of excavation work and the placement of 41 backfill following facility completion. At some sites, this could cause a localized decline in 42 water-table elevation in a surficial aquifer, if present. However, recharge basins incorporated 43 into the stormwater management system design can make such alterations undetectable at the 44 site boundary. Below-grade portions of a new SCPC plant also could alter the direction of 45 groundwater flow beneath a site, although such effects would likely be very localized at most 46 site locations. Finally, application of BMPs in accordance with a state-issued NPDES general 47 Environmental Impacts of Alternatives 8-21 permit, including appropriate waste management, water discharge, and spill prevention 1 practices, would prevent or minimize any groundwater quality impacts during construction. 2 During the construction period, groundwater could be used to provide water for potable and 3 sanitary uses, concrete production, dust suppression, and soil compaction. However, it is more 4 likely that water would be supplied via a temporary utility connection, if available, or trucked to 5 the point of use from offsite sources. The SPCP alternative would require a peak construction 6 workforce of 2 , 500 (Exelon 2011), as described in Section 8.2.8. While the potential demands 7 for groundwater based on this workforce combined with construction uses might result in water 8 demands nearing 100 gpm (380 L/min) during the peak construction period, the staff determined 9 that any impacts would be very temporary and localized. 10 For SCPC plant operations, the NRC assumed that the SCPC alternative would entail the same 11 relative ratio of groundwater use to surface water use as that used at LGS Units 1 and 2. This 12 includes the use of groundwater for service water makeup and potable and sanitary uses. 13 Consequently, it is expected that total groundwater usage and potential aquifer effects would be 14 much less under this alternative than those under current LGS operations. This is because of 15 the smaller number of auxiliary systems requiring groundwater and the much smaller workforce 16 under this alternative. The only mechanism identified that could adversely affect groundwater 17 quality under normal operations would be operation of the disposal facility. However, the 18 leaching of contaminants from the fly ash and scrubber sludge and impacts to groundwater can 19 be minimized in modern facilities with protective barriers, disposal cell liners, and leachate 20 collection and treatment systems, along with groundwater monitoring systems. Therefore, 21 based on the above assessment, the impacts on groundwater use and quality under this 22 alternative would be SMALL. 23 8.2.3. Surface Water Resources 24 Impacts from construction activities associated with the SCPC alternative on surface water 25 resources would be expected to be similar to but somewhat greater than those under the NGCC 26 alternative. This is attributable to the additional land required for construction of the power block 27 and for excavation and construction of an onsite disposal facility for coal ash and scrubber 28 sludge. However, additional offsite impacts, including hydrologic changes in affected streams 29 and contaminant runoff, would occur from coal mining (see Section 8.2.7). At the SCPC site, 30 some temporary impacts to surface water quality may result from increased sediment loading 31 and from any pollutants in stormwater runoff from disturbed areas and from dredging activities. 32 There also would be the potential for water quality effects to occur from the extension or 33 refurbishment of a rail spur to transport coal to the site location. Nevertheless, as described in 34 Section 8.1.3, water quality impacts would be minimized by the application of BMPs and 35 compliance with state-issued NPDES permits. Any dredging would be conducted under 36 a permit from the COE requiring the implementation of BMPs to minimize impacts. 37 During operations, the SCPC alternative would use slightly less water than LGS because of the 38 greater generation -efficiency of the SCPC technology. Therefore, the water resources impact 39 assessment presented in Section 4.3.2 of this SEIS generally applies to the SCPC alternative. 40 The NRC assumed that water treatment additives for the SCPC alternative would be essentially 41 identical to LGS. Existing intake and discharge infrastructure would be used at the selected 42 power plant site but it could require refurbishment or expansion. Similar to LGS, surface water 43 withdrawals would be subject to applicable state water allocation requirements, and effluent 44 discharges and stormwater discharges associated with industrial activity would be subject to 45 a state-issued NPDES permit under this alternative. The NRC further assumes that the SCPC 46 plant and waste disposal facility would be operated in accordance with appropriate management 47 plans with adherence to appropriate BMPs and procedures to minimize the release of 48 Environmental Impacts of Alternatives 8-22 non-nuclear fuels, chemicals, and other materials to soil, surface water, and groundwater (see 1 Section 8.1.3). As a result, the overall impacts on surface water use and quality from 2 construction and operations under the SCPC alternative would be SMALL. 3 8.2.4. Aquatic Resources 4 Construction activities for the SCPC alternative (such as construction of heavy-haul roads and 5 the power block) could affect drainage areas or other onsite aquatic features. Minimal impacts 6 on aquatic ecology resources are expected because the plant operator would likely implement 7 BMPs to minimize erosion and sedimentation. Stormwater control measures, which would be 8 required to comply with Pennsylvania NPDES permitting, would minimize the flow of disturbed 9 soils into aquatic features. Depending on the available infrastructure at the selected site, the 10 SCPC alternative may require modification or expansion of the existing intake or discharge 11 structures, or construction of new intake and discharge structures. Dredging activities that 12 result from infrastructure construction would require BMPs for in -water work to minimize 13 sedimentation and erosion. Because of the short-term nature of the dredging activities, the 14 hydrological alterations to aquatic habitats likely would be localized and temporary. 15 During operations, the SCPC alternative would require slightly less cooling water to be 16 withdrawn from the Schuylkill River or other similar water body than required for LGS Units 1 17 and 2. The number of fish and other aquatic resources affected by cooling water intake and 18 discharge operations, such as entrainment, impingement, and thermal stress, would be equal or 19 less for an SCPC alternative compared to LGS. The cooling system for a new SCPC plant 20 would have similar chemical discharges as LGS, but the SCPC plant would emit small amounts 21 of ash and particulates that would settle onto the river surface and introduce a new source of 22 pollutants as described in Section 8.2.1. 23 The impacts on aquatic ecology would be minor because construction activities would require 24 BMPs and stormwater management permits, and because the surface water withdrawal and 25 discharge for this alternative would be slightly less compared to LGS Units 1 and 2. Therefore, 26 impacts on aquatic ecology would be SMALL. 27 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 28 of an SCPC plant would not adversely affect any Federally listed species or adversely modify or 29 destroy designated critical habitat. Consultation with NMFS under the Magnuson -Stevens Act 30 would require the NRC to evaluate impacts to EFH. NMFS would provide conservation 31 recommendations if there would be adverse impacts to EFH. Coordination with state natural 32 resource agencies would further ensure that the plant operator would take appropriate steps to 33 avoid or mitigate impacts to state -listed species, habitats of conservation concern, and other 34 protected species and habitats. Consequently, the impacts of construction and operation on 35 protected species and habitats would be SMALL. 36 8.2.5. Terrestrial Resources 37 Construction of an SCPC plant would require approximately 280 ac (113 ha), as described in 38 Section 8.2.7. The SCPC alternative may require up to 46,600 ac (18,860 ha) of additional land 39 for coal mining and processing (NRC 1996). Approximately 464 ac (188 ha) of land also would 40 be required for disposal of ash and scrubber sludge (Exelon 2011). However, land for disposal 41 would likely be located on site (see Section 8.2.7). Because of the relatively large land 42 requirement for the site, a portion of the site would likely be land that had not been previously 43 disturbed, which would directly affect terrestrial habitat by removing existing vegetative 44 communities and displacing wildlife. The level of direct impacts would vary substantially based 45 on site selection. Offsite construction would occur mostly on land where coal extraction is 46 Environmental Impacts of Alternatives 8-23 ongoing. To the extent practicable, Exelon would route the railroad spur along an existing, 1 previously disturbed railroad corridor. Erosion and sedimentation, fugitive dust, and 2 construction debris impacts would be minor with implementation of appropriate BMPs 3 (Exelon 2011). Impacts to terrestrial habitats and species from transmission line operation and 4 corridor vegetation maintenance, and operation of the cooling system would be similar in 5 magnitude and intensity as those resulting from operating nuclear reactors and would, therefore, 6 be SMALL (NRC 1996). Because of the potentially large area of undisturbed habitat that could 7 be affected from construction of an SCPC plant, the impacts of construction on terrestrial 8 habitats and species could range from SMALL to MODERATE depending on the specific site 9 location. The impacts of operation would be SMALL. 10 As with the NGCC alternative, consultation with FWS under the ESA would avoid potential 11 adverse impacts to Federally listed species or adverse modification or destruction of designated 12 critical habitat. Coordination with state natural resource agencies would further ensure that 13 Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats 14 of conservation concern, and other protected species and habitats. Consequently, the impacts 15 of construction and operation of an SCPC plant on protected species and habitats would be 16 SMALL. 17 8.2.6. Human Health 18 Impacts on human health from construction of the SCPC alternative would be similar to impacts 19 associated with the construction of any major industrial facility. Compliance with worker 20 protection rules would control those impacts on workers at acceptable levels. Impacts from 21 construction on the general public would be minimal since limiting active construction area 22 access to authorized individuals is expected. Therefore, impacts on human health from the 23 construction of the SCPC alternative would be SMALL. 24 Coal-fired power plants introduce worker risks from coal and limestone mining, coal and 25 limestone transportation, and disposal of coal combustion residues and scrubber wastes. In 26 addition, there are public risks from inhalation of stack emissions and the secondary effects of 27 eating foods grown in areas subject to deposition from plant stacks. 28 Human health risks of coal -fired power plants are described, in general, in Table 8-2 of the 29 GEIS (NRC 1996). Cancer and emphysema as a result of the inhalation of toxins and 30 particulates are identified as potential health risks to occupational workers and members of the 31 public (NRC 1996). The human health risks associated with coal -fired power plants, both for 32 occupational workers and members of the public, are greater than those of the current LGS 33 reactors because of exposures to chemicals such as mercury, SO x, NO x, radioactive elements 34 such as uranium and thorium contained in coal and coal ash, and polycyclic aromatic 35 hydrocarbon (PAH) compounds, including benzo(a)pyrene. 36 Regulations restricting emissions enforced by either EPA or delegated state agencies have 37 reduced potential health effects, but have not entirely eliminated them. These agencies also 38 impose site -specific emission limits as needed to protect human health. Even if the coal -fired 39 alternative were located in a nonattainment area, emission controls and trading or offset 40 mechanisms could prevent further regional degradation; however, local effects could be visible. 41 Many of the byproducts of coal combustion responsible for health effects are largely controlled, 42 captured, or converted in modern power plants, although some level of health effects may 43 remain. 44 Aside from emissions impacts, the coal -fired alternative introduces the risk of coal pile fires and 45 for those plants that manage coal combustion residue liquids and sludge in waste 46 impoundments, the release of the waste may result because of a failure of the impoundment. 47 Environmental Impacts of Alternatives 8-24 Good housekeeping practices to control coal dust greatly reduce the potential for coal dust 1 explosions or coal pile fires. Although there have been several instances in recent years, 2 sludge impoundment failures are still rare. Free water also could be recovered from such waste 3 streams and recycled and the solid or semi -solid portions removed to permitted offsite disposal 4 facilities. 5 Overall, given extensive health-based regulation and controls likely to be imposed as permit 6 conditions applicable to waste handling and disposal, the staff expects human health impacts 7 from operation of the coal -fired alternative at an alternate site to be SMALL. 8 8.2.7. Land Use 9 The GEIS generically evaluates the impact of constructing and operating various replacement 10 power plant alternatives on land use, both on and off each power plant site. The analysis of 11 land-use impacts focuses on the amount of land area that would be affected by the construction 12 and operation of an SCPC power plant at an existing power plant site. 13 Based on scaled GEIS estimates, more than 3,800 ac (1,540 ha) of land could be needed 14 to support a coal -fired alternative to replace the LGS. This amount of land use would include 15 other plant structures and associated infrastructure and is unlikely to exceed the 3,800 ac 16 (1,540 ha) estimate, excluding land needed for coal mining and processing. Exelon estimated 17 280 ac (113 ha) for new unit construction (Exelon 2011). The NRC determined that this 18 estimate is reasonable because it is consistent with land requirements for modern coal -fired 19 facilities. It is expected that the SCPC alternative would be located at an existing power plant 20 site or otherwise disturbed industrial site, and thus the land -use impacts from construction would 21 range from SMALL to MODERATE. Depending on existing power plant infrastructure, 22 additional l and may be needed for frequent coal and limestone deliveries by rail or barge. 23 Offsite land-use impacts would occur from coal mining, in addition to land-use impacts from the 24 construction and operation of the new power plant. Using the GEIS figure, the SCPC alternative 25 might require up to 49,600 ac (20,100 ha) of land for coal mining and waste disposal during 26 power plant operations. However, much of the land in existing coal mining areas already has 27 experienced some level of disturbance. An additional 464 ac (188 ha) of land would be required 28 for disposal of ash and scrubber sludge (Exelon 2011). It is likely that most of the land needed 29 for disposal would be found within the 22,000 ac (8,900 ha) requirement estimated in the GEIS. 30 The elimination of uranium fuel for the LGS could partially offset some, but not all, of the land 31 requirements for the SCPC alternative. Scaling from GEIS estimates, approximately 1,640 ac 32 (660 ha) no longer would be needed for mining and processing uranium during the operating life 33 of the SCPC plant. Since a substantial amount of land could be converted for coal and 34 limestone delivery and waste disposal, land-use impacts could range from SMALL to 35 MODERATE. 36 8.2.8. Socioeconomics 37 As previously explained in Section 8.1. 8, two types of jobs would be created by this alternative: 38 (1) construction jobs, which are transient, short in duration, and less likely to have a long -term 39 socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for 40 permanent, long -term socioeconomic impacts. Workforce requirements for the construction and 41 operation of the SCPC alternative were evaluated to measure their possible effects on current 42 socioeconomic conditions. 43 Scaling from GEIS estimates, the construction workforce would peak at 5,638 workers. Exelon 44 estimated 2,500 workers at the peak of construction (Exelon 2011). This estimate appears to 45 Environmental Impacts of Alternatives 8-25 be reasonable and is consistent with trends toward lowering labor costs by reducing the size of 1 plant workforces. Therefore, Exelon's estimate of 2,500 workers is used throughout this 2 analysis. The relative economic impact of this many workers on the local economy and tax 3 base would vary, with the greatest impacts occurring in communities where the majority of 4 construction workers reside and spend their income. As a result , local communities could 5 experience a short-term "boom" from increased tax revenue and income generated by 6 construction expenditures and the increased demand for temporary (rental) housing and 7 business services. Some construction workers could relocate in order to be closer to the 8 construction work site. However, given the proximity of many existing power plants to 9 metropolitan area s, workers could commute to the construction site, thereby reducing the need 10 for rental housing. After completing the installation of the subcritical coal -fired power plant, local 11 communities could experience a return to pre -construction economic conditions. Based on this 12 information and given the number of construction workers, socioeconomic impacts during 13 construction in local communities could range from SMALL to MODERATE. 14 Scaling from GEIS estimates, the plant operations workforce would be 564 workers. Exelon 15 estimated a plant operations workforce of approximately 141 workers (Exelon 2011). This 16 estimate appears to be reasonable and is consistent with trends toward lowering labor costs by 17 reducing the size of plant operations workforces. Therefore, Exelon's estimate of 141 workers 18 is used throughout this analysis. This alternative would result in a loss of approximately 19 700 relatively high -paying jobs at LGS, with a corresponding reduction in purchasing activity and 20 tax contributions to the regional economy. In addition, the permanent housing market also 21 could experience increased vacancies and decreased prices if operations workers and their 22 families move out of the region. However, a larger amount of property taxes may be paid to 23 local jurisdictions under the SCPC alternative as more land may be required for coal -fired power 24 plant operations than LGS. Therefore, socioeconomic impacts during operations could range 25 from SMALL to MODERATE. 26 8.2.9. Transportation 27 Transportation impacts associated with construction and operation of a four -unit, SCPC power 28 plant would consist of commuting workers and truck deliveries of construction materials to the 29 power plant site. During periods of peak construction activity, up to 2,500 workers could be 30 commuting daily to the site (Exelon 2011), as described in Section 8.2.8. Workers commuting 31 to the construction site would arrive by site access roads and the volume of traffic on nearby 32 roads could increase substantially during shift changes. In addition to commuting workers, 33 trucks would be transporting construction materials and equipment to the worksite, thus 34 increasing the amount of traffic on local roads. The increase in vehicular traffic would peak 35 during shift changes, resulting in temporary levels of service impacts and delays at 36 intersections. Some power plant components and materials could also be delivered by train or 37 barge, depending on location. Train deliveries could cause additional traffic delays at railroad 38 crossings. Based on this information, traffic-related transportation impacts during construction 39 could range from MODERATE to LARGE. 40 Traffic-related transportation impacts on local roads would be greatly reduced after the 41 completion of the power plant. Transportation impacts would include daily commuting by the 42 operating workforce, equipment and materials deliveries, and the removal of commercial waste 43 material to offsite disposal or recycling facilities by truck. During operations, t he estimated 44 number of operations workers commuting to and from the power plant would be 141 workers 45 (Exelon 2011), as described in Section 8.2.8. The increase in traffic on roadways would peak 46 during shift changes, resulting in temporary levels of service impacts and delays at 47 intersections. Frequent deliveries of coal and limestone by rail would add to the overall 48 Environmental Impacts of Alternatives 8-26 transportation impact. Onsite coal storage would make it possible to receive several trains per 1 day. Limestone delivered by rail could also add additional traffic (though considerably less 2 traffic than that generated by coal deliveries). Coal and limestone delivery and ash removal by 3 rail would cause levels of service impacts on certain roads because of delays at railroad 4 crossings. Overall, transportation impacts would be SMALL to MODERATE during power plant 5 operations. 6 8.2.10. Aesthetics 7 The analysis of aesthetic impact s focuses on the degree of contrast between the SCPC 8 alternative and the surrounding landscape and the visibility of the new SCPC plant at an existing 9 power plant site. During construction, all of the clearing and excavation would occur on the 10 existing power plant site. These activities could be visible from offsite roads. The coal-fired 11 power plant could be approximately 100 ft (30 m) tall, with two to four exhaust stacks several 12 hundred feet tall with natural-draft cooling towers approximately 400 to 500 ft (122 to 152 m) 13 in height. The facility would be visible off site during daylight hours, and some structures may 14 require aircraft warning lights. The condensate plumes from the cooling towers could add to the 15 visual impact. Noise generated during power plant operations would be limited to routine 16 industrial processes and communications. 17 In general, given the industrial appearance of the existing power plant site on which it would be 18 built, the new SCPC power plant would blend in with the surroundings. The power block of the 19 SCPC alternative could look very similar to the existing power plant and construction would 20 appear similar to other ongoing onsite activities . Aesthetic changes would therefore be limited 21 to the immediate vicinity of the existing power plant site, and any impacts would be SMALL 22 depending on its location and surroundings. 23 8.2.11. Historic and Archaeological Resources 24 The impacts of the construction of a new SCPC alternative on historic and archaeological 25 resources are similar to those impacts associated with activities for constructing an NGCC 26 facility. Any areas potentially affected by the construction of the SCPC alternative would need 27 to be surveyed to identify and record historic and archaeological resources. An inventory of a 28 previously disturbed former plant (brownfield) site may still be necessary if the site has not been 29 previously surveyed or to verify the level of disturbance and evaluate the potential for intact 30 subsurface resources. Plant operators would need to survey all areas associated with operation 31 of the alternative (e.g., roads, transmission corridors, other ROWs). Any resources found in 32 these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse 33 effects would need to be addressed if eligible resources were encountered. Areas with the 34 greatest sensitivity should be avoided. Visual impacts on significant cultural resources-such 35 as the viewsheds of historic properties near the site -should also be assessed. 36 The potential for impacts on historic and archaeological resources from the SCPS alternative 37 would vary greatly depending on the location of the proposed site. However, given that the 38 preference is to use a previously disturbed former plant site, avoidance of significant historic 39 and archaeological resources should be possible and effectively managed under current laws 40 and regulations. Therefore, the impacts on historic and archaeological resources from the 41 SCPC alternative would be SMALL. 42 8.2.12. Environmental Justice 43 The environmental justice impact analysis evaluates the potential for disproportionately high and 44 adverse human health, environmental, and socioeconomic effects on minority and low -income 45 Environmental Impacts of Alternatives 8-27 populations that could result from the construction and operation of a new power plant. As 1 previously discussed in Section 8.1.12 , such effects may include human health, biological, 2 cultural, economic, or social impacts. 3 Potential impacts to minority and low -income populations would mostly consist of environmental 4 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 5 housing impacts). Noise and dust impacts durin g construction would be short term and 6 primarily limited to onsite activities. Minority and low -income populations residing along site 7 access roads would be directly affected by increased commuter vehicle and truck traffic. 8 However, because of the temporary nature of construction, these effects are not likely to be high 9 and adverse and would be contained to a limited time period during certain hours of the day. 10 Increased demand for rental housing during construction could cause rental costs to rise 11 disproportionately affecting low -income populations who rely on inexpensive housing. However, 12 given the proximity of some existing power plant sites to metropolitan areas, workers could 13 commute to the construction site, thereby reducing the need for rental housing. 14 Emissions from the operation of a SCPC plant could affect minority and low -income populations 15 as well as the general population living in the vicinity of the new power plant. However, all 16 would be exposed to the same potential effects from SCPC power plant operations and any 17 impacts would depend on the magnitude of the change in ambient air quality conditions . 18 Permitted air emissions are expected to remain within regulatory standards. 19 Based on this information and the analysis of human health and environmental impacts 20 presented in this SEIS, the construction and operation of a new SCPC power plant would not 21 have disproportionately high and adverse human health and environmental effects on minority 22 and low-income populations. 23 8.2.13. Waste Management 24 Coal combustion generates several waste streams, including ash (a dry solid) and sludge 25 (a semi-solid byproduct of emission control system operation). The staff estimates that a 26 2,120-MW(e) power plant would use approximately 7,340,000 tons (6,659,000 MT) of coal 27 annually with an ash content of 16.29 percent. This would generate approximately 28 1,196,000 tons (1, 085,000 MT) of ash and 559,000 tons (507,125 MT) of scrubber sludge each 29 year. About 538,059 tons (488,119 MT) or 45 percent of the ash waste would be marketed for 30 beneficial use (Exelon 2011). Therefore, approximately 559,000 tons (507,125 MT) of ash 31 would be disposed of on site if space were available. According to Exelon (2011), disposal of 32 the ash and sludge would require approximately 464 ac (1 87 ha) over 20 years. Disposal of the 33 remaining waste could noticeably affect land use and ground water quality, but with proper siting 34 and implementation of groundwater monitoring and management practices, in accordance with 35 25 Pa. Code 290, it would not destabilize important resources. After closure of the waste site 36 and revegetation, the land could be available for other uses. 37 The impacts from waste generated during construction would be minor, although the waste 38 generated during operation of this coa l-fired alternative would be MODERATE; the impacts 39 would be clearly visible, but would not destabilize any important resource. The amount of the 40 construction waste would be small compared to the amount of waste generated during the 41 operational stage and much of it could be recycled (i.e, marketed for beneficial use). Therefore, 42 the staff concludes that the overall waste management impacts from construction and operation 43 of this alternative would be MODERATE. 44 Environmental Impacts of Alternatives 8-28 Table 8-3. Summary of Environmental Impacts of the Supercritical Coal -Fired Alternative 1 Compared to Continued Operation of LGS 2 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) (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 3 In this section, the NRC evaluates the environmental impacts of a new nuclear alternative to 4 LGS. In the Commonwealth of Pennsylvania, 34 percent of electricity was generated using 5 nuclear power plants in 2010 (EIA 2012). Throughout PJM, nuclear units also provided 6 34 percent of electricity in 2011 (Monitoring Analytics 2012) . As noted by EIA in its Annual 7 Energy Outlook (EIA 2011b), nuclear generation is expected to account for 3 percent of capacity 8 additions through 2035. A new nuclear power plant is likely to be similar to LGS in terms of 9 capacity factor. 10 Several designs are possible for a new nuclear facility. However, a two-unit nuclear power plant 11 similar to the existing LGS in output is most likely. While two Westinghouse AP1000 reactors 12 would provide an approximately equivalent output, it is possible that other designs also would 13 be available. The new nuclear alternative would rely on a closed -cycle cooling system, similar 14 to the cooling system currently in place at LGS. 15 In its ER, Exelon determined that the current LGS site was not viable to accommodate a new 16 nuclear alternative with net generating capacity sufficient to meet the power production of LGS 17 because of insufficient space at the LGS site (ER 2011). Exelon also indicated that a new 18 nuclear alternative was most likely to be constructed on a site that already hosts a nuclear 19 power plant. This placement would allow the new nuclear alternative to take advantage of 20 existing site infrastructure, including transmission lines and some support facilities. The staff 21 concurs that a new nuclear facility is most likely to be sited at the location of an existing nuclear 22 power plant. Utilities in PJM have expressed interest in either early site permits or combined 23 licenses for new nuclear facilities at several sites, including Calvert Cliffs (in Maryland), Hope 24 Environmental Impacts of Alternatives 8-29 Creek (New Jersey), North Anna (Virginia), and Bell Bend (adjacent to the Susquehanna site in 1 Pennsylvania). 2 New nuclear power plants are commercially available and feasible alternatives to LGS license 3 renewal. The overall environmental impacts of a nuclear alternative, as well as the 4 environmental impacts of proposed LGS license renewal, are shown in Table 8 -4. Additional 5 details of the impacts on individual resources of the new nuclear alternative are provided in 6 subsequent section. 7 8.3.1. Air Quality 8 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 9 Pennsylvania, which is part of the Metropolitan Philadelphia Int erstate Air Quality Control 10 Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards 11 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 12 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM 10; and nonattainment 13 with respect to ozone and PM2.5 (40 CFR 81.339). 14 A new nuclear generating plant would have similar air emissions to those of the existing LGS 15 site; air emissions would be primarily from backup diesel generators and boilers as well as 16 particulates from the cooling towers. As noted in Section 2.2.2.1, Exelon maintains a Title V 17 operating permit (TVOP 00038) for sources of air pollution at the LGS site (Exelon 2011). 18 Because air emissions would be similar for a new nuclear plant, the staff expects similar air 19 permitting conditions and regulatory requirements. 20 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 21 including the review of the new sources that may affect visibility in any Federal Class I area. If a 22 new nuclear plant were located close to a mandatory Class I area, additional air pollution control 23 requirements may be required. As noted in Section 2.2.2.1, there are no Mandatory Class I 24 Federal areas within 50 miles (80 km) of the LGS site. There are a total of 13 designated 25 Class 1 Federal areas (40 CFR 81) located in the following PJM states: Kentucky, Michigan, 26 New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. The following air 27 emissions were reported by Exelon and are from the year 2011 for the existing LGS site (Exelon 28 2012). 29 sulfur oxides (SO x) - 7.8 T (7.1 MT) per year, 30 nitrogen oxide (NO x) - 32.8 T (29.8 MT) per year, 31 carbon monoxide (CO) - 24.2 tons (21.9 MT) per year, and 32 PM 10 and PM2.5 - 166.3 T (150.9 MT) per year. 33 The staff expects similar air emissions from a new nuclear plant because these emissions are 34 primarily from backup diesel generators that would also be used at a new nuclear plant. 35 Activities associated with the construction of the new nuclear plant would cause some 36 additional, temporary air effects as a result of equipment emissions and fugitive dust from 37 operation of the earth -moving and material -handling equipment. Emissions from workers' 38 vehicles and motorized construction equipment exhaust would be temporary. The construction 39 crews could use dust -control practices to control and reduce fugitive dust. The staff concludes 40 that the impact of vehicle exhaust emissions and fugitive dust from operation of the 41 earth-moving and material -handling equipment would be SMALL. 42 Greenhouse Gas Emissions 43 In Chapter 6, the staff discussed the relative GHG emissions of nuclear power compared to 44 other electric generation technologies. This discussion, where applicable, addressed the 45 Environmental Impacts of Alternatives 8-30 nuclear lifecycle, including construction and operation. Impacts during construction of this 1 alternative would result primarily from the consumption of fossil fuels in the engines of 2 construction vehicles and equipment, workforce vehicles used in commuting to and from the 3 work site, and delivery vehicles. However, all such impacts would be temporary. 4 Greenhouse gas emissions from the new nuclear alternative during operation arise primarily 5 from operation of onsite diesel generators and other auxiliary equipment. For additional 6 discussion of GHG emissions from nuclear generation, see Chapter
- 6. 7 Given the expected workforces, relatively short construction period , and minor GHG emissions 8 during operation, the overall impact from the releases of GHGs of the new nuclear alternative 9 would be SMALL. 10 Conclusion 11 The overall air quality impacts of a new nuclear plant located at the LGS site would be 12 designated as SMALL.
13 8.3.2. Groundwater Resources 14 Under this alternative, deep excavation work on the order of 70 ft (21 m) below ground surface 15 for the nuclear island may require active dewatering during construction. Depending on the site 16 and local hydrogeology, this dewatering could have localized drawdown effects on local wells 17 and require the use of cofferdams, sumps, wells, or other methods to address high water -table 18 conditions. However, grout injection and diaphragm walls can be installed to effectively 19 eliminate offsite drawdown impacts and reduce the need for dewatering. Facility construction 20 also would increase the amount of impervious surface at the site location and alter the 21 subsurface strata because of excavation work and the placement of backfill following facility 22 completion. This could cause a localized decline in water -table elevation in the surficial aquifer, 23 but the incorporation of recharge basins into the stormwater management system design can 24 make such alterations undetectable at the site boundary. Below -grade portions of a new 25 nuclear power plant also could alter the direction of groundwater flow beneath a site. Such 26 effects would likely be very localized at most site locations, encompassing the area around the 27 nuclear island, and would not be expected to affect offsite wells at most sites. In addition, 28 application of BMPs in accordance with a state -issued NPDES general permit, including 29 appropriate waste management, water discharge, and spill prevention practices, would prevent 30 or minimize any groundwater quality impacts during construction. 31 During the construction period, groundwater could be used to provide potable water for potable 32 and sanitary uses, concrete production, dust suppression, and soil compaction. However, it is 33 more likely that water would be supplied via a temporary utility connection, if available, or 34 trucked to the point of use from offsite sources. Exelon (2011) estimated a peak construction 35 workforce of 3,650. While the potential demands for groundwater based on this workforce 36 combined with construction uses might result in water demands nearing 100 gpm (380 L/min) 37 during the peak construction period, the staff determined that any effects would be temporary 38 and localized. To support operations of a new nuclear power plant, the NRC assumed that this 39 alternative would entail the same relative ratio of groundwater use to surface water use as that 40 at LGS Units 1 and 2, along with a similar -sized workforce and operational activities. This 41 includes the use of groundwater for service water makeup and potable and sanitary uses. 42 Therefore, the groundwater resources impact assessment presented in Section 4.4 of this SEIS 43 generally applies to the new nuclear alternative. Based on this assessment, impacts on 44 groundwater use and quality under this alternative would be SMALL. 45 Environmental Impacts of Alternatives 8-31 8.3.3. Surface Water Resources 1 Surface water resources impacts from construction activities associated with the new nuclear 2 alternative at an alternative site would be similar to but somewhat greater in scale than those 3 described for the SCPC alternative (see Section 8.2.3). While no ash and sludge disposal 4 facility would be required as under the SCPC alternative, deep excavation work for the nuclear 5 island and more extensive site clearing and larger laydown area for facility construction would 6 have potentially greater impacts to water resources from water use and stormwater runoff. 7 Thus, temporary impacts to surface water quality may result from increased sediment loading 8 and from any pollutants in stormwater runoff from disturbed areas and from any required 9 dredging activities. Nevertheless, as described in Section 8.1.3, water quality impacts would be 10 minimized by the application of BMPs and compliance with state-issued NPDES permits. Any 11 dredging would be conducted under a permit from the COE requiring the implementation of 12 BMPs to minimize impacts. To support operations of a new nuclear power plant, the NRC has 13 assumed that the new facility would consumptively use and discharge the same amount of 14 water as LGS. Therefore, the water resources impact assessment presented in Section 4.3.2 of 15 this SEIS applies to the new nuclear alternative. In Section 4.3.2, the NRC determined that the 16 impacts of LGS operations on surface water resources are SMALL. The NRC assumed that 17 water treatment additives for this alternative would be essentially identical to LGS. Existing 18 intake and discharge infrastructure would be used at the selected power plant site, but it could 19 require refurbishment or expansion. Similar to LGS, surface water withdrawals would be 20 subject to applicable state water allocation requirements, and effluent discharges and 21 stormwater discharges associated with industrial activity would be subject to a state -issued 22 NPDES permit. The NRC further assumes that the new nuclear plant would be operated in 23 accordance with appropriate management plans with adherence to appropriate BMPs and 24 procedures to minimize the release of non -nuclear fuels, chemicals, and other materials to soil, 25 surface water, and groundwater (see Section 8.1.3). Therefore, based on this assessment, the 26 overall impacts on surface water use and quality from construction and operations under the 27 new nuclear alternative would be SMALL. 28 8.3.4. Aquatic Resources 29 Construction activities for the new nuclear alternative (such as construction of heavy -haul roads 30 and the power block) could affect drainage areas or other onsite aquatic features. Minimal 31 impacts on aquatic ecology resources are expected because the plant operator would likely 32 implement BMPs to minimize erosion and sedimentation. Stormwater control measures, which 33 would be required to comply with state NPDES permitting, would minimize the flow of disturbed 34 soils into aquatic features. Depending on the available infrastructure at the selected site, the 35 new nuclear alternative may require modification or expansion of the existing intake or 36 discharge structures, or construction of new intake and discharge structures. Dredging activities 37 that result from infrastructure construction would require BMPs for in -water work to minimize 38 sedimentation and erosion. Because of the short-term nature of the dredging activities, the 39 hydrological alterations to aquatic habitats would likely be localized and temporary. 40 During operations, the new nuclear alternative would require a similar amount of water from the 41 Schuylkill River, or other similar water body, as is required for LGS Units 1 and 2. The number 42 of fish and other aquatic resources affected by cooling water intake and discharge operations, 43 such as entrainment, impingement, and thermal stress, would be similar for a new nuclear 44 alternative as for those associated with LGS Units 1 and 2, provided the cooling -water intake 45 and blowdown operations involve a water body similar in species composition and populations 46 to the Schuylkill River. 47 Environmental Impacts of Alternatives 8-32 The impacts on aquatic ecology would be minor because construction activities would require 1 BMPs and stormwater management permits, and because the surface water withdrawal and 2 discharge for this alternative would be similar to LGS Units 1 and 2 (as discussed in 3 Section 4.5). Therefore, the staff concluded that impacts on aquatic ecology would be SMALL. 4 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 5 of a new nuclear plant would not adversely affect any Federally listed species or adversely 6 modify or destroy designated critical habitat. Consultation with NMFS under the 7 Magnuson-Stevens Act would require the NRC to evaluate impacts to EFH. NMFS would 8 provide conservation recommendations if there would be adverse impacts to EFH. Coordination 9 with state natural resource agencies would further ensure that the plant operator would take 10 appropriate steps to avoid or mitigate impacts to state -listed species, habitats of conservation 11 concern, and other protected species and habitats. Consequently, the impacts of construction 12 and operation on protected species and habitats would be SMALL. 13 8.3.5. Terrestrial Resources 14 The new nuclear alternative, including the new reactor units and auxiliary facilities, would affect 15 630 ac to 1,260 ac (255 ha to 510 ha) of land at the site of an existing power station other than 16 LGS (Exelon 2011), as described in Section 8.3.7. Because of the significant land requirement 17 for the site, impacts to terrestrial species and habitats would vary depending on the amount of 18 previously undisturbed land that would be cleared for the new nuclear alternative. By siting the 19 new nuclear alternative at an existing nuclear site or adjacent to an existing site, the majority of 20 land that would be affected by construction would be developed or previously disturbed. 21 However, as with the SCPC alternative, the level of direct impacts would vary based on site 22 selection. Erosion and sedimentation, fugitive dust, and construction debris impacts would be 23 minor with implementation of appropriate BMPs (Exelon 2011). Impacts to terrestrial habitats 24 and species from transmission line operation and corridor vegetation maintenance, and 25 operation of the cooling system would be similar in magnitude and intensity to those resulting 26 from operating nuclear reactors and would, therefore, be SMALL (NRC 1996). The offsite land 27 requirement (1, 000 ac (400 ha)) (NRC 1996) and impacts associated with uranium mining and 28 fuel fabrication to support the new nuclear alternative would be no different from those occurring 29 in support of LGS (see Section 8.3.7). Overall, the impacts of construction of a new nuclear 30 facility on terrestrial species and habitats would be SMALL to MODERATE, and the impacts of 31 operation would be SMALL. 32 As with the previously discussed alternatives, consultation with FWS under the ESA would 33 avoid potential adverse impacts to Federally listed species or adverse modification or 34 destruction of designated critical habitat. Coordination with state natural resource agencies 35 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 36 state-listed species, habitats of conservation concern, and other protected species and habitats. 37 Consequently, the impacts of construction and operation of new nuclear generation on 38 protected species and habitats would be SMALL. 39 8.3.6. Human Health 40 Impacts on human health from construction of two new nuclear units would be similar to impacts 41 associated with the construction of any major industrial facility. Compliance with worker 42 protection rules would control those impacts on workers at acceptable levels. Impacts from 43 construction on the general public would be minimal since limiting active construction area 44 access to authorized individuals is expected. Impacts on human health from the construction of 45 two new nuclear units would be SMALL. 46 Environmental Impacts of Alternatives 8-33 The human health effects from the operation of two new nuclear power plants would be similar 1 to those of the existing LGS Units 1 and 2. Most other noises during power plant operations 2 would be limited to industrial processes and communications. Impacts on human health from 3 the operation of two new nuclear units would be SMALL. 4 8.3.7. Land Use 5 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and 6 operating various replacement power plant alternatives on land use, both on and off each plant 7 site. The analysis of land -use impacts focuses on the amount of land area that would be 8 affected by the construction and operation of a new two -unit nuclear power plant at or adjacent 9 to an existing nuclear power plant site. 10 Based on GEIS estimates, approximately 1,000 ac (400 ha) of land would be needed for the 11 new nuclear alternative . Exelon estimated 630 ac to 1,260 ac (255 ha to 510 ha) of land would 12 be needed to construct and operate a new two -unit nuclear power plant (Exelon 2011). The 13 NRC determined that Exelon's estimate is reasonable because it is consistent with land 14 requirements for proposed new nuclear plants. 15 Locating the new units at or adjacent to an existing nuclear power plant would mean that the 16 majority of the affected land area would already be zoned for industrial use. Making use of the 17 existing infrastructure would reduce the amount of land needed to support the new units. Local 18 residents are already accustomed to living near a nuclear power plant. Land -use impacts from 19 constructing two new units at an existing nuclear power plant site would be SMALL. 20 The amount of land required to mine uranium and fabricate nuclear fuel during rector operations 21 would be similar to the amount of land required to support LGS, although an additional amount 22 of land would be required during the license renewal term. According to GEIS estimate s, an 23 additional 1,000 ac (400 ha) of land would be affected by uranium mining and processing during 24 the life of the new nuclear power plant. Impacts associated with uranium mining and fuel 25 fabrication to support the new nuclear alternative would generally be no different from those 26 occurring in support of the existing LGS reactors. Overall land -use impacts from nuclear power 27 plant operations would range from SMALL to MODERATE depending on whether the nuclear 28 plant is sited entirely contained within an existing nuclear power plant site or if it located on open 29 land. 30 8.3.8. Socioeconomics 31 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 32 (1) construction jobs, which are transient, short in duration, and less likely to have a long -term 33 socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for 34 permanent, long -term socioeconomic impacts. Workforce requirements for the construction and 35 operation of a new nuclear power plant were evaluated in order to measure their possible 36 effects on current socioeconomic conditions. 37 Exelon estimated 3,650 workers at the peak of construction (Exelon 2011). The relative 38 economic impact of this many workers on the local economy and tax base would vary, with the 39 greatest impacts occurring in communities where the majority of construction workers reside 40 and spend their income. As a result , local communities could experience a short -term economic 41 "boom" from increased tax revenue and income generated by construction expenditures and the 42 increased demand for temporary (rental) housing and business services. Some construction 43 workers could relocate in order to be closer to the construction work site. However, given the 44 Environmental Impacts of Alternatives 8-34 proximity of many existing power plants to metropolitan area s, workers could commute to the 1 construction site, thereby reducing the need for rental housing. 2 After completing the installation of the two new reactor units, local communities could 3 experience a return to pre -construction economic conditions. Based on this information and 4 given the number of construction workers, socioeconomic impacts during construction in local 5 communities could range from SMALL to LARGE. 6 Exelon estimated that the number of operations workers at the new nuclear power plant would 7 be similar to the number of operations workers at LGS (Exelon 2011). The amount of property 8 taxes paid under the new nuclear alternative may increase if additional land is required to 9 support this alternative. However, the reduction in employment at LG S from operations to 10 decommissioning and shut down could affect property tax revenue and income in local 11 communities and businesses. In addition, the permanent housing market could also experience 12 increased vacancies and decreased prices if operations workers and their families move out of 13 the region. Therefore, socioeconomic impacts during operations could range from SMALL to 14 MODERATE. 15 8.3.9. Transportation 16 Transportation impacts associated with construction and operation of a new nuclear power plant 17 would consist of commuting workers and truck deliveries of construction materials to the power 18 plant site. During periods of peak construction activity, up to 3,650 workers could be commuting 19 daily to the site (Exelon 2011). Workers commuting to the construction site would arrive by site 20 access roads and the volume of traffic on nearby roads could increase substantially during shift 21 changes. In addition to commuting workers, trucks would be transporting construction materials 22 and equipment to the worksite, thus increasing the amount of traffic on local roads. 23 The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 24 service impacts and delays at intersections. Some power plant components and materials 25 could also be delivered by train or barge, depending on location. Train deliveries could cause 26 additional traffic delays at railroad crossings. Based on this information, traffic-related 27 transportation impacts during construction could range from MODERATE to LARGE. 28 Traffic-related transportation impacts on local roads would be greatly reduced after the 29 completion of the power plant. Transportation impacts would include daily commuting by the 30 operating workforce, equipment and materials deliveries, and the removal of commercial waste 31 material to offsite disposal or recycling facilities by truck. During operations, t he estimated 32 number of operations workers commuting to and from the power plant would be 820 workers 33 (Exelon 2011). Traffic-related transportation impacts would be similar to current operations at 34 LGS, because the new units would employ the same number of workers as currently employe d 35 at LGS. Overall, transportation impacts would be SMALL to MODERATE during power 36 operations. 37 8.3.10. Aesthetics 38 The analysis of aesthetic impacts focuses on the degree of contrast between the new nuclear 39 power plant and the surrounding landscape and the visibility of the new units at an existing 40 nuclear power plant site. The power block of the two new units would look very similar to the 41 power block(s) at the existing nuclear power plant. 42 During construction, all of the clearing and excavation would occur on site. These activities may 43 be visible from offsite roads. Since the existing power plant site already appears industrial, 44 Environmental Impacts of Alternatives 8-35 construction of the new nuclear power plant would appear similar to other ongoing onsite 1 activities. 2 Located near an existing power plant, the tallest power plant structures, the natural draft cooling 3 towers could be 400 to 500 ft (122 to 152 m) tall. Visible off site during daylight hours, they may 4 require aircraft warning lights. Associated condensate plumes could add to the visual impact. 5 Noise generated during power plant operations would mostly be limited to routine industrial 6 processes and communications. Natural draft cooling towers would also generate noise. 7 In general, given the industrial appearance of an existing power plant site, the new nuclear 8 power plant would blend in with the surroundings. Aesthetic changes would therefore be limited 9 to the immediate vicinity of the existing power plant site, and any impacts would be SMALL to 10 MODERATE, depending on its location and surroundings. 11 8.3.11. Historic and Archaeological Resources 12 The impacts of constructing the new nuclear alternative on historic and archaeological 13 resources are similar to those impacts associated with activities for constructing an NGCC 14 facility. Any areas potentially affected by the construction of the SCPC alternative would need 15 to be surveyed to identify and record historic and archaeological resources. An inventory of a 16 previously disturbed former plant (brownfield) site may still be necessary if the site has not been 17 previously surveyed or to verify the level of disturbance and evaluate the potential for intact 18 subsurface resources. Plant operators would need to survey all areas associated with operation 19 of the alternative (e.g., roads, transmission corridors, other ROWs). Any resources found in 20 these surveys would need to be evaluated for eligibility on the NRHP, and mitigation of adverse 21 effects would need to be addressed if eligible resources were encountered. Areas with the 22 greatest sensitivity should be avoided. Visual impacts on significant cultural resources-such 23 as the viewsheds of historic properties near the site-should also be assessed. 24 The potential for impacts on historic and archaeological resources from the new nuclear 25 alternative would vary greatly depending on the location of the proposed site. However, given 26 that the preference is to use a previously disturbed former plant site, avoidance of significant 27 historic and archaeological resources should be possible and effectively managed under current 28 laws and regulations. Therefore, the impacts on historic and archaeological resources from the 29 new nuclear alternative would be SMALL. 30 8.3.12. Environmental Justice 31 The environmental justice impact analysis evaluates the potential for disproportionately high and 32 adverse human health, environmental, and socioeconomic effects on minority and low -income 33 populations that could result from the construction and operation of a new power plant. As 34 previously discussed in Section 8.1.12, such effects may include human health, biological, 35 cultural, economic, or social impacts. 36 Potential impacts to minority and low -income populations would mostly consist of environmental 37 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 38 housing impacts). Noise and dust impacts during construction would be short term and 39 primarily limited to onsite activities. Minority and low -income populations residing along site 40 access roads would be directly affected by increased commuter vehicle and truck traffic. 41 However, because of the temporary nature of construction, these effects are not likely to be high 42 and adverse and would be contained to a limited time period during certain hours of the day. 43 During construction, increased demand for rental housing in the vicinity of the site could affect 44 low-income populations living near the plant site. However, given the proximity of some existing 45 Environmental Impacts of Alternatives 8-36 nuclear power plant sites to metropolitan areas, workers could commute to the construction site, 1 thereby reducing the need for rental housing. 2 Potential impacts to minority and low -income populations from new nuclear power plant 3 operations would mostly consist of radiological effects; however, radiation doses are expected 4 to be well below regulatory limits. All people living near the nuclear power plant would be 5 exposed to the same potential effects from power plant operations, and any impacts would 6 depend on the magnitude of the change in ambient air quality conditions . Permitted air 7 emissions are expected to remain within regulatory standards. 8 Based on this information and the analysis of human health and environmental impacts 9 presented in this SEIS, the construction and operation of a new nuclear power plant would not 10 have disproportionately high and adverse human health and environmental effects on minority 11 and low-income populations. 12 8.3.13. Waste Management 13 During the construction stage of the new nuclear alternative, land clearing and other 14 construction activities would generate waste that could be recycled, disposed of on site, or 15 shipped to the offsite waste disposal facility. Because the new nuclear plant s would be 16 constructed at a location on and adjacent to an existing nuclear power plant (although not at 17 LGS because of space limitations), the amount of wastes produced during land clearing would 18 be reduced. 19 During the operational stage, normal plant operations, routine plant maintenance, and cleaning 20 activities would generate nonradioactive waste as well as mixed waste, low -level waste, and 21 high-level waste. Quantities of nonradioactive waste (discussed in Section 2.3.1 of this SEIS) 22 and radioactive waste (discussed in Section 6.1 of this SEIS) generated by Units 1 and 2 would 23 be comparable to that generated by the new nuclear plants. 24 According to the GEIS (NRC 1996), the generation and management of solid nonradioactive 25 waste during the terms of an extended license are not expected to result in significant 26 environmental impacts. Two new nuclear plant s would generate waste streams similar to those 27 at nuclear plants that ha ve undergone license renewal. Based on this information, the waste 28 impacts would be SMALL for the new nuclear alternative. 29 Environmental Impacts of Alternatives 8-37 Table 8-4. Summary of Environmental Impacts of the New Nuclear Alternative Compared 1 to Continued Operation of the Existing LGS 2 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 SMALL (a) 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. 8.4. Wind Alternative 3 The feasibility of wind as a baseload power source depends on the availability, accessibility, and 4 constancy of the wind resource within the region of interest. Wind power, in general, cannot be 5 stored without first being converted to electrical energy. 6 Wind power installations, which may consist of several hundred turbines, produce variable 7 amounts of electricity. LGS, however, produces electricity almost constantly. Because wind 8 power installations deliver variable output when wind conditions change, wind power cannot 9 substitute for existing baseload generation on a one -to-one basis. In its ER, Exelon discusses 10 the need for "firming capacity" to provide support to the variable wind resource and provide 11 consistent baseload power. Firming capacity could come from other generators, from 12 compressed air energy storage (CAES), from pumped hydroelectric storage, or from 13 interconnected wind installations. Archer and Jacobsen (2007), indicates that an array of 14 interconnected wind sites (19 in their study), spread across significant distances (with 15 approximately 850 km (530 mi) distance from north to south and east to west) could provide 16 21 percent of installed capacity 79 percent of the time. While the sites in Archer and Jacobsen's 17 study, in most cases, accessed higher power -class wind resources than are readily available 18 onshore in PJM, the approach suggests that approximately 20 percent of the installed capacity 19 in a series of interconnected wind installations could provide baseload power. Therefore, this 20 study indicates that interconnecting windfarms, as assumed in this alternative, may provide a 21 source of consistent, baseload power. In this alternative, the staff considers a wind alternative 22 that relies on numerous, interconnected wind installations scattered across PJM. This 23 arrangement ensures that generators are sufficiently dispersed so that low -wind or no -wind 24 conditions are unlikely to occur at all or most locations at any given time. 25 Environmental Impacts of Alternatives 8-38 Wind farms currently operate at much lower capacity factors than nuclear power. For example, 1 LGS Unit 1 has operated at a 97 percent capacity factor over the years 2003 to 2010, while LGS 2 Unit 2 has operated at a 96 percent capacity factor over the same period (NRC 2011). 3 Currently, Department of Energy (DOE) estimates that wind turbine installations operate at 4 39 percent or lower capacity factors because of the variability of wind resources. As Exelon 5 indicated in its ER, this capacity factor is likely to increase as wind turbine technology advances 6 and as operators become more experienced in maximizing output. DOE indicates that, by 7 2020, onshore wind turbines may reach a 52 percent capacity factor, while offshore units may 8 reach a 55 percent capacity factor (DOE 2008). As described in more detail below, the staff 9 finds it likely that all wind turbines in this alternative will be land -based and, therefore, used the 10 52 percent capacity factor as an upper range of the capacity factor for this analysis. 11 For a lower range of the capacity factor used in this analysis, the staff reviewed PJM's 12 13 percent "capacity credit" to wind power. Capacity credit is the amount of a generator's 13 nameplate capacity that counts toward the total generating capacity of the PJM system for 14 system planning purposes. Assumin g a 13 percent "capacity credit" for wind power , 15 18,000 MW(e) of wind power would be necessary to replace 2,340 MW(e) of LGS because of 16 the intermittency of wind power. 17 Wind power is a commercially available and feasible means of generating electricity. Assuming 18 a range of 13 to 52 percent capacity factor, the staff, in this alternative, evaluates a 19 wind-powered alternatives that contains between 4,500 MW(e) and 18,000 MW(e) of installed 20 capacity. Relying on commonly available 2 -MW(e) turbines, 2,250 to 9,000 turbines would be 21 required to replace LGS. The NRC staff determined this was a reasonable alternative because 22 wind power is currently a source of energy generation within PJM. As of October 2012, 23 approximately 6,000 MW of installed wind capacity exists within PJM (PJM 2012a). The 24 installed wind capacity within Pennsylvania, Delaware, Maryland, New Jersey, Ohio, and West 25 Virginia has grown on average 50 percent per year from 2000 through 2011 (DOE 2012). 26 Similar growth is likely within the next several years. For example, as of January 2012, a total 27 of 37,792 MW of wind energy generation is proposed within PJM (PJM 2012b). Similarly, in a 28 recent update of PJM's renewable portfolio standards, PJM (2012a) estimated that 35,600 MW 29 of wind energy would be installed by 2027. 30 As described above, this alternative assumes all wind power would be generated onshore 31 because it is currently commercially available and a feasible means of generating electricity. 32 While some offshore wind development is possible by 2024, no commercial offshore wind 33 installations currently operate in the United States, despite more than a decade of development 34 efforts. In the Atlantic Ocean, several commercial wind-power projects have been proposed, 35 but none have yet received final approvals or begun construction. The most prominent of these 36 projects, Cape Wind would consist of 130 turbines with a maximum installed capacity of 37 468 MW. The project was initially proposed in 2001; however, because of significant delays 38 related to permitting and the NEPA process, the project is currently scheduled to begin 39 construction in 2013. Cape Wind is the first and only U.S. offshore wind farm to have received 40 all required Federal and State approvals, a commercial lease, and an approved construction 41 and operations plan (BOEMRE, 2012 b). Other projects offshore of Rhode Island and New 42 Jersey are smaller than Cape Wind (Wald 2011), and another organization has proposed -43 though not yet constructed -a high-voltage direct -current powerline on the seafloor to connect 44 offshore projects (Atlantic Wind Connection undated, Wald 2011). Finally, a group working near 45 Long Island proposed an installation of 700 MW(e) of wind capacity (Con Edison 2009). While 46 wind data suggest there is potential for offshore wind farms along the coast of the mid -Atlantic 47 and in the Great Lakes, project costs likely limit the future potential of large -scale projects 48 (NREL 2010). NREL (2010) estimated that offshore project costs would run approximately 49 Environmental Impacts of Alternatives 8-39 200 to 300 percent higher than land-based systems. Also, based on current prices for wind 1 turbines, the 20 -year levelized cost of electricity produced from an offshore wind farm would be 2 above the current production costs from existing power generation facilities. In addition to cost, 3 other barriers include the immature status of the technology, limited resource area, and high 4 risks and uncertainty (NREL 2010). 5 Environmental impacts from the wind alternative are summarized in Table 8-5. 6 8.4.1. Air Quality 7 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 8 Pennsylvania, which is part of the Metropolitan Philadelphia Int erstate Air Quality Control 9 Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards 10 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 11 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM 10; and nonattainment 12 with respect to ozone and PM2.5 (40 CFR 81.339). 13 Beyond maintenance of the wind turbines, there would be no routine air emissions associated 14 with operations from wind generation. Activities associated with the construction and installation 15 of the wind turbines would cause some temporary air pollutant emissions. However, emissions 16 from workers' vehicles and construction equipment exhaust would be temporary. The staff 17 concludes that the air quality impact from construction would be SMALL. 18 Greenhouse Gas Emissions 19 Wind power releases no GHGs during operation, although some GHG emissions occur during 20 component manufacturing, transportation, and installation, as well as during site preparation. 21 Impacts from the construction of components of this alternative would result primarily from the 22 consumption of fossil fuels in the engines of construction vehicles and equipment, workforce 23 vehicles used in commuting to and from the work site, and delivery vehicles. However, all such 24 impacts would be temporary. 25 In general, wind power is one of the least carbon -intensive electric generation options available. 26 For a comparison to other means of electric generation, see the discussion in Chapter
- 6. 27 Given the expected relatively small workforces, short construction period, and GHG emissions 28 resulting from site preparation and installation, ,the overall impact from the release of GHGs of 29 the wind alternative would be SMALL. 30 Conclusions 31 Based on the above discussion, the overall air emissions and air quality impacts from the wind 32 alternative would be designated as SMALL.
33 8.4.2. Groundwater Resources 34 Groundwater dewatering, where required for installation of wind turbines on land, would be 35 minimal because of the small footprint of foundation structures and piling emplacements. For all 36 construction activities, appropriate BMPs, including spill prevention practices, would be used 37 during wind turbine construction to prevent or minimize impacts on groundwater quality. 38 Little or no groundwater use would be expected for operation of wind turbines, and no impacts 39 on groundwater quality would be expected from routine operations. Consequently, the impacts 40 on groundwater use and quality under this alternative would be SMALL. 41 Environmental Impacts of Alternatives 8-40 8.4.3. Surface Water Resources 1 Small amounts of water would be required during the construction phase for each of the 2 2,250 wind turbines, including for dust suppression and soil compaction during site clearing and 3 for concrete production for pad and piling construction, as appropriate. Although surface water 4 from nearby water bodies may be used for pad site construction at some locations, it is likely 5 that water would be procured from offsite sources and trucked to the point of use on an as 6 needed basis. Use of ready -mix concrete also would reduce the need for onsite use of nearby 7 water sources. 8 Further, the installation of land -based wind turbines would require installation of access roads 9 and possibly transmission lines (especially for turbine sites not already proximal to transmission 10 line corridors). Access road construction also would require some water for dust suppression 11 and roadbed compaction and would have the potential to result in soil erosion and stormwater 12 runoff from cleared areas. Water would likely be trucked to the point of use from offsite 13 locations along with road construction materials. Construction activities would be conducted in 14 accordance with state-issued NPDES or equivalent permits for stormwater discharges 15 associated with construction activity, which would require the implementation of appropriate 16 BMPs to prevent or mitigate water quality impacts. 17 To support operations of individual wind turbine installations, only very small amounts of water 18 would be needed to periodically clean turbine blades and motors as part of routine servicing. It 19 would be expected that water would be trucked to the point of use and procured from nearby 20 sources. Adherence to appropriate waste management and minimization plans, spill prevention 21 practices, and pollution prevention plans during servicing would minimize the risks to soils and 22 surface water resources from spills of petroleum, oil, and lubricant products and runoff 23 associated with the turbine installations. Therefore, the impacts on surface water use and 24 quality under the wind alternative would be SMALL. 25 8.4.4. Aquatic Resources 26 Construction activities for the land -based wind alternative (such as construction of heavy-haul 27 roads and the wind turbines) could affect drainage areas and other onsite aquatic features. 28 Minimal impacts on aquatic ecology resources are expected because the plant operator would 29 likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, 30 which would be required if an NPDES permit was necessary, would minimize the flow of 31 disturbed soils into aquatic features. During operations, the land -based wind alternative would 32 not require consumptive water use. 33 The impacts on aquatic ecology would be minor because construction activities would likely 34 require BMPs and stormwater management permits. During operations, the land -based wind 35 alternative would not require consumptive water use. Therefore, impacts on aquatic ecology 36 from the land -based wind alternative would be SMALL. 37 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 38 of wind farms would not adversely affect any Federally listed species or adversely modify or 39 destroy designated critical habitat. If wind farms were located near EFH, consultation with 40 NMFS under the Magnuson -Stevens Act would require the NRC to evaluate impacts to EFH. 41 NMFS would provide conservation recommendations if there would be adverse impacts to EFH. 42 Coordination with state natural resource agencies would further ensure that the wind farm 43 operators would take appropriate steps to avoid or mitigate impacts to state -listed species, 44 habitats of conservation concern, and other protected species and habitats. Consequently, the 45 impacts of construction and operation on protected species and habitats would be SMALL. 46 Environmental Impacts of Alternatives 8-41 8.4.5. Terrestrial Resources 1 The wind alternative would contain between 2,250 and 9,000 wind turbines requiring 2 approximately 3,200 to 13,300 ac (1,300 to 5,400 ha) of land. This land estimate includes only 3 the area directly affected by placement of turbines, and about two -thirds of this land area would 4 only experience temporary disturbance during construction. The logistics of delivering heavy or 5 oversized components to ideal locations such as hilltops or ridgelines would be challenging and 6 might require extensive modifications to existing road infrastructures and construction of access 7 roads that take circuitous routes to their destination to avoid unacceptable grades. However, 8 once construction was completed, many access roads could be reclaimed and replaced with 9 more-direct access to the wind farm for maintenance purposes. Likewise, land used for 10 equipment laydown and turbine component assembly and erection could be returned to its 11 original state. BMPs following construction that include plans to restore disturbed land would 12 also reduce the impact of construction on terrestrial habitats. Because wind turbines require 13 ample spacing between one another to avoid inter -turbine air turbulence, the footprint of 14 utility-scale wind farms could be quite large. The turbines would be spread across a total area 15 of 200 to 830 mi 2 (520 to 2,150 km 2), and most of this area will remain in compatible land uses, 16 such as agriculture and forests (Exelon, 2011). During operations, only 5 to 10 percent of the 17 total acreage within the footprint of wind installations would actually be occupied by turbines, 18 access roads, support buildings, and associated infrastructure while the remaining land areas 19 could be put to other compatible uses, including agriculture. Habitat loss and some habitat 20 fragmentation may occur as a result, especially for wind turbines installed in forested areas. 21 Overall, construction impacts on terrestrial species and habitats could range from SMALL 22 to MODERATE. 23 Operation of wind turbines could uniquely affect terrestrial species through noise, collision with 24 turbines and meteorological towers, site maintenance activities, disturbance associated wit h 25 activities of the project workforce, and interference with migratory behavior. Bat and bird 26 mortality from turbine collisions is a concern for operating wind farms; however, recent 27 developments in turbine design have reduced the potential for bird and bat strikes. Additionally, 28 impacts to those bird and bat species protected by the ESA, the Migratory Bird Treaty Act, or 29 the Bald and Golden Eagle Protection Act would be mitigated through consultation with the 30 appropriate agencies as discussed below. Impacts to terrestrial habitats and species from 31 transmission line operation and corridor vegetation maintenance would be similar in magnitude 32 and intensity to those resulting from operating nuclear reactors and would, therefore, be SMALL 33 (NRC 1996). Overall, operation impacts to terrestrial species and habitats could range from 34 SMALL to MODERATE. 35 As with the previously discussed alternatives, consultation with FWS under the ESA would 36 avoid potential adverse impacts to Federally listed species or adverse modification or 37 destruction of designated critical habitat. Coordination with state natural resource agencies 38 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 39 state-listed species, habitats of conservation concern, and other protected species and habitats. 40 Consequently, the impacts of construction and operation of a wind alternative on protected 41 species and habitats would be SMALL. 42 8.4.6. Human Health 43 Impacts on human health from construction of the wind alternative would be similar to impacts 44 associated with the construction of any major industrial facility. Compliance with worker 45 protection rules would control those impacts on workers at acceptable levels. Impacts from 46 construction on the general public would be minimal since limiting active construction area 47 Environmental Impacts of Alternatives 8-42 access to authorized individuals is expected. Impacts on human health from the construction of 1 the wind alternative would be SMALL. 2 The Massachusetts Department of Environmental Protection (MassDEP), in collaboration with 3 the Massachusetts Department of Public Health (MDPH), convened a panel of independent 4 experts to identify any documented or potential health impacts of risks that may be associated 5 with exposure to wind turbines (MassDEP and MDPH 2012). The panel conducted an 6 extensive literature review of scientific literature as well as other reports, popular media, and the 7 public comments received by MassDEP to write its report. Based on its review, the panel 8 presented findings relative to three factors associated with the operation of wind turbines: noise 9 and vibration, shadow flicker, and ice throw. 10 Noise and Vibration 11 Noise produced by wind turbines during operation depends on the design of the wind turbine. 12 Propagation of the sound is primarily a function of distance from the wind turbine, but can also 13 be affected by placement of the wind turbine, surrounding terrain, and atmospheric conditions. 14 Infrasound refers to vibrations with frequencies below 20 Hertz (Hz). Infrasound at amplitudes 15 over 100-110 Decibels (dB) can be heard and felt. Research has shown that vibrations below 16 these amplitudes are not felt. Through its research, the panel found that the highest infrasound 17 levels measured near turbines are under 90 dB at 5 Hz and lower at higher frequencies for 18 locations as close as 100 meters (m). The panel found that there was not sufficient evidence 19 to conclude that noise and vibration from wind turbines cause negative impacts on human 20 health (MassDEP and MDPH 2012). 21 Shadow Flicker 22 Shadow flicker results from the passage of the blades of a rotating wind turbine between the 23 sun and the observer. The occurrence of shadow flicker depends on the location of the 24 observer relative to the turbine and the time of day and year, and is found to only be present at 25 distances of less than 1,400 m (4,600 ft) from the turbine. The panel found through its research 26 that there was not sufficient evidence to conclude that shadow flicker causes negative impacts 27 (such as seizures from photic stimulation) on human health (MassDEP and MDPH 2012). 28 Ice Throw 29 Ice can fall or be thrown from a wind turbine during or after an event when ice forms or 30 accumulates on the blades. The distance that a piece of ice may travel from the turbine is a 31 function of the wind speed, the operating conditions, and the shape of the ice. The panel found 32 that in most documented cases of ice throw, the ice falls within a distance from the turbine equal 33 to the tower height, and very seldom does the distance exceed twice the total height of the 34 turbine (tower height plus blade length). The panel found that there is sufficient evidence that 35 falling ice is a human health impact, and measures should be taken to ensure proper hazard 36 minimization. Proper siting of the wind turbines, limitation of access by members of the public, 37 and adequate training of persons in charge of maintenance of the facility will help to minimize 38 the danger of ice throw (MassDEP and MDPH 2012). 39 Overall, given proper health -based regulation through procedures and access limitations, the 40 staff expects human health impacts from operation of the wind alternative at an alternate site 41 to be SMALL. 42 8.4.7. Land Use 43 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and 44 operating various replacement power plant alternatives on land use, both on and off each power 45 Environmental Impacts of Alternatives 8-43 plant site. The analysis of land -use impacts focuses on the amount of land area that would be 1 affected by the construction and operation of new land -based wind farms in the PJM territory. 2 Most of the wind farms would likely be located on open agricultural cropland, which would 3 remain largely unaffected by the wind turbines. 4 Since wind turbines require ample spacing between one another to avoid air turbulence, the 5 footprint of a utility scale wind farm could be quite large. Under the wind alternative, land -based 6 turbines would be located on multiple wind farms spread across approximately 130,000 to 7 534,000 ac (53,000 to 216,000 ha or 200 to 830 mi 2 [520 to 2,1 5 0 k m 2]) of land. A small portion 8 of this land, approximately 3,200 to 13,300 ac (1,300 to 5,400 ha), would be directly affected by 9 the placement of the wind turbines (Exelon 2011). This land would be temporarily affected 10 during the installation of the turbines and the construction of support facilities, and about 11 one-third of the land across a very wide area would be permanently impacted during the 12 operation. Land in between the turbines can be used for farming or grazing. 13 Delivering heavy and oversized wind turbine components would also require the construction of 14 temporary site access roads, some of which may require a circuitous route to their destination. 15 However, once construction is completed, many temporary access roads can be reclaimed and 16 replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land 17 used for equipment and material lay down areas, turbine assembly, and installation could be 18 returned to its original state. During operations, however, only 5 -10 percent of the total acreage 19 within the wind farm is actually occupied by turbines, access roads, support buildings, and 20 associated infrastructure while the remaining land area can be returned to its original condition 21 or some other compatible use, such as farming or grazing. 22 The elimination of uranium fuel for LGS could partially offset some, but not all, of the land 23 requirements for the wind farms. Scaling from GEIS estimates, approximately 1,640 ac 24 (660 ha) would no longer be needed for mining and processing uranium during the operating life 25 of the wind farms. 26 The wind farms would require a substantial amount of open land, although only a small portion 27 would be used for wind turbines, access roads, and infrastructure. Therefore, land use impacts 28 from the wind alternative would range from MODERATE to LARGE. 29 8.4.8. Socioeconomics 30 As previously explained in Section 8 1.8, two types of jobs would be created by this alternative: 31 (1) construction jobs, which are transient, short in duration, and less likely to have a long -term 32 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 33 long-term socioeconomic impacts. Workforce requirements for the construction and operation 34 of the wind alternative were evaluated in order to measure their possible effects on current 35 socioeconomic conditions. 36 Exelon estimated 200 construction and 50 operations workers would be required for this 37 alternative (Exelon 2011). These numbers appear reasonable and in line with current 38 construction and operational trends. Because of the relatively small number of construction 39 workers and the large area covered by the wind farms (i.e., 200 to 830 mi 2 [520 to 2,160 km 2]), 40 the relative economic impact of this many workers on local communities and the tax base would 41 be SMALL. Given the small number of operations workers, socioeconomic impacts associated 42 with operation of the wind farms would also be SMALL. 43 The reduction in employment at LGS could affect property tax revenue and income in local 44 communities and businesses. In addition, the permanent housing market could also experience 45 increased vacancies and decreased prices if operations workers and their families move out of 46 Environmental Impacts of Alternatives 8-44 the LGS region . However, the increased property taxes paid by wind farms may offset lost tax 1 revenues in local jurisdictions . Based on this information, socioeconomic impacts during wind 2 farm operations could range from SMALL to MODERATE. 3 8.4.9. Transportation 4 Transportation impacts during the construction and operation of the wind alternative would be 5 less than the impacts for the NGCC, SCPC, and new nuclear alternatives, discussed in the 6 previous sections, because of a smaller construction workforce and smaller volume of materials 7 and equipment needed to be transported to the construction site. 8 As described in 8.4.7, up to 200 workers could be commuting daily to the site during periods of 9 peak construction activity (Exelon 2011). Workers commuting to the construction site would 10 arrive by site access roads and the volume of traffic on nearby roads could increase during shift 11 changes. In addition to commuting workers, trucks would be transporting construction materials 12 and equipment to the worksite, thus increasing the amount of traffic on local roads. The 13 increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 14 service impacts and delays at intersections. Transporting heavy and oversized wind turbine 15 components on local roads could have a noticeable impact over a large area. Some 16 components and materials could also be delivered by train or barge, depending on location. 17 Train deliveries could cause additional traffic delays at railroad crossings. Based on this 18 information, traffic-related transportation impacts during construction could range from SMALL 19 to MODERATE depending on the location of the wind farm site, road capacities, and traffic 20 volumes. 21 During plant operations, transportation impacts would not be noticeable. Exelon estimated an 22 operational workforce of 50 workers (Exelon 2011). Given the small number of operations 23 workers, transportation impacts on local roads would be SMALL. 24 8.4.10. Aesthetics 25 The analysis of aesthetic impact s focuses on the degree of contrast between the wind farms 26 and the surrounding landscape and the visibility of wind turbines. In general, aesthetic changes 27 would be limited to the immediate vicinity of the wind farms. However, wind turbines would 28 have the greatest visual impact. At 400 ft (122 m) tall (Exelon 2011) and spread across multiple 29 sites, wind turbines would dominate the view and would likely become the major focus of 30 attention. Because wind farms are generally located in rural or remote areas, the introduction of 31 wind turbines will be in sharp contrast to the visual appearance of the surrounding environment. 32 Placing turbines along ridgelines would maximize their visibility. Wind turbines also generate 33 noise. Most other noises would be limited to industrial processes and communications. Based 34 on this information, aesthetic impacts from the construction and operation of a land -based wind 35 alternative would range from MODERATE to LARGE depending on location and surroundings. 36 8.4.11. Historic and Archaeological Resources 37 To consider effects on historic and archaeological resources, any areas potentially affected by 38 the construction of a wind alternative would need to be surveyed to identify and record historic 39 and archaeological resources. Any resources found in these surveys would need to be 40 evaluated for eligibility on the NRHP, and mitigation of adverse effects would need to be 41 addressed if eligible resources were encountered. The owner of the wind farms would need to 42 survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, 43 other ROWs). Areas with the greatest sensitivity should be avoided. Visual impacts on 44 Environmental Impacts of Alternatives 8-45 significant cultural resources-such as the viewsheds of historic properties near the sites -also 1 should be assessed. 2 The potential for impacts on historic and archaeological resources from the wind alternative 3 would vary greatly, depending on the location of the proposed sites. Areas with the greatest 4 sensitivity could be avoided or effectively managed under current laws and regulations. 5 However, construction of wind farms and their support infrastructure have the potential to 6 notably impact historic and archaeological resources because of earthmoving activities 7 (e.g., grading and digging) and the aesthetic changes they may bring to the viewshed of historic 8 properties located nearby. Therefore, depending on the resource richness of the site chosen for 9 the wind farms and associated infrastructure, the impacts could range from SMALL to LARGE. 10 8.4.12. Environmental Justice 11 The environmental justice impact analysis evaluates the potential for disproportionately high and 12 adverse human health, environmental, and socioeconomic effects on minority and low -income 13 populations that could result from the construction and operation of new wind farms. As 14 previously discussed in Section 8.1.12, such effects may include human health, biological, 15 cultural, economic, or social impacts. 16 Potential impacts to minority and low -income populations would mostly consist of environmental 17 and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise 18 and dust impacts during construction would be short term and primarily limited to onsite 19 activities. Minority and low -income populations residing along site access roads would be 20 affected by increased commuter vehicle and truck traffic. However, because of the temporary 21 nature of construction, these effects are not likely to be high and adverse and would be 22 contained to a limited time period during certain hours of the day. Increased demand for rental 23 housing during construction could affect low -income populations. However, given the small 24 number of construction workers and the possibility that workers could commute to the 25 construction site, the need for rental housing would not be significant. Minority and low -income 26 populations living in close proximity to the wind farms could be disproportionately affected by 27 wind farm operations. However, operational impacts would mostly be limited to noise and 28 aesthetic effects. The general public living near the wind farms would also be exposed to the 29 same effects. 30 Based on this information and the analysis of human health and environmental impacts 31 presented in this SEIS, the construction and operation of new wind farms would not have 32 disproportionately high and adverse human health and environmental effects on minority and 33 low-income populations. 34 8.4.13. Waste Management 35 During the construction stage of the wind alternative facility, land clearing and other construction 36 activities would produce minor quantities of waste. Only small quantities of waste, such as 37 dielectric fluids used during maintenance activities, would be produced during operation 38 (Exelon 2011). In addition, Table 8-2 of the GEIS (NRC 1996), the staff identified very minor 39 amounts of waste from maintenance of equipment and potentially removing vegetation. Based 40 on this information, waste impacts would be SMALL for a wind turbine site. 41 Environmental Impacts of Alternatives 8-46 Table 8-5. Summary of Environmental Impacts of the Wind Alternative Compared to 1 Continued Operation of the Existing LGS 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. 8.5. Purchased Power 3 The impacts from purchased power would depend substantially on the generation technologies 4 used to supply the purchased power. Given PJM 's market-based system operations, 5 replacement power could come from different generators at different times of the year, so 6 impacts are not necessarily predictable. Impacts from operation of other generators would likely 7 occur in Pennsylvania or elsewhere in PJM. 8 Exelon assumed that purchased power would be available as a reasonable alternative for 9 meeting load obligations if the LGS licenses are not renewed (Exelon 2011). The NRC staff 10 finds this assessment reasonable given the large size of PJM and wide range of existing and 11 potential energy -producing facilities available to purchase power. Purchased power would likely 12 come from one or more of the other types of alternatives considered in this chapter. As a result, 13 operational impacts would be similar to the operational impacts of the alternatives considered in 14 this chapter. Unlike the alternatives considered in this chapter, however, facilities from which 15 power would be purchased would not likely be constructed solely to replace LGS. Purchased 16 power may, however, require new transmission lines (which may require new construction), and 17 may also rely on slightly older and less efficient power plants' operating at higher capacities 18 than they currently operate. Exelon, in the ER, states that impacts would be "incremental and 19 reflective of the increased amount of power being produced," and may vary based on fuels 20 used, waste management practices, and facility locations (Exelon 2011). 21 At some times, some portion of replacement power needs may be addressed by PJM's 22 demand-response program, which the staff discusses in Section 8.6.1 4. As noted in 23 Section 8.6.1 4, impacts from DSM programs are generally small, although backup generators 24 could impact air quality. 25 Environmental Impacts of Alternatives 8-47 During operations, impacts from new nuclear, coal -fired, and natural gas -fired plants and wind 1 energy projects would be similar to that described under the new nuclear, coal, natural gas, and 2 wind alternatives described in the previous sections. Impacts from the operations of existing 3 coal and natural gas-fired plants would likely be greater than the operations of new plants 4 because older plants are more likely to be less efficient and without modern emissions controls. 5 Air quality impacts from the combination of all sources would likely be greater than license 6 renewal because a large portion of the purchased power would likely be from coal- and natural 7 gas-fired plants. 8 While purchased power is a reasonable alternative, the potential impacts of constructing and 9 operating new power generating facilities are addressed elsewhere in this chapter. In general, 10 the impacts would likely be greater than license renewal because of potential new construction 11 and because continued operation of older plants could result in higher emissions. A brief 12 summary of the impacts for each resource area is provided below: 13 Air Quality
- SMALL to MODERATE 14 New and continued nuclear and wind energy generation would not have noticeable impacts on 15 air quality.
New and continued natural gas- and coal-fired plants would have noticeable impacts 16 on air quality; both natural gas- and coal-fired plants emit higher amounts of NO x, SO x, PM, 17 PAHs, CO, CO 2, and mercury as compared to LGS Units 1 and 2, and would have noticeable 18 impacts. 19 Groundwater and Surface Water
- SMALL 20 New and continued operation of nuclear, coal
-fired, and natural gas -fired plants and wind 21 energy projects would not have noticeable impacts on water resources assuming all energy 22 generating facilities operate within their associated water quality and water use permits. 23 Terrestrial and Aquatic
- SMALL to MODERATE 24 New and continued operation of existing natural gas
-fired and nuclear plants would not have 25 noticeable impacts on aquatic and terrestrial resources assuming plants are built in areas that 26 avoid sensitive species and habitats. New land-based wind energy projects would not have 27 noticeable impacts on aquatic resources assuming projects are built in areas that avoid 28 sensitive species and habitats. New wind energy projects would have noticeable impacts on 29 avian and bat communities. Any new transmission lines would likely be collocated with existing 30 right-of-way, which would minimize impacts to ecological resources. New and continued 31 operation of coal -fired plants would have noticeable impacts primarily because of the deposition 32 of ash and other pollutants and because of the extent of terrestrial habitat disturbance 33 associated with coal mining. 34 Human Health
- SMALL 35 New and continued operation of existing nuclear, coal
-fired, and natural gas -fired plants and 36 wind energy projects would not have noticeable impacts on human health because of the extent 37 of regulations to protect public health. 38 Land Use: SMALL to LARGE 39 Purchased power from existing nuclear power plants would not cause any land use changes. 40 New power plants would be constructed at existing power plant sites. Purchased power from 41 coal- and natural gas -fired plants could have a noticeable impact on land use because of the 42 amount of land required for coal mining and gas drilling. Wind energy projects would have a 43 noticeable land -use impact because of the large amount of land required for wind farms. Any 44 new transmission lines would likely be collocated with existing right -of-way, which would 45 minimize any land use impacts. 46 Environmental Impacts of Alternatives 8-48 Socioeconomics , Transportation, and Aesthetics: SMALL to LARGE 1 Purchased power from existing power plants would not have any socioeconomic impact, 2 because there would be no change in power plant operations or workforce. Construction of new 3 electrical power generating facilities could cause noticeable short -term socioeconomic and 4 transportation impacts because of the number of construction workers required to build the new 5 power plant. Traffic volumes would increase on local roads during shift changes. Continued 6 operations of existing power plants would not have noticeable increased socioeconomic impacts 7 as there would be no change in the number of workers at existing power generation facilities. 8 Wind energy projects would have the greatest visual impact; wind turbines would dominate the 9 view and would likely become the major focus of attention. 10 Archaeological and Historic Properties
- SMALL to LARGE 11 No direct impacts on historic and archaeological resources are expected from purchased power.
12 If new transmission lines were needed to convey power to the PJM area, surveys similar to 13 those discussed in Section 8.1.11 would need to be performed. However, transmission lines 14 would likely be collocated with existing right -of-ways minimizing any impacts to historic and 15 archaeological resources. 16 Indirectly, construction of new nuclear, coal -fired, and natural gas -fired plants, wind energy 17 projects and any new transmission lines to support the purchased power alternative could affect 18 archaeological and historic resources. Any areas potentially affected by the construction would 19 need to be surveyed to identify and record historic and archaeological resources. Resources 20 found in these surveys would need to be evaluated for eligibility on the NRHP and mitigation of 21 adverse effects would need to be addressed if eligible resources were encountered. Plant 22 operators would need to survey all areas associated with operation of the alternative 23 (e.g., roads, transmission corridors, other ROWs). The potential for impacts on historic and 24 archaeological resources would vary greatly depending on the location of the proposed sites; 25 however, using previously disturbed sites could greatly minimize impacts to historic and 26 archaeological resources. Areas with the greatest sensitivity could be avoided or effectively 27 managed under current laws and regulations. Therefore, depending on the resource richness of 28 the sites chosen, the impacts could range from SMALL to LARGE. 29 Environmental Justice 30 Low-income populations could be disproportionately affected by increased utility bills because of 31 the cost of purchased power. However, programs, such as the low income home energy 32 assistance program in Pennsylvania, are available to assist low -income families in paying for 33 increased electrical costs. 34 Waste Management
- SMALL to MODERATE 35 New and continued operations of existing nuclear and natural gas
-fired plants and wind energy 36 projects would not have noticeable impacts. However, new and continued generation of 37 coal-fired plants would have noticeable impacts because of the accumulation of ash and 38 scrubber sludge. 39 The impacts presented in Table 8 -6 represent the potential range of impacts from relying on 40 purchased power to replace LGS. Impacts from operation of other generators would likely occur 41 elsewhere in PJM. The overall impacts would range from SMALL to MODERATE. 42 Environmental Impacts of Alternatives 8-49 Table 8-6. Summary of Environmental Impacts of Purchased Power Compared to 1 Continued Operation of the Existing LGS 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 LARG E 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. 8.6. Alternatives Considered but Dismissed 3 Alternatives to LGS license renewal that were considered and eliminated from detailed study 4 are presented in this section. These alternatives were eliminated because of technical, 5 resource availability, or current commercial limitations. Many of these limitations would continue 6 to exist when the current LGS licenses expire. 7 8.6.1. Solar Power 8 Solar technologies, including photovoltaic (PV) and solar thermal (also known as concentrated 9 solar power (CSP)), use the sun's energy to produce electricity at a utility scale. In PV systems, 10 special PV materials convert the energy contained in photons of sunlight incident to direct 11 current (DC) electricity that can be aggregated, converted to alternating current (AC), and 12 connected to the high -voltage transmission grid. Some PV installations, especially those 13 located on existing buildings, provide power directly to consumers without first going onto the 14 grid. CSP technologies produce electricity by capturing the sun's heat energy. CSP facilities 15 are typically grid connected, and owing to their size and operational characteristics, are not 16 located atop existing structures. Although some aspects of solar generation result in few 17 environmental impacts, solar technology requires substantial land areas, and CSP technologies 18 require roughly the same amount of water for cooling of the steam cycle as most other 19 thermoelectric technologies. 20 The potential for solar technologies to serve as reliable baseload power alternative to LGS 21 depends on the value, constancy, and accessibility of the solar resource. Both PV and CSP are 22 enjoying explosive growth worldwide, especially for various off -grid applications or to augment 23 grid-provided power at the point of consumption; however, discrete baseload applications still 24 have technological limitations. As Exelon indicates in the ER, solar power generation typically 25 requires backup generation or other means of balancing its variable output. Further, PV 26 installations have no ability to provide power at night, and they provide reduced levels of power 27 on overcast days, during fog events, and when snow accumulates. While their generation 28 Environmental Impacts of Alternatives 8-50 during summer months is high when electricity consumption is high, their capacity to generate 1 electricity in winter declines before the evening electricity demand peaks. 2 EIA reports the total solar generating capacity (CSP and solar PV) in the United States in 2009 3 was 619 MW, 0.005 percent of the total nationwide generating capacity. Solar power produced 4 891,000 MWh of power in 2009, 0.02 percent of the nationwide production (EIA 2011a). The 5 staff is not aware of any CSP facilities in the United States that are not located in the southwest, 6 while many PV installation s occur throughout the country. As a result, the staff determined that 7 a solar-powered alternative in PJM would rely on solar PV technology rather than CSP 8 technology. 9 Because PV does not produce electricity at night and produces diminished amounts of power 10 during particular weather conditions, the staff does not consider solar PV to provide a viable, 11 standalone alternative to license renewal. The staff considers a standalone PV alternative here, 12 however, because Exelon includes solar PV in its range of alternatives to LGS license renewal 13 in the ER, and because solar PV comprises a portion of the combination alternative in 14 Section 8.6.2. 15 This section addresses only the solar PV impacts, and does not address impacts from load 16 balancing or firming methods, which would be necessary for solar to serve as a standalone 17 alternative to LGS. Technology to achieve load balancing or firming methods is not yet feasible 18 or commercially available, which is part of the reason why the staff's determined that this 19 alternative is not reasonable. As a result, this analysis likely understates potential impacts from 20 a solar PV alternative because technology to achieve load balancing or firming methods would 21 also result in environmental impacts. As discussed in the wind power section, pumped 22 hydroelectric storage, compressed air energy storage, and backup generating capacity could all 23 conceivably offset the variable power output of solar PV facilities. Unlike wind power, however, 24 interconnected solar installations cannot span a sufficient area to provide consistent output at 25 night. 26 Within PJM, solar PV installations receive a 38 percent capacity credit (PJM 2010). On this 27 basis, approximately 6,160 MW(e) of solar capacity would be necessary to replace LGS. 28 Exelon indicates that a utility -scale solar PV facility located in PJM receives 2.8 to 3.9 kWh of 29 solar radiation per square meter per day (2011). (These estimates take into account average 30 weather conditions, and they also account for solar unavailability at night. The estimate thus 31 also accounts for solar capacity factors.) As a result, Exelon estimated that a solar PV facility 32 would require approximately 6.5 ha (16 ac) per MW(e) of capacity (Exelon 2011). The total area 33 necessary for solar PV installations, then, is approximately 40,000 ha (98,900 ac). 34 The staff notes that much of the solar capacity installed in PJM is likely to be in the form of 35 rooftop installations. This type of installation minimizes land disturbance, can provide electricity 36 directly to end -users, and minimizes the modifications necessary to the transmission system. 37 Some land-based installations are also likely to occur. They are likely to be larger than rooftop 38 installations, and they will require some degree of land disturbance for installation purposes. 39 Environmental impacts from the solar PV alternative are summarized in Table 8-7. 40 8.6.1.1. Air Quality 41 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 42 Pennsylvania, and is part of the Metropolitan Philadelphia Int erstate Air Quality Control Region 43 AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), 44 EPA has designated Montgomery and Chester Counties as unclassified or in attainment with 45 respect to carbon monoxide, lead, sulfur dioxide, and PM 10; and nonattainment with respect 46 to ozone and PM2.5 (40 CFR 81.339). 47 Environmental Impacts of Alternatives 8-51 Beyond maintenance activities (e.g. serving equipment or repairs), there would be no routine air 1 emissions associated with operations from solar PV. Activities associated with the construction 2 and installation would cause some temporary air pollutant emissions. However, emissions from 3 workers' vehicles and construction equipment exhaust would be temporary. The staff concludes 4 that the air quality impact from construction would be SMALL. 5 Greenhouse Gas Emissions 6 Solar PV installations release no GHGs during operation, although some GHG emissions occur 7 during component manufacturing, transportation, and installation, as well as during site 8 preparation. Greenhouse gas emissions during construction of this alternative would result 9 primarily from the consumption of fossil fuels in the engines of construction vehicles and 10 equipment, workforce vehicles used in commuting to and from the work site, and delivery 11 vehicles. However, all such impacts would be temporary. In general, solar PV installations are 12 among the least carbon -intensive electric generation options available. For a comparison to 13 other means of electric generation, see the discussion in Chapter 6. 14 Given the expected small workforces and GHGs emitted during construction, site preparation 15 and installation, the overall impact from the release of GHGs of the solar PV alternative would 16 be SMALL. 17 Conclusion 18 Based on the above analysis, the impact would be SMALL. 19 8.6.1.2. Groundwater Resources 20 For construction of solar PV installations, the need for groundwater dewatering likely would be 21 minimal because of the small footprint and shallow depth of excavation for PV installations. For 22 all construction activities, appropriate BMPs, including spill prevention practices, would be used 23 during construction to prevent or minimize impacts on groundwater quality. Operation of PV 24 units would not be expected to have any appreciable effect on groundwater resources. Based 25 on the foregoing, the impacts on groundwater use and quality associated with the solar PV 26 alternative would be SMALL. 27 8.6.1.3. Surface Water Resources 28 Siting and construction of solar PV installations would require relatively small amounts of water 29 for dust suppression and soil compaction during site clearing and for concrete production. The 30 NRC assumes that required water would be procured from offsite sources and trucked to the 31 point of use on an as needed basis. Use of ready -mix concrete also would reduce the need for 32 onsite use of nearby water sources. To support operations, water additionally would be 33 required to clean PV panels. The staff expects that water would be trucked to the point of use 34 and procured from nearby sources or could be supplied from a municipal water source. 35 Adherence to appropriate waste management and minimization plans, spill prevention practices, 36 and pollution prevention plans during servicing of PV installations would minimize the risks to 37 soils and surface water resources from spills of petroleum, oil, and lubricant products and runoff. 38 As a result, the impacts on surface water use and quality under this alternative would be 39 SMALL. 40 8.6.1.4. Aquatic Resources 41 Construction activities for the solar PV alternative (such as construction of heavy -haul roads and 42 the solar panels) could affect drainage areas or other onsite aquatic features. Minimal impacts 43 on aquatic ecology resources are expected because BMPs would likely be used to minimize 44 erosion and sedimentation at large facilities. Stormwater control measures, which would be 45 required if an NPDES permit was necessary, would minimize the flow of disturbed soils into 46 Environmental Impacts of Alternatives 8-52 aquatic features. Many of the solar panels would be installed on rooftops. Because 1 construction would occur within an existing structure, impacts to aquatic resources would be 2 minimal. During operations, the solar PV alternative would not require consumptive water use. 3 For installations that do not occur on top of existing buildings, operators of the solar PV 4 alternative would need to assess the occurrence and potential impacts to protected aquatic 5 species within surface waters potentially affected during construction. In compliance with the 6 ESA, FWCA, and the Magnuson-Stevens Act, the solar PV operators would need to consult with 7 state officials, NMFS, and FWS to determine whether any avoidance or mitigation measures 8 would be required and to ensure that construction and operation do not adversely affect any 9 Federally listed species or adversely modify or destroy designated critical habitat. 10 The impacts on aquatic ecology would be minor because construction activities would likely 11 require BMPs and stormwater management permits. During operations, the solar PV alternative 12 would not require consumptive water use. Therefore, impacts on aquatic ecology from the solar 13 PV alternative would be SMALL. 14 8.6.1.5. Terrestrial Resources 15 Up to 155 mi 2 (420 km 2) of land would be needed to support a solar PV alternative to replace 16 LGS if all installations were located at standalone solar sites (see Section 8.6.1.7). Because the 17 solar PV alternative would include many relatively small installations on building roofs or existing 18 residential, commercial, or industrial sites, impacts to terrestrial species and habitats would be 19 minimal. Some installations may be built on standalone solar sites, and impacts to terrestrial 20 species and habitats on these sites would vary greatly depending on site selection and the 21 allocation of installations on buildings versus standalone sites. Because many of the 22 installations would likely be installed in developed areas that are already connected to the 23 regional electric grid, construction of additional transmission lines or access roads to solar PV 24 installation sites would likely be unnecessary. The impacts of construction to terrestrial habitats 25 and species could range from SMALL to MODERATE, and the impacts of operation to terrestrial 26 habitats and species would be SMALL. 27 Impacts to protected species and habitats would only occur in locations where solar PV 28 installations are constructed on standalone solar sites. However, as with the previously 29 discussed alternatives, consultation with FWS under the ESA would avoid any potential adverse 30 impacts to Federally listed species or adverse modification or destruction of designated critical 31 habitat. Coordination with state natural resource agencies would further ensure that Exelon 32 would take appropriate steps to avoid or mitigate impacts to state -listed species, habitats of 33 conservation concern, and other protected species and habitats. Consequently, the impacts of 34 construction and operation of the solar PV alternative on protected species and habitats would 35 be SMALL. 36 8.6.1.6. Human Health 37 The manufacture of solar cells involves the use of many hazardous chemicals, including toxic 38 gases (e.g., arsine, phosphine, silane, sulfur hexafluoride, molybdenum hexafluoride, tungsten 39 hexafluoride, hydrogen selenide, hydrochloric, and hydrofluoric acids), toxic metals 40 (e.g., arsenic, cadmium, selenium, and various other heavy metals), and numerous flammable, 41 corrosive, or highly reactive chemicals. In addition, the photocells contain cadmium, selenium, 42 and other heavy metals. However, worker exposure to these hazards often are minimized. For 43 example, a 2003 study conducted jointly by the Electric Power Research Institute (EPRI) and 44 the California Energy Commission (CEC) concluded that the manufacture and use of photocells 45 presented no significant health or environmental risk (EPRI and CEC 2003). In the study, EPRI 46 and CEC (2003) state that the greatest possibility of human health risks comes from the 47 Environmental Impacts of Alternatives 8-53 manufacturing of the solar PV cells. The study states that, because of these health risks, 1 extensive work has been done to reduce those hazards to plant workers. It also states that 2 OSHA and similar state agencies set standards for allowable exposure limits to the various toxic 3 chemicals used in the manufacturing process. 4 Impacts on human health from construction of the solar PV alternative would be similar to 5 impacts associated with the construction of any major industrial facility. Compliance with worker 6 protection rules would control those impacts on workers at acceptable levels. Impacts from 7 construction on the general public would be minimal since limiting active construction area 8 access to authorized individuals is expected. Impacts on human health from the construction of 9 the solar PV alternative would be SMALL. 10 Solar PV panels are encased in heavy -duty glass or plastic. As a result, there is little risk that 11 the small amounts of hazardous semiconductor material they contain will be released into the 12 environment. 13 In the event of a fire, hazardous particulate matter could be released to the atmosphere. Given 14 the short duration of fires and the high melting points of the materials found in the solar 15 photovoltaic panels, the impacts from inhalation are minimal. Also, the risk of fire at 16 ground-mounted solar installations is minimal because of precautions taken during site 17 preparation, such as the removal of fuels and the lack of burnable materials contained in the 18 solar photovoltaic panels. Another potential risk associated with photovoltaic systems and fire is 19 the potential for shock or electrocution if a person would come in contact with a high -voltage 20 conductor. Proper procedures and clear marking of system components should be used to 21 provide emergency responders with appropriate warnings to diminish risk of shock or 22 electrocution (OIPP 2010). 23 Photovoltaic solar panels do not produce electromagnetic fields at levels considered harmful to 24 human health established by the International Commission on Non -Ionizing Radiation 25 Protection. These small electromagnetic fields diminish significantly with distance and are 26 indistinguishable from normal background levels within several yards (OIPP 2010). 27 Overall, given proper health -based regulation through procedures and access limitations, the 28 staff expects human health impacts from operation of the Solar PV alternative at an alternate 29 site to be SMALL. 30 8.6.1.7. Land Use 31 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and 32 operating various replacement power plant alternatives on land use, both on and off each power 33 plant site. The analysis of land -use impacts focuses on the amount of land area that would be 34 affected by the installation and operation of solar PV technologies. PV technologies would 35 generally be installed on building roofs at existing residential, commercial, or industrial sites. 36 Some solar installations may also be built at standalone solar sites. Land use impacts may vary 37 depending on the amount of additional land required and the actual allocation of solar 38 installations. 39 The footprint of a utility scale standalone PV solar installation would be quite large. Based on 40 Exelon's local PJM territory estimates, approximately 98,900 ac (40,000 ha or 155 mi 2 41 [400 km 2]) of land would be needed to support a solar PV alternative to replace the LGS 42 (Exelon 2011). Land required for a standalone PV solar installation would alter the existing land 43 to energy production, and would preclude most other land uses from coexisting. Land would 44 also be needed for transmission lines to connect PV solar installations to the electrical power 45 grid and site access roads for maintenance purposes. Installing PV solar technologies on 46 building rooftops would reduce the amount of land required for standalone solar. 47 Environmental Impacts of Alternatives 8-54 The elimination of uranium fuel for the LGS would partially offset some, but not all, of the land 1 requirements for standalone PV solar sites. Scaling from GEIS estimates, approximately 2 1,640 ac (660 ha) (NRC 1996) would no longer be needed for mining and processing uranium 3 during the operating life of the plant. Based on this information, overall land -use impacts from 4 the construction and operation of a PV solar alternative could range from SMALL to LARGE, 5 depending in part on the extent to which PV installations occur on existing buildings rather than 6 standalone sites. 7 8.6.1.8. Socioeconomics 8 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 9 (1) construction jobs, which are transient, short in duration, and less likely to have a long -term 10 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 11 long-term socioeconomic impacts. Workforce requirements for the construction and operation 12 of the PV alternative were evaluated in order to measure their possible effects on current 13 socioeconomic conditions. 14 Exelon estimated 200 construction and 50 operations workers would be required for this 15 alternative (Exelon 2011). These estimates appear reasonable and in line with current 16 construction and operational trends. Because of the relatively small number of construction 17 workers and the potentially large area covered by the PV solar installations at standalone sites 18 and other locations, the relative economic impact of this many workers on local communities 19 and the tax base would be SMALL. Given the small number of operations workers, 20 socioeconomic impacts associated with operation of the PV solar installations would also be 21 SMALL. 22 The reduction in employment at LGS could affect property tax revenue and income in local 23 communities and businesses. In addition, the permanent housing market could also experience 24 increased vacancies and decreased prices if operations workers and their families move out of 25 the LGS region. However, the amount of property taxes paid for a utility -scale standalone PV 26 solar installation may offset lost tax revenues in the socioeconomic region around local 27 jurisdictions if more land is required for solar installations. Based on this information, 28 socioeconomic impacts during PV solar power generating operations could range from SMALL 29 to MODERATE. 30 8.6.1.9. Transportation 31 Transportation impacts during the construction and operation of the PV alternative would be 32 similar to the wind alternative, discussed in Section 8.4.10, as a smaller construction workforce 33 and smaller volume of materials and equipment would be needed to be transported to the 34 construction site. 35 During periods of peak construction activity, up to 200 workers could be commuting daily to the 36 sites (Exelon 2011). Workers commuting to the construction sites would arrive by site access 37 roads and the volume of traffic on nearby roads could increase during shift changes. In addition 38 to commuting workers, trucks would be transporting construction materials and equipment to the 39 worksites, thus increasing the amount of traffic on local roads. The increase in vehicular traffic 40 would peak during shift changes, resulting in temporary levels of service impacts and delays at 41 intersections. Delays may not be noticeable because the solar alternative may be spread 42 across multiple sites. Some components and materials could also be delivered by train or 43 barge, depending on the locations. Train deliveries could cause additional traffic delays at 44 railroad crossings. Based on this information, traffic related transportation impacts during 45 construction could range from SMALL to MODERATE depending on the location of the 46 standalone site, road capacities, and traffic volumes. 47 Environmental Impacts of Alternatives 8-55 During plant operations transportation impacts would not be noticeable because of the small 1 estimated operational workforce spread across multiple sites. Exelon estimated an operational 2 workforce of 50 workers (Exelon 2011), which appears reasonable. Given the small numbers of 3 operations workers, the traffic impacts on local roads from PV solar installation operations would 4 be SMALL. 5 8.6.1.10. Aesthetics 6 The analysis of aesthetic impacts focuses on the degree of contrast between PV solar 7 installations and the surrounding landscape and the visibility of PV installed technologies. In 8 general, aesthetic changes would be limited to the immediate vicinity of PV solar installations. 9 As previously discussed, the footprint of a utility scale standalone PV solar installation would be 10 quite large, and could create a noticeable visual impact. Spread across a large site, the utility 11 scale standalone PV solar installation could dominate the view and would likely become the 12 major focus of attention. The introduction of a utility scale standalone PV solar installation 13 would be in sharp contrast to the visual appearance of the surrounding environment. Installing 14 PV solar technologies on building rooftops, although noticeable to a lesser degree in urban 15 settings, would reduce the amount of land required for standalone solar sites. Any noise at 16 utility scale standalone PV solar installation would be limited to industrial processes and 17 communications. Based on this information, aesthetic impacts from the construction and 18 operation of a PV alternative could range from MODERATE to LARGE depending on the type of 19 solar technology installed and its location and surroundings. 20 8.6.1.11. Historic and Archaeological Resources 21 Any areas potentially affected by the construction of the solar alternative would need to be 22 surveyed to identify and record historic and archaeological resources. Resources found in 23 these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse 24 effects would need to be addressed if eligible resources were encountered. Plant operators 25 would need to survey all areas associated with operation of the alternative (e.g., roads, 26 transmission corridors, other ROWs). Visual impacts on significant cultural resources-such as 27 the viewsheds of historic properties near the sites -should also be assessed. 28 The impacts of the construction of a new solar PV alternative on historic and archaeological 29 resources will vary depending on the form of the solar capacity installed in PJM. Rooftop 30 installations minimize land disturbance and the modifications necessary to the transmission 31 system, thereby minimizing impacts to historic and archaeological resources. Land -based 32 installations are larger than rooftop installations and will require some degree of land 33 disturbance for installation purposes, potentially causing greater impacts to historic and 34 archaeological resources. Aesthetic changes caused by the installation of both forms could 35 have a noticeable effect on the viewshed of nearby historic properties. Using previously 36 disturbed sites for land -based installations and collocating any new transmission lines with 37 existing right -of-ways could minimize impacts to historic and archaeological resources. Areas 38 with the greatest sensitivity could be avoided or effectively managed under current laws and 39 regulations. Therefore, depending on the resource richness of the sites chosen and the type of 40 solar technology installed, the impacts could range from SMALL to LARGE. 41 8.6.1.13. Environmental Justice 42 The environmental justice impact analysis evaluates the potential for disproportionately high and 43 adverse human health, environmental, and socioeconomic effects on minority and low -income 44 populations that could result from the construction and operation of PV solar installations. As 45 previously discussed in Section 8.1.12, such effects may include human health, biological, 46 cultural, economic, or social impacts. 47 Environmental Impacts of Alternatives 8-56 Potential impacts to minority and low -income populations would mostly consist of environmental 1 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 2 housing impacts). Noise and dust impacts during construction would be short term and 3 primarily limited to onsite activities. Minority and low -income populations residing along site 4 access roads would be affected by increased commuter vehicle and truck traffic. However, 5 because of the temporary nature of construction, these effects would only occur during certain 6 hours of the day and not likely to be high and adverse and would be contained to a limited time 7 period during certain hours of the day. Increased demand for rental housing during construction 8 could affect low -income populations. However, given the small number of construction workers 9 and the possibility that workers could commute to the construction site, the need for rental 10 housing would not be significant. 11 Minority and low -income populations living in close proximity to the PV solar installations could 12 be disproportionately affected by operations. However, operational impacts would mostly be 13 limited to aesthetic effects. The general public living near the PV solar installation would also be 14 exposed to the same effects. 15 Based on this information and the analysis of human health and environmental impacts 16 presented in this SEIS, the construction and operation of PV solar installations would not have 17 disproportionately high and adverse human health and environmental effects on minority and 18 low-income populations. 19 8.6.1.14. Waste Management 20 During the construction stage of a solar PV facility, land clearing and other construction 21 activities would produce minor quantities of waste. During operation, very small quantities of 22 waste might be produced when operators perform maintenance activities. Based on this 23 information, waste impacts would be SMALL for the solar PV alternative. 24 Table 8-7. Summary of Environmental Impacts of the Solar PV Alternative Compared to 25 Continued Operation of the Existing LGS 26 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 SMAL L (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
Environmental Impacts of Alternatives 8-57 8.6.2. Combination Alternative: Wind, Solar, and NGCC 1 The combination alternative consists of 2,300 MW(e) of installed wind capacity, 3,000 MW(e) of 2 solar PV capacity, and 400 MW(e) of NGCC capacity to provide the balance needed to replace 3 LGS. The impacts of this alternative are similar to the combined and scaled impacts of the 4 NGCC, wind, and solar PV alternatives considered in Sections 8.1, 8.4, and 8. 6.1, respectively. 5 The staff assumes that sufficient rooftop space exists throughout PJM to support installation of 6 the solar-PV portion of this alternative solely on existing structures, thus minimizing potential for 7 land-use and terrestrial ecology impacts from solar PV installations. The staff applied a 8 capacity-factor-based approach to determining the relative amount of wind power (much as it 9 did in Section 8.4), and applied a capacity -credit approach to solar -PV capacity (using PJM's 10 38 percent capacity credit) in this alternative. The NGCC capacity considered here provides 11 backup and firming capacity to the variable wind and solar PV resources, though it may not be 12 adequate to provide full firming capacity at all times (e.g., on nights with little wind across PJM). 13 At the same time, this alternative may produce markedly more power than LGS on days that are 14 both sunny and windy. 15 Because this alternative many not be able to generate 2,340 MW(e) because of the variable 16 wind and solar PV resources, the staff does not consider the wind, solar, and NGCC 17 combination alternative to provide a viable, standalone alternative to license renewal. The staff 18 considers a standalone alternative here, however, because Exelon includes a wind, solar, and 19 NGCC combination alternative in its range of alternatives to LGS license renewal in the ER. 20 Table 8-8 summarizes the environmental impacts of the combination alternative compared to 21 the continued operation of LGS. 22 8.6.2.1. Air Quality 23 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 24 Pennsylvania, and is part of the Metropolitan Philadelphia Int erstate Air Quality Control Region 25 AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), 26 EPA has designated Montgomery and Chester Counties as unclassified or in attainment with 27 respect to carbon monoxide, lead, sulfur dioxide, and PM 10; and nonattainment with respect to 28 ozone and PM2.5 (40 CFR 81.339). 29 This alternative includes a combination of generation from wind, solar, and NGCC capacity. 30 Operational air emissions would only be associated with the NGCC portion (400 MW[e]) of this 31 alternative. The NGCC component would qualify as a new major -emitting industrial facility and 32 would be subject to PSD under CAA requirements (EPA 2012a). The Pennsylvania Department 33 of Environmental Protection (PADEP) has adopted 25 Pa. Code Chapter 127, which implements 34 the EPA's PSD review. The NGCC plant would need to comply with the standards of 35 performance for stationary combustion turbines set forth in 40 CFR Part 60 Subpart KKKK. 36 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 37 including the review of the new sources that may affect visibility in any Federal Class I area. If 38 the NGCC component of this combination alternative were located close to a mandatory Class I 39 area, additional air pollution control requirements would be required. As noted in 40 Section 2.2.2.1, there are no Mandatory Class I Federal areas within 50 miles (80 km) of the 41 LGS site. There are a total of 13 designated Class 1 Federal areas (40 CFR 81) located in the 42 following PJM states: Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, 43 and West Virginia. 44 A new NGCC plant would have to comply with Title IV of the CAA (42 USC §7651) reduction 45 requirements for SO 2 and NOx, which are the main precursors of acid rain and the major cause 46 of reduced visibility. Title IV establishes maximum SO 2 and NOx emission rates from the 47 Environmental Impacts of Alternatives 8-58 existing plants and a system of SO 2 emission allowances that can be used, sold, or saved for 1 future use by the new plants. 2 More recently, EPA has promulgated additional rules and requirements that apply to certain 3 fossil-fueled power plants, such as NGCC generation. The Cross -State Air Pollution Rule 4 (CSAPR) and the Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) 5 Tailoring Rule impose several additional standards to limit ozone, particulate, and GHG 6 emissions from fossil -fuel based power plants (EPA 2012c). A new NGCC plant would be 7 subject to these additional rules and regulations. 8 The EPA has developed standard emission factors that relate the quantity of released air 9 pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the 10 staff projects the following air emissions for the NGCC portion of this alternative: 11 sulfur oxides (SO x) - 31.4 tons (28.5 MT) per year, 12 nitrogen oxides (NO x) - 91.5 tons (83.0 MT) per year, 13 carbon monoxide (CO) - 138.7 tons (125.8 MT) per year, 14 PM 10 and PM 2.5 - 61.0 tons (55.4 MT) per year, and 15 carbon dioxide (CO
- 2) - 1,016,100 tons (922,622 MT) per year.
16 Activities associated with the construction of the combination alternative, which includes wind, 17 solar, and NGCC, would cause some additional, temporary air effects as a result of equipment 18 emissions and fugitive dust from operation of the earth -moving and material -handling 19 equipment. Emissions from workers' vehicles and motorized construction equipment exhaust 20 would be temporary. Construction crews would use dust -control practices to control and reduce 21 fugitive dust. The staff concludes that the impact of vehicle exhaust emissions and fugitive dust 22 from operation of the earth -moving and material -handling equipment would be SMALL. 23 Greenhouse Gas Emissions 24 As discussed in Sections 8.1.1 and 8.2.1, combustion of fossil fuels, including natural gas, is the 25 greatest anthropogenic source of GHG emissions in the United States. As noted in 26 Sections 8.4.1 and 8.6.1.1-and discussed in Section 6.2 -wind power and solar PV generation 27 are among the least GHG -intensive generation options available. 28 Greenhouse gas emissions during construction of this alternative would result primarily from the 29 consumption of fossil fuels in the engines of construction vehicles and equipment, workforce 30 vehicles used in commuting to and from the work site, and delivery vehicles. However, all such 31 impacts would be temporary. 32 Only the NGCC portion of this alternative would emit GHGs during operations, and it would emit 33 approximately 25 percent of the emissions of the full NGCC alternative that the staff evaluated 34 in Section 8.1.1. As discussed in Section 8.1.1, NETL estimates that CCS will capture and 35 remove as much as 90 percent of the CO 2 from the exhausts of combustion turbines but wil l 36 result in a power production capacity decrease of approximately 14 percent, a reduction in net 37 overall thermal efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a potential 38 increase in the levelized cost of electricity produced in NGCC units so equipped by as much as 39 30 percent (NETL 2007). Further, permanent sequestering of the CO 2 would involve removing 40 impurities (including water) and pressurizing it to meet pipeline specifications and transferring 41 the gas by pipeline to acceptable geologic formations. Even when opportunities exist to utilize 42 the CO 2 for enhanced oil recovery (rather than simply dispose of the CO 2 in geologic 43 formations), permanent disposal costs could be substantial, especially if the NGCC unit is far 44 removed from acceptable geologic formations. With CCS in place, the NGCC portion of this 45 alternative would release 92,2 62 MT per year (0.102 million tons) of CO
- 2. Without CCS in place, 46 Environmental Impacts of Alternatives 8-59 the staff's projected CO 2 emissions for the NGCC portion would be 922,622 MT (1,016,100 1 tons) per year. 2 Given the expected relatively small workforces, relatively short construction period for 3 constructing the alternatives' components, and GHG emissions resulting from operations of the 4 NGCC portion, the overall from the releases of GHGs of the combination alternative would be 5 SMALL to MODERATE. 6 Conclusion 7 There would be no routine air emissions associated with the wind and solar component of this 8 alternative. However, the NGCC component of this alternative would result in routine air 9 emissions. Therefore, the overall air
-quality impact from this combination alternative would be 10 SMALL to MODERATE. 11 8.6.2.2. Groundwater Resources 12 Impacts on groundwater resources from constructing and operating a new NGCC plant under 13 this alternative would be a fraction of those described in Section 8.1.2. For construction of wind 14 turbine and solar PV installations, the need for groundwater dewatering likely would be minimal. 15 For all construction activities, appropriate BMPs, including spill prevention practices, would be 16 used during wind turbine construction to prevent or minimize impacts on groundwater quality. 17 Operation of the wind turbine and PV components of this alternative would not be expected to 18 have any appreciable effect on groundwater resources. Based on the above, the impacts on 19 groundwater use and quality under this alternative would be SMALL. 20 8.6.2.3. Surface Water Resources 21 Impacts on surface water resources from constructing and operating a new NGCC plant under 22 this alternative would be a fraction of those described in Section 8.1.3 because the NGCC 23 component has been scaled back to 400 MW(e). Construction of the wind turbine and solar PV 24 installations would each require relatively small amounts of water for dust suppression and soil 25 compaction during site clearing and for concrete production. The NRC assumes that required 26 water would be procured from offsite sources and trucked to the point of use on an as needed 27 basis. Use of ready -mix concrete would also reduce the need for onsite use of nearby water 28 sources. 29 To support operation of individual wind turbine installations, only very small amounts of water 30 would be needed to periodically clean turbine blades and motors as part of routine servicing. 31 Water also would be required to clean PV panels. The staff expects that water would be 32 trucked to the point of use and procured from nearby sources. Adherence to appropriate waste 33 management and minimization plans, spill prevention practices, and pollution prevention plans 34 during servicing of turbine and PV installations would minimize the risks to soils and surface 35 water resources from spills of petroleum, oil, and lubricant products and runoff. As a result, the 36 impacts on surface water use and quality under the combination alternative would be SMALL. 37 8.6.2.4. Aquati c Resources 38 Construction activities for the wind, solar, and NGCC combination alternative (such as 39 construction of heavy -haul roads, the NGCC power block, wind turbines, and solar panels) 40 could affect drainage areas or other onsite aquatic features. Minimal impacts on aquatic 41 ecology resources are expected because BMPs would likely be used to minimize erosion and 42 sedimentation. Stormwater control measures, which would be required to comply with 43 Pennsylvania NPDES permitting, would minimize the flow of disturbed soils into aquatic 44 features. Depending on the available infrastructure at the selected site, the NGCC plant may 45 require modification or expansion of the existing intake or discharge structures. Because of the 46 Environmental Impacts of Alternatives 8-60 relatively low withdrawal rates compared to the NGCC, SCPC, or new nuclear alternatives, it is 1 unlikely that the operators would need to construct new intake and discharge structures for the 2 combination alternative. Dredging activities that result from infrastructure construction would 3 require BMPs for in -water work to minimize sedimentation and erosion. Because of the 4 short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would 5 likely be localized and temporary. 6 Similar to the NGCC alternative described in Section 8.1.4, during operations, the NGCC 7 component of the combination alternative would require cooling water to be withdrawn from the 8 Schuylkill River or other similar water body, would have chemical discharges, and would emit 9 some pollutants that could settle onto the river surface. However, these impacts would be less 10 than that described in Section 8.1.4 because NGCC would be a smaller portion of this 11 alternative. During operations, the solar PV and wind components of the combination 12 alternative would not require consumptive water use. 13 The impacts on aquatic ecology would be minor because construction activities would require 14 BMPs and stormwater management permits, and because the surface water withdrawal and 15 discharge for this alternative would be less than for LGS Units 1 and 2. Therefore, the staff 16 concluded that impacts on aquatic ecology would be SMALL. 17 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 18 of wind, solar, NGCC plants would not adversely affect any Federally listed species or adversely 19 modify or destroy designated critical habitat. If new infrastructure were located near EFH, 20 consultation with NMFS under the Magnuson -Stevens Act would require NRC to evaluate 21 impacts to EFH and NMFS would provide conservation recommendations if there would be 22 adverse impacts to EFH. Coordination with state natural resource agencies would further 23 ensure that the plant and wind farm operators would take appropriate steps to avoid or mitigate 24 impacts to state-listed species, habitats of conservation concern, and other protected species 25 and habitats. Consequently, the impacts of construction and operation on protected species 26 and habitats would be SMALL. 27 8.6.2.5. Terrestrial Resources 28 Impacts to terrestrial species and habitats from construction and operation of this combined 29 alternative would be similar to those described under each individual alternative in 30 Sections 8.1.5, 8.4.5, and 8.6.1.5. The same is true of mitigation measures. The primary 31 difference in this alternative is that each portion of this alternative is smaller than the 32 full-replacement alternatives considered in Sections 8.1, 8.4, and 8.8.1. Also, solar PV capacity 33 would be installed almost entirely at already -developed sites on building rooftops. Th e 34 wind-power portion of this alternative would require approximately half of the area required for 35 the standalone wind alternative in Section 8.4. The development of the solar component on 36 land already in use for other purposes, combined with the reduced size of the wind -power 37 component, would likely result in minimal additional impacts to terrestrial species and habitats 38 during construction and operation. The NGCC component of this alternative would be smaller 39 and require less land than the NGCC plant described in Section 8.1.5. This alternative still 40 assumes that the NGCC plant would be sited on an already existing power station other than 41 LGS, and predominantly previously developed or pre -disturbed land would be affected. The 42 impacts of construction and operation of this alternative on terrestrial species and habitats 43 would be SMALL because of this alternative's extensive use of developed or previously 44 disturbed land. 45 Because the solar PV installations would be sited on buildings and other already -developed 46 sites, impacts to protected species and habitats would be most likely to occur as a result of the 47 wind or NGCC component of this alternative. As with the previously discussed alternatives, 48 Environmental Impacts of Alternatives 8-61 consultation with FWS under the ESA would avoid potential adverse impacts to Federally list ed 1 species or adverse modification or destruction of designated critical habitat. Coordination with 2 state natural resource agencies would further ensure that Exelon would take appropriate steps 3 to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other 4 protected species and habitats. Consequently, the impacts of construction and operation of this 5 alternative on protected species and habitats would be SMALL. 6 8.6.2.6. Human Health 7 Impacts on human health from construction of the wind alternative, the NGCC alternative, and 8 the solar PV portion of this alternative would be similar to impacts associated with the 9 construction of any major industrial facility. Compliance with worker protection rules would 10 control those impacts on workers at acceptable levels. Impacts from construction on the 11 general public would be minimal since limiting active construction area access to authorized 12 individuals is expected. Impacts on human health from the construction of the wind alternative 13 would be SMALL. 14 Given proper health -based regulation through procedures and access limitations, the staff 15 expects human health impacts from operation of the solar PV and the wind portions of this 16 alternative at an alternate site to be SMALL. 17 The staff notes that human health effects of gas -fired generation are generally low, although in 18 Table 8-2 of the GEIS (NRC 1996), the staff identified cancer and emphysema as potential 19 health risks from gas -fired plants. NO x emissions contribute to ozone formation, which in turn 20 contributes to human health risks. Emission controls on the NGCC alternative can be expected 21 to maintain NO x emissions well below air quality standards established for the purposes of 22 protecting human health, and emissions trading or offset requirements mean that overall NO x 23 releases in the region will not increase. Health risks for workers may also result from handling 24 spent catalysts used for NO x control that may contain heavy metals. Impacts on human health 25 from the operation of the NGCC alternative would be SMALL. 26 8.6.2.7. Land Use 27 As discussed in Section 8.1.7, the GEIS (NRC 1996) generically discusses the impact of 28 constructing and operating various replacement power plant alternatives on land use, both on 29 and off each power plant site. The analysis of land -use impacts here focuses on the amount of 30 land area that would be affected by the construction and operation of a combination of wind 31 turbines, PV solar installations, and a NGCC power plant in the PJM territory. 32 L and-use impacts from this alternative would be similar those described for each of the 33 alternatives described in Sections 8.1.7, 8.4.7, and 8. 6.1.7. Because each component of this 34 alternative would individually be generating less electricity, the magnitude of the impacts from 35 each individual component would be less than those previously described. For example, under 36 this combination alternative, solar PV technology would be installed on existing building 37 rooftops, and approximately half the number of wind turbines would be installed as would be 38 installed in the standalone wind alternative (Section 8.4). In addition, the NGCC component 39 would be constructed at an existing power plant site. 40 The elimination of uranium fuel for the LGS would partially offset some, but not all, new land 41 requirements. Scaling from GEIS estimates, approximately 1,640 ac (660 ha) would no longer 42 be needed for mining and processing uranium during the operating life of the plant. Based on 43 this information, overall land -use impacts from the construction and operation of a combination 44 of wind, solar, and NGCC alternatives would range from SMALL to MODERATE. 45 Environmental Impacts of Alternatives 8-62 8.6.2.8. Socioeconomics 1 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 2 (1) construction jobs, which are transient, short in duration, and less likely to have a long -term 3 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 4 long-term socioeconomic impacts. Workforce requirements for the construction and operation 5 of a combination of wind turbines, PV solar installations, and a NGCC power plant were 6 evaluated in order to measure their possible effects on current socioeconomic conditions. 7 Approximately 200 construction and 50 operations workers would be required for the utility scale 8 wind alternative and 200 construction and 50 operations workers would be required for the 9 solar alternative (see Sections 8.4.8, and 8.6.1.8) (Exelon 2011). These estimates appear 10 reasonable and in line with current construction and operational trends. The construction and 11 operation workforce requirements for these two components of this combination alternative 12 would be much less. The NGCC component scaled down to 400 MW(e) would require 150 13 (Exelon 2011) to 500 (NRC 199 6) construction workers during peak construction and 8 to 14 60 operations workers. Socioeconomic impacts would be similar to those described for NGCC, 15 wind, and solar alternatives discussed in Sections 8.1.8, 8.4.8, and 8.6.1.8, but on a smaller 16 scale than each of the full alternatives. Because of the relatively small number of construction 17 workers scattered over a large area at various locations, the relative economic impact of this 18 many workers on local communities and the tax base would be SMALL. Given the small 19 number of operations workers, socioeconomic impacts associated with operation of the NGCC, 20 wind, and solar components of this combination alternative would also be SMALL. 21 The net reduction in employment at LGS could affect property tax revenue and income in local 22 communities and businesses. In addition, the permanent housing market could also experience 23 increased vacancies and decreased prices if operations workers and their families move out of 24 the region. Nevertheless, the amount of property taxes paid under the combination alternative 25 may offset lost tax revenues in the socioeconomic region around LGS. Based on this 26 information, socioeconomic impacts during operations could range from SMALL to MODERATE. 27 8.6.2.9. Transportation 28 Transportation impacts during the construction and operation of the NGCC, wind, and solar 29 components of this combination alternative would be less than the impacts for the NGCC, wind, 30 and PV solar alternatives, discussed in Sections 8.1.7, 8.4.7, and 8.6.1.7. This is because the 31 construction workforce for each component and the volume of materials and equipment needing 32 to be transported to each respective construction site would be smaller than each of the 33 individual alternatives. In other words, the transportation impacts would not be as concentrated 34 as in the other alternatives, but spread out over a wider area. 35 As previously described for each alternative, workers commuting to the construction site would 36 arrive by site access roads and the volume of traffic on nearby roads could increase during shift 37 changes. In addition to commuting workers, trucks would be transporting construction materials 38 and equipment to the worksite, thus increasing the amount of traffic on local roads. The 39 increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 40 service impacts and delays at intersections. Transporting heavy and oversized wind turbine 41 components on local roads could have a noticeable impact over a large area. Some 42 components and materials could also be delivered by train or barge, depending on location. 43 Train deliveries could cause additional traffic delays at railroad crossings. Based on this 44 information, traffic-related transportation impacts during construction could range from SMALL 45 to MODERATE depending on the location of the NGCC power plant, wind farm, and PV solar 46 installation; road capacities; and traffic volumes. 47 Environmental Impacts of Alternatives 8-63 During operations, transportation impacts would be less noticeable during shift changes and 1 maintenance activities. Given the small number of operations workers, the levels of service 2 traffic impacts on local roads from NGCC power plant, wind farm, and PV solar installation 3 operations would be SMALL. 4 8.6.2.10. Aesthetics 5 The analysis of aesthetic impacts focuses on the degree of contrast between the wind, solar, 6 and NGCC alternative and surrounding landscapes and the visibility of new wind turbines at 7 existing wind farms, PV solar technologies on existing buildings, and the new NGCC plant at an 8 existing power plant site. In general, aesthetic changes would be limited to the immediate 9 vicinity of the wind farms, PV solar installations, and NGCC power plant. 10 Wind turbines would have the greatest potential visual impact. At 400 ft (122 m) tall 11 (Exelon 2011) and spread across multiple sites, wind turbines often dominate the view and 12 become the major focus of attention. However, adding additional wind turbines to existing wind 13 farms at multiple sites is not likely to increase the visible impact of the wind farm unless it 14 significantly increases the number of wind turbines at the wind farm. PV solar technologies 15 located on building rooftops, depending on the angle of the roof, may or may not be seen offsite , 16 and would be less noticeable in urban settings. 17 Located near an existing power plant site, the NGCC power plant could be approximately 100 ft 18 (30 m) tall, with an exhaust stack up to 150 ft (46 m) tall and have two cooling towers over 500 ft 19 (152 m) high (Exelon 2011). The facility would be visible off site during daylight hours, and 20 some structures may require aircraft warning lights. The power block of the new NGCC power 21 plant unit could look very similar to the existing power plant at the site where it would be 22 constructed. The addition of mechanical draft cooling towers and associated condensate 23 plumes could add to the NGCC power plant visual impact. Mechanical draft cooling towers also 24 generate noise. Most other noises during power NGCC plant operations would be limited to 25 industrial processes and communications. Pipelines delivering natural gas fuel could be audible 26 off site near gas compressor stations. 27 Based on this information, aesthetic changes caused by this combination alternative would be 28 limited to the immediate vicinity of the existing facilities and would therefore be SMALL to 29 MODERATE depending on location and surroundings. 30 8.6.2.11. Historic and Archaeological Resources 31 Areas potentially affected by the construction of the NGCC, wind, and solar PV alternative 32 would need to be surveyed to identify and record historic and archaeological resources. Any 33 resources found in these surveys would need to be evaluated for eligibility on the NRHP and 34 mitigation of adverse effects would need to be addressed if eligible resources were 35 encountered. An inventory of a previously disturbed former plant (brownfield) site may still be 36 necessary if the site has not been previously surveyed or to verify the level of disturbance and 37 evaluate the potential for intact subsurface resources. Plant operators would need to survey all 38 areas associated with operation of the alternative (e.g., roads, transmission corridors, other 39 ROWs). Areas with the greatest sensitivity should be avoided. Visual impacts on significant 40 cultural resources-such as the viewsheds of historic properties near the sites -should also be 41 assessed. 42 The impacts of this alternative are similar to the combined and scaled impacts of the NGCC, 43 wind, and solar PV alternatives considered in Sections 8.1, 8.4, and 8. 6.1, respectively. The 44 potential for impacts would vary greatly depending on the location of the proposed site
- s. Use of 45 a previously disturbed site for the NGCC alternative and rooftop PV technology could minimize 46 affects to historic and archaeological resources. Wind turbines could be installed in 47 Environmental Impacts of Alternatives 8-64 pre-established wind farms. Areas with the greatest sensitivity could be avoided or effectively 1 managed under current laws and regulations. However, construction of wind farms sites and 2 their support infrastructure on developed sites, agricultural areas, or previously undisturbed 3 have t he potential to notably impact historic and archaeological resources because of 4 earthmoving activities (e.g., grading and digging). Aesthetic changes from wind farms and solar 5 technology may also impact the viewshed of historic properties located nearby.
Therefore, 6 depending on the resource richness of the site chosen for the NGCC, wind, and solar PV 7 alternative, the impacts could range from SMALL to MODERATE. 8 8.6.2.12. Environmental Justice 9 The environmental justice impact analysis evaluates the potential for disproportionately high and 10 adverse human health, environmental, and socioeconomic effects on minority and low -income 11 populations that could result from the construction and operation of a combination of wind 12 turbines, PV solar installations, and a NGCC power plant. As previously discussed in 13 Section 8.1.12, such effects may include human health, biological, cultural, economic, or social 14 impacts. 15 Potential impacts to minority and low -income populations would mostly consist of environmental 16 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 17 housing impacts). Noise and dust impacts during construction would be short term and 18 primarily limited to onsite activities. Minority and low -income populations residing along sit e 19 access roads would be affected by increased commuter vehicle and truck traffic. However, 20 because of the temporary nature of construction, these effects are not likely to be high and 21 adverse and would be contained to a limited time period during certain hours of the day. During 22 construction, increased demand for rental housing in the vicinity of the site could affect 23 low-income populations living near the plant site. However, given the small number of 24 construction workers and the possibility that workers could commute to the construction site, the 25 need for rental housing would not be significant. 26 Minority and low -income populations living in close proximity to the power generating facilities 27 could be disproportionately affected by wind farm, PV solar, and NGCC power plant operations. 28 However, all would be exposed to the same potential effects from operations, and any effects 29 would depend on the magnitude of the change in ambient conditions. Operational impacts from 30 the wind turbines and PV solar installations would mostly be limited to noise and aesthetic 31 effects. The general public living near the wind farms and PV solar installations would be 32 exposed to the same effects. 33 Based on this information and the analysis of human health and environmental impacts 34 presented in this SEIS, the construction and operation of new wind turbines, PV solar 35 installations, and a NGCC power plant would not have disproportionately high and adverse 36 human health and environmental effects on minority and low -income populations. 37 8.6.2.13. Waste Management 38 During the construction stage of this combination of alternatives (wind, solar, and NGCC), land 39 clearing and other construction activities would generate wastes that could be recycled, 40 disposed of on site, or shipped to the offsite waste disposal facility. During the operational 41 stage, spent SCR catalysts, which control NO x emissions from the NGCC plant, would make up 42 the majority of the waste generated by this alternative, along with some wastes generated 43 during maintenance for the wind and solar operations. 44 The staff concludes that overall waste impacts from the combination of the NGCC unit 45 constructed on an existing site, and renewable energy components such as wind and solar, 46 would be SMALL. 47 Environmental Impacts of Alternatives 8-65 Table 8-8. Summary of Environmental Impacts of the Combination Alternative Compared 1 to Continued Operation of the Existing LGS 2 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) (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 3 In compressed air energy storage (CAES), an electric motor uses electricity to pump air into an 4 underground, pressurized cavity, and when electricity is needed, the operator releases the 5 compressed air through a gas turbine generator. The compressed air provides some power to 6 the generator (essentially, reducing the need for compression by the turbine), and burning 7 natural gas provides heat to increase pressure and to power the turbine. Thus, CAES is not 8 solely an energy storage technology, but also relies on additional fossil fuel (future, 9 as-yet-undeveloped CAES technologies promise no reliance on natural gas). 10 CAES is a commercially viable technology for energy storage, though it is seldom -used on a 11 utility scale. It is in use at one site in the United States and one site in Germany (with capacities 12 of 110 MW[e] and 290 MW[e], respectively). 13 Currently, no state or utility in the United States is operating wind power in combination with 14 compressed air energy storage, let alone doing so to offset baseload power supplies. A group 15 of utilities had proposed a 270 -MW(e) project of that type in Iowa but have since terminated the 16 project because of geologic unsuitability of the proposed site (ISEPA 2011). The McIntosh 17 facility in Alabama is the only existing U.S. compressed air energy storage installation; it 18 provides peaking capacity to existing non -wind generation, and it is relatively small. It provides 19 110 MW(e) of power for up to 26 hours. The McIntosh facility and Germany's Huntorf facility are 20 both based in salt domes. 21 Currently, no compressed air energy storage facilities exist in PJM. In Ohio, First Energy has 22 acquired the Norton Energy Storage project, a proposed CAES facility that could be constructed 23 in a retired limestone mine. The First Energy Nuclear Operating Company (FENOC) indicates 24 that the Norton Energy Storage facility could have a maximum of 536 MW(e) of capacity 25 Environmental Impacts of Alternatives 8-66 available by 2017 (though it has not committed to install this capacity in that time period) and 1 that it has an air permit for up to 804 MW(e) of capacity that the site (FENOC 2011). FENOC 2 indicates that the maximum potential storage capacity at the Norton Energy Storage project is 3 2,700 MW(e) (FENOC 2011). However, the NRC is not aware of a CAES project coupled with 4 wind generation that is providing baseload power. Therefore, the NRC concludes that the use 5 of CAES in combination with wind turbines to generate 2,340 MW(e) in PMJ is unlikely. 6 Because the use of CAES in combination with wind turbines to generate 2,340 MW(e) in PMJ is 7 unlikely, the staff does not consider CAES in combination with wind to provide a viable, 8 standalone alternative to license renewal. The staff considers a standalone alternative here, 9 however, because Exelon includes a CAES and wind combination alternative in its range of 10 alternatives to LGS license renewal in the ER. 11 This section analyzes the potential impacts from a CAES and wind combination alternative. 12 NREL (2006) suggests that 2,000 MW(e) of wind power together with 900 MW(e) of CAES can 13 provide a near -constant 900 MW(e) of output. Using the high capacity factors the staff applied 14 to the windpower alternative in Section 8.4 (which exceeds current wind capacity factors), this 15 alternative relies on 2,000 MW(e) of CAES capacity from a facility similar in operation to the 16 Norton project and 4,500 MW(e) of onshore wind capacity. While the approach in NREL (2006) 17 suggests that 2,340 MW(e) of CAES may be necessary to provide firming capacity that would 18 provide similar baseload potential as that provided by LGS, this alternative underestimates the 19 amount of CAES capacity necessary to provide for technological advances and avoid 20 overstating the potential impacts from relying on a combination of wind and CAES. In general, 21 the staff relies on information from the Norton project to describe the potential impacts of a 22 CAES project, though the staff notes that projects at different sites may incur varying levels of 23 environmental impacts. Where appropriate, the staff scales impacts from the Norton project to 24 account for the size of the CAES project considered here. 25 Table 8-9 summarizes the environmental impacts of the wind and CAES alternative compar ed 26 to the continued operation of LGS. 27 8.6.3.1. Air Quality 28 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 29 Pennsylvania, and is part of the Metropolitan Philadelphia Int erstate Air Quality Control Region 30 AQCR (40 CFR 81.15). With regard to the NAAQS, EPA has designated Montgomery and 31 Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur 32 dioxide, and PM 10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339). 33 This alternative relies on CAES to store electricity produced by wind turbines, which is then 34 released during periods of low wind production. CAES facilities burn natural gas to heat the 35 compressed air; therefore, they produce air emissions. The CAES facility would qualify as a 36 new major-emitting industrial facility and would be subject to PSD under CAA requirements 37 (EPA 2012). The PADEP has adopted 25 Pa. Code Chapter 127, which implements the EPA's 38 PSD review. The CAES plant would need to comply with the standards of performance for 39 stationary combustion turbines set forth in 40 CFR Part 60 Subpart KKKK. 40 Subpart P of 40 CFR Part 51.307 contains visibility protection regulatory requirements, including 41 the review of the new sources that may affect visibility in any Federal Class I area. If the CAES 42 component of this combination alternative were located close to a mandatory Class I area, 43 additional air pollution control requirements would be required. As noted in Section 2.2.2.1, 44 there are no Mandatory Class I Federal areas within 50 miles of the LGS site. There are a total 45 of 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: 46 Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 47 Environmental Impacts of Alternatives 8-67 A new CAES facility would have to comply with Title IV of the CAA (42 USC §7651) reduction 1 requirements for SO 2 and NO x, which are the main precursors of acid rain and the major cause 2 of reduced visibility. Title IV establishes maximum SO 2 and NO x emission rates from the 3 existing plants and a system of SO 2 emission allowances that can be used, sold, or saved for 4 future use by the new plants. 5 More recently, the EPA has promulgated additional rules and requirements that apply to certain 6 fossil-fuel based power plants, such as the CAES portion of this alternative. The CSAPR and 7 the Prevention of Significant Deterioration and Title V GHG Tailoring Rule impose several 8 additional standards to limit ozone, particulate, and GHG emissions from fossil -fuel based 9 power plants (EPA 2012c). A new CAES plant would be subject to these additional rules and 10 regulations. 11 Air emission permits from the Norton CAES Project in Norton, Ohio, were used as a basis for 12 estimating emissions for this alternative. The current Norton air emissions permit allows 13 804 MW(e), so the staff scales the values from the Norton CAES project to 2,000 MW(e) to 14 determine air quality impacts associated with this alternative. The staff projects the following air 15 emissions for the CAES alternative: 16 sulfur oxides (SO x) - 105.5 tons (96.2 MT) per year, 17 nitrogen oxides (NO x) - 233.0 tons (212.4 MT) per year, 18 carbon monoxide (CO) - 224.8 tons (204.9 MT) per year, 19 PM 10 and PM2.5 - 116.0 tons (105.8 MT) per year, and 20 carbon dioxide (CO
- 2) - 1,694,279 tons (1,544,735 MT) per year.
21 Activities associated with the construction of the CAES alternative would cause some additional, 22 temporary air effects as a result of equipment emissions and fugitive dust from operation of the 23 earth-moving and material -handling equipment. Emissions from workers' vehicles and 24 motorized construction equipment exhaust would be temporary. Construction crews could use 25 dust-control practices to control and reduce fugitive dust. The staff concludes that the impact of 26 vehicle exhaust emissions and fugitive dust from operation of the earth -moving and 27 material-handling equipment would be SMALL. 28 Greenhouse Gas Emissions 29 Greenhouse gas emissions during construction of this alternative would result primarily from the 30 consumption of fossil fuels in the engines of construction vehicles and equipment, workforce 31 vehicles used in commuting to and from the work site, and delivery vehicles. However, all such 32 impacts would be temporary. 33 Greenhouse gas emissions during operation would primarily be from natural gas combustion in 34 the combustion turbines (at both the NGCC facility and the CAES facility). However, other 35 miscellaneous ancillary sources such as truck and rail deliveries of materials to the site and 36 commuting of the workforce would make minor contributions. 37 NETL estimates that CCS will capture and remove as much as 90 percent of the CO 2 from the 38 exhausts of combustion turbines, but will result in a power production capacity decrease of 39 approximately 14 percent, a reduction in net overall thermal efficiency of the CTs studied from 40 50.8 percent to 43.7 percent, and a potential increase in the levelized cost of electricity 41 produced in NGCC units so equipped by as much as 30 percent (NETL 2007). Further, 42 permanent sequestering of the CO 2 would involve removing impurities (including water) and 43 pressurizing it to meet pipeline specifications and transferring the gas by pipeline to acceptable 44 geologic formations. Even when opportunities exist to utilize the CO 2 for enhanced oil recovery 45 (rather than simply dispose of the CO 2 in geologic formations), permanent disposal costs could 46 be substantial, especially if the combustion turbines are far removed from acceptable geologic 47 Environmental Impacts of Alternatives 8-68 formations. With CCS in place, the CAES alternative would release 0.154 million MT per year 1 (0.169 million tons) of CO
- 2. Without CCS in place, the CAES alternative would release 1.54 2 million MT (1.69 million tons) of CO 2 per year 3 Given the temporary impacts during the construction period and GHG emissions resulting from 4 operations, the overall from the releases of GHGs of the CAES alternative would be SMALL to 5 MODERATE. 6 Conclusion 7 The overall air quality impacts from CAES alternative would be similar to those of an NGCC 8 facility and would be designated as SMALL to MODERATE.
9 8.6.3.2. Groundwater Resources 10 Impacts on groundwater resources of constructing and operating wind turbine installations 11 under this alternative would be similar to those described in Section 8.4.2. Similarly, for 12 construction and operation of the CAES facility, it is expected that overall impacts would be 13 similar to and would be bounded by those described for the NGCC alternative (see 14 Section 8.1.2) because construction and operations of the two facilities would be relatively 15 similar, although the NGCC plant would be larger than the CAES facility. As an additional 16 impact, pressurization of an underground cavity associated with CAES operations could affect 17 groundwater flow on a localized basis. However, overall impacts on groundwater use and 18 quality under this alternative would be SMALL. 19 8.6.3.3. Surface Water Resources 20 Impacts on surface water resources of constructing and operating wind turbine installations 21 under this alternative would be similar to those described in Section 8.4.3. For construction and 22 operation of the CAES facility, it is expected that overall impacts on surface water would be 23 similar to and would be bounded by those described for the NGCC alternative (see 24 Section 8.1.3). The nature of potential surface water impacts of CAES would depend on the 25 type of CAES reservoir. For CAES using hard rock caverns, makeup water would be required 26 because of evaporation from the surface reservoir and some potential for leakage. With these 27 systems, as well as with porous rock reservoirs, there is generally a provision for pumping of 28 water into the caprock or zones above the caprock to ensure hydraulic overpressure that would 29 counter the potential for air leakage. In general, however, the potential for effects from caprock 30 overpressure requirements would be smaller than the makeup water required for cooling. 31 As a result, the projected cooling water demands would be smaller than the requirement 32 presented in Section 8.1.3 for the NGCC alternative; the demands would relate primarily to 33 removing waste heat from compression of the stored air. In conclusion, the overall impacts on 34 surface water use and quality under this alternative would be SMALL. 35 8.6.3.4. Aquatic Resources 36 Construction activities for the wind and CAES alternative (such as construction of heavy -haul 37 roads, the wind turbines, and CAES facility) could affect drainage areas and other onsite aquatic 38 features. Minimal impacts on aquatic ecology resources are expected as the plant operator 39 would likely implement BMPs to minimize erosion and sedimentation elsewhere on the site. 40 Stormwater control measures, which would be required to comply with Pennsylvania NPDES 41 permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the 42 available infrastructure at the selected site, the CAES facility may require modification or 43 expansion of the existing intake or discharge structures. Because of the relatively low 44 withdrawal rates compared to the NGCC, SCPC, or new nuclear alternatives, it is unlikely that 45 the operators would need to construct new intake and discharge structures. Dredging activities 46 Environmental Impacts of Alternatives 8-69 that result from infrastructure construction would require BMPs for in -water work to minimize 1 sedimentation and erosion. Because of the short-term nature of the dredging activities, the 2 hydrological alterations to aquatic habitats would likely be localized and temporary. 3 During operations, the CAES alternative would require less cooling water to be withdrawn from 4 the Schuylkill River, or other similar water body, than required for LGS Units 1 and 2. In 5 addition, the cooling system for a CAES plant would have similar chemical discharges as LGS. 6 The flow of the Schuylkill River, or other similar waterbo dy, would likely dissipate and dilute the 7 concentration of pollutants resulting in minimal exposure to aquatic biota. 8 The impacts on aquatic ecology would be minor because construction activities would require 9 BMPs and stormwater management permits, and because the surface water withdrawal and 10 discharge for this alternative would be less than for LGS Units 1 and 2. Therefore, the staff 11 concluded that impacts on aquatic ecology would be SMALL. 12 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 13 of wind farms and CAES facility would not adversely affect any Federally listed species or 14 adversely modify or destroy designated critical habitat. If new infrastructure were located nea r 15 EFH, consultation with NMFS under the Magnuson -Stevens Act would require NRC to evaluate 16 impacts to EFH and NMFS would provide conservation recommendations if there would be 17 adverse impacts to EFH. Coordination with state natural resource agencies would further 18 ensure that the CAES and wind farm operators would take appropriate steps to avoid or mitigate 19 impacts to state -listed species, habitats of conservation concern, and other protected species 20 and habitats. Consequently, the impacts of construction and operation on protected species 21 and habitats would be SMALL. 22 8.6.3.5. Terrestrial Resources 23 Impacts to terrestrial species and habitats from construction and operation of this combined 24 alternative would be similar in type, magnitude, and intensity as those described in Section 8.4.5 25 for the wind alternative. The primary difference in impact would result from the additional 92 ac 26 (37 ha) required for the CAES facility. Impacts resulting from the CAES facility would vary 27 depending on the site of the facility, but would generally not contribute considerably more 28 impacts than the wi nd component because of the wind component's large land area 29 requirements. Consequently, the impacts of construction and operation of this alternative to 30 terrestrial habitats and species could range from SMALL to MODERATE. 31 As with the previously discussed alternatives, consultation with FWS under the ESA would 32 avoid potential adverse impacts to Federally listed species or adverse modification or 33 destruction of designated critical habitat. Coordination with state natural resource agencies 34 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 35 state-listed species, habitats of conservation concern, and other protected species and habitats. 36 Consequently, the impacts of c onstruction and operation of a wind and CAES alternative on 37 protected species and habitats would be SMALL. 38 8.6.3.6. Human Health 39 CAES is a process by which air is compressed and forced into a holding area (like a large 40 underground cavern) for later use in powering a gas turbine. Construction impacts of a CAES 41 facility would be similar to impacts associated with the construction of any major industrial 42 facility. Although constructing an energy facility with and near a suitable holding area (like a 43 large underground cavern) would pose some unique challenges, proper regulation through state 44 and Federal agencies would ensure that human health impacts are minimized. 45 Environmental Impacts of Alternatives 8-70 Impacts on human health from construction of the wind alternative would be similar to impacts 1 associated with the construction of any major industrial facility. Compliance with worker 2 protection rules would control those impacts on workers at acceptable levels. Impacts from 3 construction on the general public would be minimal since limiting active construction area 4 access to authorized individuals is expected. Impacts on human health from the construction of 5 the wind alternative would be SMALL. 6 Given proper health -based regulation through procedures and access limitations, the staff 7 expects human health impacts from operation of the CAES and the wind alternative at an 8 alternate site to be SMALL. 9 8.6.3.7. Land Use 10 As discussed in Section 8.1.7, the GEIS generically discusses the impact of constructing and 11 operating various replacement power plant alternatives on land use, both on and off each power 12 plant site. The analysis of land -use impacts focuses on the amount of land area that would be 13 affected by the construction and operation of new wind turbines and CAES. 14 Land-use impacts from the wind turbines would be similar to the impacts described for the wind 15 alternative (see Section 8.4.7). Most of the wind farms would be located on open agricultural 16 cropland, which would remain largely unaffected by the presence of the wind turbines. Since 17 wind turbines require ample spacing between one another to avoid air turbulence, the footprint 18 of a utility scale wind farm could be quite large. Exelon estimates 3,200 ac (1,300 ha) of land 19 would be directly affected by the placement of the wind turbines (Exelon 2011). These 20 estimates appear reasonable based upon the size of current and proposed wind farms. 21 Nevertheless, wind turbines would be located on multiple wind farms spread across 22 approximately 130,000 ac (53,000 ha or 200 mi 2 [520 km 2]) of land. Most of this land would be 23 temporarily affected during the installation of the turbines and the construction of support 24 facilities, and about one -third of the land would be permanently impacted. Based on Exelon's 25 estimates, approximately 3,200 ac (1,300 ha) of land would be needed to support the wind 26 portion of the alternative to replace the LGS. This amount of land use would include the area 27 directly affected by the placement of turbines. Turbines would be spread across about 200 mi 2 28 (520 km 2). Additional land would be needed for any new transmission lines to connect wind 29 farms to the grid and for any needed access roads. 30 Delivering heavy and oversized wind turbine components would also require the construction of 31 temporary site access roads, some of which may require a circuitous route to their destination. 32 However, once construction is completed, many temporary access roads can be reclaimed and 33 replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land 34 used for equipment and material lay down areas, turbine assembly, and installation could be 35 returned to its original state. During operations, only 5 -10 percent of the total acreage within 36 the wind farm is actually occupied by turbines, access roads, support buildings, and associated 37 infrastructure while the remaining land area can be returned to its original condition or some 38 other compatible use, such as farming or grazing. 39 Land-use impacts from the gas -fired portion of the energy recovery process associated with the 40 CAES portion of this alternative would be similar to the impacts described for a NGCC power 41 plant (see Section 8.1.7). Only a minor amount of land would be needed above the geologic 42 storage formation. As a whole, construction and operation of a wind generation facility 43 combined with the construction and operation of a CAES facility would have relatively greater 44 impacts than the wind generation facilities alone. 45 The elimination of uranium fuel for LGS would partially offset some, but not all, of the land 46 requirements for the wind farms. Scaling from GEIS estimates, approximately 1,640 ac 47 Environmental Impacts of Alternatives 8-71 (660 ha) would no longer be needed during the operating life of the wind farms and the CAES 1 facility. Overall land -use impacts from the construction and operation of new wind farms and a 2 CAES facility would range from MODERATE to LARGE. 3 8.6.3.8. Socioeconomics 4 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 5 (1) construction jobs, which are transient, short in duration, and less likely to have a long -term 6 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 7 long-term socioeconomic impacts. Workforce requirements for the construction and operation 8 of a combination of wind turbines and a CAES facility were evaluated in order to measure their 9 possible effects on current socioeconomic conditions. 10 Socioeconomic impacts from the wind turbine component would be similar to the impacts 11 described for the wind alternative (see Section 8.4.8). Exelon estimated the wind alternative 12 would require 200 construction and 50 operations workers (Exelon 2011). These estimates 13 appear reasonable and in line with current construction and operational trends. Impacts from 14 the construction and operation of the gas -fired portion of the energy recovery process 15 associated with the CAES component would be similar to the impacts described for a NGCC 16 power plant (see Section 8.1.8). Because of the relatively small number of construction workers 17 at wind farms scattered over a large area at various locations, the relative economic impact of 18 this many workers on local communities and the tax base would be SMALL. Given the small 19 number of operations workers, socioeconomic impacts associated with operation of the wind 20 and CAES components of this combination alternative would also be SMALL. 21 The reduction in employment at LGS could affect property tax revenue and income in local 22 communities and businesses. In addition, the permanent housing market could also experience 23 increased vacancies and decreased prices if operations workers and their families move out of 24 the LGS region . However, t he amount of property taxes paid by wind farms and CAES may 25 offset lost tax revenues in the socioeconomic region around local jurisdictions if additional land 26 is required to support this alternative . Based on this information, socioeconomic impacts during 27 wind farm operations and CAES could range from SMALL to MODERATE. 28 8.6.3.9. Transportation 29 Transportation impacts during the construction and operation of the wind and CAES 30 components of this combination alternative would be similar to the impacts for the NGCC and 31 wind alternatives, discussed in Sections 8.1.7 and 8.4.7. This is because the construction 32 workforce for each component and the volume of materials and equipment needing to be 33 transported to each respective construction site would be the same. 34 As previously described for the NGCC and wind alternatives, workers commuting to the 35 construction site would arrive by site access roads and the volume of traffic on nearby roads 36 could increase during shift changes. In addition to commuting workers, trucks would be 37 transporting construction materials and equipment to the worksite, thus increasing the amount 38 of traffic on local roads. The increase in vehicular traffic would peak during shift changes, 39 resulting in temporary traffic volume impacts and delays at intersections. Transporting heavy 40 and oversized wind turbine components on local roads could have a noticeable impact over a 41 large area. Some components and materials could also be delivered by train or barge, 42 depending on location. Train deliveries could cause additional traffic delays at railroad 43 crossings. Based on this information, traffic-related transportation impacts during construction 44 could range from SMALL to MODERATE depending on the location of the wind farm and CAES 45 facility; road capacities; and traffic volumes. 46 Environmental Impacts of Alternatives 8-72 During operations, transportation impacts would be less noticeable during shift changes and 1 maintenance activities. Given the small numbers of operations workers, traffic impacts on local 2 roads from wind turbine and CAES facility operations would be SMALL. 3 8.6.3.10. Aesthetics 4 The analysis of aesthetic impacts focuses on the degree of contrast between the wind and 5 CAES alternative and surrounding landscapes and the visibility of new wind turbines at existing 6 wind farms and the new CAES facility. In general, aesthetic changes would be limited to the 7 immediate vicinity of the wind farms and CAES facility. 8 Aesthetic impacts during the construction and operation of the wind and CAES components of 9 this combination alternative would be similar to the impacts for the NGCC and wind alternatives, 10 discussed in Sections 8.1.10 and 8.4.10. Wind turbines would have the greatest potential visual 11 impact. At 400 ft (122 m) tall (Exelon 2011) and spread across multiple sites, wind turbines 12 often dominate the view and become the major focus of attention. Because wind farms are 13 generally located in rural or remote areas, the introduction of wind turbines will be in sharp 14 contrast to the visual appearance of the surrounding environment. Placing turbines along 15 ridgelines would maximize their visibility. Wind turbines also generate noise. 16 The new CAES facility could be sited at a previously undisturbed location. The mechanical draft 17 cooling towers and associated condensate plumes along with the CAES facility surface 18 structures would be the only significant visual for this part of the alternative. Mechanical draft 19 cooling towers also generate noise. Most other noises during facility operations would be 20 limited to industrial processes and communications. Based on this information, aesthetic 21 impacts from the construction and operation of new wind farms and CAES facility would range 22 from MODERATE to LARGE depending on location and surroundings. 23 8.6.3.11. Historic and Archaeological Resources 24 Any areas potentially affected by the construction of a wind and CAES alternative should be 25 surveyed to identify and record historic and archaeological resources. Resources found in 26 these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse 27 effects would need to be addressed if eligible resources were encountered. Plant operators 28 would need to survey all areas associated with operation of the alternative (e.g., roads, 29 transmission corridors, other ROWs). Visual impacts on significant cultural resources-such as 30 the viewsheds of historic properties near the sites -should also be assessed. 31 The potential for impacts on historic and archaeological resources from the wind and CAES 32 alternative would vary greatly depending on the location of the proposed sites. Areas with the 33 greatest sensitivity could be avoided or effectively managed under current laws and regulations. 34 However, construction of wind farms and CAES could have the potential to notably impact 35 historic and archaeological resources because of ground disturbing activities (e.g., grading , 36 digging an underground geologic repository). Aesthetic changes caused by the installation of 37 wind turbines could also have a noticeable effect on the viewshed of nearby historic properties. 38 Therefore, depending on the resource richness of the site chosen for the wind farm and CAES 39 alternative, the impacts could range from SMALL to LARGE. 40 8.6.3.12. Environmental Justice 41 T he environmental justice impact analysis evaluates the potential for disproportionately high and 42 adverse human health, environmental, and socioeconomic effects on minority and low -income 43 populations that could result from the installation and operation of wind turbines and a CAES 44 facility. As previously discussed in Section 8.1.12, such effects may include human health, 45 Environmental Impacts of Alternatives 8-73 biological, cultural, economic, or social impacts. Some of these potential effects have been 1 identified in resource areas discussed in this SEIS. 2 Potential impacts to minority and low -income populations would mostly consist of environmental 3 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 4 housing impacts). Noise and dust impacts during construction would be short term and 5 primarily limited to onsite activities. Minority and low -income populations residing along site 6 access roads would be affected by increased commuter vehicle and truck traffic. However, 7 because of the temporary nature of construction, these effects would only occur during certain 8 hours of the day and are not likely to be high and adverse and would be contained to a limited 9 time period during certain hours of the day. During construction, increased demand for rental 10 housing in the vicinity of the site could affect low -income populations living near the alternatives. 11 However, given the small number of construction workers and the possibility that workers could 12 commute to the construction site, the need for rental housing would not be significant. 13 Minority and low -income populations living in close proximity to the wind farms and CAES 14 facility could be disproportionately affected by operations. However, operational impacts would 15 mostly be limited to noise and aesthetic effects. The general public living near the wind farms 16 and CAES facility would also be exposed to the same effects. 17 Based on this information and the analysis of human health and environmental impacts 18 presented in this SEIS, the construction and operation of new wind turbines and a CAES facility 19 would not have disproportionately high and adverse human health and environmental effects on 20 minority and low -income populations. 21 8.6.3.13. Waste Management 22 During the construction stage of the combination of wind and CAES alternative, land clearing 23 and excavation, and other construction activities would generate wastes that could be recycled, 24 disposed of on site, or shipped to the offsite waste disposal facility. During the operational 25 stage, the wind and CAES alternative might generate minor amounts of waste. 26 The staff concludes that overall waste impacts from the combination of the wind and CAES 27 alternative would be SMALL. 28 Environmental Impacts of Alternatives 8-74 Table 8-9. Summary of Environmental Impacts of the Wind and CAES Alternative 1 Compared to Continued Operation of the Existing LGS 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) (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 3 As noted in the GEIS (NRC 1996), the use of wood waste to generate utility -scale baseload 4 power is limited to those locations where wood waste is plentiful. Wastes from pulp, paper, and 5 paperboard industries and from forest management activities can be expected to provide 6 sufficient, reliable supplies of wood waste as feedstocks to external combustion sources for 7 energy generation. Beside the fuel source, the technological aspects of a wood -fired generation 8 facility are virtually identical to those of a coal -fired alternative -combustion in an external 9 combustion unit such as a boiler to produce steam to drive a conventional STG. Given 10 constancy of the fuel source, wood waste facilities can be expected to operate at equivalent 11 efficiencies and reliabilities. Costs of operation would depend significantly on processing and 12 delivery costs. Wood waste combustors would be sources of criteria pollutants and GHGs, and 13 pollution control requirements would be similar to those for coal plants. Unlike coal plants, there 14 is no potential for the release of HAPs such as mercury. Co -firing of wood waste with coal is 15 also technically feasible. Processing the wood waste into pellets can improve the overall 16 efficiency of such co -fired units. 17 Although co -fired units can have capacity factors similar to baseload c oal-fired units, such levels 18 of performance are dependent on the continuous availability of the wood fuel. In the 19 Commonwealth of Pennsylvania, 2010 electricity generating capacity from wood waste was 20 108 MW(e) and produced 675,000 MWh (EIA 2011c). Given the limited capacity and modest 21 actual electricity production, the staff has determined that production of electricity from wood 22 waste at levels equivalent to LGS would not be a feasible alternative to LGS license renewal. 23 Environmental Impacts of Alternatives 8-75 8.6.5. Conventional Hydroelectric Power 1 Three technology variants of hydroelectric power exist-dam and release (also known as 2 impoundment), run -of-the-river (also known as diversion), and pumped storage. In each variant, 3 flowing water spins turbines of different designs to drive a generator to produce electricity. Dam 4 and release facilities affect large amounts of land behind the dam to create reservoirs but can 5 provide substantial amounts of power at capacity factors greater than 90 percent. Power 6 generating capacities of run -of-the-river dams fluctuate with the flow of water in the river, and 7 the operation of such dams is typically constrained (and stopped entirely during certain periods) 8 so as not to create undue stress on the aquatic ecosystems present. Pumped storage facilities 9 use electricity from other power sources to pump water from lower impoundments or flowing 10 watercourses to higher elevations during off -peak load periods. Water is then released during 11 peak load periods through turbines to generate electricity. Capacities of pumped storage 12 facilities are dependent on the configuration and capacity of the elevated storage facility. 13 A comprehensive survey of hydropower resources in Pennsylvania was completed in 1997 by 14 DOE's Idaho National Environmental Engineering Laboratory (now known as the Idaho National 15 Laboratory). In the study, generating potential was defined by a model that considered the 16 existing hydroelectric technology at developed sites or applied the most appropriate technology 17 to undeveloped sites and introduced site -specific environmental considerations and limitations. 18 Pennsylvania had modest hydroelectric potential, with a total generating potential of 703 MW(e) 19 (INEEL 1997). This potential was spread across 104 sites, only one of which had the potential 20 for more than 100 MW(e) of generation. Most other states in PJM have very limited potential 21 (INEEL 1998b), with the exception of West Virginia, which has 1,149 MW(e) spread across 22 37 sites (INEEL 1998a) 23 More recently, EIA reported that, in 2010, conventional hydroelectric power (excluding pumped 24 storage) was the principal electricity generation source among renewable sources in 25 Pennsylvania (EIA 2011c). Nevertheless, only 747 MW(e) of hydroelectric capacity was 26 installed in the Commonwealth. Those installations provided 2,332 gigawatt-hours of electricity 27 (EIA 2011a). Although hydroelectric facilities can demonstrate relatively high capacity factors, 28 the small potential capacities and actual recent power generation of hydroelectric facilities in 29 Pennsylvania, combined with the diminishing public support for large hydroelectric facilities 30 because of their potential for adverse environmental impacts, supports the staff's conclusion 31 that hydroelectric is not a feasible alternative to LGS. 32 8.6.6. Ocean Wave and Current Energy 33 Ocean waves, currents, and tides represent kinetic and potential energies. The total annual 34 average wave energy off the U.S. coastlines at a water depth of 60 m (197 ft) is estimated at 35 2,100 terawatt-hours (TWh) (MMS 2006). Waves, currents, and tides are often predictable and 36 reliable; ocean currents flow consistently, while tides can be predicted months and years in 37 advance with well -known behavior in most coastal areas. Four principal wave energy 38 conversion (WEC) technologies have been developed to date to capture the potential or kinetic 39 energy of waves-point absorbers, attenuators, overtopping devices, and terminators. All have 40 similar approaches to electricity generation but differ in size, anchoring method, spacing, 41 interconnection, array patterns, and water depth limitations. Point absorbers and attenuators 42 both allow waves to interact with a floating buoy, subsequently converting its motion into 43 mechanical energy to drive a generator. Overtopping devices and terminators are also similar 44 in their function. Overtopping devices trap some portion of the incident wave at a higher 45 elevation than the average height of the surrounding sea surface, thus giving it higher potential 46 Environmental Impacts of Alternatives 8-76 energy, which is then transferred to power generators. Terminators allow waves to enter a tube, 1 compressing air trapped at the top of the tube, which is then used to drive a generator. 2 Capacities of point absorbers range from 80 -250 kW, with capacity factors as high as 3 40 percent; attenuator facilities have capacities of as high as 750 kW. Overtopping devices 4 have design capacities as high as 4 MW, while terminators have design capacities ranging from 5 500 kW-2 MW and capacity factors as high as 50 percent (MMS 2007). 6 The most advanced technology for capturing tidal and ocean current energy is the submerged 7 turbine. Underwater turbines share many design features and functions with wind turbines, but 8 because of the greater density of water compared to air, they have substantially greater 9 power-generating potential than wind turbines with comparably sized blades. Only a small 10 number of prototypes and demonstration units have been deployed to date, however. 11 Underwater turbine "farms" are projected to have capacities of 2-3 MW, with capacity factors 12 directly related to the constancy of the current with which they interact. 13 The staff is not currently aware of any plans to develop or deploy ocean wave and ocean 14 current generation technologies on a scale similar to that of LGS. Consequently, the relatively 15 modest power capacities, relatively high costs, and limited planned implementation support the 16 staff's conclusion that water energy current technologies are not feasible substitutes for LGS. 17 8.6.7. Geothermal Power 18 Geothermal technologies extract the heat contained in geologic formations to produce steam to 19 drive a conventional steam -turbine generator. The following variants of the heat exchanging 20 mechanism have been developed: 21 Hot geothermal fluids contained under pressure in a geological formation are 22 brought to the surface where the release of pressure allows them to flash into 23 steam (the most common of geothermal technologies applied to electricity 24 production). 25 Hot geothermal fluids are brought to the surface in a closed loop system and 26 directed to a heat exchanger where they convert water in a secondary loop 27 into steam. 28 Hot dry rock technologies involve fracturing a rock formation and extracting 29 heat through injection of a heat transfer fluid. 30 Facilities producing electricity from geothermal energy can routinely demonstrate capacity 31 factors of 95 percent or greater, making geothermal energy clearly eligible as a source of 32 baseload electric power. However, as with other renewable energy technologies, the ultimate 33 feasibility of geothermal energy serving as a baseload power replacement for LGS depends on 34 the quality and accessibility of geothermal resources within or proximate to the region of 35 interest-in this case, Pennsylvania or PJM. As of April 2010, the United States had a total 36 installed geothermal electricity production capacity of 3,087 MW(e) originating from geothermal 37 facilities in nine states-Alaska, California, Hawaii, Idaho, Nevada, New Mexico, Oregon, Utah, 38 and Wyoming. Additional geothermal facilities are being considered for Colorado, Florida, 39 Louisiana, Mississippi, and Oregon. Neither Pennsylvania nor PJM has adequate geothermal 40 resources to support utility -scale electricity production (GEA 2010). NRC concludes, therefore, 41 that geothermal energy does not represent a feasible alternative to LGS. 42 Environmental Impacts of Alternatives 8-77 8.6.8. Municipal Solid Waste 1 Municipal solid waste (MSW) combustors use three types of technologies -mass burn, modular, 2 and refuse -derived fuel. Mass burning is currently the method used most frequently in the 3 United States and involves no (or little) sorting, shredding, or separation. Consequently, toxic or 4 hazardous components present in the waste stream are combusted, and toxic constituents are 5 exhausted to the air or become part of the resulting solid wastes. Currently, approximately 6 86 waste-to-energy plants operate in 24 states, processing 97,000 tons (88,000 MT) of 7 municipal solid waste per day. Approximately 26 million tons (24 million MT) of trash wer e 8 processed in 2008 by waste -to-energy facilities. With a reliable supply of waste fuel, 9 waste-to-energy plants have a nationwide aggregate capacity of 2,572 MW(e) (compared to 10 2,340 MW[e] capacity at LGS) and can operate at capacity factors greater than 90 percent 11 (ERC 2010). The EPA estimates that, on average, air impacts from MSW -to-energy plants are 12 as follows: 13 carbon dioxide (CO 2) -3,685 lb (1,672 kg)/MWh, 14 sulfur dioxid e (SO X) -1.2 lb (0.54 kg)/MWh, and 15 nitrogen oxide (NO x) - 6.7 lb (3.0 kg)/MWh. 16 Depending on the composition of the municipal waste stream, air emissions can vary greatly, 17 and the ash produced may exhibit hazardous characteristics that require special treatment and 18 handling (EPA 2010). 19 Estimates in the GEIS suggest that the overall level of construction impact from a waste -fired 20 plant would be approximately the same as that for a coal -fired power plant. Additionally, 21 waste-fired plants have the same or gre ater operational impacts as coal -fired technologies 22 (including impacts on the aquatic environment, air, and waste disposal). The initial capital costs 23 for municipal solid-waste plants are greater than those for comparable steam -turbine technology 24 at c oal-fired facilities or at wood -waste facilities because of the need for specialized waste 25 separation and handling equipment (NRC 1996). 26 The decision to burn municipal waste to generate energy is usually driven by the need for an 27 alternative to landfills, rather than energy considerations. The use of landfills as a waste 28 disposal option is likely to increase in the near term as energy prices increase (and especially 29 since such landfills, of sufficient size and maturity, can be sources of easily recoverable 30 methane fuel); however, it is possible that municipal waste combustion facilities may become 31 attractive again. 32 Regulatory structures that once supported municipal solid waste incineration no longer exist. 33 For example, the Tax Reform Act of 1986 made capital -intensive projects, such as municipal 34 waste combustion facilities, more expensive relative to less capital -intensive waste disposal 35 alternatives such as landfills. Additionally, the 1994 Supreme Court decision C&A 36 Carbone, Inc. v. Town of Clarkstown, New York, struck down local flow control ordinances that 37 required waste to be delivered to specific municipal waste combustion facilities rather than 38 landfills that may have had lower fees. In addition, environmental regulations have increased 39 the capital cost necessary to construct and maintain municipal waste combustion facilities. 40 Given the limited nationwide implementation of MSW -based generation to date (only 10 percent 41 greater than the capacity of LGS), small average installed size of municipal solid waste plants, 42 the likelihood that additional stable streams of MSW are not likely to be available to support 43 numerous new facilities, and the increasingly unfavorable regulatory environment, the staff does 44 not consider municipal solid waste combustion to be a reasonable alternative to LGS license 45 renewal. 46 Environmental Impacts of Alternatives 8-78 8.6.9. Biomass Fuels 1 When used here, "biomass fuels" include crop residues, switchgrass grown specifically for 2 electricity production, forest residues, methane from landfills, methane from animal manure 3 management, primary wood mill residues, secondary wood mill residues, urban wood wastes, 4 and methane from domestic wastewater treatment. The feasibility of using biomass fuels for 5 baseload power depends on its geographic distribution, available quantities, constancy of 6 supply, and energy content. A variety of technical approaches has been developed for 7 biomass-fired electric generators, including direct burning, conversion to liquid biofuels, and 8 biomass gasification. In a study completed in December 2005, Milbrandt of NREL documented 9 the geographic distribution of biomass fuels within the United States, reporting the results in 10 metric tons available (dry basis) per year (NREL 2005). Most counties in Pennsylvania have 11 limited potential biomass fuels, with the exception of Philadelphia and Bucks County. Use of 12 biomass fuels in Pennsylvania is also limited. Beyond the wood and wood waste considered in 13 Section 8.6.4, generators in the Commonwealth used biomass fuels to produce merely 14 3,000 MWh of electricity in 2010 (EIA 2011c). 15 In the GEIS, the NRC indicated that technologies relying on a variety of biomass fuels had not 16 progressed to the point of being competitive on a large scale or of being reliable enough to 17 replace a baseload plant such as LGS. After reevaluating current technologies, and after 18 reviewing existing statewide capacities and the extent to which biomass is currently being used 19 to produce electricity, the staff finds biomass -fueled alternatives are still unable to replace the 20 LGS capacity and are not considered feasible alternatives to LGS license renewal. 21 8.6.10. Oil-Fired Power 22 Although oil has historically been used extensively in the Northeast for comfort heating, EIA 23 projects that oil -fired plants will account for very little of the new generation capacity constructed 24 in the United States during the 2008 to 2030 time period. In 2010, Pennsylvania generated 25 0.2 percent of its total electricity from oil (EIA 2012). Further, EIA does not project that oil -fired 26 power will account for any significant additions to capacity (EIA 2011b). 27 The variable costs of oil -fired generation tend to be greater than those of nuclear or coal-fired 28 operations, and oil -fired generation tends to have greater environmental impacts than natural 29 gas-fired generation. In addition, future increases in oil prices are expected to make oil -fired 30 generation increasingly expensive (EIA 2011b). The high cost of oil has prompted a steady 31 decline in its use for electricity generation. Thus, the staff does not consider oil -fired generation 32 as a reasonable alternative to LGS license renewal. 33 8.6.11. Delayed Retirement 34 Exelon currently plans to retire three coal -fired units and one oil -fired unit (Exelon 2011). These 35 units total 946 MW(e) of capacity, far less than the 2,340 MW(e) LGS currently provides. In 36 PJM, however, Exelon indicates that generators have retired 5,945 MW(e) from 2003 to 2009 37 (Exelon 2011). 38 Most retired units are dirtier and less efficient than new units. Often, units are retired because 39 operation is no longer economical. In some cases, the cost of environmental compliance or 40 necessary repairs and upgrades are too high to justify continued operation. As a result, the staff 41 does not consider delayed retirement a reasonable alternative to license renewal. It is possible, 42 however, that a site where a unit has been retired could play host to a new generation facility, 43 like the NGCC and SCPC alternatives considered in Sections 8.1 and 8.2, and the NGCC 44 portion of the combination alternative considered in Section 8.6.2. 45 Environmental Impacts of Alternatives 8-79 8.6.12. Fuel Cells 1 Fuel cells oxidize fuels without combustion and its environmental side effects. Power is 2 produced electrochemically by passing a hydrogen -rich fuel over an anode and air (or oxygen) 3 over a cathode and separating the two by an electrolyte. The only byproducts (depending on 4 fuel characteristics) are heat, water, and CO
- 2. Hydrogen fuel can come from a variety of 5 hydrocarbon resources by subjecting them to steam reforming under pressure. Natural gas is 6 typically used as the source of hydrogen.
7 Currently, fuel cells are not economically or technologically competitive with other alternatives 8 for electricity generation. EIA projects that fuel cells may cost $5,478 per installed kW (total 9 overnight costs, 2008 dollars) (EIA 2010c). This amount is substantially greater than coal 10 ($2,223), advanced (natural gas) combustion turbines ($648), onshore wind ($1,966), or 11 offshore wind ($3,937), but it is cost -competitive with solar PV ($6,171) or CSP solar ($5,132). 12 Installed costs provided for PV and CSP solar are before application of Investment Tax Credits 13 provided in Federal statutes. More importantly, fuel cell units are likely to be small in size (the 14 EIA reference plant is 10 MWe). While it may be possible to use a distributed array of fuel cells 15 to provide an alternative to LGS, it would be extremely costly to do so and would require many 16 units and wholesale modifications to the existing transmission system. Accordingly, the staff 17 does not consider fuel cell technology to be a reasonable alternative to LGS license renewal. 18 8.6.13. Coal-Fired Integrated Gasification Combined-Cycle 19 Integrated gasification combined-cycle (IGCC) is an emerging technology for generating 20 electricity with coal that combines modern coal gasification technology with both gas turbine and 21 steam turbine power generation. Gasifiers, similar to those used in oil refineries, use heat 22 pressure and steam to pyrolyze (thermally reform complex organic molecules without oxidation) 23 coal to produce synthesis gases (generically referred to as syngas) typically composed of 24 carbon monoxide, hydrogen, and other flammable constituents. After processing to remove 25 contaminants and produce various liquid chemicals, the syngas is combusted in a combustion 26 turbine to produce electric power. Separating the CO 2 from the syngas before combustion is 27 also possible. Latent heat is recovered both from the syngas as it exits the gasifier and from the 28 combustion gases exiting the combustion turbine and directed to a heat recovery steam 29 generator feeding a conventional Rankine cycle STG to produce additional amounts of 30 electricity. Emissions of criteria pollutants would likely be slightly higher than those from an 31 NGCC alternative but significantly lower than those from the supercritical coal -fired alternative. 32 Depending on the gasification technology employed, IGCC would use less water than SCPC 33 units but slightly more than NGCC (NETL 2007). Long -term maintenance costs of this relatively 34 complex technology would likely be greater than those for a similarly sized SCPC or NGCC 35 plant. 36 Only a few IGCC plants are operating at utility scale. Operating at higher thermal efficiencies 37 than supercritical coal -fired boilers, IGCC plants can produce electrical power with fewer air 38 pollutants and solid wastes than coal -fired boilers. To date, however, IGCC technologies have 39 had limited application and have been plagued with operational problems such that its effective, 40 long-term capacity factors are often not high enough for them to reliably serve as baseload 41 units. Although IGCC technology may become more commonplace in the future, current 42 operational problems that compromise reliability result in the dismissal of this technology as a 43 viable alternative to LGS. 44 Environmental Impacts of Alternatives 8-80 8.6.14. Demand-Side Management 1 In its ER, Exelon indicates that DSM does not fulfill the stated purpose of license renewal 2 because it does not provide power generation capacity (Exelon 2011). Exelon also notes that 3 the purpose of LGS license renewal is to "allow Exelon to sell wholesale power generated by 4 LGS to meet future demand. " The ER continues to note that, because "Exelon engages solely 5 in the sale of wholesale electric power, the Company has no business connection to end -users 6 of its electricity and, therefore, no ability to implement DSM. " While the staff finds this position 7 reasonable for purposes of this analysis, it notes that DSM is an option for energy planners and 8 decisionmakers -and it may be a potential consequence of no action -and so will discuss it in 9 brief in this section. 10 DSM measures -unlike the energy supply alternatives discussed in previous sections -address 11 energy end uses. DSM can include measures that do the following: 12 reduce energy consumption; 13 shift energy consumption to different times of the day to reduce peak loads; 14 interrupt certain large customers during periods of high demand; 15 interrupt certain appliances during high demand periods; and 16 encourage customers to switch from gas to electricity for water heating and 17 other similar measures that utilities use to boost sales. 18 In terms of overall ability to offset or replace an existing baseload power plant, DSM measures 19 that reduce energy consumption, typically referred to as energy conservation and energy 20 efficiency, are the most useful. Though often used interchangeably, energy conservation and 21 energy efficiency are different concepts. Energy efficiency typically means deriving a similar 22 level of service by using less energy, while energy conservation simply indicates a reduction in 23 energy consumption. The GEIS directly addressed energy conservation, and note d that it is not 24 a discrete power -generating source; it represents an option that states and utilities may use to 25 reduce their need for power generation capability (NRC 1996). Conservation measures may 26 include incentives to reduce overall energy consumption, while efficiency measures may include 27 incentives to replace older, less efficient appliances, lighting, or heating and cooling systems. 28 A variety of conservation or energy efficiency measures would likely be necessary to replace the 29 capacity currently provided by LGS. 30 Another DMS approach is called demand -response. PJM currently has a robust 31 demand-response program, which, unlike energy efficiency and energy conservation measures, 32 generally aims to reduce consumption during times of high demand. This program also reduces 33 stresses on the PJM transmission system. 34 PJM's demand-response program provides payments to participants who reduce demand 35 (PJM 2012 c, PJM undated). The payments increase as the price of electricity increases, so that 36 participants are most likely to reduce consumption when electricity is most expensive, which 37 usually (though not always) occurs during times of high demand (this may also occur during 38 certain emergencies). This type of approach usually offsets intermediate and peaki ng 39 generation rather than baseload generation. Exelon notes, in the ER, that it is unlikely that 40 demand reductions in PJM could be sufficiently increased to replace the LGS baseload capacity 41 (Exelon 2011). The NRC staff determined that this conclusion is reasonable because a 42 considerable amount of demand reduction efforts are currently in place and it is unlikely that 43 additional programs could reduce use by another 2,340 MW(e). 44 Environmental Impacts of Alternatives 8-81 As Exelon noted in its ER, the impacts of DSM at most sites are generally SMALL. The staff 1 has considered energy efficiency or energy conservation in several SEISs 2 (see, e.g., NUREG-1437, Supplements 33, 37, and 38) and in each case has found the impacts 3 to be SMALL, except when conservation or efficiency measures are unlikely to offset 4 socioeconomic impacts of plant shutdown. For LGS, the conservation or efficiency measures 5 may not offset the socioeconomic plant shutdown because the measures could occur across the 6 entire PJM territory, which includes several states. The GEIS also indicates that impacts from 7 energy conservation are likely to be SMALL. The staff notes, however, that some generation 8 owners recently expressed concern that in cases where demand -response programs trigger 9 increased reliance on backup diesel generators, air-quality impacts may occur, particularly in 10 PJM (see, e.g., Beattie 2012). The EPA has provided clean -air waivers for the use of these 11 generators for a limited number of hours throughout the year. Emergency use of these 12 generators is likely to occur during the hottest days of the summer, when impaired air quality 13 often also occurs (Beattie 2012). So me air quality effects from some DSM measures are 14 possible, but they would depend on the specific DSM measures employed. Because it is 15 unlikely that demand reductions in PJM could be sufficiently increased to replace the LGS 16 baseload capacity, the NRC did not consider DSM to be a reasonable alternative. 17 8.7. No-Action Alternative 18 This section examines the environmental effects that occur if NRC takes no action. No action, 19 in this case, means that NRC denies the renewed operating licenses for LGS and the licenses 20 expire at the end of the current license terms, in 2024 and 2029. If the NRC denies the 21 renewed operating licenses, the plant will shut down at or before the end of the current licenses. 22 After shutdown, plant operators will initiate decommissioning in accordance with 10 CFR 50.82. 23 No action does not satisfy the purpose and need for this SEIS, as it neither provides 24 power-generation capacity nor meets the needs currently met by LGS or that the alternatives 25 evaluated in Sections 8.1-8.5 would satisfy. Assuming that a need currently exists for the 26 power generated by LGS, the no -action alternative would require the appropriate energy 27 planning decision -makers (not NRC) to rely on an alternative to replace the capacity of LGS, 28 rely on energy conservation or power purchases to offset parts of the LGS capacity, or rely on 29 some combination of measures to offset and replace the generation provided by the facility. 30 This section addresses only those impacts that arise directly as a result of plant shutdown. The 31 environmental impacts from decommissioning and related activities have already been 32 addressed in several other documents, including the "Final Generic Environmental Impact 33 Statement on Decommissioning of Nuclear Facilities," NUREG -0586, Supplement 1 34 (NRC 2002); the license renewal GEIS, Chapter 7 (NRC 1996); and Chapter 7 of this SEIS. 35 These analyses either directly address or bound the environmental impacts of decommissioning 36 whenever Exelon ceases to operate LGS. 37 Even with a renewed operating license, LGS will eventually shut down, and the environmental 38 effects we address in this section will occur at that time. Because these effects have not 39 otherwise been addressed in this SEIS, the impacts are addressed in this section. As with 40 decommissioning effects, shutdown effects are expected to be similar whether they occur at the 41 end of the current license or at the end of a renewed license. Table 8-10 provides a summary 42 of the environmental impacts of the no -action alternative. 43 8.7.1. Air Quality 44 When the plant stops operating, there will be a reduction in emissions from activities related to 45 plant operation, such as use of diesel generators and employee vehicles. In Chapter 4, the staff 46 Environmental Impacts of Alternatives 8-82 determined that these emissions would have a SMALL impact on air quality during the renewal 1 term; therefore, if emissions decrease, the impact on air quality would also decrease and would 2 be SMALL. 3 8.7.2. Groundwater Resources 4 Impacts to groundwater resources would decrease, as the plant would withdraw less water than 5 it does during operations. Therefore, shutdown would reduce the impacts to groundwater 6 resources, which would remain SMALL. 7 8.7.3. Surface Water Resources 8 Impacts to surface water resources would decrease, as the plant would withdraw and discharge 9 less water than it does during operations. Therefore, shutdown would reduce the impacts to 10 surface water resources, which would remain SMALL. 11 8.7.4. Aquatic and Terrestrial Resources 12 Impacts to aquatic ecology would decrease, as the plant would withdraw and discharge less 13 water than it does during operations. Therefore, fewer organisms would be subject to 14 impingement, entrainment, and heat shock. Shutdown would reduce the impacts to aquatic 15 ecology, which would remain SMALL. 16 Terrestrial ecology impacts would remain SMALL. No additional land disturbances on or offsite 17 would occur. 18 8.7.5. Human Health 19 In Chapter 4 of this SEIS, the staff concluded that the impacts of continued plant operation on 20 human health would be SMALL. After cessation of plant operations, the amounts of radioactive 21 material released to the environment in gaseous and liquid forms, all of which are currently 22 within respective regulatory limits, would be reduced or eliminated. Therefore, the staff 23 concludes that the impact of plant shutdown on human health would also be SMALL. In 24 addition, the potential for a variety of accidents would also be reduced to only those associated 25 specifically with shutdown activities and fuel handling. In Chapter 5 of this SEIS, the staff 26 concluded that impacts of accidents during operation would be SMALL. It follows, therefore, 27 that impacts on human health from a reduced suite of potential accidents after reactor operation 28 ceases would also be SMALL. Therefore, the staff concludes that impacts on human health 29 from the no -action alternative would be SMALL. 30 8.7.6. Land Use 31 Plant shutdown would not affect onsite land use. Plant structures and other facilities would 32 remain in place until decommissioning. Most transmission lines connected to the LGS would 33 remain in service after the plant stops operating. Maintenance of most existing transmission 34 lines would continue as before. Impacts on land use from plant shutdown would be SMALL. 35 8.7.7. Socioeconomics 36 Plant shutdown would have a noticeable impact on socioeconomic conditions in the 37 communities located in the immediate vicinity of LGS. Should LGS shut down, there would be 38 immediate socioeconomic impact from the loss of jobs (some, though not all, of the 39 820 employees would begin to leave), and tax payments may be reduced. As the majority of 40 Environmental Impacts of Alternatives 8-83 LGS employees reside in Montgomery, Berks, and Chester Counties, socioeconomic impacts 1 from plant shutdown would be concentrated in these counties, with a corresponding reduction in 2 purchasing activity and tax contributions to the regional economy. Revenue losses from LGS 3 operations would directly affect Montgomery County and other local taxing districts and 4 communities closest to, and most reliant on, the nuclear plant's tax revenue. The impact of the 5 job loss, however, may not be as noticeable given the amount of time required to decontaminate 6 and decommission existing facilities and the proximity of LGS to the Philadelphia metropolitan 7 area. The socioeconomic impacts of plant shutdown (which may not entirely cease until after 8 decommissioning) could, depending on the jurisdiction, range from SMALL to MODERATE. 9 8.7.8. Transportation 10 Traffic volumes on the roads in the vicinity of LGS would be reduced after plant shutdown. Most 11 of the reduction in traffic volume would be associated with the loss of jobs at the nuclear power 12 plant. The number of deliveries to the power plant would be reduced until decommissioning. 13 Transportation impacts would be SMALL as a result of plant shutdown. 14 8.7.9. Aesthe tics 15 Plant structures and other facilities would remain in place until decommissioning. Most sources 16 of operational noise would cease. Therefore, aesthetic impacts of plant closure would be 17 SMALL. 18 8.7.10. Historic and Archaeological Resources 19 Impacts from the no -action alternative on historic and archaeological resources would be 20 SMALL. A separate environmental review addressing the protection of historic and 21 archaeological resources would be conducted for decommissioning. 22 8.7.11. Environmental Justice 23 Impacts to minority and low -income populations would depend on the number of jobs and the 24 amount of tax revenues lost by communities in the immediate vicinity of the power plant after 25 LGS ceases operations. Closure of LGS would reduce the overall number of jobs (there ar e 26 currently 820 employed at the facility) and tax revenue for social services attributed to nuclear 27 plant operations. Minority and low -income populations in the vicinity of LGS could experience 28 some socioeconomic effects from plant shutdown, but these effects would not likely be high and 29 adverse. 30 8.7.12. Waste Management 31 If the no-action alternative were implemented, the generation of high -level waste would stop, 32 and generation of low -level and mixed waste would decrease. Impacts from implementation of 33 the no-action alternative are expected to be SMALL. 34 Environmental Impacts of Alternatives 8-84 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 SMALL(a) 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 8.8. Alternatives Summary 2 In this SEIS, the staff has considered alternative actions to lice nse renewal of LGS, including 3 in-depth evaluations of new generation alternatives (Sections 8.1-8.4), a purchased power 4 alternative (Section 8.5), alternatives that the staff dismissed from detailed evaluation as 5 infeasible or inappropriate (Section 8.6; including in -depth consideration of solar PV generation 6 and two combination alternatives), and the no -action alternative in which the operating license is 7 not renewed (Section 8.7). Impacts of all alternatives considered in detail are summarized in 8 Table 8-11. 9 Based on the above evaluations, the staff concludes that the environmental impacts of renewal 10 of the operating license for LGS would be smaller than those of feasible and commercially 11 viable alternatives studied in this SEIS that satisfy the purpose and need of license renewal 12 (providing 2,340 MWe of baseload power to the grid). Impacts on air quality are less from 13 continued operation of LGS than from any of the alternatives involving fossil fuels, though they 14 are likely to be greater than wind and solar PV alone. Finally, the staff concluded that under the 15 no-action alternative, the act of shutting down LGS on or before its license expiration would 16 have mostly SMALL impacts, although socioeconomic impacts would be SMALL to 17 MODERATE. Depending on how the power lost to the region from reactor shutdown was 18 replaced (decisions outside of the NRC's authority and made instead by Exelon, other power 19 producers, PJM operators, and state or non-NRC Federal authorities), the net environmental 20 impact of the no -action alternative could be greater than continued reactor operation, especially 21 when fossil energy power plants provide replacement generation capacity. 22 8BEnvironmental Impacts of Alternativ es Table 8-11. Summary of Environmental Impacts of Proposed Action and Alternatives 1 Alternative Impact Area 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 License Renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL (a) NGCC at an Alternate Site SMALL to MODERATE SMALL SMALL SMALL SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL SCPC at an Alternate Site MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL to LARGE SMALL MODERATE New Nuclear at an Alternate Site SMALL SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL to LARGE SMALL SMALL(a) Wind Power SMALL SMALL SMALL to MODERATE SMALL MODERATE to LARGE SMALL to LARGE SMALL to LARGE SMALL Purchased Power SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to LARGE SMALL to LARGE SMALL to LARGE SMALL to MODERATE Solar PV (dismissed in Section 8.6.1) SMALL SMALL SMALL to MODERATE SMALL SMALL to LARGE SMALL to LARGE SMALL to LARGE SMALL Wind, Solar, and NGCC (dismissed in Section 8.6.2) SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL Wind and CAES (dismissed in Section 8.6.3) SMALL to MODERATE SMALL SMALL to MODERATE SMALL MODERATE to LARGE SMALL to LARGE SMALL to LARGE SMALL No-Action Alternative SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE 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. 8-85 8BEnvironmental Impacts of Alternatives 8-86 8.9. References 1 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 2 production and utilization facilities." 3 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 4 protection regulations for domestic licensing and related regulatory functions." 5 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 6 "Standards of performance for new stationary sources." 7 40 CFR Part 75. Code of Federal Regulations, Title 40, Protection of Environment, Part 75, 8 "Continuous emission monitoring." 9 40 CFR Part 80. Code of Federal Regulations, Title 40, Protection of Environment, Part 80, 10 "Designation of areas for air quality planning purposes." 11 65 FR 79825. U.S. Environmental Protection Agency. 2000b. Regulatory finding on the 12 emissions of hazardous air pollutants from electric utility steam generating units. Federal 13 Register 65(245):79825 -79831. December 20, 2000. 14 65 FR 33214. U.S. Environmental Protection Agency. 2000c. Notice of regulatory determination 15 on wastes from the combustion of fossil fuels." Federal Register 65(99): 32214 -32237. 16 May 22, 2000. 17 76 FR 24976. U.S. Environmental Protection Agency. 2011c. National emission standards for 18 hazardous air pollutants from coal and oil -fired electric utility steam generating units and 19 standards of performance for fossil -fuel-fired electric utility, industrial -commercial -institutional, 20 and small industrial -commercial -institutional steam generating units." Federal Register 21 76(85):24976 -24147. May 3, 2011. Available at 22 <http://www.epa.gov/ttn/atw/utility/fr03my11.pdf > (accessed 9 May 2011). 23 25 Pa. Code 2
- 90. Pennsylvania Administrative Code, Part 1, Department of Environmental 24 Protection, Title 25, Environmental Protection, Chapter 290 , "Beneficial Use of Coal Ash." 25 Available at <http://www.pacode.com/secure/data/025/chapter290/chap290toc.html> (accessed 26 November 2012). 27 [ACAA] American Coal Ash Association. 2010. 2009 Coal Combustion Product (CCP) 28 Production and Use Survey Report. Aurora, CO: ACAA. November
- 3. Available at 29 <http://www.acaa
-usa.org/displaycommon.cfm?an=1&subarticlenbr=3 > (accessed 30 29 November 2010). 31 Archer CL, Jacobson MZ. 2007. Supplying baseload power and reducing transmission 32 requirements by interconnecting wind farms. Journal of Applied Meteorology and Climatology 33 46(11)1701 -1717. 34 Atlantic Wind Connection. Undated. "Right of Way Application -FAQs." Available at 35 <http://atlanticwindconnection.com/ferc/BOEM/ROW%20application%20FAQs.pdf > (accessed 36 3 November 2011). 37 Beattie J. EPA easing emissions rules for demand response -generators. The Energy Daily. 38 Vol. 40, No. 30 (February 13, 2012). 39 [BLM] Department of the Interior, Bureau of Land Management. 2005. Final Programmatic 40 Environmental Impact Statement on Wind Energy Development on BLM -Administered Lands in 41 the Western United States. Washington, DC: BLM. June. Available at 42 <http://windeis.anl.gov/documents/fpeis/index.cfm\> (accessed 17 May 2011). 43 8BEnvironmental Impacts of Alternatives 8-87 [Con Edison] Con Edison and Long Island Power Authority (LIPA). 2009. Joint Con Edison -LIPA 1 Offshore Wind Power Integration Project Feasibility Assessment. March 20, 2009. Available at 2 <http://www.linycoffshorewind.com/PDF/Feasibility%20Study.pdf > (accessed 3 2 December 2011). 4 [DOE] U.S. Department of Energy (DOE). 2008. 20% Wind Energy by 2030, Increasing Wind 5 Energy's Contribution to U.S. Electricity Supply. DOE/GO-102008-2567. July. Available at 6 <http:// www.nrel.gov/docs/fy08osti/41869.pdf > (accessed 1 June 2012). 7 [DOE] BLM and Department of Energy (DOE). 2010. Draft Programmatic Environmental Impact 8 Statement for Solar Energy Development in Six Southwestern States. DES 10-59; 9 DOE/EIS 0403. December. Available at 10 <http://www.solareis.anl.gov/documents/dpeis/index.cfm > (accessed 28 January 2011). 11 [DOE] U.S. Department of Energy (DOE). 2012. Wind Powering America. Available at: 12 http://www.windpoweringamerica.gov Accessed November 6, 2012. 13 [DSIRE] Database of State Incentives for Renewables and Efficiency. 2011. Alternative Energy 14 Portfolio Standard. Available at 15 <http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=PA06R&re=1&ee=1> 16 (accessed 7 May 2012). 17 [EIA] U.S. Energy Information Administration. 2010a. Cost and Quality of Fuels for Electric 18 Plants 2009 Edition, Table 15A Destination and Origin of Coal to Electric Plants by State: Total 19 (All Sectors), 2010. Washington, DC: EIA. November. Available at 20 <http://www.eia.doe.gov/cneaf/electricity/cq/cqa2009.pdf > (accessed 11 May 2012). 21 [EIA] U.S. Energy Information Administration. 2010b. Assumptions to the Annual Energy 22 Outlook 2010 with Projections to 2035. Washington, DC: EIA. April 9, 2010. DOE/EIA -0554 23 (2010). Available at <http://www.eia.doe.gov/oiaf/aeo/assumption/index.html > (accessed 24 7 December 2010). 25 [EIA] U.S. Energy Information Administration. 2011a. Electric Power Annual with Data for 2009, 26 Summary Statistics for the United States. Washington, DC: EIA. April. Available a t 27 <http://www.eia.doe.gov/cneaf/electricity/epa/epates.html > (accessed 5 May 2011). 28 [EIA] U.S. Energy Information Administration. 2011b. Annual Energy Outlook for 2011 with 29 Projections to 2035, Electricity. DOE/EIA 0383(2010). Washington, DC: EIA. April
- 26. Available 30 at <http://www.eia.doe.gov/oiaf/aeo/electricity.html>
(accessed 5 May 2011). 31 [EIA] U.S. Energy Information Administration. 2011c. Pennsylvania Renewable Energy Profile, 32 2010. Washington, DC: EIA. March. Available at 33 <http://205.254.135.7/renewable/state/pennsylvania/pdf/Pennsylvania.pdf> (accessed 34 18 May 2012). 35 [EIA] U.S. Energy Information Administration. 2012. State Electricity Profiles 2010. Washington, 36 DC: EIA. January 27, 2012. Available at <http://205.254.135.7/electricity/state/pdf/sep2010.pdf> 37 (accessed 7 May 2012). 38 [EPA] U.S. Environmental Protection Agency. 1998. Section 1.1, Bituminous and Subbituminous 39 Coal Combustion: Final Section Supplement E. In: Compilation of Air Pollutant Emission 40 Factors, Volume 1: Stationary Point and Area Sources: AP 42. 5th ed . Washington, DC: EPA. 41 Available at <http://www.epa.gov/ttn/chief/ap42/ch03/final/c03s01.pdf>. 42 [EPA] U.S. Environmental Protection Agency. 2000a. "Air Pollution Control Technology Fact 43 Sheet, Selective Catalytic Reduction (SCR)." Washington DC: EPA. EPA -452/F-03-032. 44 Available at <http://ww.epa.gov/ttn/catc/dir1/fscr.pdf> (accessed 9 November 2010). 45 8BEnvironmental Impacts of Alternatives 8-88 [EPA] U.S. Environmental Protection Agency. 2009a. "List of 156 Mandatory Class I Federal 1 Areas." Available at <http://www.epa.gov/visibility/class1.html > (accessed 7 March 2011). 2 [EPA] U.S. Environmental Protection Agency. 2009b. " NO x Trading Programs ." April. Available 3 at <http://www.epa.gov/airmarkt/progsregs/nox/index.html > (accessed 3 March 2011). 4 [EPA] U.S. Environmental Protection Agency. 2010. "Municipal Solid Waste, Electricity from 5 Municipal Solid Waste." Last updated March 17, 2010. Washington, DC: EPA. Available at 6 <http://www.epa.gov/cleanenergy/energy -and-you/affect/municipal -sw.html> (accessed 7 10 December 2010). 8 [EPA] U.S. Environmental Protection Agency. 2011a. Draft Inventory of U.S. Greenhouse Gas 9 Emissions and Sinks: 1990 -2009. Washington, DC: EPA. EPA 430-R-11-005. February
- 15. 10 Available at <http://www.epa.gov/climatechange/emissions/usinventoryreport.html
> (accessed 11 2 March 2011). 12 [EPA] U.S. Environmental Protection Agency. 2011b. " NO x Trading Programs ." Available at 13 <http://www.epa.gov/airmarkt/progsregs/nox/index.html > (accessed 3 March 2011). 14 [EPA] U.S. Environmental Protection Agency. 2012a. "New Source Review." Available at 15 <http://www.epa.gov/nsr/ > (accessed 10 April 2012). 16 [EPA] Environmental Protection Agency. 2012b. "Emission Factors & AP42, Compilation of Air 17 Pollutant Emission." Available at <http://www.epa.gov/ttnchie1/ap42/ > (accessed 10 April 2012). 18 [EPA] Environmental Protection Agency (EPA). 2012c. "Reducing Air Pollution from Power 19 Plants." Available at <http://www.epa.gov/airquality/powerplants/ > (accessed 10 April 2012). 20 [EPRI and CED] Electric Power Research Institute and Commission for Environmental 21 Cooperation. 2003. Potential Health and Environmental Impacts Associated with the 22 Manufacture and Use of Photovoltaic Cells, Final Report. Report 1000095. November 2003. 23 Prepared by Tetra Tech, Inc., Lafayette: CA for EPRI, Palo Alto: CA and California Energy 24 Commission, Sacramento: CA. Available at 25 <http://www.energy.ca.gov/reports/500 053.PDF> (accessed 2 May 2012). 26 [ERC] Energy Recovery Council. 2010. The 2010 ERC Directory of Waste -To-Energy Plants. 27 November 12, 2010. Available at 28 <http://www.energyrecoverycouncil.org/erc -releases-directory-waste-energy-plants-a3045> 29 (accessed 9 December 2010). Agencywide Documents Access and Management System 30 (ADAMS) Accession No. ML11266A009. 31 [GCRP] Global Change Research Program. Global Climate Change Impacts in the United 32 States. New York, NY: Cambridge University Press. 2009. Available at 33 <http://downloads.globalchange.gov/usimpacts/pdfs/climate -impacts-report.pdf > (accessed 34 19 May 2012). 35 [GEA] Geothermal Energy Association. 2010. U.S. Geothermal Power Production and 36 Development Update -Special NYC Forum Edition. Figure 4. January. Available at 37 <http://www.geo -energy.org/reports.aspx > (accessed 1 December 2010). 38 Hong, BD, Slatick ER. 1994. "Carbon Dioxide Emission Factors for Coal." Originally published in 39 Energy Information Administration, Quarterly Coal Report , January-April 1994. 40 DOE/EIA-0121(94Q1). Washington, DC: EIA. August 1994. Available at 41 <http://www.eia.doe.gov/cneaf/coal/quarterly/co2_article/co2.html > (accessed 42 21 December 2009). 43 8BEnvironmental Impacts of Alternatives 8-89 [INEEL] Idaho National Engineering and Environmental Laboratory. 1997. U.S. Hydropower 1 Resource Assessment for Pennsylvania. DOE-ID/10430(PA). Idaho Falls: ID. December 1997. 2 Available at <http://hydropower.inel.gov/resourceassessment/pdfs/states/pa.pdf > (accessed 3 18 May 2012). 4 [INEEL] Idaho National Engineering and Environmental Laboratory. 1998a. U.S. Hydropower 5 Resource Assessment for West Virginia. DOE-ID/10430(WV). Idaho Falls: ID. February 1998. 6 Available at <http://hydropower.inel.gov/resourceassessment/pdfs/states/wv.pdf> (accessed 7 18 May 2012). 8 [INEEL] Idaho National Engineering and Environmental Laboratory. 1998b. U.S. Hydropower 9 Resource Assessment, Final Report. DOE-ID/10430. Washington, DC. December. Available at 10 <http://hydropower.inel.gov/resourceassessment/pdfs/doeid -10430.pdf> (accessed 11 18 May 2012). 12 [ISEPA] Iowa Stored Energy Park Agency. 2011. "Iowa Stored Energy Park Project 13 Terminated." Press release. July 28, 2011. Available at 14 <http://www.cipco.net/state -news_initiatives.cfm?action=article&page= 15 0&id=084f54ef -69f3-4b3d-a496-dd441388da6b > (accessed 4 November 2011). 16 [MASSDEP and MDPH] Massachusetts Department of Environmental Protection (MassDEP) 17 and Massachusetts Department of Public Health (MDPH). 2012. Wind Turbine Health Impact 18 Study: Report of Independent Expert Panel. Springfield: MA. January 2012. Available at 19 <http://www.mass.gov/dep/energy/wind/turbine_impact_study.pdf> (accessed 2 May 2012). 20 [MMS] Minerals Management Service. 2006. Technology White Paper on Wave Energy 21 Potential on the U.S. Outer Continental Shelf. MMS Renewable Energy and Alternate Use 22 Program. Available at <http://ocsenergy.anl.gov> (accessed 13 December 2010). 23 [MMS] Minerals Management Service. 2009. Cape Wind Energy Project Final Environmental 24 Impact Statemen
- t. January 2009. Available at 25 <http://www.boemre.gov/offshore/AlternativeEnergy/PDFs/FEIS/
26 Cape%20Wind%20Energy%20Project%20FEIS.pdf> (accessed 20 December 2010). 27 Monitoring Analytics, LLC (Monitoring Analytics). 2012. State of the Market Report for PJM, 28 2011, Volume 2: Detailed Analysis. March 15, 2012. Available at 29 <http://www.monitoringanalytics.com/reports/PJM_State_of_the_Market/2011/2011 -som-pjm-vo 30 lume2.pdf> (accessed 5 May 2012). 31 [NERC] North American Electric Reliability Corporation. 2008. 2008 Long-Term Reliability 32 Assessment: 2008 -2017. Princeton: NJ. October 2008. Available at 33 <http://www.nerc.com/files/LTRA2008%20v1.1.pdf> (accessed 19 May 2011). 34 [NETL] National Energy Technology Laboratory. 2007. Cost and Performance Baseline for 35 Fossil Energy Plants, Vol. 1, Bituminous Coal and Natural Gas to Electricity. DOE/NETL 36 2007/1281. Final Report. Pittsburgh, PA: U.S. Department of Energy (Original Issue May). 37 Revision 1, August. Available at 38 <http://www.fossil.energy.gov/news/techlines/2007/07057 -DOE_Issues_Plant_Performance_Re 39 por.html> (accessed 17 May 2011). 40 [NETL] National Energy Technology Laboratory. 2010. Cost and Performance Baseline for 41 Fossil Energy Plants, Volume 1, Bituminous Coal and Natural Gas to Electricity, Revision 2. 42 DOE/NETL 2010/1397. November 2010. Available at 43 <http://www.netl.doe.gov/energy -analyses/pubs/BitBase_FinRep_Rev2.pdf> (accessed 44 17 May 2011). 45 8BEnvironmental Impacts of Alternatives 8-90 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statemen t 1 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437, Volumes 1 2 and 2. May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 3 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 - Transportation; Table 9.1, 4 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 5 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 6 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 7 No. ML04069720. 8 [NRC] U.S. Nuclear Regulatory Commission. 2002. Generic Environmental Impact Statement 9 on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 10 Nuclear Power Reactors. Washington, DC: NRC. NUREG -0586, Supplement 1, Volumes 1 11 and 2. 12 [NRC] U.S. Nuclear Regulatory Commission. 2011. Information Digest, 2011 -2012. Washington, 13 DC: NRC. NUREG -1350, Volume 23. Available at 14 <http://www.nrc.gov/reading -rm/doc-collections/nuregs/staff/sr1350/v23/sr1350v23.pdf > 15 (accessed 7 May 2012). 16 [NREL] National Renewable Energy Laboratory. 2005. Milbrandt A. A Geographic Perspective 17 on the Current Biomass Resource Availability in the United States. Technical Report NREL/TP 18 560 39181. December. Available at <http://www.nrel.gov/gis/biomass.html > (accessed 19 17 May 2012). 20 [NREL] National Renewable Energy Laboratory. 2006. Creating Baseload Wind Power Systems 21 Using Advanced Compressed Air Energy Storage Concepts. NREL/PO -640-40674. October. 22 ADAMS Accession No. ML100151731. 23 [NREL] National Renewable Energy Laboratory. 2010. Solar Insolation Maps, Dynamic Maps, 24 GIS Data and Analysis Tools. Interactive website. Available at 25 <http://www.nrel.gov/gis/solar.html > (accessed 19 May 2012). [NREL] National Renewable 26 Energy Laboratory. 2011. "Estimates of Windy Land Area and Wind Energy Potential, by State, 27 for Areas >=30% Capacity Factor at 80m." Updated April 13, 2011. Available at 28 <http://www.windpoweringamerica.gov/docs/wind_potential_80m_30percent.xlsx > (accessed 29 3 November 2011). 30 Office of Innovative Partnerships and Alternate Funding, Highway Division, Oregon Department 31 of Transportation, State of Oregon (OIPP). 2010. Health and Safety Concerns of Photovoltaic 32 Solar Panels. Salem, Oregon. Available at 33 <http://www.oregon.gov/ODOT/HWY/OIPP/docs/SafetyConcernsPVPanels012510.pdf?ga=t> 34 (accessed 2 May 2012). 35 PJM. Undated. "PJM Demand Response Fact Sheet for End -Use Customers." Available at 36 <http://www.pjm.com/markets -and-operations/~/media/markets -ops/dsr/end -use-customer-fact-37 sheet.ashx> (accessed 19 May 2012). 38 PJM. 2010. PJM Manual 21, Rules and Procedures for Determination of Generating Capability. 39 Revision: 09. PJM System Planning Department. Effective Date: May 1, 2010. Available at 40 <http://pjm.com/documents/manuals.aspx> (accessed 9 November 2011). 41 PJM. 2012a. Transmission Expansion Advisory Committee. October, 11, 2012. Available at: 42 http://www.pjm.com/~/media/committees -groups/committees/teac/20121011/20121011 -reliabilit 43 y-analysis-update.ashx Accessed November 6, 2012. 44 PJM. 2012b. Renewable Energy Dashboard. January 4, 2012. Available at: 45 http://www.pjm.com/about -pjm/renewable -dashboard.aspx Accessed November 6, 2012. 46 8BEnvironmental Impacts of Alternatives 8-91 PJM. 2012 c. "Demand Response." Available at 1 <http://www.pjm.com/markets -and-operations/demand -response.aspx> (accessed 19 2 May 2012). 3 Reuters. 2011. "NYPA Pulls Plug on Great Lakes Offshore Wind Project." September 27, 2011. 4 Available at <http://www.reuters.com/assets/print?aid=USTRE78Q5SC20110927> (accessed 5 1 November 2011). 6 [Siemens] Siemens Power Generation. 2007. Technical Data: Combined Cycle Power Plant 7 Performance Data. Available at 8 <http://www.powergeneration.siemens.com/products -solutions-services/9 power-plant-soln/combined-cycle-power-plants/technical -data> (accessed July 2009). 10 Sovacool B. 2008. Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical 11 Survey. Energy Policy 36 (2008) 2940 -2953. Available at 12 <http://www.nirs.org/climate/background/sovacool_nuclear_ghg.pdf> (accessed 13 16 December 2010). 14 Wald ML. "Offshore Wind Is a Bit Closer, Backers Say." Green: A Blog about Energy and the 15 Environment. The New York Times. October 13, 2011. Available at 16 <http://green.blogs.nytimes.com/2011/10/13/offshore -wind-is-inching-closer-backers-say/> 17 (accessed 2 November 2011). 18 Wind Powering America. 2011. "Installed Wind Capacity by State." Updated April 29, 2011. 19 Available at <http://www.windpoweringamerica.gov/docs/installed_wind_capacity_by_state.xls> 20 (accessed 3 November 2011). 21
9-1
9.0 CONCLUSION
1 This draft supplemental environmental impact statement (SEIS) contains the environmental 2 review of Exelon's application for renewed operating licenses for Limerick Generating Station, 3 Units 1 and 2 (LGS), as required by the Code of Federal Regulations (CFR), Part 51 of 4 Title 10 (10 CFR Part 51), the U.S. Nuclear Regulatory Commission's (NRC 's) regulations that 5 implement the National Environmental Policy Act (NEPA). This chapter presents conclusions 6 and recommendations from the site -specific environmental review of LGS and summarizes 7 site-specific environmental issues of license renewal that the NRC staff (staff) noted during the 8 review. Section 9.1 summarizes the environmental impacts of license renewal; Section 9.2 9 presents a comparison of the environmental impacts of license renewal and energy alternatives; 10 Section 9.3 discusses unavoidable impacts of license renewal, energy alternatives, and 11 resource commitments; and Section 9.4 presents conclusions and staff recommendations. 12 9.1. Environmental Impacts of License Renewal 13 The staff's review of site-specific environmental issues in this SEIS leads to the conclusion that 14 issuing renewed license s at LGS would have SMALL impacts for the Category 2 issues 15 applicable to license renewal at LGS, as well as environmental justice and chronic effects for 16 electromagnetic fields. 17 The staff considered mitigation measures for each Category 2 issue, as applicable. For surface 18 water use, current measures to mitigate the environmental impacts of plant operations were 19 found to be adequate. The Delaware River Basin Commission (DRBC) requires LGS to shift to 20 an alternative water source when the flow of the Schuylkill River falls to 560 (15.9 m 3/s) to 21 ensure that LGS cooling water withdrawals and associated consumptive use will not reduce flow 22 by more than 12 percent during low -flow periods. 23 The staff also considered cumulative impacts of past, present, and reasonably foreseeable 24 future actions, regardless of what agency (Federal or non -Federal) or person undertakes them. 25 The staff concluded in Section 4.11 that cumulative impacts of LGS's license renewal would be 26 SMALL for all areas except aquatic ecology and terrestrial ecology. For aquatic ecology, the 27 staff concluded that the cumulative impact would be SMALL to MODERATE. For terrestrial 28 ecology, the cumulative impacts would be MODERATE. 29 9.2. Comparison of Alternatives 30 In the conclusion to Chapter 8, the staff considered the following alternatives to LGS license 31 renewal: 32 natural-gas-fired combined -cycle (NGCC), 33 supercritical pulverized coal, 34 new nuclear, 35 wind power, 36 purchased power, and 37 no-action. 38 The staff concluded that the environmental impacts of renewal of the operating license for LGS 39 would be smaller than those of feasible and commercially viable alternatives. The no -action 40 alternative, the act of shutting down LGS on or before its license expires, would have SMALL 41 environmental impacts in most areas with the exception of socioeconomic impacts which would 42 have SMALL to MODERATE environmental impact. Continued operations would have SMALL 43 Conclusion 9-2 environmental impacts in all areas. The staff concluded that continued operation of the existing 1 LGS is the environmentally preferred alternative. 2 9.3. Resource Commitments 3 9.3.1. Unavoidable Adverse Environmental Impacts 4 Unavoidable adverse environmental impacts are impacts that would occur after implementation 5 of all workable mitigation measures. Carrying out any of the energy alternatives considered in 6 this SEIS, including the proposed action, would result in some unavoidable adverse 7 environmental impacts. 8 Minor unavoidable adverse impacts on air quality would occur due to emission and release of 9 various chemical and radiological constituents from power plant operations. Nonradiological 10 emissions resulting from power plant operations are expected to comply with 11 U.S. Environmental Protection Agency (EPA) emissions standards, although the alternative of 12 operating a fossil -fueled power plant in some areas may worsen existing attainment issues. 13 Chemical and radiological emissions would not exceed the National Emission Standards for 14 hazardous air pollutants. 15 During nuclear power plant operations, workers and members of the public would face 16 unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 17 exposed to radiation and chemicals associated with routine plant operations and the handling of 18 nuclear fuel and waste material. Workers would have higher levels of exposure than member s 19 of the public, but doses would be administratively controlled and would not exceed standards or 20 administrative control limits. In comparison, the alternatives involving the construction and 21 operation of a non -nuclear power generating facility would also result in unavoidable exposure 22 to hazardous and toxic chemicals to workers and the public. 23 The generation of spent nuclear fuel and waste material, including low -level radioactive waste, 24 hazardous waste, and nonhazardous waste would also be unavoidable. In comparison, 25 hazardous and nonhazardous wastes would also be generated at non -nuclear power generating 26 facilities. Wastes generated during plant operations would be collected, stored, and shipped for 27 suitable treatment, recycling, or disposal in accordance with applicable Federal and State 28 regulations. Due to the costs of handling these materials, power plant operators would be 29 expected to carry out all activities and optimize all operations in a way that generates the 30 smallest amount of waste possible. 31 9.3.2. Short-Term Versus Long -Term Productivity 32 The operation of power generating facilities would result in short -term uses of the environment, 33 as described in Chapters 4, 5, 6, 7, and 8. "Short -term" is the period of time that continued 34 power generating activities take place. 35 Power plant operations require short -term use of the environment and commitment of resources 36 and commit certain resources (e.g., land and energy), indefinitely or permanently. Certain 37 short-term resource commitments are substantially greater under most energy alternatives, 38 including license renewal, than under the no -action alternative because of the continued 39 generation of electrical power and the continued use of generating sites and associated 40 infrastructure. During operations, all energy alternatives require similar relationships between 41 local short -term uses of the environment and the maintenance and enhancement of long -term 42 productivity. 43 Conclusion 9-3 Air emissions from power plant operations introduce small amounts of radiological and 1 nonradiological constituents to the region around the plant site. Over time, these emissions 2 would result in increased concentrations and exposure, but they are not expected to impact air 3 quality or radiation exposure to the extent that public health and long -term productivity of the 4 environment would be impaired. 5 Continued employment, expenditures, and tax revenues generated during power plant 6 operations directly benefit local, regional, and State economies over the short term. Local 7 governments investing project -generated tax revenues into infrastructure and other required 8 services could enhance economic productivity over the long term. 9 The management and disposal of spent nuclear fuel, low -level radioactive waste, hazardous 10 waste, and nonhazardous waste requires an increase in energy and consumes space at 11 treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet 12 waste disposal needs would reduce the long -term productivity of the land. 13 Power plant facilities are committed to electricity production over the short term. After 14 decommissioning these facilities and restoring the area, the land could be available for other 15 future productive uses. 16 9.3.3. Irreversible and Irretrievable Commitments of Resources 17 This section describes the irreversible and irretrievable commitment of resources that have 18 been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit 19 the future options for a resource. An irretrievable commitment refers to the use or consumption 20 of resources that are neither renewable nor recoverable for future use. Irreversible and 21 irretrievable commitment of resources for electrical power generation include the commitment of 22 land, water, energy, raw materials, and other natural and man -made resources required for 23 power plant operations. In general, the commitment of capital, energy, labor, and material 24 resources are also irreversible. 25 The implementation of any of the energy alternatives considered in this SEIS would entail the 26 irreversible and irretrievable commitment of energy, water, chemicals, and in some cases, fossil 27 fuels. These resources would be committed during the license renewal term and over the entire 28 life cycle of the power plant, and they would be unrecoverable. 29 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 30 operations and electricity for equipment and facility operations. Electricity and fuel would be 31 purchased from offsite commercial sources. Water would be obtained from existing water 32 supply systems. These resources are readily available, and the amounts required are not 33 expected to deplete available supplies or exceed available system capacities. 34 Conclusion 9-4 9.4. Recommendations 1 The NRC's preliminary recommendation is that the adverse environmental impacts of license 2 renewal for LGS are not great enough to deny the option of license renewal for energy -planning 3 decisionmakers. This recommendation is based on the following: 4 the analysis and findings in NUREG -1437, Volumes 1 and 2, Generic 5 Environmental Impact Statement for License Renewal of Nuclear Plants, 6 the environmental report submitted by Exelon, 7 consultation with Federal, state, and local agencies, 8 the NRC's environmental review, and 9 consideration of public comments received during the scoping process. 10 10-1 10.0 LIST OF PREPARERS 1 Members of the U.S. Nuclear Regulatory Commission's (NRC's) Office of Nuclear Reactor 2 Regulation (NRR) prepared this SEIS with assistance from other NRC organizations and 3 contract support from Pacific Northwest National Laboratory (PNNL). Table 10-1 lists each 4 contributor's name, affiliation, and function or expertise. 5 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 Contractor(a) 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
11-1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 1 TO WHOM COPIES OF THIS SEIS ARE SENT 2 Table 11-1. List of Agencies, Organizations, and Persons to Whom Copies of this SEIS 3 Are Sent 4 Name and Titl e 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 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
List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent 11-2 Name and Titl e 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
List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent 11-3 Name and Titl e 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 List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent 11-4 Name and Titl e 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 15 th 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 Ga le 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 List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent 11-5 Name and Titl e 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
12-1 12.0 INDEX 1 2 A 3 accidents, xviii, 4-38, 5-1, 5-2, 5-3, 5-4, 4 5-5, 5-7, 5-8, 5-9, 5-10, 5-12, 5-13, 5-14, 5 8-82,A-12, A-27, A-29, A-31, A-32, A-33, 6 B-9 7 Advisory Council on Hispanic 8 Preservation (HCHP), 1-7, 2-83, 2-94, 9 4-31, 4-59, 11-1 10 alternatives, iii, xviii, xix, 1 -6, 5-2, 5-3 , 11 5-3, 5-7, 5-13, 6-3, 6-4, 6-5, 8-1, 8-2, 8-3, 12 8-4, 8-5, 8-8, 8-9, 8-10, 8-12, 8-18, 8-24, 13 8-28, 8-32, 8-33, 8-37, 8-41, 8-42, 8-43, 14 8-46, 8-48, 8-49, 8-51, 8-53, 8-56, 8-58, 15 8-59, 8-60, 8-61, 8-62, 8-63, 8-64, 8-66, 16 8-68, 8-69, 8-70, 8-71, 8-72, 8-73, 8-77, 17 8-78, 8-79, 8-81, 8-84, 9-1, 9-2, 9-3, 10-1, 18 A-1, A-7, A-8, A-9, A-22, A-29, A-30, 19 A-31, A-32, A-33, A-42, B-9 20 archaeological resources, xviii, 1-7, 21 2-80, 2-82, 3-2, 4-28, 4-31, 4-52, 8-3, 22 8-15, 8-26, 8-35, 8-44, 8-47, 8-54, 8-55, 23 8-63, 8-72, 8-83, 8-85, 10-1, B-9, D-1 24 B 25 biota, 2-32, 2-37, 2-40, 2-43, 2-45, 4-7, 26 4-13, 4-14, 4-46, 4-47, 4-48,8-11, 8-69, 27 B-2 28 boiling water reactor, 2-1, 3-1, 5-6, A-30, 29 B-7 30 burnup, 2-1, 5-12, 5-13, B-13 31 C 32 chronic effects, 1-3, 4-21, 4-28, 9-1, B-7 33 Clean Air Act (CAA), 2-26, 2-87, 4-43, 34 8-7, 8-18, 8-19, 8-57, 8-66, 8-86, A-10, 35 C-2 36 closed-cycle cooling, xvi, 1-4, 1-6, 2-16, 37 2-20, 2-21, 2-31, 2-54, 4-8, 4-9, 4-10, 38 4-13, 4-15, 4-47, 8-3, 8-5, 8-6, 8-11, 8-22, 39 8-23, 8-28, 8-32, 8-69, 8-80, B-2, B-3, B-4 40 core damage frequency (CDF), A-30 41 Council on Environmental Quality 42 (CEQ), 1-4, 4-55 43 critical habitat, 2-52, 2-57, 2-59, 2-60, 44 2-61, 2-85, 4-15, 4-19, 8-11, 8-12, 8-22, 45 8-23, 8-32, 8-40, 8-41, 8-51, 8-59, 8-60, 46 8-69, C-4 47 D 48 design-basis accident, 4-38, 5-1, B-9 49 dischargers, 2-2, 2-8 , 2-16, 2-20, 2-33, 50 2-34, 2-45, 4-5, 4-6, 4-8, 4-9, 4-13, 4-14, 51 4-24, 4-44, 4-45, 4-47, 4-48, 8-10, 8-11, 52 8-21, 8-22, 8-31, 8-39, 8-59, 8-69, A-33, 53 A-41, A-41, B-1, B-2, B-7, C-3, F-2, F-3, 54 F-4 55 dose, 2-2, 4-8, 4-22, 4-23, 4-24, 4-25, 56 4-38, 4-40, 4-50, 4-51 , 4-53, 5-8, 5-9, 57 5-12, 5-13, 7-1, 8-35, 9-2, A-18, A-19, 58 A-20, B-7, B-9, B-10, B-11, B-12, B-13 59 E 60 education, 2-67, 2-76, 2-93, 2-95, 2-96, 61 3-2, 4-28, A-23, B-8 62 electromagnetic fields, xviii, 1-3, 4-8, 63 4-21, 4-27, 4-28, 8-52, 9-1, B-6, B-7 64 endangered and threatened species, 65 1-7, 1-8, 2-15, 2-50, 2-52, 2-59, 2-85, 66 2-88. 2-93. 4-10. 4-16. 4-54. 4-58, 8-11, 67 C-4, D-1 68 Index 12-2 Endangered Species Act (ESA), 1-7, 1 1-8, 2-15, 2-50, 2-52, 2-59, 2-85, 2-88, 2 2-93, 4-10, 4-16, 4-54, 4-58, 8-11, C-4, 3 D-1 4 entrainment, 4-7, 4-13, 8-11, 8-22, 8-31, 5 8-82, B-2, B-3, B-4 6 environmental justice (EJ), xviii, 1-3, 7 1-6, 3-2, 4-28, 4-32, 4-33, 4-38, 4-51, 8 4-54, 4-55, 8-3, 8-15, 8-26, 8-35, 8-44, 9 8-48, 8-55, 8-63, 8-72, 8-83, 9-1, 10-1, 10 B-13 11 essential fish habitat (EFH), C-4, D-1 12 F 13 Fish and Wildlife Coordination Act 14 (FWCA), C-4 15 G 16 Generic Environmental Impact 17 Statement (GEIS), xv, xvi, xvii, xx, 1 -3, 18 1-4, 1-5, 1-6, 1-8,.2-70, 2-71, 3-1, 3-2, 19 4-1, 4-2, 4-27, 4-28, 4-29, 4-30, 4-33, 20 4-39, 4-40, 5-1, 5-2, 5-3, 5-4, 5-5, 5-8, 21 5-14, 6-1, 6-2, 6-3, 7-1, 7-2, 8-1, 8-2, 8-9, 22 8-12, 8-13, 8-16, 8-23, 8-24, 8-25, 8-33, 23 8-36, 8-42, 8-45, 8-53, 8-61, 8-70, 8-74, 24 8-77, 8-78, 8-80, 8-81, A-1, A-5, B-1, B-9 25 greenhouse gases, 6-3, A-34, A-35, 26 A-38, A-39 27 groundwater, xviii, 1-6, 2-16, 2-21, 2-22, 28 2-23, 2-35, 2-26, 2-3, 7, 2-55, 2-56, 2-68, 29 3-1, 4-4, 4-5, 4-6, 4-7, 4-21, 4-23, 4-24, 30 4-39, 4-40, 4-41, 4-43, 4-45, 4-46, 4-53, 31 4-55, 8-3, 8-8, 8-9, 8-10, 8-16, 8-20, 8-21, 32 8-22, 8-27, 8-28, 8-30, 8-31, 8-36, 8-39, 33 8-45, 8-46, 8-48, 8-50, 8-56, 8-58, 8-65, 34 8-68, 8-74, 8-81, 8-84, 8-85, A-7, A-12, 35 A-13, A-41, B-4, B-5, B-9, C-1 36 H 37 hazardous waste, 2-7, 2-8, 2-85, 2-86, 38 9-2, 9-3, C-4, C-6 39 heat shock, 4-7, 8-82, B-4 40 high-level waste, xvi, 1-4, 6-1, 6-2, 8-36, 41 8-83, B-9, B-10, B-11, B-12, B-13 42 I 43 Impingement, 4-7, 4-18, 8-11, 8-22, 8-31, 44 8-82, B-2, B-4, 4-7, 4-13 45 Independent spent fuel storage 46 installation, 2-2, 2-70, 4-42, 4-50, 4-53, 47 A-12, F-5 48 L 49 low-level waste, 6-1, 8-36, B-12 50 M 51 Magnuson-Stevenson Fishery 52 Conservation and Management Act 53 (MSA), 1-7, 2-50, C-4 54 Marine Mammal Protectino Act 55 (MMPA), C-4, 56 maximum occupational dose, 4-22, B-7 57 mitigation, xvi, xvii, 1 -4, 1-6, 2-15, 2-82, 58 4-7, 4-9, 4-22, 4-29, 4-40, 4-42, 5-3, 5-5, 59 5-6, 5-7, 5-9, 5-11, 5-13, 5-13, 5-14, 5-15, 60 5-16, 5-17, 6-10, 7-1, 7-2, 8-15, 8-26, 61 8-35, 8-44, 8-47, 8-51, 8-54, 8-60, 8-68, 62 8-72, 9-1, 9-2, 10-1, A-6, A-12, A-24, 63 A-29, A-30, A-31, A-33 64 mixed waste, 2-7, 6-1, 8-36, 8-83, B-12 65 N 66 National Environmental Policy Act 67 (NEPA), xii, 1-1, 1-8, 2-92, 4-31, 4-33, 68 4-55, 4-58, 6=-2, 8-1, 9-1, 8-13, A-43, B-1, 69 B-10, B-11 70 Index 12-3 National Marine Fisheries Service 1 (NMFS), 1-7, 2-38, 2-40, 2-45, 2-50, 2-51. 2 2=-52. 2-53. 2-54. 2-84. 2-93. 4=-10. 4-11. 3 4-12, 4-58, 4-59, 8-11, 8-22, 8-32, 8-40, 4 8-51, 8-59, 8-60, 8-69, C-4 5 National Pollutant Discharge 6 Elimination System (NPDES), 2-8, 2-16, 7 2-20, 2-21, 2-31, 2-32, 2-33, 2-36, 2-45, 8 2-90, 4-13, 4-14, 4-26, 4-47, 8-9, 8-10, 9 8-20, 8-21, 8-22, 8-30, 8-31, 8-39, 8-40, 10 8-51, 8-59, 8-68, A-41, A-42, B-2, C-1, 11 C-3, C-5 12 nonattainment, 2-26, 2-86, 3-2, 4-42, 13 8-7, 8-18, 8-23, 8-29, 8-38, 8-50, 8-57, 14 8-66, B-6 15 O 16 once-through cooling, B-2, B-3, B-4 17 P 18 peak dose, B-10 19 pressurized water reactor, 3-1 20 R 21 radon, 4-23, A-19, B-9 22 Ranny wells, B-5 23 reactor, xv, xvi, 1 -1, 1-5, 2-1, 2-2, 2-6, 24 2-9, 2-29, 2-70, 2-84, 3-1, 4-1, 4-6, 4-24, 25 4-25, 4-26, 4-29, 4-50, 4-51, 4-54, 5-1, 26 5-2, 5-3, 5-4, 5-5, 5-6, 5-12, 5-14, 6-2, 27 6-4, 6-10, 7-1, 8-2, 8-6, 8-11, 8-17, 8-23, 28 8-28, 8-32, 8-41, 8-82, 8-84, A-11, A-12, 29 A-18, A-21, A-23, A-24, A-25, A-26, A-30, 30 A-31, A-42, B-5, B-7, B-9, B-12 31 refurbishment, 2-2 7, 2-80, 3-1, 3-2, 4-2, 32 4-9, 4-10, 4-11, 4-12, 4-13, 4-15, 4-16, 33 4-21, 4-25, 4-33, 4-42, 4-43, 4-53, 8-21, 34 8-31, A-11, B-1, B-2, B-4, B-6, B-7, B-8, 35 B-9 36 S 37 salinity gradients, 4-3, B-1 38 scoping, iii, xv, xvii, xx, 1 -2, 1-3, 1-6, 39 2.95, 4-1, 4-2, 4-3, 4-5, 4-7, 4-8, 4-9, 4-21, 40 4-22, 4-29, 4-32, 4-41, 5-2, 5-11, 5-12, 41 5-17, 6-2, 7-2, 9-4, A-1, A-2, A-3, A-6, 42 A-18, A-44, E-2, F-1 43 severe accident mitigation alternative 44 (SAMA), 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 45 5-10, 5-11, 5-12, 5-13, 5-14, A-6, A-7, 46 A-22, A-27, A-29, A-30, A-31, A-32, A-33 47 severe accidents, 4-38, 5-1, 5-2, 5-3, 48 5-4, 5-5, 5-7, 5-9, 5-10, 5-13, 5-14, A-12, 49 A-29, A-31, A-32, A-33, B-9 50 solid waste, xix, 2-2, 2-6, 2-7, 6-1, 6-2, 51 7-2, 8-2, 8-76, 8-77, 8-79, A-10, B-13, 52 C-1, C-4 53 spent fuel, xvi, 1-4, 2-1, 2-2, 2-70, 4-50, 54 5-5, 5-6, 6-1, 6-2, 6-10, 8-16, 8-28, 8-36, 55 8-45, 8-48, 8-56, 8-65, 8-74, 8-84, 8-85, 56 A-12, A-24, A-28, A-29, A-33, A-34, B-9, 57 B-10, B-11, B-12, B-13, F-5 58 State Historic Preservation Office 59 (SHPO), 2-84, 2-94, 4-59, B-9 60 surface water, 2-21, 2-22, 2-31, 2-32, 61 2-36, 2-60, 2-67, 3-1, 4-2, 4-3, 4-4, 4-5, 62 4-6, 4-23, 4-38, 4-39, 4-43, 4-44, 4-45, 63 4-47, 4-48, 4-53, 8-3, 8-9, 8-10, 8-11, 64 8-21, 8-22, 8-30, 8-31, 8-39, 8-51, 8-59, 65 8-68, 8-69, 8-81, 9-1, A-10, A-13, A-41, 66 A-42, B-1, B-4, C-1, C-3 67 T 68 Transmission lines, 2-15 , 2-49, 2-50, 69 2-51, 2-52, 2-59, 2-82, 2-97, 4-2, 4-10, 70 4-13, 4-14, 4-15, 4-16, 4-17, 4-18, 4-20, 71 4-27, 4-28, 4-42, 4-49, 4-52, 4-61, 8-6, 72 8-28, 8-39, 8-46, 8-47, 8-51, 8-53, 8-55, 73 8-70, 8-82, B-6, B-9 74 Index 12-4 U 1 U.S. Department of Energy (DOE), 4-28, 2 8-3, 8-37, 8-38, 8-75, 8-87, 8-89, 8-90, 3 B-11 4 U.S. Environmental Protection Agency 5 (EPA), 1-1, 1-7, 2-7, 2-8, 2-9, 2-24, 2-26, 6 2-35, 2-36, 2-37, 2-69, 2-70, 2-89, 4-6, 7 4-25, 4-40, 4-42, 4-45, 4-46, 4-47, 4-50, 8 4-55, 8-3, 8-7, 8-18, 8-19, 8-23, 8-29, 9 8-38, 8-50, 8-57, 8-66, 8-67, 8-77, 8-80, 10 8-86, 8-87, 8-88, 9-2, 11-1, A-13, A-14, 11 B-1, B-11, C-1, C-2, C-3, C-4, C-6, F-5 12 U.S. Fish and Wildlife Service (FWS), 13 2-50, 2-51, 2-52, 2-55, 2-57, 2-59, 2-60, 14 2-61, 2-62, 2-84, 2-90, 2-91, 4-10, 4-11, 15 4-12, 4-17, 4-18, 4-19, 4-57, 8-11, 8-12, 16 8-22, 8-23, 8-32, 8-40, 8-41, 8-51, 8-59, 17 8-60, 8-69, D-1, D-2 18 uranium, 2-1, 2-2, 4-50, 5-12, 6-1, 6-2, 19 6-4, 6-5, 6-6, 6-7, 6-8, 6-9, 8-5, 8-13, 20 8-23, 8-24, 8-32, 8-33, 8-42,8-53, 8-61, 21 8-70, A-34, B-9, B-12, B-13 22 W 23 wastewater, 2-8, 2-21, 2-31, 2-33, 2-36, 24 2-40, 2-45, 4-3, 4-43, 4-44, 4-47, 8-77, 25 A-40, B-2, F-2, F-3 26 Y 27 Yucca Mountain, B-10, B-11, B-13 28 APPENDIX A 1 COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 2 UNITS 1 AND 2, ENVIRONMENTAL REVIEW 3
A-1 COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 1 UNITS 1 AND 2, ENVIRONMENTAL REVIEW 2 A.1. Comments Received during Scoping 3 The scoping process began on August 26, 2011, with the publication of the U.S. Nuclear 4 Regulatory Commission's (NRC 's) notice of intent to conduct scoping in the Federal Register 5 (FR) (75 FR 53498). As part of the scoping process, the NRC held two public meetings at the 6 Sunnybrook Ballroom in Pottstown, PA, September 22, 2011. Approximately 100 members of 7 the public attended the meetings. After the NRC staff presented prepared statements pertaining 8 to the license renewal and the scoping process es, the meetings were opened to members of the 9 public for their comments. Attendees provided oral statements that were recorded and 10 transcribed by a certified court reporter. Transcripts of the entire meeting are available using 11 the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS 12 Public Electronic Reading Room is accessible at http://www.nrc.gov/reading -rm/adams.html. 13 Transc ripts for the afternoon and evening meetings are available in ADAMS under Accession 14 Nos. ML11287A207 and ML11287A21 1, respectively (NRC 2011a, NRC 2011b). In addition to 15 the comments received during the public meetings, comments were received through the mail 16 and e-mail. 17 Each commenter was given a unique identifier so that every comment could be traced back to 18 its author. Table A-1 identifies the individuals who provided comments applicable to the 19 environmental review and the commenter ID associated with each person's set of comments. 20 The individuals are listed in the order in which they spoke at the public meeting and in random 21 order for the comments received by letter or e--mail. To maintain consistency with the scoping 22 summary report, the unique identifier used in that report for each set of comments is retained in 23 this appendix. 24 Specific comments were categorized and consolidated by topic. Comments with similar specific 25 objectives were combined to capture the common essential issues raised by participants. 26 Comments fall into one of the following general groups: 27 Specific comments that address environmental issues within the purview of 28 the NRC environmental regulations related to license renewal. These 29 comments address the Category 1 (generic) or Category 2 (site-specific) 30 issues identified in NUREG -1437, "Generic Environmental Impact Statement 31 for License Renewal of Nuclear Plants" (GEIS), or issues not addressed in 32 the GEIS. The comments also address alternatives to license renewal and 33 related Federal actions. There are also comments that do not identify new 34 information for the NRC to analyze as part of its environmental review. 35 There are comments that address issues that do not to fall within or are 36 specifically excluded from the purview of NRC environmental regulations 37 related to license renewal. These comments typically address issues such as 38 the need for power, emergency preparedness, security, current operational 39 safety issues, and safety issues related to operation during the renewal 40 period. 41 42 Appendix A A-2 Table A-1. Individuals Providing Comments during the Scoping Comment Period 1 Commenters are identified below, along with their affiliations 2 and how their comments were submitted. 3 Commenter Affiliation (if stated) ID Comment source ADAMS Accession Number Dr. Lewis Cuthbert Alliance for a Clean Environment 1 Afternoon scoping meeting ML11287A207 Evening scoping meeting ML11287A211 Letters ML11354A392 ML11036A244 ML11036A245 Bill Maguire Limerick Site Vice President, Exelon 2 Afternoon scoping meeting Ml11287A207 Evening scoping meeting ML11287A211 Representative Tom Quigley State Representative 3 Afternoon scoping meeting ML11287A207 Lorraine Ruppe Resident 4 Afternoon scoping meeting ML11287A207 Evening scoping meeting ML11287A211 Letter ML11308B354 Mike Gallagher Vice President for License Renewal, Exelon 5 Afternoon scoping meeting ML11287A207 Evening scoping meeting ML11287A211 Dr. Fred Winter Resident 6 Afternoon scoping meeting ML11287A207 Evening scoping meeting ML11287A211 Letter ML11305A016 Thomas Neafcy Resident 7 Afternoon scoping meeting ML11287A207 Dr. Anita Baly Resident 8 Afternoon scoping meeting ML11287A207 Letter ML11035A010 Tim Fenchel Schuylkill River Heritage Area 9 Afternoon scoping meeting ML11287A207 Bill Vogel Resident 10 Afternoon scoping meeting ML11287A207
Appendix A A-3 Commenter Affiliation (if stated) ID Comment source ADAMS Accession Number Eileen Dautrich Tri-County Area Chamber of Commerce 11 Afternoon scoping meeting ML11287A207 Billy Albany 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 Thomas Saporito Saporito-Associates 16 Evening scoping meeting ML11287A207 Jeff Chomnuk Resident 17 Evening scoping meeting ML11287A207 Daniel Ludwig Resident 18 Evening scoping meeting ML11287A207 Catherine Allison 19 Evening scoping meeting ML11287A207 Jeffrey Norton Pennsylvania Energy Alliance 20 Evening scoping meeting ML11287A207 Dan Ely Resident 21 Evening scoping meeting ML11287A207 Jay Beckermen Resident 22 Evening scoping meeting ML11287A207 Jim Der Pottstown Energy Advisory Committee 23 Evening scoping meeting ML11287A207 Traci Confer 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 Brice Obermeyer Delaware Tribe Historic Preservation Office 31 Letter ML11279A113 Sherry White Stockbridge -Munsee Tribal Historic Preservation Office 32 Letter ML11279A114
Appendix A A-4 Commenter Affiliation (if stated) ID Comment source ADAMS Accession Number Unknown 33 Letter ML11286A298 Richard Kolsch Resident 34 E-ma il ML11286A299 Charles and Elizabeth Shank Resident 35 Letter ML11286A300 Nancy Leaming Resident 36 E-mail ML11290A102 Cynthia Gale Resident 37 E-mail ML11290A103 Jude Schwegel 38 E-mail ML11290A104 Michael Gale Resident 39 E-mail ML11290A105 Melissa Antrim Resident 40 E-mail ML11291A155 Michael Antrim Resident 41 E-mail ML11291A156 Joan McGone 42 E-mail ML11292A011 Mary Lou and Harold Smith Resident 43 Letter ML11294A208 Lisa Smoyer 44 E-mail ML11300A011 Unknown 45 Letter ML11300A012 Lori Molinari Resident 46 Letter ML11305A072 Doris Meyers Resident 47 E-mail ML11305A014 Ken Sekellick Resident 48 E-mail ML11305A015 Anthony Gonyea 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 Thomas Sullivan 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 Barbara Miller Resident 59 Letter ML11311A063 Debra Schneider Resident 60 Letter ML11313A013
Appendix A A-5 To evaluate the comments, the NRC staff gave each comment a unique identification code that 1 categorizes the comment by technical issue and allows each comment or set of comments to be 2 traced back to the commenter and original source (transcript, letter, or e-mai l) from which the 3 comments were submitted. 4 Comments were placed into one of the technical issue categories, which are based on the 5 topics that will be contained within the staff's supplemental environmental impact statement 6 (SEIS) for Limerick Generating Station (LGS), as outlined by the GEIS. These technical issue 7 categories and their abbreviation codes are presented in Table A-2. 8 Table A-2. Technical I ssue Categories 9 Comments were divided into 1 of the 16 categories below, each of which has a unique 10 abbreviation code. 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 S R Support of License Renewal SW Surface Water (a) 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 12 section, along with the NRC response. They are presented in the order shown in Table A -3. 13 The comments that are outside the scope of the environmental review for LGS are not included 14 here but can be found in the scoping summary report, which can be accessed throug h ADAMS, 15 Accession No. ML12131A499. 16 Appendix A A-6 Table A-3. Comment R esponse Location in Order of Resource Area 1 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 A.1.1. Alternative Energy Sources (AL) 2 Comment: 1-44-AL; We have had 26 years of insults to our environment, and I choose that 3 word purposely, insults to our environment and costly nuclear power. We can replace it with 4 safe, clean, renewable energy before 2029. That is a matter of scientific fact. 5 Comment: 4-8-AL; Solar wind, geothermal, ocean thermal, energy conservation and efficiency 6 are now cheaper than nuclear power, along with being truly clean and safe. The Department of 7 Energy 2006 report stated solar alone could provide 55 times our entire nation's energy needs 8 which leads me to a point, there have been numerous studies proving the many dangerous and 9 deadly consequences of nuclear power. 10 Comment: 5-3-AL; We also reviewed the alternatives if Limerick would not have its license 11 renewed and another source of electric generation would need to be installed either here on site 12 or someplace else to generate the replacement electricity. We concluded that any other means 13 of generating the replacement electricity would have more of an impact on the environment than 14 continued operation of Limerick. For instance, if Limerick could be replaced by a wind 15 generation facility, the wind from [it] would have to occupy between 10 and 40 percent of all the 16 land in the state of Delaware and that would have a huge impact on the land. If a solar facility 17 could replace Limerick, it would need to cover 32 to 50 percent the entire land area of 18 Montgomery County. 19 Comment: 6 AL; Please listen to this advice after years of doing my best for America. Rely 20 on more and truly safe and renewable sources like solar, wind, and geothermal power. 21 A patriotic duty to protect our kids. 22 Appendix A A-7 Comment: 16-7-AL; The NRC is required under the law in this review, the environmental 1 review to consider renewable energy sources, alternatives. And that means need. Is there 2 really a need for these two nuclear plants to operate and the answer is no. Simply stated if all 3 the customers who receive power from these nuclear plants were to simply remove their hot 4 water heaters and replace them with on -demand electric water heaters you would reduce the 5 electric base load demand by 50 to 70 percent. You wouldn't need either one of those nuclear 6 power plants to operate. If you take that further and introduce other energy conservation you 7 would actually have the licensee shut down more of their other power plants because of you 8 would need a demand. If you take wind energy which is plentiful up there in Pennsylvania and 9 even the new solar panel which can operate when the sun isn 't shining on a cloudy day you 10 could replace even more operating power plants. So these renewable energy sources even 11 with respect to wind energy since you have a common grid throughout the United States you 12 can have wind farms generate power to a common grid point and supplying the power that 13 these nuclear plants are now providing. The NRC 's required under the law to consider these 14 alternatives to extending this license. And I would hope that the NRC 's final evaluation and 15 review shows a complete and thorough analysis of all these renewable energy sources 16 including installing on demand hot water electric heater and doing an analysis of how many 17 megawatts you're going to take off the grid and based on those evaluations make a licensing 18 determination whether or not this license should be extended. Because 20 years from now all 19 these renewable resources are going to be all that much more advanced and capable of 20 supplying all that much more power than they 're currently supplying. 21 Comment: 25-5-AL; Other forms of energy can and must be utilized to meet consumption 22 demands. 23 Comment: 27-1-AL; I am under the belief that the natural disaster in Japan is enough for 24 Pennsylvania to make a move toward clean energy. 25 Comment: 28-2-AL; I support more healthy and efficient sources of energy such as Solar and 26 Wind Power. Please stop ignoring the detrimental effects that this power plant is having on our 27 environment, health, and children's health -it's time to move on to betters things for all involved. 28 Comment: 29-1-AL; I hope Exelon Energy does not get Renewed. I am sure we could find 29 alternative energy that would not be contaminating the whole area. 30 Comment: 35-6-AL; The nuclear process is not an enlightened way to generate electrical 31 energy. This plant needs to transition itself into a more intelligent way of generating energy by 32 actually phasing out and safely shutting down the nuclear plant. By retraining its workers and 33 adopting the safer green technologies, it could truly partner with the local community without 34 putting its workers out of jobs. 35 Comment: 37 A, 39-16-AL; Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not 36 Needed. It Can And Should Be Replaced With Safe, Clean, Renewable Energy 37 Comment: 44-5-AL; We as a society need to wake up and start paying attention to the 38 massive harm power plants can cause to the people, animals, water, air, etc. Why does 39 everyone want to pay attention when it is way too late?? There are safer alternative forms of 40 energy available to our country/communities. We should be working on them and training 41 employees, who currently work for the nuclear power plants, how to work with safer forms of 42 energy to help our country move forward in today 's society. 43 Comment: 44-10-AL; We deserve to live in a community where our air and water isn 't being 44 contaminated constantly with hazardous chemicals, radiation, etc., when there are other energy 45 alternatives out there that are being used that are safer for the community. 46 Appendix A A-8 Comment: 44-12-AL; Do your job knowing that you are doing what is morally right and safe for 1 humanity and for my children and for the future of generations to come. Please help women 2 have a chance to carry a baby full term without complications due to any possible air and water 3 pollution that may have been caused by allowing more radiation into the environment when 4 there are safer alternatives for energy. 5 Comment: 53-2-AL; We need cleaner air and water. We need to decrease radiation. We 6 need clean, safe, renewable energy. 7 Comment: 60-3-AL; Do not extend -Plenty of safe alternatives -water-solar-wind-8 geothermal. 9 Comment: 60-19-AL; Can replace with clean renewable energy before current license expires. 10 Response: In evaluating alternatives to license renewal, the NRC staff first selects energy 11 technologies or options currently in commercial operation, as well as some technologies not 12 currently in commercial operation but likely to be commercially available by the time the current 13 LGS's operating licenses expire, in 2024 and 2029. 14 Second, the NRC staff screens the alternatives to remove those that cannot meet future system 15 needs. Then, the remaining options are screened to remove those whose costs or benefits 16 don't justify inclusion in the range of reasonable alternatives. Any alternatives remaining, then, 17 constitute alternatives to the proposed action that the NRC staff evaluates in depth throughout 18 Chapter 8. 19 The staff will evaluate all reasonable alternatives in Chapter 8 of the SEIS. In this chapter, the 20 NRC staff examines the potential environmental impacts of alternatives to license renewal for 21 LGS, as well as alternatives that may reduce or avoid adverse environmental impacts from 22 license renewal, when and where these alternatives are applicable. 23 In addition to evaluating alternatives to the proposed action, the NRC staff also -when 24 appropriate -examines alternatives that may reduce or avoid environmental impacts of the 25 proposed action; the NRC staff does so to illustrate how such alternatives may mitigate potential 26 impacts of license renewal. 27 The NRC staff considered 18 alternatives to the proposed action and then narrowed to the five 28 alternatives considered. In addition to the five alternative, the staff considered the no -action 29 alternative (not renewing the operating license). 30 The alternatives evaluated in depth included the following; 31 natural-gas-fired combined -cycle (NGCC) 32 supercritical pulverized coal 33 new nuclear 34 wind power 35 purchased power 36 no action 37 Other alternatives considered, but dismissed, are listed below: 38 solar power 39 combination alternative of wind, solar, and NGCC 40 combination alternative of wind and compressed -air energy storage 41 wood waste 42 conventional hydroelectric power 43 ocean wave and current energy 44 Appendix A A-9 municipal solid waste 1 biofuels 2 oiled-fired power 3 delayed retirement 4 c oal-fired integrated gasification combined-cycle 5 demand-side management 6 A.1.2. Air & Meteorology (AM) 7 Comment: 1 AM; Major air pollution issues under health -based standards of the Clean Air 8 Act, 32 individual sources listed. Drastic, harmful increases permitted in particulate matter 9 known also as PM -10 from the cooling towers, other air pollution increases also permitted. 10 Comment: 1-22-AM; They are a major air polluter under the Clean Air Act and to say they're 11 not doing it anymore, they just asked for the conditions that would allow an eightfold increase in 12 dangerous air pollution that actually is claimed to kill people, thousands of deaths per year. And 13 they asked for an eightfold increase. As a matter of fact, these are all the air pollution sources 14 and the pollutants they list in their own permit. If you add that to all the radiation emissions 15 there's a broad range of radionuclides. 16 Comment: 1-32-AM; [M]ajor air pollution under health -based standards of the Clean Air Act. 17 A Title 5 permit being issued to this facility means by definition that they are a major air polluter 18 under the federal Clean Air Act. 19 Comment: 37-2-AM, 39-3-AM; Major Air Pollution Under Health Based Standards of the Clean 20 Air Act 21 Comment: 60-8-AM; They want increase emissions -Pollutants 22 Response: Air pollutant emissions associated with LGS operations are presented in 23 Sections 2.2.2.1 of the SEIS. The NRC's evaluation of LGS's air emissions is presented in 24 Section 4.2 of this SEIS. 25 Comment: 35-3-AM; Limerick Nuclear's request for re -licensing is ludicrous, considering its 26 aging and inadequate equipment, its increased air pollution by particulate matter, its horrific 27 destruction of Schuylkill river 28 Response: Aging management of plant systems is evaluated as part of the LRA safety review. 29 The results of the staff's safety review of the LRA for LGS will be documented in the staff's 30 safety evaluation report (SER). 31 Air pollutant emissions associated with LGS operations are presented in Sections 2.2.2.1 of the 32 SEIS. The NRC's evaluation of LGS's air emissions is presented in Section 4.2 of this SEIS. 33 Surface water resources at LGS, including the Schuylkill River, and the effects of plant 34 operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of 35 the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied upon 36 by LGS and including the sources of water used to augment low flows in the Schuylkill River. 37 A.1.3. Decommissioning (DC) 38 Comment: 34-2-DC; A firm closure plan should be approved before license renewal is 39 accepted. This must include what is to be done with the site, where the nuclear waste will be 40 disposed of etc. 41 Appendix A A-10 Response: Decommissioning would occur whether LGS were shut down at the end of its 1 current operating license or at the end of the period of extended operation. Environmental 2 impacts from the activities associated with the decommissioning of any reactor before or at the 3 end of an initial or renewed license are evaluated in the GElS (NUREG-1437) and in 4 NUREG-0586 Generic Environmental Impact Statement for Decommissioning Nuclear Facilities, 5 Supplement 1, "Regarding the Decommissioning of Nuclear Power Reactors," published 6 in 2002. The findings from these two documents are used to support the findings in the SEIS by 7 the use of tiering. Tiering is a process by which agencies eliminate repetitive discussions. The 8 effects of license renewal on the impacts of decommissioning are stated in Chapter 7 of this 9 SEIS. 10 A.1.4. Geology (GE) 11 Comment: 1 GE; Limerick, in addition, is now third on the earthquake risk list for nuclear 12 plants in the United States. 13 Comment: 4-2-GE; [F]our months have passed since the NRC failed to get back to me when I 14 asked how close the Remapo fault line is to the Limerick nuclear reactors? 15 Comment: 4-14-GE; It took five months for the Nuclear Regulatory Commission to answer my 16 question concerning how close the nearest fault line is to Limerick Nuclear Plant. No wonder! 17 Two faults are dangerously close. Chalfont Fault is only 9 miles East. Ramapo Fault is 17 18 miles Northwest. This is alarming! 19 Comment: 30-2-GE; Limerick should NOT be approved for an extension with their permit for 20 the following reasons: 21 Limerick is designated as one of the TOP THREE nuclear plants in the 22 country based on it's construction (which is similar to the ones in Japan -and 23 we see how they failed) and the fact that it sits on an earthquake fault line. 24 The NRC JUST a few weeks ago stated that "more information needs to be 25 done and studied" regarding further fortifying nuclear plants regarding 26 earthquakes. Thus, until you folks know exactly what needs to be done, 27 etc.THERE IS NOTHING TO APPROVE as long as Limerick sits in it's 28 current position. 29 Do NOT think that earthquakes only happen on the West Coast -as we 30 JUST had a 6+ earthquake less than a month ago. BY ONLY luck was there 31 no damage to the plant, environment or community. 32 Comment: 51-4-GE; Limerick is built on a fault 33 Comment: 52-5-GE; It is one of the six most dangerous plants in the country because [of] its 34 proximity to an earthquake fault. 35 Comment: 60-2-GE; Earthquake Fault 36 Response: Geologic and seismic conditions were considered in the original design of nuclear 37 power plants and are part of the license bases for operating plants. Seismic conditions are 38 attributes of the geologic environment that are not affected by continued plant operations and 39 refurbishment and are not expected to change appreciably during the license renewal term for 40 all nuclear power plants. Nevertheless, as part of characterizing the environmental baseline 41 (affected environment) and associated resource conditions of LGS and the vicinity, 42 Section 2.2.3 of the SEIS includes a discussion of the current geologic environment, including 43 its seismic setting. Specifically, the section includes a discussion of the Ramapo fault system. 44 Appendix A A-11 This fault system encompasses the Chalfont fault and other named geologic faults. In addition, 1 the NRC and Exelon considered in Chapter 5 of this SEIS whether increased seismic risk could 2 provide a seriously different picture of severe accidents mitigation at Limerick. 3 As noted in the section, the nearest mapped faults to LGS have not been geologically active for 4 more than 140 million years. 5 To the extent that the comments express concern for the seismic design of LGS, the seismic 6 design of structures are beyond the scope of the environmental review. NRC's assessment of 7 seismic hazards for existing nuclear power plants is a separate and distinct process from 8 license renewal reviews. Seismic hazard issues are being addressed by the NRC on an 9 ongoing basis at all licensed nuclear facilities. The NRC requires all licensees to take seismic 10 activity into account to maintain safe operating conditions at all nuclear power plants. When 11 new seismic hazard information becomes available, the NRC evaluates the new data and 12 models to determine if any changes are needed at existing plants, regardless of whether or not 13 a plant has renewed its license or is applying for license renewal. This reactor oversight 14 process, which includes seismic safety, remains separate from license renewal. 15 Unrelated to license renewal, the NRC completed the Generic Issues Program Safety/Risk 16 Assessment Stage for Generic Issue (GI) 199 in August 2010, "Implications of Updated 17 Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing 18 Plants," which evaluated recent updates to estimates of the seismic hazard in the central and 19 eastern United States. The results of the GI-199 Safety/Risk Assessment indicated that the 20 currently operating nuclear power plants have adequate safety margin for seismic issues. The 21 NRC's assessment indicated that overall seismic risk estimates remain SMALL, and adequate 22 protection is maintained. NRC Information Notice 2010-18 (ADAMS Accession 23 No. ML101970221) was then issued to nuclear power plants and independent spent fuel 24 storage installations (ISFSI). It provided notice of the NRC's intent to follow the appropriate 25 regulatory process to request that operating plants and ISFSIs provide specific information 26 relating to their facilities to enable the NRC staff to complete the Regulatory Assessment, in 27 which candidate backfits would be identified and evaluated. The NRC then developed a draft 28 Generic Letter to request needed data from power reactor licensees. 29 However, following the accident at the Fukushima Dai -ichi nuclear power plant resulting from 30 the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the NRC established 31 the Near-Term Task Force, as directed by the Commission. The Japan Near -Term Task Force 32 assessment resulted in the issuance of letters requesting information per Title 10 of the Code of 33 Federal Regulations (10 CFR) 50.54(f) letter on March 12, 2012. These letters were issued to 34 all power reactor licensees and holders of construction permits and address GI -199 in its 35 entirety in recommendation 2.1 regarding seismic reevaluations, (ADAMS Accession 36 No ML12056A046). The NRC staff will use this information, as well as information requested in 37 the 10 CFR 50.54(f) letter, to determine if further regulatory action is needed, including issuing 38 orders to modify, suspend, or revoke a license. 39 A.1.5. Groundwater (GW) 40 Comment: 1 GW, 37-5-GW, 39-6-GW; Radioactive Groundwater Contamination. 41 Comment: 37-4-GW, 39-5-GW; Schuylkill River Depletion and Major Drink Water 42 Contamination 43 Comment: 45 GW; Limerick contaminated groundwater. Radioactive leaks and spills over 44 the years were never cleaned up. More radioactive leaks can be expected in the future through 45 earthquakes, deterioration, and corrosion. Many residential well are very close to Limerick. 46 Appendix A A-12 Response: This comment deals with groundwater quality issues related to the operation of 1 LGS. Groundwater resources at LGS, and the effects of plant operations on groundwater 2 hydrology and quality, are presented in Sections 2.2.5 and 4.4 of the SEIS. Specifically, 3 Section 2.2.5.1 discusses groundwater users at and in the vicinity of the plant, and 4 Section 2.2.5.2 summarizes the results of the NRC's review of Exelon's Radiological 5 Groundwater Protection Program for LGS, including the placement of site groundwater 6 monitoring wells. As part of this evaluation, the NRC staff specifically reviewed the 7 hydrogeologic investigation prepared for LGS in 2006 and the results of ongoing groundwater 8 quality monitoring. Chapter 2 of this SEIS cites all studies reviewed by the NRC staff. 9 Based on the staff's review, and as presented in Section 4.4.3 of this SEIS, no strontium -90 or 10 gamma-emitting radionuclides have been detected in groundwater or surface water associated 11 with LGS operations or at levels above natural background. While inadvertent releases of 12 liquids containing tritium (a radioactive isotope of hydrogen) have occurred to the ground and 13 subsurface at LGS, levels in groundwater have been less than one -tenth of the EPA establish ed 14 drinking water standard of 20,000 picoCuries per liter. No upward trend in tritium levels has 15 been observed, and Exelon's ongoing Radiological Groundwater Protection Program functions 16 to detect and address potential new sources of groundwater contamination. Further, there are 17 no offsite drinking water wells downgradient of LGS that could be affected by inadvertent 18 releases of radionuclides to groundwater. 19 A.1.6. Historical and Archaeological (HA) 20 Comment: 31-1-HA; Thank you for informing the Delaware Tribe on the proposed construction 21 associated with the above referenced project. Our review indicates that there are no religious or 22 culturally significant sites in the project area. As such, we defer comment to your office as well 23 as to the State Historic Preservation Office and/or the State Archaeologist. 24 We wish to continue as a consulting party on this project and look forward to receiving a copy of 25 the cultural resources survey report if one is performed. We also ask that if any human remains 26 are accidentally unearthed during the course of the survey and/or the construction project that 27 you cease development immediately and inform the Delaware Tribe of Indians of the inadvertent 28 discovery. 29 Comment: 49-1-HA; Thank you for providing the Onondaga Nation with information about this 30 project. If any changes are made, I would like to be consulted. I realize that Unit 1 and Unit 2 31 have licenses that may be renewed in 2024 and 2029 respectively, therefore you may send 32 updates and information until then. 33 In the event that during project construction, any archeological resources or remains, including, 34 without limitation, human remains, funerary objects, sacred objects, or objects of cultural 35 patrimony are uncovered, please immediately stop construction and contact me at 36 (315) 952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at 37 (315) 475-2559. 38 Response: In accordance with 36 CFR 800.8(c), the NRC has elected to coordinate 39 compliance with section 106 of the National Historical Preservation Act with steps it has taken to 40 meet its requirements under the National Environmental Policy Act (NEPA). An overview of 41 consultation activities that occurred during the preparation of this SEIS is given in 42 Section 4.10.6. All consultation parties will receive a copy of the draft SEIS to review and 43 provide comments to the NRC. 44 Appendix A A-13 A.1.7. Human Health (HH) 1 Comment: 1-15-HH; Research has confirmed radiation in our children's baby teeth in this 2 community. 3 Comment: 1 HH; Alarming cancer increases that have been well documented in this 4 community repeatedly far higher than national and state averages after Limerick started 5 operating until the late 1990s. 6 Comment: 1 HH; The sooner this place closes the better off we'll all be. Even if you look at 7 infant mortality rates we have higher infant mortality rates and neonatal mortality rates far above 8 state averages and even above Philadelphia and Reading, and we've had these for quite 9 awhile. The fact is when babies are the most vulnerable in the womb what else would we 10 expect? And by the way, for those of you who have been saying that ACE data is anecdotal 11 today I have news for you. This infant mortality report for example is state data reported by 12 EPA in 2003. Every cancer statistic that you see back there is based on Pennsylvania Cancer 13 Registry statistics or CDC statistics. So it is not anecdotal, those are the cancer increases, 14 those are the cancer above the national average that have happened here since Limerick 15 started operating. 16 Comment: 1 HH; We have so many cancers above the national average. Childhood 17 cancer, 92.5 percent higher than the national average. Think about that. We track the cost of 18 one child with cancer diagnosed at six months to two years and up until that time it was 19 $2.2 million. How many more kids have that above the national average? Cost that out and 20 how many other cancers are above the national average? 21 Comment: 1 H; [D]ocumented alarming cancer increases especially in our children since 22 Limerick started operating 23 Comment: 4-6-HH; There has been increased particulate matter in the air and other toxics 24 from Limerick causing increased asthma, heart attacks, and strokes. And to add insult to injury, 25 Limerick was granted a permit to allow an eight -fold increase in air pollution since 2009. Cancer 26 rates in our area have skyrocketed since Limerick has been up and running in the '80s and 27 rates have steadily increased. 28 Comment: 4-7-HH; The Toothfairy Project showed high levels of strontium 90, a radionuclide 29 in baby teeth of children nearest to nuke plants. Baby teeth near Limerick plant had the highest 30 levels in the whole United States. This stuff and God knows what else is in our bodies now 31 thanks to a Nuclear Regulatory Commission that to put it nicely is less than enthusiastic about 32 protecting us. 33 Comment: 6-1-HH; As a physician practicing radiology for over 50 years, I still have strong 34 concern about cancer sensitivities from harmful radiation exposures, naturally. My medical 35 colleagues share the same concerns because we have seen our cancer rates increase since 36 the Limerick power plant started, especially thyroid cancer. It jumped to 78 percent higher here 37 than the national average. And some of the people I talked to, this is because people are aging 38 more now, getting older, so there are more cancers. But that's not true because in other areas 39 similar to our area in Pottstown, they're not nearly getting the thyroid cancers that we are. This 40 has been well established by the state. 41 Comment: 6-2-HH; Having attended a Hiroshima, Japan atom bomb clinic right after World 42 War II, naturally I had a chance to see the worst results of harmful radiation. All those little kids 43 I saw who only lived for a few days, it left me with a very sad memory. Of course, what is 44 happening here will be taking much longer, but it sure is not good. I don't know whether you've 45 heard that some scientists are already predicting that -- I'm sorry to tell you this, but nuclear 46 Appendix A A-14 energy has the capacity of destroying mankind. It may take about 100 years, but our whole 1 world is exposed to the harmful effects, maybe not so much here in the United States, but the 2 whole world can be affected. 3 Comment: 6-6-HH; According to the National Center of Disease Control, Pennsylvania ranks 4 No. 1 for the highest incidence of Thyroid cancer. This occurred after installation of nuclear 5 power plants in our area as well as in the rest of the State. Medical journals are reporting high 6 rates of cancer near nuclear plants. 7 Comment: 6-8-HH; Incidentally, baby teeth studies have revealed Strontium 90 radioactive 8 particles which can affect the child's immune system for more illness. 9 Comment: 19-6-HH; but I hate to tell you I have so many friends and coworkers and people 10 that are only 35, 40, 50 years old, cancer. And why? We have to stop and think. Go home, 11 don't just always, you know, just go watch TV and get on your computer. Stop and think what 12 we're doing to ourselves, our bodies, our children, our grandchildren. 13 This is again, this licensing renewal is coming down to human lives, the quality of our lives. 14 Again, why all this cancer? Microwaves and electricity. So I won't go on and on, but I just think 15 us as a group can't just all be just complaining about the power companies, we are the ones 16 using the electricity. That's all I'm saying. Maybe we should cut back and we won't need power 17 plants. 18 Comment: 21-2-HH; Some people don't understand about radiation and I read when the 19 Japanese thing occurred and I heard on the news a radiologist talking about oh, the radiation is 20 such a low amount. It really isn't the low amount of radiation exposure that we get incidentally 21 in standing next to a nuclear power plant. It's three ten -thousandths of a gram of plutonium that 22 is death for you if you breathe that dust particle. It's almost certain death. And the problem 23 becomes you can't have -- and it's not going to be a nuclear bomb. It's going to catch on fire if 24 the fuel pool girders were to fail and you'll have a cloud of a material that in and of itself you 25 might not have radiation exposure to it but that particle when it deposits itself can be an issue 26 much the same as fluoride is what causes thyroid cancer when it's a radioactive fluoride. That's 27 why we're very careful in building a plant with no Teflon and no fluoride components 28 Comment: 36-1-HH; I am concerned about the effects of our surrounding air and water supply 29 of my children and grandchildren, some of whom are already inflicted with cancer and other 30 diseases. 31 Comment: 37-1-HH, 39-2-HH; Radiation into Air and Water From Routine and Accidental 32 Emissions 33 Comment: 37-7-HH, 39-8-HH; Alarming cancer increases, especially in children, since 34 Limerick started operating 35 Comment: 37 HH, 39-15-HH; Increased Costs to the Public -More cancers and other 36 costly illnesses, more emergency room visits and hospitalization from massive increases in 37 PM-10 and TDS, treatment of public drinking water, environmental clean -up 38 Comment: 25-2-HH; The scientific statistics citing dramatic increase in cancer rates, infant 39 mortality, and Schuylkill River water pollution is disturbing. 40 Comment: 36-3-HH; I am more concerned about the effects of surrounding air and water 41 supply and the future of my children and grandchildren, some of whom are already inflicted with 42 cancer and other diseases. 43 Comment: 40-4-HH; it doesn't take an accident or disaster for Limerick to poison the region's 44 residents with radiation. Radiation from Limerick's routine and accidental emissions alone f or 45 Appendix A A-15 the past 26 years is reason enough to deny Exelon's request. It's not credible for NRC to claim 1 continuous radiation levels are safe for me and my family when there is no safe level of 2 exposure according to the National Academy of Sciences and Physicians for Social 3 Responsibility. 4 NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by 5 Exelon and DEP cannot be trusted. Exposure to radiation [is] known to cause cancer. It should 6 be obvious to NRC that Limerick played a major role in our tragic, well documented cancer crisis 7 after Limerick started operating in the mid 1980s to late 1990s. Four cancer studies based on 8 PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far higher 9 than national and state averages, especially in children. Our children had the highest levels of 10 Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick 11 Nuclear Plant released SR -90 into our air and water that got into the milk, vegetation, and food 12 since Limerick started operating. 13 Comment: 40-5-HH; Thyroid cancer increased by 128% from 1985 to 1997 -was as side note, 14 with no family history or other obvious risk factors in my life, I was recently treated for thyroid 15 cancer. Since my diagnosis, I have learned of many other locals like me. It's scary to think the 16 choice of where we lived could kill us. 17 Comment: 41-3-HH; Exposure to radiation is known to cause cancer. NRC has not done any 18 radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and D EP 19 cannot be trusted -it's ridiculous to think they could monitor themselves. It should be obvious 20 to NRC that Limerick played a major role in our cancer crisis after Limerick started operating 21 mid 1980s to 2000. Four cancer studies based on Pennsylvania Cancer Registry and the CDC 22 showed skyrocketing rates for several cancers much higher than national and state averages, 23 especially children -innocent children. Thyroid cancer increased 128% from 1985 to 1997. I 24 have local friends and family with thyroid cancer and brain cancer -not one, but several. Sadly 25 it is uncommon in other areas of the country. It used to be uncommon here too -prior to 26 Limerick. Would you want to live here? Would you approve a license renewal so close to 27 home? Your job is to safely review the facts. 28 Comment: 42-2-HH; The increased risk of cancer is well founded in the literature also. 29 Comment: 44-8-HH; The most alarming and compelling thing to me as a taxpayer, 30 homeowner, and mother is the overwhelming and alarming cancer increases to the public after 31 Limerick had started operating. The CDC website showed 92.5% higher than the national 32 average for childhood cancer in six communities close to the Limerick Nuclear Plant which 33 included, Pottstown, West Pottsgrove, Lower Pottsgrove, North Conventry, and Douglas Berks 34 Township from cancers diagnosed from 1995 -1999. The Pennsylvannia State Cancer Registry 35 For Montgomery County from 1985 -86 to 1996 -97 also shows cancer rates skyrocketed in 36 Montgomery County where the Limerick Nuclear Plant is located during the Mid 80's and 90's 37 after they opened. Prostate Cancer increased 132%, Thyroid Cancer increased 128%, Kidney 38 cancer increased 96%, Multiple Myeloma increased 91%, Hodgkin's Disease increase 67%, 39 Non-Hogdin's Lymphoma increased 61%, Breast cancer increased 61%, Pancreas cancer 40 increased 54%, and Leukemia increased 48%. 41 Radiation exposure can cause cancer and other serious disease and disability, at any level of 42 exposure according the National Academy of Sciences and Physicians Responsibility. 43 Permissible radiation levels does not mean that they are safe levels for everyone in the 44 community. Most permissible levels based on the average healthy adult. They are not levels 45 that were based or researched for fetuses, infants, toddlers, and children or pets. Fetuses, 46 infants, children, pets, and the elderly and immuned compromised individuals are at most risk of 47 health problems. There is a broad range of dangerous randionulcides routinely released into air 48 Appendix A A-16 and water from the Limerick Nuclear Plant as well as any accidental releases. Permissible 1 radiation levels does not mean that they are safe radiation levels, it only means that they are 2 allowed. 3 Comment: 44-9-HH; I have children as well as other loved ones that have or have had 4 allergies, asthma, learning disabilities, speech disabilities, behavioral disabilities, thyroid 5 conditions, cancers, skin disorders and irritation, etc. I know neighbors and other community 6 members that have suffered from the same and more. 7 Comment: 45-6-HH; But, it doesn't take an accident or disaster for Limerick to poison the 8 region's residents with radiation. Radiation from Limerick routine and accidental emissions 9 alone for the past 26 years is reason enough to deny Exelon's request. It's not credible for NRC 10 to claim continuous radiation levels are safe for me and my family when there is no safe level of 11 exposure according to the National Academy of Sciences and Physicians for Social 12 Responsibility. 13 Comment: 45-7-HH; NRC is failing to acknowledge obvious health harms from Limerick's 14 continuous additive, cumulative, and synergistic radiation releases which get into water, food, 15 soil, vegetation, milk, and our bodies. NRC has no idea what health harms some of the region's 16 residents experienced from Limerick Nuclear Plant. NRC never did any radiation monitoring or 17 testing at Limerick. Evidence shows testing done by Exelon and DEP cannot by trusted. 18 Comment: 45-8-HH; Exposure to radiation is known to cause cancer. It should be obvious to 19 the NRC that Limerick played a major role in our tragic, well documented cancer crisis after 20 Limerick started operating in the mid 1980s to the late 1990s. Four cancer studies based on 21 PA Cancer Registry and CDC data showed skyrocketing rate for several cancers for higher than 22 the national and state averages, especially children. Our children had the highest levels of 23 Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick 24 Nuclear Plant release SR -90 into our air and water that got into the milk, vegetation, and food 25 since Limerick started operating. Thyroid cancer increased by 128% from 1985 to 1997. Other 26 cancers rose dramatically as well. 27 Comment: 46-6-HH; Finally, my concerns regarding the impact of this nuclear power plant on 28 my community are not limited to catastrophic scenarios that might potentially occur. There have 29 been studies published in health journals that show a higher incidence of certain illness -30 particular among children -in communities surrounding nuclear plants. While these studies 31 were conducted in a variety of locations, they seem to be consistent with some of the data that 32 Pottstown's local Alliance for a Clean Environment presents on its website regarding increased 33 cancer and leukemia rates -also especially among children -in the greater Pottstown area. 34 Comment: 47-2-HH; I am fully aware of the amount of cancer that is prevalent in this area. 35 Comment: 48-2-HH; I moved to Pottstown, Pa., some time ago in perfect health. In 2006, 36 I was diagnosed with prostate cancer. Although, I cannot prove it was a direct cause of t he 37 nuclear power plant, I feel that much further, unbiased studies and tests need to be done prior 38 to the relicensing of the Limerick plant by reputable sources not by corporate interests groups 39 that can manipulate the statistics in Exelon's favor. 40 Wouldn't it be in the best interest of our community and surrounding communities if the higher 41 cancer rate was due the Limerick power plant? This question is a "no brainer." There is plenty 42 of time for testing to be done prior to relicensing. 43 Comment: 51-3-HH; Cancer rates are higher than the national average and NRC is going with 44 the status quo. 45 Appendix A A-17 Comment: 52-6-HH; The surrounding area has abnormally high cancer rates among adults 1 and children. 2 Comment: 57-3-HH; I also feel its presence has led to [an] increase of cancer in our area. 3 Comment: 58-1-HH; I feel that there is a lot of people that had not known to report anything 4 because of not knowing who to go to. I don't understand why the hospitals don't give statistical 5 information based on areas? 6 Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children's 7 Hospital until she was 5. With several years of chemotherapy she is now 18 and in remission. 8 We had lived on Limerick Center Road for most of our young lives and now with our kids. I don't 9 know what other information you would need but I would be happy to get you whatever you 10 might need. 11 Comment: 60 HH; High infant mortality rates and neo natal, cancer increase, thyroid 12 cancer rates 70% higher 13 Comment: 60 HH; cancer increases, especially children 14 Response: The NRC's mission is to protect the public health and safety and the environment 15 from the effects of radiation from nuclear reactors, materials, and waste facilities. The NRC's 16 regulatory limits for radiological protection are set to protect workers and the public from the 17 harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. 18 Radiation standards reflect extensive scientific study by national and international organizations. 19 The NRC actively participates and monitors the work of these organizations to keep current on 20 the latest trends in radiation protection. 21 Recently, the NRC asked the National Academy of Sciences (NAS) to perform a state -of-the-art 22 study on cancer risk for populations surrounding nuclear power facilities. The NAS study will 23 update the 1990 U.S. National Institutes of Health -NCI report, "Cancer in Populations Living 24 near Nuclear Facilities." 25 The study will be carried out in two consecutive phases. A Phase 1 scoping study will identify 26 scientifically sound approaches for carrying out an epidemiological study of cancer risks. This 27 scoping study began on September 1, 2010, and will last for 15 months. The result of this 28 Phase 1 study will be used to inform the design of the cancer risk assessment, which will be 29 carried out in a future Phase 2 study. 30 Although radiation can cause cancers at high doses, currently there are no data to 31 unequivocally establish the occurrence of cancer following exposure s to low doses, below about 32 10 rem (0.1 Sv). Radiation protection experts conservatively assume that any amount of 33 radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is 34 higher for larger radiation exposures. Therefore, a linear, no -threshold dose response 35 relationship is used to describe the relationship between radiation dose and detriments such as 36 cancer induction. Simply stated, any increase in dose, no matter how small, is assumed to 37 result in an incremental increase in health risk. This theory is accepted by the NRC as a 38 conservative model for estimating health risks from radiation exposure, recognizing that the 39 model probably over -estimates those risks. Based on this theory, the NRC conservatively 40 establishes limits for radioactive effluents and radiation exposures for workers and members of 41 the public. While the public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC 42 (10 CFR Pa rt 20, "Standards for Protection Against Radiation"), the NRC has imposed 43 additional constraints on nuclear power reactors. Each nuclear power reactor, including LGS, 44 has license conditions that limit the total annual whole body dose to a member of the public 45 outside the facility to 25 mrem (0.25 mSv). In addition, there are license conditions to limit the 46 Appendix A A-18 dose to a member of the public from radioactive material in gaseous effluents to an annual dose 1 of 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, a dose limit of 3 mrem 2 (0.03 mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ. 3 Chapter 4 of this SEIS discusses the Radiological Environmental Monitoring Program (REMP) 4 that LGS uses for environmental monitoring. The purpose of the LGS Radiological REMP is to 5 evaluate the radiological impact that operation may have on the environment. The program is 6 designed to highlight and look at specific consumption pathways for local inhabitants and 7 special interest groups. The LGS radiological environmental monitoring program is made up of 8 three categories based on the exposure pathways to the public. They are as follows: 9 atmospheric, aquatic, and ambient gamma radiation. The atmospheric samples taken around 10 LGS are airborne particulate, airborne iodine, milk, and broad leaf vegetation. Sampling for the 11 LGS REMP program is performed as specified in Appendix I to 10 CFR Part 50, "Domestic 12 licensing of production and utilization facilities," as well as agreements made with the State of 13 Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection. 14 The amount of radioactive material released from nuclear power facilities is well measured, well 15 monitored, and known to be very small. The doses of radiation that are received by members of 16 the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few 17 millirem) that resulting cancers attributed to the radiation have not been observed and would not 18 be expected. To put this in perspective, each person in this country receives a total annual 19 dose of about 300 mrems (3 mSv) from natural sources of radiation (i.e., radon, 200 mrem; 20 cosmic rays, 2 mrem; terrestrial (soil and rocks), 28 mrem; and radiation within our body, 21 39 mrem) and about 63 mrem (0.63 mSv) from man -made sources (i.e., medical x -rays, 22 39 mrem; nuclear medicine, 14 mrem; consumer products, 10 mrem; occupational, 0.9 mrem; 23 nuclear fuel cycle, <1 mrem; and fallout, <1 mrem). 24 A number of studies have been performed to examine the health effects around nuclear power 25 facilities. The following is a list of some of the studies that have been conducted: 26 In 1990, at the request of Congress, the National Cancer Institute (NCI) 27 conducted a study of cancer mortality rates around 52 nuclear power plants 28 and 10 other nuclear facilities. The study covered the period from 1950 -1984 29 and evaluated the change in mortality rates before and during facility 30 operations. The study concluded there was no evidence that nuclear facilities 31 may be casually linked to excess deaths from leukemia or from other cancers 32 in populations living nearby. 33 Investigators from the University of Pittsburgh found no link between radiation 34 released during the 1979 accident at the Three Mile Island Nuclear Station 35 and cancer deaths among nearby residents. This study followed more than 36 32,000 people who lived within 5 miles (mi) (8 kilometers (km)) of the facility 37 at the time of the accident. 38 In January 2001, the Connecticut Academy of Sciences and Engineering 39 issued a report on a study around the Haddam Neck Nuclear Power Plant, in 40 Connecticut, and concluded that exposures to radionuclides were so low as 41 to be negligible and found no meaningful associations to the cancers studied. 42 In 2001, the American Cancer Society concluded that, although reports about 43 cancer clusters in some communities have raised public concern, studies 44 show that clusters do not occur more often near nuclear plants than they do 45 by chance elsewhere in the population. Likewise, there is no evidence linking 46 Appendix A A-19 the isotope strontium -90 with increases in breast cancer, prostate cancer, or 1 childhood cancer rates. 2 In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims 3 that there are striking increases in cancer rates in southeastern Florida 4 counties caused by increased radiation exposures from nuclear power plants. 5 However, using the same data to reconstruct the calculations on which the 6 claims were based, Florida officials did not identify unusually high rates of 7 cancers in these counties compared with the rest of the state of Florida and 8 the nation. 9 In 2000, the Illinois Public Health Department compared childhood cancer 10 statistics for counties with nuclear power plants to similar counties without 11 nuclear plants and found no statistically significant difference. 12 In summary, there are no studies to date that are accepted by the nation's leading scientific 13 authorities that indicate a causative relationship between radiation dose from nuclear power 14 facilities and cancer in the general public. The amount of radioactive material released from 15 nuclear power facilities is well measured, well monitored, and known to be very small. 16 The staff addresses human health impacts of renewing the LGS operating licenses in 17 Chapters 2 and 4 of the draft SEIS. 18 A.1.8. Land Use (LU) 19 Comment: 54-5-LU; The county has been working hard to develop an interconnected system 20 of open space and trails along the Schuylkill River and within other natural resource areas of the 21 county. In doing this, the county has provided funding to local municipalities and non profit 22 conservation organizations to purchase open space and park land; acquired county land and 23 agriculture easements; and developed trails. The Limerick Generating Station site contains 24 significant land along the Schuylkill River that has been identified as part of the Schuylkill River 25 Greenway in the county plan. The use and management of these lands relative to the county 26 open space and natural areas inventory plans should be evaluated in the relicensing process. 27 Response: Current onsite and offsite land use conditions in the vicinity of LGS are described in 28 Sections 2.2.1 and 2.2.9.3 of this SEIS. The NRC's evaluation of LGS's impacts on onsite and 29 offsite land use during the license renewal term is presented Section 4.1 of this SEIS. While 30 license renewal is not expected to affect the use and management of LGS lands identified as 31 part of the Schuylkill River Greenway, this information will be evaluated with other potential 32 cumulative effects in Section 4.12.6. 33 A.1.9. License Renewal and its Process (LR) 34 Comment: 1-4-LR; Current 40 -year operating licenses expire in 2024 and 2029. Why the rush 35 to renew these licenses now? 36 Comment: 1 LR; While NRC is required to prepare a supplement to the Limerick 37 Environmental Impact Statement for license renewal, we have little confidence in the process 38 based on NRC's regulatory history. It would be difficult to enumerate a short list, so I'm going to 39 rely on written documents. 40 Comment: 4-9-LR; But my big question of the day is why is Exelon applying for an extension 41 18 years ahead of time? 42 Appendix A A-20 Comment: 4 LR; Exelon is rushing the timeline to reissue a license (18 years ahead of 1 time) to run Limerick Nuclear Plant into the unknown, yet it took more than 5 months for the 2 NRC to get back me concerning an already known survey of fault lines. 3 Comment: 8-1-LR; I'm a retired Lutheran pastor and my concern today is with the speed at 4 which this application process is going. I mean it seems to me that to predict what 5 environmental factors will be in place 13 years hence and 18 years hence, posits a kind of 6 omniscience and prescience that we should attribute to Almighty God, but certainly not to any of 7 us human beings. I would favor a slower process. 8 Comment: 8-5-LR; As I stated then, I continue to be concerned and puzzled about the very 9 early and pre -mature application of Exelon to extend the licenses of the towers. One [of] those 10 does not come up for renewal until 2024 and the other 2029. I ask the NRC not work on the 11 relicensing for this facility for at least ten years. The wait could only ensure better information. 12 The public can not possibly benefit from a decision to renew the licenses at this time. The best 13 decision will be made based on the best possible information. The NRC does not have the best 14 information this early. Much will happen in the next ten years. I urge NRC to wait and see how 15 any of it affects the prospect of continuing these plants at that later date. 16 What can happen in the next ten years that we can all learn from the relevantly could be 17 anything. It may be better information about how natural disasters are affecting nuclear 18 facilities; we may know more about weather patterns that could cause damage. We will 19 certainly know more about the world situation in terms of advances in terrorist technological 20 capabilities and goals. We will know more about how well nuclear plants in general and the 21 Limerick facility are faring as they continue age. If someone steps forward to fund studies, we 22 will know yet more about cancer rates in the nuclear zones 23 Comment: 16-4-LR; This particular nuclear plant, these plants, you know, their license is 24 already good till 2024. Why are we here now 12 years ahead of time trying to extend this 25 license? And the only reason is because it's a foot race the NRC's in with Congress and 26 nothing more. This has nothing to do with protecting public health and safety, it's the NRC's 27 zeal to continue to rubber -stamp these license extensions without allowing citizens due process 28 like I already talked about and without doing a cost intense and thorough review. 29 Comment: 19-4-LR; He was stating the fact why are we re -licensing them, what, 12 years 30 ahead of time. To me that is absurd. Like maybe a year before or they have to do some 31 studies, two years before. Why do they want us, and I love Thomas's words, rubber -stamp 32 something? Twelve years beforehand to go into what, 2024 for Unit 1 was it and 2029 for 33 Unit 2? Why do they need to push this licensing renewal? You've got to stop and think. 34 Comment: 25-1-LR; First of all, considering the impact of the outcome to many area residents, 35 this forum was not widely publicized for local citizens to be aware of this important matter and 36 offer feedback. Secondly, it does not make sense that Exelon is pursuing renewal for a license 37 that does not expire until 2024. 38 Comment: 30-1-LR; It is NOT due to expire until 2024 -thus, Exelon has nothing to [lose] but 39 getting an extension sooner than later so they can sit back and relax operating for the next 40 20+ years. 41 Comment: 30 LR; Since the reactor has until 2024 -why the rush, and only one public 42 meeting. I if you have not heard it, you will. There is a major public outrage over this one 43 meeting and not know about it until too late. People want public meetings so that people hear 44 that many are against this plant rather than just submitting comments to the NRC which appears 45 to be rubber stamping license requests -which is not comforting to me and many. 46 Appendix A A-21 Comment: 3-1-LR; Why is the request so early -The NRC should get a request closer to [the] 1 expiration date. Also, the inspection should [be] done closer to the expiration date. In 2023, 2 not 2013. 3 Comment: 34-1-LR; Why is there rush to renew the license? It is not due until 2024, approval 4 at the earliest should be 2019. This would allow 5 years for the business plan of PECO to either 5 continue or close the plant and make arrangements for additional power to replace the closed 6 plant. 7 Comment: 41-1-OR; The possible renewal of Limerick Nuclear Plant's license for 20 years 8 past its current 2024 and 2029 expiration dates more than 12 years ahead of time, worries me a 9 great deal. It's hard to understand why something this major would be done so far in advance. 10 It's IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth 11 would this be renewed early? It's lengthy process that could begin earlier, but in no way should 12 something this important be rushed through now. Why not wait until closer to the expiration 13 dates, and then seek approval? I understand this how the original guidelines were set up -but 14 those are long outdated. Approving Limerick Nuclear Plant to be relicensed until 2049 would be 15 jeopardizing the health of millions. Renewing this license could be catastrophic to millions. 16 Comment: 48-3-LR; Also, why the hurry? Common sense would indicate that Exelon knows 17 something which we are not aware. Why must the license be renewed at this time when they 18 are licensed through 2024 and 2029? 19 Again, Why The Hurry? To relicense now is not the best interest of everyone in our area. 20 Comment: 56-2-LR; Finally, we have grave misgivings regarding the future time -dependence, 21 accuracy, and relevance of the licensee's current ER, as presumptively incorporated in the 22 NRC's planned SEIS for LGS license extension, given that such license extension will not 23 become effective until the current unit operating licenses expire in 2024 (for Unit 1) and 2029 for 24 Unit 2. We submit that any decision to relicense these units must be supported by the most 25 timely NEPA and SAMA analysis obtainable within a reasonable interval (e.g. five years) prior to 26 actual expiration of the existing licenses. 27 Intervals of 12 and 17 years are not required for corporate planning purposes and are far too 28 long to credibly sustain the accuracy and relevance of NEPA analyses, or for the NRC to 29 accurately project both the future condition of the plant, the future state of nuclear safety 30 knowledge, trends in local resource use, population, and the affected environment, and the 31 future range of reasonable electricity supply alternatives to LGS license extension. By 32 comparison, major government owned nuclear installations, such as nuclear laboratories and 33 weapon production sites, are required to conduct site -wide NEPA reviews of their operations 34 and facility plans every \five years. Using this federal standard for timeliness, the NRC's NEPA 35 analysis for LGS relicensing should not commence before 2019, for Unit 1, and before 2024 for 36 Unit 2, or should be subjected to mandatory reassessment and supplementation after those 37 dates. 38 Comment: 60-5-LR; 12 years ahead of time -no way to guarantee safety 39 Comment 60 LR; NRC should not be considering this so far in advance -no way to assure 40 safety-shut it down 41 Response: According to NRC regulations, 10 CFR Part 54, "Requirements for renewal of 42 operating licenses for nuclear power plants," a nuclear power plant licensee may apply to the 43 NRC to renew a license as early as 20 years before expiration of the current license. The NRC 44 determined that 20 years of operating experience is sufficient to assess aging and 45 environmental issues at the site. Additionally, 20 years is a reasonable lead period because if 46 Appendix A A-22 the NRC denies the license renewal application, it takes about 10 years to design and construct 1 major new generating facilities, and long lead time times are required by energy -planning 2 decision makers. 3 Comment: 54-7-LR; As part of the environmental assessment process and the evaluation of 4 the plant safety and long term operational capacity, we think that it is important for the NRC to 5 maintain close communication with the community surrounding the plant. Overall education 6 about the plant and the associated risks presented by its operation should be provided in a 7 variety of ways so that the public is better informed about the plant and the overall evaluation 8 taking place as part of the relicensing. 9 Response: The NRC's Office of Public Affairs (OPA) is available to address the public 10 concerns and questions regarding nuclear safety and information regarding about LGS. The 11 office follows news coverage of the agency and responds to media and public inquiries. If 12 members of the public have questions or comments about the NRC, nuclear safety, or related 13 topics, they can contact OPA at OPA.Resource@nrc.gov. For specific questions and concerns 14 regarding Limerick, the public can contact the Region I OPA at OPA1.Resource.@nrc.gov. 15 Additional contact information for OPA can be accessed at http://www.nrc.gov/ 16 about-nrc/organization/opafuncdesc.html 17 Comment: 1-6-LR; The public was led to believe that Limerick's generators, fuel pools, and 18 miles of underground pipes and cables could operate safely for 40 years and then the facility 19 would close. Is Exelon fearful that the longer they wait the more serious problems may arise? 20 Response: The original licenses for commercial nuclear power plants were granted for 40 year 21 period, which was set by the Atomic Energy Act 1954 and the NRC's regulations. It was 22 imposed for economic and antitrust reasons rather than technical limitations of the plant. 23 According NRC regulations, 10 CFR Part 54, a nuclear power plant licensee may apply to the 24 NRC to renew a license as early as 20 years before expiration of the current license. Part 54 25 requires the applicant to demonstrate that it can successfully manage aging at the facility during 26 the period of extended operation. 27 Comment: 22-1-LR; I'm a resident of Phoenixville. I found out about this meeting because I 28 scan a lot of newspaper websites. I found the notice of the meeting on the West Chester Daily 29 Local website. Didn't find it in the Phoenixville paper, didn't see it in the Philadelphia 30 newspaper, didn't hear about it on any of the local radio stations, didn't hear about it on cable, 31 didn't hear about it on any of the television. 32 Comment: 60 LR; Should have been more public notice for hearing -Mail notices so 33 people have an opportunity to attend. 34 Response: The NRC provides notice of the environmental public meetings through the Federal 35 Register, press releases, and local advertisements. The public also can get information about 36 all NRC public meetings at the NRC public W eb site, http://www.nrc.gov/public -involve/ 37 public-meetings/index.cfm. The public also can receive public meeting notices and press 38 releases by subscribing to e-mail notices for reactor correspondence for Limerick at 39 http://www.nrc.gov/public -involve/listserver/plants -by-region.html. 40 Comment: 22-3-LR: The slide behind me documents exactly two libraries that the documents 41 are going to go in. Why not in my library in Phoenixville? Why not in Montgomery County and 42 Norristown and all of the other public libraries that are in areas that can be affected by the 43 plume should something happen here? Why are the documents in such a restricted area? 44 Response: The NRC contacts the local libraries in the communities surrounding the plant to 45 ask if the agency could send them copies of license renewal applications and other documents 46 Appendix A A-23 related to the license renewal review so that they could be accessed by members of the public. 1 However, some libraries have limited shelf space and may not be able to accommodate the 2 NRC. Member s of the public also can access the license renewal application and SEIS on the 3 Limerick license renewal W eb page on the NRC public W eb site. The public can access the site 4 at http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html . 5 Additionally, the NRC will have hard copies and CDs of the draft SEIS available for the public 6 during the public meeting on the draft SEIS. Members of the public also can contact the NRC to 7 request a hard copy or CD of the SEIS. 8 Comment: 16-2-LR; And I'd like to correct that statement. He stated that the NRC is extending 9 the original operating license which was granted by the NRC for a 40 -year period of time that 10 that initial 40- year license was not based on safety considerations or technical considerations. 11 But that's absolutely not true and there was recently a year -long investigative report done by the 12 Associated Press who interviewed expert nuclear personnel, engineers, safety engineers in the 13 nuclear industry who told them that the 40 -year licenses issued by the NRC for 104 nuclear 14 plants in the United States was based on safety and technical -safety technical analysis. So 15 these proceedings, these license extension proceedings like the one we're currently at are a 16 rubber-stamping of these 20 -year license extensions. 17 Comment: 16-3-LR; This is in fact a foot race between the Nuclear Regulatory Commission 18 and the United States Congress where Congress wants to stop this process, put a moratorium 19 on the re-licensing until the Fukushima disasters can be fully understood and the enhancement 20 enacted in August for our power plants here. 21 Reponses: As a result of Fukushima, the NRC issued three orders requiring safety 22 enhancements of operating reactors, construction permit holders, and combined license 23 holders. These orders require nuclear power plants to implement safety enhancements related 24 to (1) mitigation strategies to respond to extreme natural events resulting in the loss of power at 25 plants, (2) ways to ensure reliable hardened containment vents, and (3) ways to enhance spent 26 fuel pool instrumentation. The plants are required to promptly begin implementation of the 27 safety enhancements and complete implementation within two refueling outages or by 28 December 31, 2016, whichever comes first. In addition, the NRC issued a request for 29 information asking each licensee to reevaluate the seismic and flooding hazards at the site 30 using present -day methods and information, conduct walkdowns of its facilities to ensure 31 protection against the hazards in its current design basis, and reevaluate emergency 32 communications systems and staffing levels. LGS is required to comply with the NRC orders or 33 revised regulations whether or not the operating licenses are renewed. 34 A.1.10. Opposition to License Renewal (OR) 35 Comment: 1-5-OR; We urge the NRC to say no to Exelon's requested license renewals. 36 Comment: 1 LR; It's long past time for the NRC to summon the courage to do the right 37 thing in our judgment and actually protect the environment and the public, rather than the 38 industry. 39 Comment: 1 OR; Based on the compelling body of evidence of environmental harms to 40 date and the enormous increased population in proximity to this facility, Limerick Nuclear Plant 41 must be closed by 2029. There is no amount of energy production that is worth risking the lives 42 of so many people. 43 Comment: 1-29-OR; Nuclear Regulatory Commission today and that is very simply that 44 Limerick nuclear power plant must be closed by the NRC, not re -licensed until 2049. 45 Appendix A A-24 Comment: 6-5-OR; So please, ask your politicians, reliable politicians to close the Limerick 1 power plant. Let's save America for our kids and descendants 2 Comment: 6-9-OR; We can't control the use of nuclear in the rest of the world, but we can 3 keep the U.S. safer by eliminating nuclear energies. Fortunately, many European allies 4 including Australia have decided to phase out reactors. We should join them [to] reduce human 5 suffering. Also this can reduce our increasing costs of health care. 6 Comment: 6 OR; Limerick Power Plant is ranked in the top 3 riskiest nuclear power plants 7 in the U.S.A. Limerick Power Plant must be closed not relicensed. 8 Comment: 10-1-OR; If Limerick Unit 1 or 2 fails, all hell breaks loose, no disrespect. That's 9 what a nuclear failure is, hell. It affects everybody in this room, everybody in the community, 10 everybody in the tri -state area, not for a week, but for decades. It's very, very last thing we want 11 to happen. 12 And I think we're putting ourselves in harm's way by taking something that had a lifespan of 13 40 years and adding another 20 to it. It doesn't make sense. The only way to rationalize it is 14 through our personal fear of being inconvenienced because we lose a very, very good source of 15 power. It's done a great job for us. But like me, you get to a point where your ability to provide 16 a great job is at an end and things start deteriorating. Let's not put ourselves in that position. 17 Let's make an intelligent decision now and allow these two units to expire at their nameplate 18 time. 19 Comment: 19-3-OR; So from day one I think power plants never should have been built but 20 now that they are here why would we ever want to re -license. 21 Comment: 25-4-OR; I attend to agree with the fourteen reasons provided by the Alliance For A 22 Clean Environment why Exelon should be denied the renewal license. In my opinion, the 23 long-term negative consequences caused by the Limerick Generating Station far outweigh any 24 possible benefits it may contribute. 25 Comment: 26-1-OR; Please do NOT extend the Limerick licenses! 26 Comment: 27-2-OR; Renewing Limerick's license just as controversies are arising with pushes 27 to move from dependence on Nuclear energy is a bold business strategy by them. I don't think 28 this the right move to make. A long term contract will limit any sort of wiggle room to address 29 future issues that may arise. 30 I ask that you please consider the future of our great state. I don't think oil or nuclear energy is 31 the way. I truly believe in heart, that in order to protect the health of our population for the 32 future, we must change our ways today. 33 Comment: 28-1-OR; I object being continuously poisoned by the Limerick Nuclear Plant's 34 radiation and other dangerous toxins. Please do not allow for an extension of the Limerick 35 Nuclear Power Plant's operation license. 36 Comment: 29-2-OR; The Reactor time has served its years and should not be renewed. 37 Comment: 30 OR; I feel firmly and many in the community feel the exact same way, that 38 there is no reason to approve NOW (especially so far in advance, with no answer on usage on 39 rods nor what needs to be done to prevent a meltdown due to an earthquake, etc.) or Ever since 40 the population will only increase and the facility age further. It is the wrong timing, wrong plant, 41 wrong place, etc. for Limerick. Maybe Exelon can put in as much effort and "energy" to develop 42 solar fields, etc- They would rather beat the hell out of a high efficiency plan at any and all cost 43 to the environment and community. This where the NRC does the right thing and says NO until 44 a year before it expires. 45 Appendix A A-25 Comment: 35-1-OR; Limerick Nuclear 's influence is vast and horrific. This industry is a 1 behemoth that has not been honest with the public about its true impact, forming its own 2 "environmental" partnerships that are pure pronuclear propaganda tools. It's economic 3 contributions are miniscule when compared to its enormous profits, while destroying our quality 4 of life. The nuclear process's devastating environmental effect on our community cannot be 5 understated. 6 Comment: 35-7-OR; Ordinary daily nuclear generation has had devastating community-wide 7 consequences that need to be addressed. Re -licensing should not even be a consideration! 8 The NRC must fully investigate the environmental concerns presented Dr. Lewis and Donna 9 Cuthbert (ACE), Dr. Winter, and each resident who so civilly represented this community's 10 concerns at the September 22, 2011 hearings. The Limerick Nuclear Power Plant should NOT 11 be re-licensed and should, instead, begin to address the pollution issues it has already created 12 as it seriously and carefully shuts down its reactors. 13 Comment: 38-1-OR; I'm writing to you to state my opposition to the relicensing of Limerick 14 Generating Station in Limerick Township, Pennsylvania. 15 Comment: 40-1-OR; I attended the recent meeting on the possible renewal of Limerick 16 Nuclear Plant's license for 20 years past its current 2024 and 2029 expiration dates. I strongly 17 believe, as do many of my local friends and family that the Limerick Nuclear Plant must be 18 closed, not relicensed. Approving Limerick Nuclear Plant to be relicensed until 2049 would be 19 jeopardizing the health of thousands and thousands of people in neighboring communities. 20 There is substantial evidence readily available which justifies closing Limerick. Renewing this 21 license could lead to a catastrophic meltdown. 22 Comment: 40-6-OR; It would be careless, unethical and immoral for NRC to approve Exelon's 23 requested license extensions Limerick Nuclear Power Plant. Limerick Nuclear Power Plant must 24 be closed by 2029. 25 Comment: 41-4-OR; Just remember, it would be careless, unethical and immoral for NRC to 26 approve Exelon's requested license extensions for Limerick Nuclear Power Plant. Limerick 27 Nuclear Plant must be closed by 2029. 28 Comment: 42-3-OR; Why does the NRC think they can play God with people lives? It is no 29 longer debatable, shut it down before our very lives are jeopardized. 30 So-called quality life issues addressed as part of public debate, e.g. "the power is always on" 31 seems irrelevant to us when our families are required to evacuate during disaster. Limerick 32 must be closed and NOT relicensed at any cost, specifically the cost of life itself! 33 Comment: 43-1-OR; Do NOT renew Limerick licenses. It's too dangerous and too old. Please 34 listen to their neighbors like us. 35 Comment: 44-1-OR; There are so many reasons why you as a group should already know that 36 it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, 37 wildlife in general and the environment for you to refuse/oppose Limerick Power Plant from 38 re-licensing. The problem that always seems to come up at some of the public hearings and 39 sessions where businesses/corporations want to expand and become bigger and run their 40 businesses long past the time that they should truly be allowed in order keep safe, always 41 comes back to the issue of money, offerings, bribes, donations, etc. in the end. When these 42 things occur, people and businesses turn a "blind eye" so to speak to the dangers of allowing a 43 business like the Limerick Power Plant to renew its license again. That is unacceptable. I 44 expect and demand better service from you to help protect myself and my family from harm! 45 Appendix A A-26 Comment: 44-4-OR; It is disgusting and heart wrenching to know that officials and 1 organizations are not paying attention to what can happen to the public if Limerick Power Plant 2 continues to operate longer than expected. Ignoring the obvious problems our community is 3 facing and hoping that after they serve their term, it will be someone else problem to deal with is 4 unacceptable. Now is the time. Step up and [do] what is morally right for humanity 5 Comment: 44 OR; I expect you to what is morally right now for me, my family, my 6 neighbors, my community, and the pets, wildlife, air, water, and environmental in whole by 7 rejecting, refusing, and opposing Limerick Power Plant from relicensing to run their business 8 longer than originally planned for 2029. 9 Comment: 45-1-OR; I urge NRC to deny Exelon's request to renew Limerick Nuclear Plant's 10 license for 20 years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant 11 must be closed, not relicensed, for many valid reasons. Approval of Limerick Nuclear Plant to 12 be relicensed until 2049 would be reckless and would show blatant disregard for the health and 13 safety of the public. There is more than sufficient evidence of harms and threats to justify 14 closing Limerick. There are too many things beyond NRC's control that could lead to a 15 catastrophic meltdown. 16 Comment: 45 OR; It would be both unethical and immoral for NRC to approve Exelon's 17 requested license extensions for Limerick Nuclear Power Plant. All of the unprecedented 18 harms, threats, risks from Limerick Nuclear Plant will increase if NRC approves and additional 19 20 year Limerick license extension, until 2049. Limerick Nuclear Plant must be closed by 2029. 20 Comment: 46-1-OR; I am writing to express my opposition to the re -licensing of Limerick 21 nuclear power generating station, which is located about 20 miles from my home. There are 22 several reasons why this relicensing in not in the best interests of people living in the 23 surrounding community 24 Comment: 48-1-OR; Just a quick note requesting the NRC to NOT allow the relicensing of the 25 Limerick, PA, nuclear plant at this time. 26 Comment: 51-1-OR; Please protect our citizens from possible disaster and do not relicense 27 Limerick 28 Comment: 52-1-OR; As a resident of New Hanover Twp., Montgomery County, PA (less than 29 5 miles from Exelon's Limerick Nuclear Power Plant), I urge you to vote AGAINST the 30 premature relicensing of that facility. 31 Comment: 53-1-OR; I implore you to not relicense the Nuclear Power Plant of Limerick when 32 its licenses expires in 2029. If I had my wish, the power plant would be closed years before 33 2029. 34 Comment: 57-1-OR; Just wanted to voice my opinion for a no vote to renew the license for the 35 Limerick power plant. 36 Response: These comments are general in nature and express opposition to Exelon, nuclear 37 power, and license renewal of LGS. Portions of these comments that express general 38 opposition to renewing the licenses for LGS provide no new and significant information and 39 have not resulted in any changes to this SEIS. Portions of these comments that address 40 particular technical issues are addressed in the respective technical sections of this appendix. 41 Appendix A A-27 A.1.11. Postulated Accidents & SAMA (PA) 1 Comment: 1-1-PA; Whether a natural disaster or terrorist attack occurs, by relicensing 2 Limerick, NRC would in effect be pla ying Russian roulette with the lives of more than eight 3 million people. NRC must close Limerick Nuclear Plant by 202
- 9. 4 Comment: 1 PA; With loss of cooling water, Limerick's fuel rods could heat up, self ignite, 5 and burn in an unstoppable fire with catastrophic results
. Exelon has not been required to 6 spend the money to guard limerick against terrorists, missiles, or air strike despite repeated 7 requests to do so. 8 Comment: 1 PA; It's not safe, it's a ticking time bomb. And nuclear power, they say it's 9 always on. That's not true either as evidence by shutdowns, some for long periods caused by 10 earthquakes, tornadoes, hurricanes, fires, heat, and drought and more. 11 Comment: 4-1-PA; Increasing floods, droughts, earthquakes, tornados have made us all feel 12 insecure, making nuclear power increasingly risky, especially with the Limerick plant basically in 13 our backyards. Any earthquake that comes through this area could be a possible Fukushima, 14 Chernobyl or Three Mile Island-15 Comment: 4 PA; The 9-21-11 Mercury article said "whether or not earthquake risk is a 16 factor in the current relicensing request for Limerick remains to be seen". It would be grossly 17 unacceptable for the NRC to ignore Limerick's extreme vulnerability to earthquake damage. 18 Earthquake risk should be on the top of NRC's relicensing concerns for Limerick. Earthquake 19 risks are far greater for Limerick than previously realized -increased by 141%. We now know 20 Limerick is 3rd on nation's earthquake risk list Plus evidence shows earthquakes in the East can 21 be far stronger than Limerick's "design basis" can withstand. 22 There's a good chance that an earthquake can exceed Limerick's design basis, causing a 23 severe nuclear accident, jeopardizing the health, safety and financial well being of our entire 24 region. 25 The Virginia 8 11 earthquake caused shaking in PA at Limerick Nuclear Plant. Since 26 January there have been 2 small earthquakes in Philadelphia, only 21 miles from Limerick. 27 Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to 28 nuclear disaster. It's disquieting that NRC uses a "visual inspection" to determine damage on 29 buried pipes. Problems may not be identified until it's too late. 30 For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on 31 fires and earthquakes. To save money, Exelon typically concludes Limerick is "safe enough". 32 This is unacceptable! 33 10-5-11, the Mercury reported a flaw was found in the mechanism to shut down the nuclear 34 plant. The warning was tied to renewed focus on earthquake risk. It's difficult to see how 35 Limerick's design flaws can be fixed, even if Exelon WOULD spend the money. 36 There is no proof whatsoever Limerick's design can withstand other threats ranging from 37 hurricanes, tornadoes, floods, or terrorist attacks to an impact from a jet airliner. 38 We need precaution before there is a catastrophe. NRC should close Limerick as soon as 39 possible. 40 Comment: 6-3-PA; Of course, what is happening here will be taking much longer, but it is sure 41 not good news. Besides harmful power plant exposures, we have environmental disasters and 42 a concern about our nearby earthquake fault and others in the eastern U.S., especially one near 43 Appendix A A-28 New York City. And then there are the radioactive spent fuel deadly waste material sitting 1 around, supposedly protected. 2 Comment: 6-7-A; An earthquake in our area is not too far fetched. And of course, threat of 3 terrorism with vulnerable spent fuel are always a concern. 4 Comment: 8-6-PA; One big concern -because of Japan's recent experience and the fact that 5 we had an earthquake in the Limerick plant's territory -is refurbishing the plants so they can 6 withstand earthquakes. It has been widely reported by MSNBC and the AP, using NRC data -7 that the Limerick plant has the nation's third highest risk of being damage by an earthquake. 8 When the plant was built, no one thought this area would get earthquakes. Now we do. I 9 understand Congress is now or soon will be considering increasing earthquake preparedness 10 capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would 11 encourage them to do less than they should to make the plant safer. 12 Comment: 19-1-A; Now lately with the -- unfortunately it's a reality now that we have 13 hurricanes, more tornadoes, tsunamis throughout the world. And I hate to say it but it is a reality 14 now that we have terrorist attacks and Limerick is definitely one. I don't want to be blowing this 15 out of proportion but it's just something that I know that we've all been concerned about, not 16 wanting to say yes, Limerick, and all the people that built the power plant and the company say 17 oh, there's no impact to the air and the water pollution and so forth. So we've kind of just 18 blinded our, you know, selves to that and let's believe then, okay, let's take a minute. Let's 19 really believe that there is no impact in our clean air, clean water and those type of things and 20 cancer, et cetera. Let's just go into the new reality which is terrorist attacks which would 21 happen. Let's just say for example there was human error there with the spent fuel rods and 22 something happened, or a radiation leak. 23 Comment: 30-10-PA; Let's also mention a fact that Category I Hurricane Irene, which could 24 have been Category 3, just zipped less than 100 miles away from the site a few weeks ago and 25 then Hurricane Lee which decided to travel further east case close to also causing chaos. 26 Limerick is still TOO close to the disaster of Hurricanes as well. 27 Comment: 37 PA, 39-12-PA; Increased Risked of Meltdown From More Frequent and 28 Stronger Earthquakes and Other Natural Disasters 29 Comment: 45-2-PA; Limerick is 3 rd on the earthquake risk list. It is too dangerous to keep 30 Limerick operating. Earthquakes and other natural disasters are more frequent and stronger. 31 Underground pipes and cables can shake and break, then lead to loss of power, loss of cooling 32 water, and meltdown. Limerick's substandard containment flaw means more radiation would be 33 released. 34 Comment: 47-1-PA; Limerick Generating Station is old and I don't think it is strong enough to 35 with stand plane impacts, earthquakes, or tornadoes that occur here. 36 Response: The comments express concern for the potential adverse environmental impacts 37 associated with postulated accidents. The impacts of design basis accidents were evaluated in 38 the GElS and determined to be small for all plants; therefore, it is a Categor y 1 issue. The GElS 39 evaluated severe accidents for all plants including LGS, and it concluded that the impact was 40 small under Part 51, "Environmental protection regulations for domestic licensing and related 41 regulatory functions." In accordance with 10 CFR 51.53(c)(3)(ii)(L), the license renewal 42 Environmental Reports must provide consideration of alternatives to mitigate severe accidents if 43 the staff has not previous evaluated SAMAs for the applicant's plants in an environmental 44 impact statement or related supplement or in an environmental assessment. The staff has 45 previously performed a site -specific analysis of severe accidents mitigation in the NEPA 46 Appendix A A-29 document for LGS. For the license renewal review, the staff must consider whether new and 1 significant information affects the environmental determination in the NRC regulations. 2 A detailed discussion of postulated accidents, and the staff's considerations of new and 3 significant information related to SAMA, including seismic risk, can be found in Chapter 5 of this 4 SEIS. 5 Comment: 56-1-PA; The original SAMA analysis for the Limerick Generating Station (LGS) is 6 a 1989 report that was issued as the result of a ruling by the U.S. Court of Appeals for the Third 7 Circuit, which concluded that the NRC had failed to consider a "reasonable set" of Severe 8 Accident Mitigation Design Alternatives ("SAMDAs"). In 1989, the NRC subsequently adopted 9 this SAMDA analysis and agency staff concluded they had "discovered no substantial changes 10 in the proposed action as previously evaluated in the FES [Final Environmental Statement] that 11 are relevant to environmental concerns nor significant new circumstances or information 12 relevant to environmental concerns and bearing on the licensing of [LGS]". 13 As the original LGS SAMDA effort in 1989 was the first mandated effort to focus on SAMAs, the 14 notion that an updated SAMA analysis need not be completed at the license renewal stage (for 15 the exact reactor site that gave birth to the regulatory requirement) we find highly objectionable, 16 particularly in light of the catastrophic nuclear accident that befell similar Boiling Water Reactor 17 (BWR) units in Japan in March, 2011. It has become clear in the 770 years of combined 18 U.S. BWR operational experience since 1989 that domestic and international events provide 19 numerous examples of "new information" and make a strong case for the need to reconsider all 20 that has been learned about newly discovered risks and vulnerabilities of nuclear power plants. 21 It has been noted that global core damage events happen at a rate that exceeds NRC's 22 presumptions of what should be considered safe at plants within the U.S., which implies that 23 either the NRC estimates for domestic plants are wrong or that international nuclear plants have 24 a core damage frequency much higher than what the NRC deems safe. Either scenario is 25 troubling and deserves the industry's full attention and effort. Exelon's 1989 effort in response 26 to the Court was, respectfully, less than one would have hoped for in light of the seriousness o f 27 the issue. The LGS 1989 SAMDA can in no way claim necessary conservatism with regard to 28 public safety over the total timeframe of a possible sixty year reactor lifetime. 29 In contrast to the 1989 SAMDA, relatively recent SAMA analyses conducted in other license 30 renewal applications, such as those for sites at Nine Mile Point, Three Mile Island, and the 31 Joseph M. Farley Nuclear Plant, to name a few, were considerably more thorough and 32 addressed a range of detailed alternatives. Pursuant to regulatory analysis techniques supplied 33 by NRC and aided by an industry -supplied guidance document most modern -day SAMA 34 analyses are designed using a fairly prescriptive set of initial assumptions, baseline calculations, 35 and cost benefit arithmetic recipes that employ the use of sophisticated codes in their evaluation 36 of potential risk and the benefit of removing this risk. 37 The most common code used is the MELCOR accident consequence code system (MACCS2), 38 which provides a modeling framework for calculating the off -site consequences of a severe 39 accident. This code accepts an advanced set of input parameters, including population density 40 distributions within 50 miles, detailed regional economic data obtained from multiple sources, 41 nuclide release scenarios accounting for reactor core inventory, emergency response and 42 exposure variables, and meteorological data for plume migration pathways. The current state of 43 knowledge regarding the assumptions and understanding of severe accident events has 44 expanded and improved in the intervening twenty -two years since the initial SAMDA analysis 45 for LGS. 46 Appendix A A-30 While we acknowledge that this analysis was limited by the knowledge available at the time, the 1 limitations and shortcomings of a previous era in no way disqualify the claim that, in light of 2 numerous advances in modeling capabilities, a library of discovered cost -beneficial SAMAs, and 3 the saliency of severe accident risks following the disaster at Fukushima Daiichi, not only is 4 there new and significant information, there are significant volumes of this information acquired 5 since 1989. 6 In the licensee's current environmental report, the identification and treatment of new and 7 significant information (four items in total) were developed only in the narrow context of how 8 they may affect the dated SAMDA analysis. It should go without saying that this approach does 9 not comprise all of the applicable new and noteworthy severe accident mitigation strategies 10 bearing on the site in question, or serve to remedy gaps and omissions in the original SAMDA 11 analysis. 12 The entire set of first -stage envisioned alternatives in the initial SAMDA analysis was no more 13 than fifteen options. The "analysis" in the current environmental report consists of perfunctory, 14 "back-of-the-envelope" calculations in lieu of a proper SAMA analysis. The current operator 15 Exelon referred to these considerations as representing an "abundance of caution." We 16 disagree. 17 One of the largest problems with the calculations offered, aside from only focusing on an 18 arbitrarily limited number of alternatives, is that licensee evaluated each item of new information 19 in isolation of the other factors that would also change the cost -benefit conclusion for a 20 particular alternative. The effects of each changed parameter (e.g., population, offsite economic 21 risk, cost per person -rem averted, and seismic hazards) should be evaluated in a 22 comprehensive model that shows the aggregate benefit, as performed in all current day SAMA 23 analyses. Unfortunately, their analysis barely scraped the surface of how this new information 24 should actually be considered in the context of environmental impacts. 25 In comparison, a "reasonable set" of alternatives for another recently relicensed plant included 26 an initial consideration of 128 SAMA candidates developed from previous lists at other plants, 27 NRC documents, and documents related to advanced power reactor designs. After screening 28 this initial set for non -applicable or previously implemented designs as well as 29 combining/dropping common -benefit options, the applicant was still left with a set of forty unique 30 SAMA candidates, for which it was required to enter preliminary cost estimates in a so -called 31 "Phase I Analysis." A total of fifteen SAMA candidates survived this screening to enter more 32 detailed cost consideration in the Phase II analysis, of which none were deemed cost -beneficial. 33 However, in another renewal application, the SAMA analysis found eleven potentially 34 cost-beneficial options from an initial set of thirty -three. 35 In an NRC report discussing insights on SAMAs in connection with plant license renewals, the 36 agency authors list numerous potentially cost -beneficial SAMAs relating to station blackouts, 37 protection and support systems, procedures and training, and external events such as flood, 38 fire, and seismic hazards. The authors note that "averted onsite costs (AOSC) is a critical factor 39 in cost-benefit analyses and tends to make preventative SAMAs more attractive than mitigative 40 SAMAs." This AOSC factor was not considered in either the original SAMDA or the recently 41 submitted environmental report. 42 Finally, NRDC believes that in addition to a comprehensively updated SAMA analysis, the 43 licensee or agency must conduct a study that, as part of the supplemental environmental impact 44 statement, presents postulated accident scenarios showing the full range and weight of 45 environmental, economic, and health risks posed by these accidents. This type of study should 46 model site -specific severe accidents and illustrate the full consequences of a range of severe 47 accident scenarios so that the public and their policy makers can make informed decisions 48 Appendix A A-31 whether to continue plant operations after the existing licenses expire, thereby continuing to run 1 the risk of a severe nuclear accident, invest in additional accident mitigation capabilities, or 2 alternatively, avoid these risks altogether by relying on a portfolio of low carbon electricity 3 generation alternatives that could meet future electricity service needs over the license 4 extension period. 5 The SAMA analyses are inadequate in this regard because they only address isolated issues in 6 a cost-benefit analysis that discounts the cumulative impacts on displaced populations, regional 7 economic losses, and environmental cleanup. These types of calculations do not present a 8 clear picture of the potential hazards or costs experienced in the event of a severe accident. 9 Instead they tend to mask the full range of accident consequences that policy makers may wish 10 to avoid. Recently, NRDC produced an analysis, of the type we believe should be included in 11 the Limerick NEPA analysis, to inform ongoing relicensing efforts at the Indian Point nuclear 12 plant site. 13 In order to illustrate the full extent of a major accident, the NRDC study used the 14 U.S. Department of Defense computer model HPAC (Hazard Prediction and Assessment 15 Capability) to calculate site -specific release radiological source -terms, resulting fallout plumes, 16 and data on the effects on nearby populations. The results were compared to similar modeling 17 of the Fukushima disaster to provide a sense of scale, and to estimate the rough magnitude of 18 financial and economic damages that would be incurred if a severe accident were to occur at 19 Indian Point. This is not a hypothetical issue. Policy makers in several countries, including 20 Germany and Switzerland, have made decisions not to grant nuclear plant license extensions to 21 avoid having to endure the continuing risk of severe nuclear plant accidents. 22 Regardless of Exelon's own corporate understanding of its legal obligations, NEPA is clear in its 23 well-established mandates and what it requires of the NRC. NEPA requires that federal 24 agencies characterize environmental impacts broadly to include not only ecological effects, such 25 as physical, chemical, radiological and biological effects, but also aesthetic, historic, cultural, 26 economic, and social effects. NEPA requires an agency to consider both the direct effects 27 caused by an action and any indirect effects that are reasonably foreseeable. Effects include 28 direct effects caused by the action and occurring at the same time and place and indirect effects 29 caused by the action, but later in time or farther removed in distance, but still reasonably 30 foreseeable. 31 Most specifically, NEPA directs that NRC take a "hard look" at the environmental impacts of its 32 proposed action, in this instance the relicensing of two BWR Mark 2 units for an additional 33 20 years, and compare them to a full range of reasonable alternatives. "What constitutes a 34 'hard look' cannot be outlined with rule -like precision, but it at least encompasses a thorough 35 investigation into the environmental impacts of an agency's action and a candid 36 acknowledgement of the risks that those impacts entail." Nat'l Audubon Soc. v. Dept of the 37 Navy, 422 F.3d 174, 185 (4th Cir. 2005) (emphasis added). As a stalking horse for the NRC's 38 draft EIS, the applicant's ER does not meet this standard. In taking the "hard look" required by 39 law, the NRC must therefore address the potential environmental impacts of a range of severe 40 accidents-and accident mitigation strategies -especially in light of the new information 41 provided by the Fukushima nuclear disaster on the performance of BWR radiological 42 containment in a prolonged loss -of-coolant, core -damage scenario. 43 For the reasons stated above, NRDC urges that NRC direct that a thorough and lawful SAMA 44 analysis be conducted as part of (or supplement to) the required supplemental environmental 45 impact statement, the draft of which is currently scheduled for August 2012 and the final SEIS 46 currently scheduled for February 2013. Additionally, the full cumulative effect of severe 47 accidents must be studied and presented as part of these documents. These analyses must 48 Appendix A A-32 make every effort to meet the current expectations of what these studies should encompass an d 1 use the necessary guidance and tools commonly utilized by the industry and NRC. The NRC's 2 legal obligation to consider new information and determine its nuclear safety significance exists 3 independently of whether a SAMA has or has not been prepared previously: in the event a 4 SAMA has not been prepared, then new and potentially significant nuclear safety information 5 must be included in the initial SAMA; if a previous SAMA exists, then it must be updated to 6 reflect this new information, and the resulting costs and benefits of the full spectrum of 7 reasonable accident mitigation alternatives must be considered as part of the Draft 8 Supplemental Environmental Impact Statement, and issued for public comment. 9 Response: For license renewal, the NRC discharges its NEPA obligation to consider severe 10 accidents mitigation through 10 CFR 51.539(c)(3)(ii)(L) and Table B -1. In accordance with 11 10 CFR 51.53(c)(3)(ii)(L), the license renewal ERs must provide consideration of alternatives to 12 mitigate severe accidents if the staff has not previous evaluated SAMAs for the applicants 13 plants in an environmental impact statement or related supplement or in an environmental 14 assessment. LGS is a plant that had a previous SAMA documented in a NEPA document. 15 Under NEPA, the NRC must consider whether new and significant information affects 16 environmental determination in the NRC's regulations, including the determination in 10 CFR 17 51353(c)(3)(ii)(L) and Table B -1, that the agency need not reconsider SAMAs at license 18 renewal if it has already done so in a NEPA document for the plant. New information is 19 significant if it provides a seriously different picture of the impacts of the Federal action under 20 consideration. For SAMAs, new information may be significant if it indicated a given 21 cost-beneficial SAMA would substantially reduce the risk of a severe accident, by reducing the 22 probability, or the consequences of a severe accident. 23 The staff's evaluation of new and significant information for SAMAs is addressed in Section 5.3 24 of this SEIS. 25 A.1.12. Radioactive & Non -Radioactive Waste (RW) 26 Comment: 1-10-RW; This aging plant is an accident waiting to happen. Large volumes, more 27 than 6,000 assemblies weighing more than a thousand tons of highly radioactive waste in the 28 form of spent fuel rods are stored in densely -packed pools, elevated five stories above and 29 outside the reinforced containment structure. 30 Comment: 1-11-RW; This plant will produce about two more tons of dangerous spent fuel rods 31 every year that it operates. 32 Comment: 1 RW; Dry cask storage and transport are also very dangerous alternatives. 33 It's time to close Limerick and stop producing such deadly waste for which there is no safe 34 solution. As long as Limerick operates harms to us and our environment will increase. 35 Comme nt: 1-30-RW; [R]adiation into air and water from routine and accidental emissions 36 Comment 1 RW; [D]eadly high -level radioactive wastes that are packed in vulnerable fuel 37 pools on this site and they are in fact unprotected. They are above ground and unprotected 38 Comment: 6-4-RW; [T]he radioactive spent fuel deadly waste material sitting around, 39 supposedly protected 40 Comment: 18-1-RW; One would be what are we going to do with the 20 years of spent rods 41 and how are you going to take care of those. 42 Appendix A A-33 Comment: 23-3-RW; And then to -I'm sure that the generic plan includes a pretty good 1 discussion of fuel storage long -term and short -term onsite but certainly the site -specific fuel 2 storage considerations. 3 Comment: 30-7-RW; The NRC and USA Government still have not decided where to store 4 spent nuclear rods and as we speak each spent rod is sitting in baths on the Limerick sit e , 5 stacking up -expanding even a greater hazard to the community, environment, etc. So put 6 simply, there absolutely no reason to approve this request for years until the US Government 7 decides how they will handle such rod and such rods and properly stored. 8 Comment: 34-3-RW; The disposal area must be in operation not some theoretical site like the 9 now defunct Yucca site. The public and our future generation deserves to know what is 10 expected to be done at the site. Radioactive material must not be allowed to remain on the site. 11 Comment: 35-5-RW; Limerick Nuclear's request for re -licensing is ludicrous, considering its 12 aging and inadequate equipment, its increased air pollution by particular matter, its horrific 13 destruction of the Schuylkill River and dangerous above -ground spent fuel rod storage. 14 Comment: 37-8-RW, 39-9-RW; Deadly high level radioactive wastes packed in vulnerable fuel 15 pools on site 16 Comment: 52-5-RW; The plant can no longer store its used fuel rods and has asked 17 permission to begin transporting them to another facility. 18 Comment: 60-4-RW; Spent fuel -Storage-Uranium mining -Dirty 19 Comment: 60 RW; Nuclear waste -nothing clea n 20 Comment: 60 RW; Radiation in air and water -Radioactive ground water 21 Response: Radioactive and non -radioactive waste management is discussed in Section 2.1.2 22 in this SEIS. The NRC's evaluation of impacts of the uranium fuel cycle and waste 23 managemen t are addressed in Chapter 6 of this SEIS. 24 A.1.13. Socioeconomics (SE) 25 Comment: 1 SE; Then you take the property taxes. They tried to get zero for their property 26 taxed by the end of the 90s and didn't pay any property taxes until the early 2000s at which time 27 they paid $3 million instead of $17 million they were suppose to pay. So when you think about 28 that no wonder Exelon's willing throw around a couple million in the community. They owe this 29 community a lot more than what they're giving. 30 Comment: 52-3-SE; The area around the facility has exploded with homes and businesses 31 Response: The property taxes paid by Exelon are presented Section 2.2.9.2 in this SEIS. 32 Section 2.2.9.1 discusses the total number of vacant and occupied housing units in Berks, 33 Chester, and Montgomery counties. Section 2.2.9.6 presents information on the number of 34 businesses in the area. Section 4.9 presents the NRC's evaluation of socioeconomic impacts of 35 continued operation of LGS. In addition, the socioeconomic impacts of not renewing the 36 operating license are discussed in Chapter
- 8. 37 A.1.14. Support of License Renewal (SR) 38 Comment: 2-1-SR; Operating Limerick Generating Station safely and reliably is a responsibility 39 that everyone at the power station takes very seriously.
We understand our obligation to the 40 community, to the environment, and to each other to operate the plant safely. 41 Appendix A A-34 A key component of a thriving community like ours is the availability of safe, clean, and reliable 1 electricity. And as we look into the future for the power needs of Pennsylvania and the United 2 States as a whole, we can see the increasing demand for this very important resource. 3 At the same time, there's a growing concern about greenhouse gases and climate change that 4 is a result of burning fossil fuels. To help meet that growing power demand and to help keep 5 our environment clean, Exelon has applied to the U.S. Nuclear Regulatory Commission for a 6 20-year extension to the plant's operating license. Limerick's current license for Unit 1 wil l 7 expire in 2024 and Unit 2 in 2029. With license renewal, Limerick can provide our region with 8 clean power through 2049. 9 We understand our special obligation to operate the plant safely and reliably and to maintain a 10 close relationship with our neighbors. We pledge to continue that special trust as we operate 11 the plant well into the future. 12 Comment: 3-1-SR; I'm here today to voice my strong support for the relicensing of the 13 Limerick Generating Station. I wanted to touch on a couple points of why I feel it is important for 14 this facility to be relicensed. 15 First is the amount of electricity that is produced by this facility. One of the things that myself 16 and my colleagues in Harrisburg hear consistently from businesses and the Commonwealth and 17 our citizens is the demand for energy and electricity now and more importantly what that 18 demand is going to be in the future. 19 Right now this facility generates enough electricity for two millions homes and without producing 20 some of the greenhouse gases that we hear so much about that could be produced by coal, 21 natural gas, or oil. And I'm going to put a caveat in there for my good friends out in the western 22 part of the state where coal is a big part of the Pennsylvania economy and I 'm suggesting that 23 this be done to the exclusion of coal and nevertheless, some of the technologies that they're 24 developing out there are also important for that industry and important for the Commonwealth of 25 Pennsylvania. 26 Again, one of the concerns we hear consistently from businesses is how can we come here into 27 Pennsylvania with the infrastructure being what it is which needs to be improved for the 28 transmission of the electricity, but more importantly the generation of that electricity? 29 Number two, I think is important is the jobs and overall economy. Again, in these tough 30 economic times that we're facing here in the Commonwealth of Pennsylvania and also in this 31 nation, one of the top issues that we hear consistently about is jobs. 32 And as was mentioned by the site vice president, over 860 people are employed here with an 33 annual payroll of $75 million. The direct impact that is to the Commonwealth of Pennsylvania, 34 of course, is realized through the state income tax and also all of these local municipalities most 35 of them enact an earned income tax which again sustains their townships as well as their 36 respective school districts. To have that taken away I think would have an even more dramatic 37 impact on our local economy. 38 As was mentioned the impact for the local area here, the temporary workers who show up here 39 during the outages and the refueling, there's already been two hotels that have sprung up along 40 the 422 corridor with another one planned right up here at the Sanatoga area. Again, more jobs 41 and more economic growth here for our communities. 42 Thirdly, I want to talk about the communication that I 've experienced in the seven years that I've 43 been in office with Exelon and with their Government Affairs people as well as with their site 44 people. I've been on the site three times, twice for a tour and one to make a presentation during 45 an anniversary of the facility. And I have to say that it is a very secure area. I know a lot of 46 Appendix A A-35 people are concerned about terrorism attacks or people being on the property. But unless 1 you've actually gone over there and gone through a tour, seeing how things are set up, seeing 2 the armed guards there, seeing the security measures that are in place, I think you come away 3 much more relieved with that. And I'm able to speak to my constituents more affirmatively about 4 the safety and security of the facility. 5 Any time that there's been the slightest occurrence there, whether it will be a couple times a 6 hunter has wandered onto the property where the authorities were called, the Government 7 Affairs people at Exelon are on the phone to me or with an email right away to let me know 8 what's happening before the word gets out to the media or to the press. So they're always very 9 well prepared in their explanations, not only of things that happen at the plant itself, but also 10 incidents and issues that occur around the country and around the world. 11 Obviously, what took place in Japan with the incident over there, they were on the phone with 12 me and met with me a few times to explain what took place over there and how the safeguards 13 are being put in place here so that doesn 't happen at this facility. 14 Comment: 5-1-SR; Because the license Generating Station can be operated safely and 15 reliably, Exelon decided to pursue license renewal for Limerick. Limerick is a very clean energy 16 source which produces no greenhouse gas emissions. Limerick is also good for the economy in 17 that it lowers market prices on electricity for the citizens of Pennsylvania to the tune of 18 $880 million per year. 19 Comment: 5-4-SR; [W]e operate Limerick safely and we can continue to operate it safely for 20 an additional 20 years. Limerick will provide approximately 2340 megawatts of base -load 21 generation that's not only safe, but it's clean, reliable and economical. 22 Continued operation of Limerick will benefit this community, the Commonwealth of Pennsylvania 23 and our nation. 24 Comment: 7-1-SR; As the largest private employer in the region, the Board is thankful for the 25 860 jobs that Exelon provides, the positive impact of their operation, the vitality of our local 26 community. The community and local economy are enhanced by the needed services provided 27 by the township, which includes the roadway network maintained by our Limerick Township 28 Public Works, public safety provided by the Limerick and Linfield Fire C ompanies, and our local 29 emergency medical response, our public parks, our recreation facilities and also the police 30 protection that's provided by Limerick 's 21 sworn officers. 31 Because of Limerick Generating Station's location within our borders, the Limerick Township 32 Police Department is the only municipal police department in Pennsylvania with the primary 33 jurisdiction over Tier 1 critical infrastructure. This Board prides itself on the services provided 34 directly both to the residents and the businesses of this community and the township's ability to 35 maintain those current levels of service during these difficult economic downturns. We are 36 thankful for the generosity of the Limerick generating plant and Exelon for being good corporate 37 neighbors and the assistance they provide to the community. Without their financial assistance 38 that impact to provide those services to the community would fall squarely on the backs of the 39 taxpayers. They assist in our fire companies. They have been corporate sponsors of our 40 Limerick Community Days. And we are confident that Limerick generating facility and Exelon 41 will continue that support in the future and be our good corporate neighbor. We also are in 42 support of the relicensing of the Limerick nuclear plant. 43 Comment: 11-1-SR; I'm president of the Tri -County Area Chamber of Commerce. I'm happy 44 to be here today to provide examples of how Limerick Generating Station is a valued community 45 and business partner and echo the statements already shared by several others. They 're one 46 of the tri -county area 's largest employer, providing professional employment opportunities for 47 Appendix A A-36 local residents. Those local residents employed by Limerick Generating Station are supporting 1 the entire tri -county business community. They 're purchasing personal goods and services from 2 local small businesses. The annual outage is a tremendous benefit to the local economy and 3 our local businesses. Limerick encourages their outage employees to visit and purchase from 4 tri-county area, local businesses, and small businesses. 5 In addition to the jobs they provide local residents, they 're making a significant investment in our 6 local communities. Municipalities and residents benefit from assistance received from Limerick 7 to start, maintain, expand parks, recreation, and quality of life opportunities. 8 Their corporate culture of giving back to the community is practiced by their hundreds of 9 employees. Nonprofit organizations are supported by Limerick Generating Station and the 10 efforts of their employees. Financial donations, as well as volunteer hours and time are 11 donated, enabling our local nonprofits to provide the much needed services that impact those 12 in need throughout the tri -county area. 13 The Limerick Generating Station is confident in the clean and safe environment they maintain in 14 our community. The community has been invited to experience the generating station firsthand. 15 The chamber hosted a membership breakfast and the site vice president, Bill Maguire provided 16 the keynote presentation. He summarized safety measures and advancements at Limerick and 17 answered questions pertaining to the Limerick plant and its safety in the wake of the tsunami in 18 Japan. 19 Comment: 12-1-SR; I don't believe that continued operations of the power plant would have 20 any detrimental effect on public safety in the southeast region. 21 Comment: 13-1-SR; Today, I would like to say that in all of the years that I 've lived in this area, 22 I've never worried at all about the safety of the nuclear power plant. I see it every day. And it 23 bothers me not in the least. I have never seen any credible evidence to suggest that there are 24 safety problems with this plant. In terms of reliability, it is the same. It is running 24/7, 365 days 25 a year and it has been doing so for a quarter of a century and I hope it continues to do so for 26 many more years to come. 27 As far as its environmental impact, I think it 's pretty widely known that nuclear power is one of 28 the cleanest environmental energies that we possess today throughout the world and to dismiss 29 it is I think a foolish notion. 30 The impact of the Limerick plant in our region has been extraordinarily positive. It provides, as 31 we all know and have heard today, lots of jobs, lots of good jobs, tax revenues for schools, local 32 governments and for those who live in the area to enjoy the fruits of public services and it also 33 provides a lot of charitable donations to the community which is very important. 34 I think that to not keep this plant running and not consider a renewal of its license for a n 35 extended period would be a tragic mistake for all of us and I would like to end this by saying that 36 the only meltdown that would concern me is the economic one that certainly would happen to 37 this area should this plant not continue to operate. 38 Comment: 14-1-SR; But I'm here today as a private citizen, as a resident of the area and as a 39 member of the Pennsylvania Energy Alliance to go on record and say I strongly favor license 40 renewal for the Limerick Generating Station. I say that because in my personal experience I 41 know in spite of some of the things you 've probably heard here today, nuclear power is safe, 42 reliable, secure and clean. But in addition to that, I would like to go on record, I would like my 43 neighbors to know we are lucky to have the Limerick Generating Station in this area. In the 44 industry, it has a top reputation. It is one of the finest nuclear power plants in America. And 45 Exelon, if not the best, is certainly one of the finest nuclear operators in the world. 46 Appendix A A-37 I have nothing but confidence that Exelon will work together with the NRC, will run through the 1 process and we will come up with the right conclusion here which is license renewal should be 2 granted to the Limerick Generating Station. I think we need to keep Limerick operating as long 3 as we can. 4 Comment: 14-2-SR; And so from my perspective as a citizen, as a business person who 5 worked in this community, I understand the value this is to the region. And for me, I applaud the 6 NRC for what they're doing here. I applaud Exelon for the great work that they 're doing there 7 and I encourage the renewal process to take place. 8 Comment: 17-1-SR; And my comments tonight are more I guess from my perspective as a 9 newly elected official with the generating station. About a year ago I had the opportunity to go 10 down to the generating station and meet with Joe Saffron and the first part of my meeting had to 11 do with looking for some support for the Pottstown Soapbox Derby. Through some 12 conversation while we were standing outside you know Joe [told] me a little bit on what Exelon 13 and the generating station do for the surrounding communities, whether it 's supporting our 14 firefighters, police departments and other civic organizations. You know, from a Pottstown 15 perspective they help us with our yearly borough cleanup, our Salvation Army and now the 16 Soapbox Derby. Thank you. 17 And we were standing outside that day, it was pretty nice out, and our conversation led to the 18 power plant itself. We were standing there looking around it's a pretty impressive sight. So I 19 asked him about, you know, possibly having a tour for municipal officials. He said he would look 20 into it and see what he could do. A couple of months later he got a group of about 20 of us and 21 gave us a tour of the plant one evening. And I have to say that from the time we walked through 22 the front gates and past the security as our tour progressed, you know, throughout the plant 23 safety was paramount. Whether you were having explained what the different colors are on the 24 different panels and what they mean to different fail safes, why you walk certain areas certain 25 ways and what lines you had to stand behind, you know, safety was paramount with them. You 26 know, from the environment, I'm looking around and this place is spotless. And I asked why 27 and it's because they can 't afford to have dirt or lint or fuzz balls around because of static 28 electricity because it could create issues. So from that aspect I thought it was a good tour and it 29 made me feel good about the safety aspects there. 30 To finish our tour we ended up in the control room upstairs. And I'd say maybe a dozen or so 31 individuals up there monitoring you know everything going on within the plant and around the 32 plant. And again, explaining the failsafes and why they're double -, trip le-checked to eliminate 33 human error. It was just very impressive and as an elected official to go down and take a tour of 34 the plant and understand how it operates. I know when I left I personally know how to issue a 35 concern with the generating station. I know I felt a lot better and a lot safer going home that 36 night. And it was also good to realize, you know, as one of our region's largest employers now 37 that they are willing to give back to the community and keep safety first. So thank you, I just 38 wanted to make those comments. 39 Comment: 20-1-SR; I'm going to be making essentially five points in support of license 40 renewal for Limerick Generating Stations and they are that, number one, nuclear energy lowers 41 electricity prices, it protects our environment against greenhouse gases, it strengthens our local 42 economies and it is safe. 43 With regard to my first point in lowering electricity prices the Limerick Generating Station has 44 reduced wholesale energy costs in Pennsylvania by $880 million in 2010 thus lowering 45 electricity prices for all consumers. It operates around the clock thereby stabilizing the nation's 46 electricity distribution system and the electricity marketplace. The average electricity production 47 costs at nuclear plants have actually declined more than 30 percent in the past 10 years due to 48 Appendix A A-38 various efficiencies. Nuclear power is cheaper to produce than other forms of electricity 1 generation such as coal and natural gas, and helps moderate the price of electricity for 2 consumers. 3 My next point is that Limerick Generating Station and nuclear plants strengthen our local 4 economies and it is a valuable economic driver for the Commonwealth of Pennsylvania. 5 Limerick Generating Station contributes $113 million annually in direct economic contributions to 6 the Pennsylvania economy through various employee wages and salaries, purchase of goods 7 and services from other Pennsylvania businesses and in property tax payments to the local 8 governments. Limerick Generating Station also contributes generously as we've also heard and 9 in fact in 2010 contributed $600,000 to various community organizations. Limerick has over 10 800 full-time employees and employs more than 1,000 skilled temporary contract employees 11 during annual refueling outages. A significant percentage of the current nuclear plant workforce 12 will reach retirement age in the next 10 years creating a demand for high -paying jobs in the 13 nuclear industry. Yes, Limerick Generating Station is one of Pennsylvania's most valuable 14 economic and energy assets and the commonwealth should embrace it. 15 My third point is that nuclear energy protects our environment from greenhouse gases and 16 reduces the need to generate electricity from fossil fuels. If Limerick Generating Station were 17 retired from service replacing the electricity would require increased natural gas -fired or 18 coal-fired generation. Nuclear energy is the nation 's largest source of carbon -free electricity 19 and is critical to our nation's environmental, security and energy goals. 20 My next point is that nuclear energy is safe. It's always on, it 's stable, it 's a reliable source of 21 electricity and the station here at Limerick has been built with multiple redundant safety layers. 22 And the workforce is committed to best practices and continuous improvement. It is also 23 important for our nation's quest to be energy -independent. According to the Bureau of Labor 24 Statistics it 's safer to work at a nuclear plant than in industries such as manufacturing, real 25 estate and finance. And according to the Department of Energy a person receives more 26 radiation exposure flying from Baltimore to Los Angeles than by standing near a nuclear plant 27 24 hours for a year. 28 On a personal note I've been inside Limerick Generating Station several times. I 've also lived 29 within 30 miles with my four boys and wife next to the Limerick Generating Station and also 30 Three Mile Island. I feel safe, secure and comfortable. That is why I'm in support of the 31 re-licensing of the Limerick Generating Station. 32 Comment: 50-1-SR; I wanted to let you know that I am complete and full supporter of the 33 Limerick Nuclear plant. I am also supportive of the scientific [judgment] and expertise of those 34 such as yourself who have the job of making the decisions. 35 Response: These comments express support for nuclear power or the license renewal of LGS 36 or both. The comments provide no new and significant information and will not be evaluated 37 further. 38 A.1.15. Surface Water (SW) 39 Comment: 1-17-SW; Dangerous depletion of the Schuylkill River, in and by itself, a singula r 40 reason to deny this permit. The Schuylkill is a vital drinking water source for nearly two million 41 people from Pottstown to Philadelphia. It is being depleted and contaminated every day that this 42 plant operates. 43 Comment: 1-23-SW; They are destroying the Schuylkill River. There was enough water in the 44 Schuylkill River to sustain this nuclear plant from the very beginning and now we're seeing the 45 Appendix A A-39 consequences of that and they more and more pollution in it. They want to pump mine water in 1 to supplement the flow for Limerick. It's contaminated and they don't filter it. And they're 2 actually asking for huge, four times Safe Drinking Water standard increase in total dissolved 3 solids which carry a lot of toxic pollutants. So they put radiation into the river 24 hours a day, 4 365 days a year, and now they're asking for these huge increases and people have the nerve to 5 get up here and say that they have no environmental impacts. 6 Comment: 1-32 SW; Schuylkill River depletion and major drinking water contamination. Keep 7 in this is vital drinking water source for nearly 2 million people from here to Philadelphia. 8 Comment: 4-5-SW; Our drinking and bathing water here is being continuously polluted by 9 Limerick every day, 24/7 for years with radiation and unfiltered toxic contaminated mine water , 10 thanks to the NRC and Exelon. This is disgusting. Most of us have to depend on the water, 11 especially for bathing. Some of us pay extra for water filtration or drink bottled water because 12 we are afraid to drink from the Schuylkill and because it tastes really bad now. Imagine how 13 toxic it would be 18 plus years from now if there was even any wate left. 14 Comment: 4-10-SW; So then there 's the cost for the pollution they 're putting in the river. 15 They're asking for increases in pollution. They want to put more mine water in. They want to 16 increase the total dissolved salts. That's going to cost water treatment systems a lot of money 17 to try to-for extra treatment for that. It can even break down their equipment, some of the stuff 18 that's coming out of the mines. And when you think about it who actually ultimately pays that 19 cost? We do. We pay for increased costs for our water because they're having to do that at the 20 water treatment systems. And it seems to me that if you really take a good look at things 21 Limerick has got to be the major cause for the radiation in Philadelphia's water. 22 Comment: 23-1-SW; Mine water issue, better defining that quality and flow particularly in light 23 of the likely pending changes in stormwater concerns and regulations in the area. Adding that 24 flow to the Schuylkill is going to affect all the municipalities around here who have to deal with 25 stormwater. 26 Comment: 44-3-SW; There is concern that should be faced regarding the Schuylkill River and 27 the affects it is going to have on the public if it becomes depleted, and/or toxic due to the 28 contaminates going in it. 29 Comment: 36-2-SW; I am more concerned about the effects of surrounding air and water 30 supply and the future of my children and grandchildren, some of whom are already inflicted with 31 cancer and other diseases. 32 Comment: 45-9-SW; Limerick Nuclear Plant is slowly destroying the vital public drinking water 33 source for almost two million people from Pottsto wn to Philadelphia. Radioactive and heated 34 wastewater is discharged by Limerick Nuclear Plant into the Schuylkill River 24/7. Limerick's 35 cooling towers are causing significant depletion. To supplement the flow to operate Limerick, 36 Exelon wants to pump more contaminated mine water into the river. No one can credibly 37 assure if drinking water will remain safe even until 2029 when Limerick's original license 38 expires. 39 Comment: 54-4-SW; Since the last impact statement was prepared in 1973, the Schuylkill 40 River has been designated as a state scenic river and as a heritage area for both the state and 41 federal government. Due to these designations and the efforts of non -profit organizations and 42 local government, access to the river has been expanded so that the river has become a 43 recreation and heritage tourism destination. Use of the river in the vicinity of the plant will 44 continue to grow. With the return of American Shad made possible through down stream fish 45 ladders, interest in the river could even grow further in the future. 46 Appendix A A-40 The Limerick Plant withdraws sizeable portions of river water. During low flow periods, 1 additional quantities of water are released into the river from the Wadesville Mine, and Still 2 Creek Reservoir in Schuylkill County to compensate for the water withdrawn at the plant. This 3 process was initially approved by the Delaware River Basin Commission (DRBC), in 2003 and 4 kept active through a series of docket amendments. Future river water use is, dependent upon 5 the ability of this water make up system to operate within various water quality and flow 6 parameters set by DRBC. It is important to evaluate the viability of the use of the river water 7 and water make up system to provide needed water through the expanded plant lifetime. 8 Analysis of this aspect of plant operation needs to account for the water quality impact from the 9 total dissolved solids in the Wadesville water among other parameters. If resumed use of the 10 Delaware water diversion is anticipated, an evaluation of that system is required to ensure that 11 the capacity is available in the conveyance system and that water quality objectives can be met 12 for discharge into the East Branch of the Perkiomen Creek. 13 Comment: 60-9-SW; Dirty polluted mine water 14 Response: These comments express concern in part over the health of the Schuylkill River, 15 including river flow and water quality. Surface water resources at LGS, including the Schuylkill 16 River, and the effects of plant operations on surface water hydrology and quality are presented 17 in Sections 2.2.4 and 4.3 of the SEIS. In addition, Section 2.1.6 of the SEIS details the surface 18 water sources relied upon by LGS and include the sources of water used to augment low flows 19 in the Schuylkill River. Section 2.1.7 further describes the surface water and groundwater 20 sources used to support plant operations, the volumes of water used, and the regulatory 21 conditions and associated regulatory agencies that govern the plant's water uses. With respect 22 to the comments regarding depletion of the Schuylkill River, the NRC's evaluation of LGS's 23 consumptive use of surface water is presented in Section 4.3.2.1 of the SEIS. As described in 24 Section 2.1.7.1 and 4.3.2.1, the Delaware River Basin Commission (DRBC) has imposed 25 consumptive use limits on LGS's surface water withdrawals. During low river flows, the DRBC 26 limits the plant's consumptive withdrawals to no more than 12 percent of river flow to be 27 protective of aquatic life and downstream water users. Under average flow conditions, 28 consumptive water use by LGS amounts to about 3 percent of river flow. 29 With respect to concerns about pollution attributable to operation of LGS, effluent discharges to 30 the Schuylkill River through its discharge structure are regulated by, and subject to, water 31 quality standards set by, the Pennsylvania Department of Environmental Protection (DEP), in 32 conjunction with the DRBC docket issued to Exelon. More precisely, these discharges are 33 regulated through the National Pollutant Discharge Elimination System (NPDES) permitting 34 process as discussed in Section 2.2.4.1. Although the Schuylkill River has historically been 35 affected by a range of activities as described in Section 2.2.4.1 and further in Section 4.11.3 36 (Cumulative Impacts), the main stem of the Schuylkill River in the vicinity of the LGS currently 37 meets designated water quality standards and uses, including use as a source for public water 38 supply. 39 As required by its operating license, Exelon Generation conducts a Radiological Environmental 40 Monitoring Program (REMP) at LGS to assess the radiological impact, if any, to its employees, 41 the public, and the environment around the plant site. The REMP measures the aquatic, 42 terrestrial, and atmospheric environment for radioactivity, as well as the ambient radiation. The 43 NRC's staff's evaluation of the radiological impacts of LGS operation and its REMP are 44 discussed in Section 4.8 of this SEIS. As part of its evaluation, the NRC staff reviewed Exelon's 45 annual radiological environmental operating reports for 2006 -2010 to look for any significant 46 impacts to the environment or any unusual trends in the data. A 5 -year period provides a 47 representative data set that covers a broad range of activities that occur at a nuclear power 48 plant. Based on the review of the radiological environmental monitoring data, the staff f ound 49 Appendix A A-41 that there were no unusual and adverse trends, and there was no measurable impact to the 1 offsite environment from LGS operations. Further, the NRC's on going Inspection Program 2 periodically inspects Exelon's Radioactive Effluent Monitoring and REMP programs for 3 compliance with the NRC's radiation protection standards in 10 CFR. The NRC's Inspection 4 Program evaluates the data for compliance with radiation protection standards. If the data were 5 to show a noncompliance with requirements, the NRC would take appropriate enforcement 6 action. Additional information for LGS can be found at http://www.nrc.gov/reactors/operating/ 7 ops-experience/tritium/plant -specific-reports/lim1 -2.html. 8 Comments 1-23-SW, 4-5-SW, 4-10-SW, 45-9-SW, 54-4-SW, and 60-9-SW specifically raise the 9 issue of the diversion of water from the Wadesville Mine Pool to augment the flow of the 10 Schuylkill River. The use of mine pool water and other diversion sources to augment surface 11 water flows to support LGS operations are described in Sections 2.1.6 and 2.1.7 of the SEIS. 12 These sections also summarize the background and current status surrounding the ongoing 13 water diversion demonstration project that is regulated by the DRBC. The NRC staff's 14 evaluation of the projected impacts on surface water resources of the continued operations of 15 LGS during the license renewal term are presented in Section 4.3 of this SEIS. Regarding use 16 of the Wadesville Mine Pool and other low flow augmentation sources, the DRBC, and not the 17 NRC, is responsible for regulating such activities. Likewise, and as mentioned above, the 18 Pennsylvania DEP through the NPDES permitting process, along with DRBC's docket approval 19 process, are responsible for regulating effluent discharges from LGS and will ultimately decide if 20 revised effluent limits on chemical and thermal discharges are appropriate. 21 Comment: 55-6-SW; A note should be added regarding the diversion of Delaware River water 22 to the East Bank of the Perkiomen. Due to the residential build -up along the Perkiomen Creek 23 area, additional consideration should be presented and discussed with the Army Corps of 24 Engineers and the National Weather Service regarding potential flooding impact this may have 25 on the area. 26 Comment: 35-4-SW; Limerick Nuclear's request for re -licensing is ludicrous, considering its 27 aging and inadequate equipment, its increased air pollution by particular matter, its horrific 28 destruction of the Schuylkill River and dangerous above -ground spent fuel rod storage. 29 Response: Aging management of plant systems is evaluated as part of the LRA safety review. 30 The results of the staff's safety review of the LRA for LGS will be documented in the staff's SER . 31 Air pollutant emissions associated with LGS operations are presented in Section 2.2.2.1 of the 32 SEIS. The NRC's evaluation of LGS's air emissions is presented in Section 4.2 of this SEIS. 33 Surface water resources at LGS, including the Schuylkill River, and the effects of plant 34 operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of 35 the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied on by 36 LGS and include the sources of water used to augment low flows in the Schuylkill River. 37 Comment: 24-1-SW; -I want to add that I want the NRC to look into potential water depletion 38 issues from shale gas fracking upriver in both rivers. 39 Comment: 60-21-SW; Depleted water due to fracking up river 40 Response: The contributions of past, present, and reasonably foreseeable future actions or 41 activities in the Delaware River Basin, including hydraulic fracturing (fracking), have been 42 considered in the cumulative impacts analyses of this SEIS as presented in Section 4.11 of the 43 SEIS. With respect to surface water, these impacts are presented in Section 4.11.3. In 44 addition, the environmental impacts of alternatives to the proposed action (i.e., whether to grant 45 a renewed operating license to LGS) are evaluated in depth in Chapter 8 of the SEIS. This 46 Appendix A A-42 includes comparative analysis of a natural gas -fired combined -cycle facility as a replacement 1 power source for LGS and considers related effects of hydraulic fracturing to supply natural gas. 2 A.2. References 3 10 CFR 2. Code of Federal Regulations, Title 10, Energy, Part 2, "Rules of practice for 4 domestic licensing proceedings and issuance of orders." 5 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 6 production and utilization facilities." 7 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental protection 8 regulations for domestic licensing and related regulatory functions." 9 10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for renewal 10 of operating licenses for nuclear power plants." 11 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 12 Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating 13 License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) 14 Accession No. ML11179A104. 15 National Environmental Policy Act of 1969. 42 U.S.C. 4321, et seq. 16 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 17 for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, DC , 18 ADAMS Accession Nos. ML040690705 and ML040690738. 19 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 20 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1, 21 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 22 Report," NUREG -1437, Volume 1, Addendum 1, Washington, D C, ADAMS Accession 23 No. ML040690720. 24 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Official Transcript of Proceeding, "Limerick 25 Generating Station License Renewal Public Meeting: Afternoon Session." Adams Accession No 26 ML11287A207 27 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Official Transcript of Proceeding, 28 "Limerick Generating Station License Renewal Public Meeting: Afternoon Session." Adams 29 Accession No ML11287A211 30 A-43 Comment Letters and Meeting Transcripts 1 The following pages contain the comments, identified by commenter designation and comment 2 number, from letters and public scoping meeting transcripts. 3 Appendix A A-44 31 1 unthinkable proportions. Whether a natura l disaster 2 pr terrorist a tt ack occurs , by relicensing Limerick , 1-1-PA I 3 N Rc would in effect be placing Russian roulette with 4 th e lives of more than eight millio n people. NRC must 5 close Limerick Nuclear Plant by 2029 0 6 There is no way for either NRC or Exelon 1-2-0S I 7 to ensure t he s afe ty of the environment or the 8 r es i dents impacted by this plant. It cannot be made 9 fn i l snfe No o t.her fncc i l i tv hns t he notent i nl to 10 render t he en t ire region uninhab i table, po ssibly for 1-3-0S I 11 cen t ur i es as the resu lt of an ac ciden t or t error ist 12 at t ack. This is t he highest-risk f acility that could 13 ex i st in any commun ity in this coun try. 14 Current 40-year operating li censes expire 15 n 202 4 and 2029 0 Why the rush to renew these 1-4-LR I 16 i censes now? 17 we urge the NKC to say no to t;xe l on s 18 requested license renewals. The public was led tl 1-5-0R I 19 eve t ha t Limerick's generators , fuel pools , and 20 f'n il es of und erground pipes and cab l es could 1 1-6-LR operate I 21 safely for 40 years and then the f ac ili ty would close. 22 Is Exelon fearful that the longer they wait the more 23 serious problems may arise? 24 After only 26 of 40 years , numerous signs 1-7-0S I 25 of agin g and risk have b een ide n tified. Corrosion , NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WAS HINGTON , D.C. 20005-3701 WW'W.nealrgr o ss.com Appendix A A-45 32 1 !deterioration , tatigue , cracKing , thinning wi tn loss 2 of material, loss of fra cture toug hness are all 1-7-0S I Cont'd 3 documented in Exelon's own re n ewal application in the 4 ag i ng m anagement section. I nst a nc es of equipmen t 5 fatigue and cracking of vital equ ipm en t include th e 6 reactor vessel and coolan t sys tem. 7 Aging equipment , af t er on ly 26 years 8 sug gests that NRC should not just close the pla nt by 1-8-0S I 9 2029 , but also ramp up their ov ersig ht vig ila nce 10 dur i ng the remaini ng 18 y ears of the current li cense. 11 In the past few years, Li merick has h ad numerous 12 nplanned shutd own s suggest i ng t here are already 13 ignif i cant pr obl e ms. Th ree occur red in on e week in 14 u ne 20 11. Loss of coolan t leaks and acc i dents at 1-9-0S I 15 imerick have already been docu m ented. Serious 16 ad i oac tive contaminat i on could go u ndetected and 17 nreported for years from the corr o ding 18 nfrastr u ct u re, mu ch of it un derg ro und. 19 There have already been two n ear misses at 20 Limerick fro m 1996 to 2001. 21 This aging pl ant is an acc i dent waiting to 22 happen. Large vo lumes, m ore than 6, 000 assemblies rL-..1....::--:=-:-:-:, 1-10-RW I 23 weighing more tha n a thousand tons of highly 2 4 radioactive waste in the form of spent fue l rods are 25 stored in de nsely-packed pools , eleva ted five stories (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-46 33 1 1 above a nd ou t side th e reinforce d contai nme nt 1-1 0-RW I Cont'd 2 3 tructure. Th is p lant ons of dan gerous spen t wi ll produc e about two more I ,...,.......,....,-::::;-:.,..., fuel r ods e very year that it 1-11-RWI 4 pera t es. LlmerlcK , ln ad dlt lon , lS n ow thl rd on th e 1 I 5 ear thq uake r isk list for nu clear p la nt s in the 6 Sta t es. 7 With loss of cool in g wa t er , Li m er i ck's 8 fuel ro ds cou ld he at up, self ignite, and burn in an 9 un st op pable fire w ith cat a str op h ic r es ul ts. Ex el on 10 has not bee n requi red to spend t he m on ey to g uar d 1-1 3-PA I 11 Limerick ag ai nst ter ror ists , miss iles , or air strik es 12 de spite re pea t ed requests to do so. 13 D ry cask st or age a nd tra nsport are als o'f:-J'-:-!-=:-:-:-:o p-14-RW I 14 e ry d angerous a lte rna t ives. It's time to close 15 imer ic k and st op pro duc i ng su ch de a dly wa ste for 16 hi ch there is no safe soluti on. As long as Limeri ck 17 perates ha r ms to us and our envi ronm e nt wil l 18 nc rease. 19 Their harmf ul e nv i ro n me nt al impacts are 20 unprecedented. At the conc lusi on of our 11-year 21 inv est i ga tion of routi ne radiation releases and review 22 of permi ts for ma j or air pollution and a va ri et y of 23 dangerous water contamination iss u es , it's clear t hat 24 this ene rgy is not ju st dir ty , it is in fact fi lthy. 25 Evid e nce that we've comp iled h as a ddressed a wide (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.nealrgr o ss.com Appendix A A-47 34 1 r ange of topics: r out in e rad iation rel eases into the 2 air, rad ioact iv e wastewater discharges into t he 3 S chu ylk i ll River, radioactive groundwater 4 c on tamination, radioactive n uclides ass oc iated wi th 5 th e pla nt det ec t ed in our soil, o ur sediment, our 6 v eg etat ion , our f ish, our wa t er , an d milk. 7 Res e arch has co nfirmed radiation in ou r 1-15-HH 8 9 10 lean Air Act , 32 i ndivid ual s ou r ces listed. Drastic , 11 armful i ncre ases p ermitted in parti cul ate matter 12 nown al so as PM-10 from the co ol i ng t owers, oth er air 13 o llution i ncreases also pe rmi tted. 14 Da n ger o us depletion of the Schuylkil l 15 sing ul ar rea s on to p-17-SW I R iver, in a nd by i tself, a 16 this permit. T he Schuy l kill is a vi tal drinking wa t er 17 s ou rce for n ear ly two mi l lion pe op le from Pottst ow n to 18 Philad elph ia. It is be ing depleted a nd contamin ated 19 eve ry day t hat this p lan t operates. 20 Alar mi ng ca n ce r increases that h ave been 21 well d oc um e nted in this community r epeatedly far j1-18-HH I 22 hi gher th an nat ional and state ave rag es a ft er Lime r ic k 23 started operati ng un ti l the l ate 1990s. T he 24 fi ndin gs of our in v es tig ation l ead us to co nclud e that 25 this p lan t is in common langu age a r ec ipe fo r (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com I Appendix A A-48 35 1 disaster. 2 While NRC is required to prepare a 3 suppleme nt t he Li m erick E nvir on m en t al to Im pac t 1-1 9-LR I 4 Statement f or lic e ns e re n ewal , we have li t tl e 5 confidence in th e process b ased on NRC's regu la tory 6 hist ory. It would be d if ficult to enu m erate a sh or t 7 li st, so I'm going to rely on written docume nts. 8 T here are cri t ics of t he NRC o ut t here who h ave done a 9 mu ch better job th an we have of gener ati ng su ch a 10 li st, mo st notably a s ca thing i ndic tment by t he 11 Associa t ed Pr ess. I'm not going to re-en u merate tha t 12 info r ma tion. 13 It's long past t ime for the NRC to su mmon r.-7:::-::::::-=, 1-20-0R I 14 t he courage to do the right thi ng in our judg ment and 15 actua ll y prot ect the environment an d the pu blic, 16 rat h er t han t he i ndus try. 17 Today, I am going to be submitt ing on the 18 record summary packets of our research on Limerick's 19 maj or air pol l ution , harms to the Schuylkil l River , 20 radioact i ve gro u ndwater contamination , link s between 21 L imerick's r ad iati on and o ur el evated cancers in this 22 co mmunity and how L imerick's nu clear po wer can , in 23 fact, be replaced with safer sources to d ay. 24 25 B ase d on the compelling body of ev id ence of environ m en t al ha rms to date an d (202) 234-4433 COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 t he enormous WW'W.nealrgross.com 1-21-0R I Appendix A A-49 1 i ncr eased p opula t ion in proxi mi ty to this facility , 2 Limerick Nuclear Plant m us t be close d by 2029. 3 T her e is no amount of energy production tha t is 4 worth risking the l iv es of so many people. Thank you 5 ve ry much. 6 (Applause.) 7 FACILITATOR BA RKLEY: Thank you , sir. 8 MR. MAGUIRE: Good afternoon. My name is 9 Bill Magu i re and I am the site vice president at 10 Limerick Generat i ng St ation. And I h ave overall 11 resp on sibility for the safe and rel iable operation of 12 t he facil i ty. 13 I have been work i ng in t he nuc l ear power 14 industry for 25 years and my career bega n at t he 15 Limeric k Generating Stat i on as an engineer. I 16 continued with a l icense to be a licensed senior 17 reactor operator supervisor in the operations 18 o rga nization and was the on-shift senior mana ger of 19 that facili ty f or man y years. 20 I have also worked at a few other nuclear 21 stations across the co u ntry and before rejoin in g 22 Limerick as the site vice pr esi den t in May of 2010 , I 23 was the site vice president at the P eac h Bottom Atomic 24 P ower Station in southeastern P en nsylv a nia in York 25 County. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com I 1-21-0R I Cont'd Appendix A A-50 37 1 Opera t ing Li m erick Generating Stat i on 2 safely and rel iabl y is a respo n sibili ty t ha t everyone 3 at the power station t akes very seriously. We 4 un derstand our obligatio n to the co mmuni ty , to t he 5 en viron m ent, a nd to each ot h er to operate the plan t 6 safely. 7 A key co m ponent of a th riving commun i ty 8 l ike o ur s is the ava ilabil ity of s afe , cl ean , and 9 re liable electricity. And as we l ook into t he fu ture 10 for the power ne eds of P ennsy lv ania a nd the Un it ed 11 Sta tes as a whole, we can see th e increas i ng de m and 12 for th is v er y impor tant res ou r ce. 13 At the same time, th ere's a gr ow i ng 14 concern ab out gree nho use gases and climate change tha t 15 is a result of bur n ing fossil f ue ls. To he lp m eet 16 t hat grow i ng p ower demand a nd to help keep our 17 envi ronment cl ean , Exe lon has appl ied to th e U.S. 18 Nu c lea r Regu latory Commiss ion for a 20-year extension 19 to the pl ant's op erating l ic ense. Limerick's cu r ren t 20 li cense fo r U ni t 1 will e xpir e in 202 4 an d Unit 2 in 21 20 29 0 Wi th l icens e renewal, Li me r ick can pr ovide our 22 region wi th clean power through 20 49. 23 We understand our specia l ob lig ation to 24 operate the plant safely and reliably an d to mai ntain 25 a cl ose relationship with o ur neighb ors. We p ledge to (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 1 2-1-S R I Appendix A A-51 38 1 ontinue that special trust as we operate the plant 2 ell into the future. 3 The 104 nuclear reactors in the United 4 States provide roughly 20 percent of our nation's 5 electric ity. More th an 7 0 reac t ors nationwide h ave 6 already received approva l from t he Nuclear Regulatory 7 Com mis sion for a 20-year li cense extension including 8 the Peac h Bo tt om Atomic Power St ation in York County. 9 L imer ick Generating St ation oper ates in a 10 ma nner t ha t preserves the environment. The plant 11 produces almost no gr een h ou se ga ses. The plan t 12 conducts approximately 1 700 t ests annually on air , 13 wa t er , fish , soil , cow's mi lk , and othe r food products 14 to measure for environmental im pact. We also ma i ntain 15 a chain of radiation monitors surrounding the plant. 16 In 2005 , the environmental managemen t 17 systems at Li m erick Generating Station ac h ieve d 18 certification und er the strict criterion of the 19 International Organization for Standardization , ISO. 20 This certification is known as ISO 14001 , a common 21 industry r eference for the env i ronmental 22 certification. The IS O 14 001 certification requ ir es a 23 commitment to excelle n ce to prevent pollution an d to 24 ensure continuous improve m ent in environmental areas. 25 (202) 234-4433 In 2010 , the W ildlife Habitat C ou nci l NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com I 2-1-sR I Cont'd Appendix A A-52 39 1 recogn i ze d Limeric k Gener ati ng Station's com m itme nt to 2 en viron m ental stewards hi p by awarding us the Wildlife 3 at Work Certi fi cation. This distinction was awarded 4 to Limerick Generating St ation for our commitmen t 5 t owar ds establishing long-term wildlife habitat 6 en hance m ents that provided un dis t urbed habitats with 7 food , water, co v er , and space f or anima l spec i es 8 livi ng on the pl ant sta ti on's la nd scape. 9 To ensure L imeri ck c ontinu es to oper ate 10 safely for years to come , Exel on is in ves t ing in 11 upgrades to p lant equip ment. S in ce 2010, Exe lon has 12 inves t ed more t han $200 mil lion i nto the plant 13 inc l ud i ng in sta l lat i on of new sa f et y equipment , new 14 elec tr i ca l cab l es , new va l ves , and re furb ishi ng t he 15 coo l ing towers. In a ddition, Lim erick h as made mor e 16 t han $40 milli on in phys ic al secur it y upgrades since 17 200 1. 18 Our investment in the fut u re does not stop 19 with equipment. We have hire d and t ra i ned over 100 20 new employees over the last thre e years, m ost ly coming 21 fr om our native reg i on here. We m aintain a steady 22 workforce of app r oximately 850 people and during our 23 annual main tena nce and ref u eling outages , we bring in 24 b etween 15 00 and 200 0 te m porary workers that provide a 25 b oost to our local eco n omy. Hiring (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 and WW'W.nealrgross.com Appendix A A-53 40 1 retain i ng top ta lent is a key priority for Limer i ck 2 Generati ng St ation. 3 Over the pas t 25 years , Lime rick has been 4 one of the best perf or m ing a nd most re li ab le 5 generating stations in the nuclear power industry. 6 Duri ng that t ime, t he p lant h as set several records 7 for cont inu ous days of oper ation and has been 8 r ecogn i zed by the i ndustry for our reliable opera ti on. 9 In March 2010 , L imeri ck co m pleted a succ ess ful r un of 10 727 contin uous days f or o ur U ni t 1 plant. This 11 r epr ese nted the s econd lon ges t cont i nuous run for a 12 bo i li ng water re actor in the United States. 13 While we do not set out to break re cords , 14 continuo us op erat ions are on indicator of t he 15 excellent huma n perform a nce and eq uipment reliability 16 t hat Limer i ck strikes for every day. 17 We also take pride in ou r investments in 18 the comm uni ty. In 2010, Limerick donated m ore than 19 $600 , 000 to the comm unit y in con tribu tions to t he 20 United Way , fire and amb ul ance compan i es , educational 21 health and youth org an i zations. And many of our 22 employees serve as volun teers in the local c ommu nities 23 around the plant. 24 In conclusion , Li merick Generating Sta tion 25 looks forward to working with the Nucle ar Regu l atory (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-54 41 1 Com mi ssion as you re view ou r license renewal. I 2 appreciate the o ppor tu nity to speak with yo u th is 3 a ft ernoon. Th a nk you. 4 FACILITATOR B ARKLEY: Thanks , Bi ll. 5 (Applause.) 6 FACILITATOR BARKLEY: R epresen t ative 7 Qu i gley. 8 REP. QUIGLEY: Good afternoon , my name is 9 State Re p resen ta tive T om Quigley. I represent t he 10 146th D is t ric t here of wh ich low er Po t tsvi ll e is a 11 party of t ha t dis trict, so I want to wel come t he N RC 12 here to day to the b eau t iful S un n ybr ook Ball room f or 13 this meeting and th ank th em for com i ng out to list en 14 to the pu blic and take c omm e ntary. 15 I'm h ere today to voice my str o ng support 16 for th e reli cens ing of the Limeri ck Ge nerat i ng 17 S ta tion. I wan t ed to to uch on a couple poin ts of why 18 I feel it is i mpo rt ant for this f acil it y to be 19 re li censed. 20 Firs t is th e amo un t of elec tri cit y that is 21 pr oduced by this fac i lity. O ne of the th i ngs tha t 22 my sel f a nd my co lleag u es in Harr isb ur g hear 23 consiste n tly from busin esses a nd the C ommo nw ea lth and 24 our citize ns is the de mand for energy a nd el ectric ity 25 now and more imp o rtantly what that dem a nd is going to (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 3-1-SR I Appendix A A-55 42 1 be in th e future. 2 Right now this facil it y genera tes e nough 3 electr icity for two millions homes and w ithout 4 producing some of th e green h ouse gases t hat we hear so 3-1-SR 5 mu ch abo ut th at could be pro du ced by coal, na tu ral 6 gas, or o il. And I'm go i ng to put a caveat in the re 7 for my good f rie n ds ou t in the wes t ern part of th e 8 s tate where coal is a b ig part of the P ennsylvania 9 economy and I'm su ggest i ng th at t his be d one to the 10 exc lusion of coal and n eve rt heless, s om e of t he 11 t echno l og ies t hat t hey're developi ng o ut t here are 12 also impo rtant f or tha t in dust ry an d im por tant for t he 13 Co mm onw ealth of Pennsylvania. 14 Aga in, one of the co ncerns we hear 15 c ons istently f ro m businesses is how can we come he re 16 into Pennsylvania with the infrastr u ct ure being wh at 17 it is wh i ch needs to be improv ed for th e transmi ss i on 18 of the el ectricity , but m ore import an tly the 19 generation of th at e lec tricity? 20 Number two, I think is im portant is the 21 jobs and o veral l economy. Again , in the se tough 22 economic t imes t hat we're faci ng here in t he 23 Commonwealt h of Pe nnsy lvania and al so in t his n at i on , 24 one of the top issues that we hear con sistent ly about 25 is jobs. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Cont'd Appendix A A-56 43 1 And as was me nt ione d by the site vi ce 2 resident , over 860 p eo pl e are em ployed h ere with an 3 n nual p ayroll of $75 m illion. The dir ec t imp ac t tha t 4 s to th e Co m monwealth of Pe nn sylvania , of cou r se, is 5 ea l ized th ro ugh the state i ncome t ax and also all of 6 h ese l oca l munic ip ali t ies most of th em e nac t an 7 8 arned in come t ax wh ic h again sustains t heir Cont'd swell as th eir resp ec t ive schoo l distr i cts. To 9 hat take n away I thi nk would ha ve an ev en mor e 10 ramatic im pact on our loc al ec onomy. 11 As was m enti o ned the i mp a ct for the l ocal 12 rea he re, t he temp orary work e rs who s how up h ere 13 uring t he out ages a nd the r ef uel i ng , there's a lread y 14 een t wo ho tels t ha t ha ve sprung up al ong t he 422 15 or r idor w ith another one planne d right up here at the 16 ana toga area. Again, more j obs a nd more economic 17 rowth here for our commun iti es. 18 Th irdly , I want to talk about the 19 om muni ca ti on that I've ex p erience d in the seven years 20 h at I've b een in office w ith E xelon and wit h their 21 overnm ent Affairs people as well as w ith their s it e 22 23 24 25 eople. I've b een on the site three times , twice for tour a nd one to make a p resentatio n during an nniversary of th e faci l ity. And I have to say that t is a very secur e area. I kn ow a l ot of p eople are (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-57 44 1 concerned about terror ism attacks or people being on 2 th e property. But u nl ess you've act ua ll y gone over 3 there a nd gone th rough a to ur , seeing h ow things are 4 set up , seeing the a rmed guards th ere , seeing t he 5 security m eas u res that are in place, I thin k you come 6 away muc h more relieved wi th that. And I'm able to 7 sp eak to my co nst itue nt s more affirmat i vely a bout th e 8 9 safe ty and s ec uri ty of t he facil ity. 1 3-1-SR I I Cont'd Any ti me that there's be en t he sl ig h tes t 10 occu rre nce the re , whether it will be a co uple ti mes a 11 hun te r has wan dered o nto t he pr o pert y where the 12 aut horit ies were cal led, the G ov e rnmen t Affa i rs people 13 at Exe lon are on the pho ne to me or with an email 14 ri ght away to le t me k now what's hap pening befo re t he 15 word gets o ut to th e me dia or to the press. So 16 they're always very wel l prepared in their 17 explanati ons, not on ly of t hings that happen at the 18 pl ant itself, bu t also i ncidents an d issues that occ ur 19 ar ound the cou ntry and around the wor ld. 20 Obviously , what took pl ace in Japan with 21 the i nc i de nt over there , the y were on the p ho ne w ith 22 me an d met w ith me a few times to explain what took 23 pl ace over there an d how t he safeguards are bei ng put 24 in place here so th at d oesn't happen at this faci lity. 25 (202) 234-4433 It was menti oned ear l ier t he dry cask NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-58 45 1 storage wh ere the sp ent fu el r ods are now stored 2 o uts i de in a dry cask storage fac i lity. When th at was 3 pr oposed back in 2005-2006 , th e Ge n erating Station 4 he ld t wo open h ouses tha t were very well a tten ded. I 5 wen t to both of th em where t hey h ad people on there to 6 ex plain to t he people what exa ctly was taking pl ace 7 with this dry ca sk storage, w hy it was nece s sary. A 8 lot of ques ti o ns a nd a nswers back and f orth and I 9 thi nk a lot of the pe ople came away be tte r in f ormed 10 about t ha t process. 11 Ju st recent ly at an op en h ou se, t he site 12 VP who ju st s poke, Bi ll Maguire , came o ut to giv e some 13 in i tial comments and wound up spending t he fu ll ho ur 14 in an impromptu qu estion and answe r session and no t 15 again just pl anted qu esti ons, a l ot of tough 16 qu estions. A nd I th ink aga in the peop le ca me away 17 fee l ing confident in the ope nness an d the transparency 18 that was displ aye d in that question and answer 19 session. 20 Another point of that is for relicensing 21 for the ov er a ll env i ronment h ere is the good corp o rate 22 ci tizenship that the Gen eratin g Station has e xhibited. 23 As was me n tione d by Bill , some of the charitable 24 contri b ut i ons that h ave gone on , not only for the ho st 25 community of Limerick, b ut also f or the surroun di ng (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-59 46 1 areas. I attended a f ew dedication services wh ere 2 t hey p ro vided money to the U pper Pr ov iden ce El eme n tar y 3 S chool and the Lim erick El eme nt a ry Sc h ool for an 4 o utside enviro n me nt al cl assroom. 5 On e of the thi ngs we talk abou t as 6 po li tical l ea de rs , and I'm on the H ouse Education 7 Comm it t ee , is th e need for our c hil dren to be educated 8 par t ic ularly in the sci ences and gi ven t he se bu dge t 9 c on stra i nts t ha t we're op erat i ng un der, both t he 10 school di stricts an d the Commonwealth, it's good to 11 see a corp o rate c it izen stepp i ng up to the plate and 12 provid i ng t hat fi na ncial su pport , particul arly in t he 13 area of sc ience. Th ey've al so partnered with t he 14 Montgomery Cou nt y Co mm u nity Col le ge to provi de 15 assistance in su pport for an associ ate degree in 16 nuc lea r engineer i ng te chno l ogy. 17 Again , we hear so much a bout our students 18 here not being well versed in te chno logy an d 19 e ng i nee ri ng a nd th ings of that natu re. So again , 20 s te pping up to the pla te to provide that ass i stance 21 when, in f act , perha ps in these t ough bu dget ti mes 22 wh ere th e government might not be able to do that. 23 Last, I want to talk about overa ll public 24 op i nion and sa f et y issues. One of the th i ngs that I 25 lo oked at when I talk about safety and the f eeling of (202) 23 4-4433 NEAL R. GROSS COURT REPORTERS A ND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.n e alrgr o ss.com Appendix A A-60 47 1 comfor t that p eople have here is how m any of the 2 peop le who work at that plant live within the t en-mile 3 radius of the f acili ty? And I asked that question 4 when I first was elected in 2004 and I just aske d it 5 again in preparation f or this hearing and 563 6 emp l oyees l ive wit hin the t en-mi le r adius. 7 The population gr ow th in my District in 8 t he pas t ten yea rs , we're gett i ng ready to r edraw our 9 lin es based on the 2010 Census, so I broke it d own by 10 t ownsh ip as to how muc h the population has i ncr ease d 11 in t hose areas: L imeri ck Township, i ncr easi ng by 33.5 12 per ce n t; U pper Po tts grove by 29.5; Royer sf or d Borou gh , 13 whe re I live, 11.9; Lower Pottsgrove , 7; Pottstown , 2; 14 now this is a l ittle bit skewed , but I have a small 15 piece of New Han ov er Township which ac tual ly i ncre ase d 16 by 54 percent. 17 When y ou l ook at the publ ic opin i on , and 18 again , we get call s on a lot of d ifferent i ssues and 19 as I m entioned t hat dry cask st o rage issue. Back 20 then , at the same t ime that that issue was being 21 rolled out to th e public, B oyd Gaming had purcha sed a 22 prope r ty next to our plant was getting ready to apply 23 --ha d applied for a lic e nse , casino lic ense. At that 24 ti me , my office ha d received 2 ca ll s in regard to the 25 dry cask storage pro ject, over 200 calls regarding the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-61 48 1 casino a ppli ca tion. So at the time, it app eared 2 p eople were more concerned ab ou t the pr os p ect of a 3 casino b eing in th e ir ne ighborhood t han th ey were a 4 dry cask st orage fa cil ity. 5 And lastly , as some of you h ea rd , ther e is 6 a propo sa l right n ow to put a hold on Ro ut e 422. And 7 again, in the past six mont hs with the incid en ts in 8 Japan, w it h the c urren t earthqu ak e we had here, w it h 9 t he AP sto ry t el l ing you h ow these plants are al l 10 fa l ling apart, I rece i ved t wo calls regarding t ha t one 11 where they could get t he KI pills, o ne where they 12 c ould --wh at wa s the evacuat ion plan for t hat , an d 13 m or e calls and em ails regarding the proposed 422. So 14 again, it appears t hat t he c ons t it u ents and the 1 46th, 15 they're mo re co nc e rne d about the prospect of paying a 16 toll to ride of 422 t han t hey are about the nuc lear 17 p ow er p lant i ss u es. 18 So again , I strongly support the 19 rel ice ns i ng of this for the reasons I mentioned. 20 Th ank you. 21 (App l ause.) 22 FACILITATOR BARKLEY: Th ank you , 23 R eprese n ta tive Q uigley. 24 T he next t hr ee people I'd li ke to ca ll , 25 first is Lorr ain e Ruppe , private citizen; and t he (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-62 49 1 next, M ichael Gallagher of Exe lon; and finally, I'd 2 l ik e to call Dr. Fr ed Wi nter aft er th at. 3 MS. RU E'E'E: Hi , my n ame is Lorraine Ruppe. 4 I am spea ki ng h ere t oday to represe nt the ch ild re n 5 a nd fu t ure gene rations , especially in our community. 6 R es i dents are f earful ab out t he p ossi bi l ity of 7 disas t ers here in li ght of F uk u shima in M arc h 2011 and 8 si nce the ea r th quake and H ur ri ca ne Irene in Augus t 9 20 11 affec ting our a rea. C limate cha ng es, etc ete ra , 10 are causin g disasters everywhere and co ntinuing to ge t 11 worse. 12 In cre asing fl oo ds, dr oughts, e ar t hqua k es , 13 t orn ados ha ve m ade us all f eel in secure , mak i ng 4-1-PA I 14 nuc le ar pow er i nc reasi ng ly risky , es pec i ally w ith t he 15 L ime rick p lan t bas i cal ly in our b ackyards. Any 16 eart h quake tha t co m es through th is area co u ld be a 17 p ossible Fukushima, Ch ernobyl or T hree M ile Is la nd 18 w hi ch re mi nds me , four mont hs h ave p assed since the 4-2-GE I 19 NRC f ailed to ge t bac k to me when I asked how cl ose 20 the Remapo f ault l ine is to the Li me rick nuc l ear 21 reactors? Maybe I can get an answer today. 22 In d ian E'oint nuke plant was sketched as a 23 p ossible terrorist target in reference to 9/11 24 attacks. A su spected t errorist wo rk ed at Lim er i ck for 25 y ears wi tho ut the ind ustry knowing it. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 H ow sc ary is WW'W.nealrgross.com 4-3-os 1 Appendix A A-63 50 1 th at? 2 The Pa cific Oc ean is now severely 4-4-0S I 3 i rradiated by F uk ush ima. Rad iation i mp acts of 4 Fuk us hima eq ua lled o ver 20 Hiros hima bo mbs when I last 5 esearched. Our drinking and bat hing water her e is 6 ei ng co ntinu ously pollu t ed by Li me rick e very day , 7 4/7 for years with radiation and unfil t ered t oxic 8 on ta m inat ed m ine water , thanks to the NRC and Exelon. 4-5-SW 1 9 Th is is dis gust ing. 10 Most of us h ave to depen d on t he wa ter , 11 specia l ly for bath i ng. S ome of us pay ex t ra for 12 ater filtrat i on or drink bo ttled water because we are 13 fr aid to drink fr om the Schuyl k ill a nd because it 14 astes r ea l ly bad now. Imagine how toxic it wo uld be 15 8 plus years fr om now if there was eve n any water 16 eft. 17 Ther e has bee n inc reased particulate 18 matter in the air and ot her t oxics from 4-6-HH I 19 causi ng increase d asth ma , heart a ttacks , and str o kes. 20 And to a dd i ns ul t to i njury, Lime rick w as granted a 21 p ermit to al low an ei ght-fold inc rease in air 22 po llution since 2009. Cancer rates in our area have 23 skyrocke ted s in ce Limerick has b een up and running in 24 the '80s an d rates have st eadi ly in creased. 25 I (202) 234-4433 The Tooth fa i ry Pro ject showed high l evels 114-7-HH I NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.nealrgr o ss.com Appendix A A-64 51 1 or strontium
- !U , a radionuclide in baby teetn or 2 children nearest to nuke plants. Ba by teeth n ear 3 Limerick p lan t had th e highest le vels in the whole 4 United States. Th is stuff and God knows what else is 5 in our bodies now t ha nks to a Nuclear Regulatory 6 Co mmiss ion t hat to put it nic el y is less than 7 e nthus i astic ab out pr ot ecting us. 8 Solar wi nd , geothermal , ocean t hermal , 9 nergy conservation and efficie n cy are now ch eaper 10 ha n nuclear power, a long with bei ng tr ul y clean and 11 afe. T he Department of Energy 2006 report stated 12 ol ar a lo ne c ould pr ov ide 55 ti mes o ur en ti re na ti on's 13 ner gy needs which leads me to a poin t, there have 14 ee n nu m erous studies pr ovi ng the many da ng er o us and 15 eadly consequences of nuc lear power. T here's no 16 den ying the m assi ve devastation it has alre ady ca u se d 17 and will contin ue to ca u se i nd efinitely , but the 18 i nd ustry still goes on in their trance-like , 19 indifferent f as hi on as if everything is safe and 20 wonderfu l and will continue to be 18 plus years from 21 now or u nti l 2049 for our commun i ty. Th is is what 22 really scares us the most. 23 The NRC has turned into a culture of 24 secrecy, h iding th e dangers a nd sweeping the p ro bl ems 25 under the rug. (202) 234-4433 T he i nd ustry's addiction to mo ney and NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com 4-7-HH I Cont'd 4-8-AL I Appendix A A-65 52 1 po wer has bli nded them to moral lif e and death issues 2 a nd facts set righ t in front of th eir faces. But my.-1:--='-::-=---, 1 4-9-LR I 3 question of t he day is why is Exelon a pply i ng for 4 an extension 18 years ahead of t ime? Th ank you. 5 (Applause.) 6 FACILITATOR BA R KLEY: Thank you, L orra ine. 7 Mi ke? 8 MR. GAL L AGHER: Good af ternoon. My name 9 is Mike G allagher and I'm the Vice P resident of 10 License Renewal for Exelon. I have ov e rall 11 resp on sibility for t he Limer i ck Generating S tati on 12 li cense ren e wal ap plicat i on. 13 Exe lon has a great deal of experience with 14 lice ns e renewal, as we have al ready ob tained t he 15 renewed lice nse s for ou r Peach B otto m an d our TMI 16 pl ant s in Pennsy l vania, our Oyste r Cree k plant in N ew 17 J ersey , and o ur D resden and Qu ad Cities pl ants in 18 Illinois. 19 Just briefly abo ut myself. I've been 20 working in the nucl ear power ind u str y for 30 years. I 21 was a license d senio r operator a nd plant m anager at 22 Li merick and I worked at two other nuc le ar plants and 23 o ur corporate offices. 24 Mr. M agu ire, the site vice pres id ent for 25 Limerick spoke about re asons for re n ewing the license (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-66 53 1 for L im erick. I'd like to speak briefly abou t the 2 pro cess f or preparing th is l ic ens e renewal application 3 and t he amount of work an d engi ne er i ng an alysis tha t 4 was put i nto preparing the app licat ion. 5 Because th e license Generating S tation can 6 pe opera t ed sa f ely a nd reliably , Exelon deci d ed to 7 p urs ue license renewal for L im erick. Lime ric k is a 8 v ery cl ean e nergy so urce whic h produces no greenhouse 9 pa s emissi o ns. L imeri ck is a lso good for the econ omy 10 n t hat it l ower s marke t pr i ces on el ectr icit y for t he 11 pi ti zens of Pen ns yl vania to t he tune of $880 m illi on 12 p er year. 13 So in 2009 , we an no u nc ed o ur i nt e nt i on to 14 seek l icense renewal for L imerick. L ater t ha t year , 15 we started the work necessary to p repa re t he 16 app lication. Af ter over two years of work , we 17 submitted the app l ication to the Nuclear Re gu l atory 18 Commission on June 22 , 20 11. The ap pl i cation , as Lisa 19 had men t ioned , whe n you print it out it's about 2100 20 p ages. And when you put it in th e binders it's three 21 large binders. It's a huge amount of in fo r ma t ion. 22 But t hat on ly represents a small part of the wor k tha t 23 was done for the engineering analysis to p repare this 24 app l icat ion. 25 The to tal amount of engineering ana lysis , (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com 5-1-SR I Appendix A A-67 54 1 if we printed it a ll out would be about 290 binders of 2 i nf o rmation. We invested over 60 , 000 man ho urs of 3 e ngin eer in g work. Once we compl eted our engineer in g 4 work to prepare th e application, we bro ught in ex p erts 5 fro m ou tsi de Exe lon to review t he application to 6 e ns ure that it was co mp le te , thorough a nd accurate. 7 Our to tal co st to prepare th e application and get t his 8 applica t io n rev i ewed by t he N RC wi ll be about $3 0 9 mil li on. 10 Th ere are t wo different pa rts of our 11 f:l pp l ica t ion, t he safety review and the envir on menta l 12 ev iew. For t he safety rev i ew, we t ook an in-depth 13 ook at the hist o ry and the co ndition of the safety 14 qu ip m ent in th e plant. We did th at to de termine 15 the necessary maintenance was being perf ormed 16 pn t hat eq ui pment and to make sure t hat the equip men t 17 be ab le to op erate when it's n ee d ed , not only for 18 oday , but also for an addit ional 20 years of 19 p peration. 20 Whe n you look b ac k at L im erick, when it 21 built, all t he eq ui p ment was new. It was 22 h orou ghly tested to make sure it would perfor m 23 p roperly , but like anything el se equipment do es age. 24 doesn't mean it won't work , but it do es age and 25 er tai n activi ti es need to be done to the equipment. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 5-2-0S I Appendix A A-68 55 1 So we perform preventive mai nten ance. So metimes we 2 refurbish th e equipment. Some equipment is replaced. 3 There m ay be modifications done to upgra de the 4 equipment in th e plant and in f act , as Bi ll M agu i re 5 has stated , Limerick h ad spent o ver $2 00 m illio n in 6 the last coup le years a lo ne to im prove a nd mo dernize 7 th e equipment and enhance pl ant ope rations and safety. 8 9 were We al so t hen perf or med as part of rev i ewed calcula t ions tha t 5-2-0S I Cont'd the o ri gi na l design of t he 10 plant t ha t were d one to e nsure t hat the plant c ould 11 operate safely for 40 years. We ana lyz ed th o se 12 ca lc ula tions and were able to conf irm t ha t the plant 13 would be able to op erate safe ly fo r 60 years. 14 Overall , our con c lusi on from our e ng i neer i ng review 15 was that Lime rick could operate safely for up to 60 16 years. 17 We als o took a l oo k at th e environmental 18 impacts of contin u ing to operate Limerick. We l ooked 19 at all t he im pacts of co nt i nued impact of the pla nt on 20 the environme nt. Our concl u sion is that imp act s on 21 the env i ronment are sma ll and I use the term s ma ll in 22 the sense that is in the reg ulat ion. T he regu la t ion 23 defines small as enviro n menta l effects are not 24 detecta bl e or are m inor. 25 (202) 234-4433 We al so revlewed the al ternatlves lf 11 5-3-AL I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-69 56 1 Limerick wo uld not have its lic ense re ne wed and 2 an other source of ele ctr ic generation w ou ld n ee d to be 3 inst alled ei t her here on site or so m eplace else to 4 generate th e rep l acement electr ic ity. We concluded 5 that any o ther m eans of ge nerating t he replacemen t 6 electr icity woul d have m ore of an im pact on t he 7 en viron m en t th an co ntinued ope rati on of L im erick. For 115-3-AL I IICont'd 8 ins t ance, if L im eric k could be rep l aced by a wi nd 9 g enera t ion faci l ity, t he wind fo rm wo u ld ha ve to 10 occupy be t ween 10 and 4 0 perc en t of all t he land in 11 t he st ate of D elaware a nd that w ou ld h ave a h uge 12 impact on the l and. If a s olar fac ilit y co ul d re place 13 L im erick, it would n eed to cover 32 to 50 percen t of 14 t he en t ire lan d area of Mon t gome ry Cou nty. 15 In conclusion , we ope r ate Li me ric k safely 16 and we ca n continue to o pe rat e it safe ly for an 17 additi ona l 20 y ears. L ime r ick will provide 18 approximately 2340 me gawat ts of base-l oa d gene ration 19 that's not only safe , but it's clean , re li able and 20 economical. 21 C ontinu ed operation of Lim e ric k w ill 22 b enef it this co mmu nity , the C ommo nw ea lth of 23 P ennsy lv ania an d our nation. T hanks for giving me the 24 ti me for this. Th ank y ou. 25 (202) 234-4433 (Appla u se.) NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 13 23 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgr o ss.com 5-4-SR I Appendix A A-70 57 1 FACILITATOR BARKLEY: Th a nk you, Mike. 2 Dr. Winter? 3 DR. WINTER: Good af ternoon. Th anks for 4 le tting me speak. We have h ea rd a lo t of pros and 5 co ns , haven't we? And it's hard to make a decision 6 that's f or sure. Bu t let me ge t going h ere. 7 As a pnys lc la n praCLlClng r aalo.Logy ror 8 o ver 50 years, I sti ll have str ong co ncer n abou t 9 cancer sensitivit i es fr om h ar mful radiation exposures , 10 na t ura l ly. My me dica l coll eagues share the same 11 concerns because we have seen o ur cancer ra t es 12 increase since t he Li me rick power plant started , 13 especial ly thyr o id cancer. It ju mped to 78 p ercen t 14 high er here th an the na ti o nal average. A nd some of 15 the peop le I ta l ked to , this is because pe ople are 16 ag i ng m ore n ow , getting ol der, so there a re more 17 cancers. But that's not true because in other areas 18 similar to our area in P ott st own , th ey're not n early 19 getting the t hyroid cancers t hat we are. This has 20 b een well esta blished by th e state. 21 You wonder why so me of ou r me dical and 22 cancer fundr ai s ers h aven't reacted with mo re 23 r espo ns ibilit y in order to stop this. They're making 24 a l ot of money, bu t not taking much eff or t to prevent 25 e nvi ronmen tal d am age. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 6-1-HH I Appendix A A-71 58 1 Yes , we are crea t ing our ow n for m of 2 t error ism. No w that sou nd s kind of funny, doesn't it? 3 But al low ing any harm ful e nv iro nmenta l events to 4 occur, we are al low ing o ur own for m of t er r or ism, j us t 5 like foreign people would come in here. 6 H aving at t en d ed a Hi rosh ima , Japan atom 7 o mb c lini c right a ft er Wo rld War II , natu ra lly I had 8 chance to s ee t he worst resu lts of harm f ul 9 adiation. All tho se lit tle kids I sa w who only lived 10 or a f ew da ys , it left me wi th a ve ry s ad memory. Of ii6-2-HH I 11 ou rse , wh at is ha pp en i ng here will be taking much 12 ong er , but it su re is no t good. 13 I don't know wh e ther you've heard that 14 orne sc ientis ts are already pr e dic t ing that I'm 15 or ry to tell you t his, but nuc lear e ne rgy has the 16 apacity of destr oy i ng mank ind. It m ay ta ke about 1 00 17 ears , but ou r whole world is exposed to the ha r mful 18 f fec ts, m ay be not so m uch here in t he Uni ted S ta tes, 19 ut the whole worl d can be aff ected. 20 Of course , what is happening h ere will be 21 taking much lo nger , but it is s ure no t good news. 22 Besides harmfu l power pla nt e xp osures , we have 23 environmental disasters and a concern about our near by 24 earth q uake fault a nd ot h ers in the easter n U.S., 25 e specia l ly one near Ne w York C ity. And then th ere are (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.nealrgr o ss.com 6-3-PA I Appendix A A-72 59 I .------------------, 1-::1-:--::::-
-::::-o 1 he radioactive spent f uel deadly waste m ater i al 6-4-os 1 2 itting aro und , supposedly protected. We can't 3 control the use of n uclear power in the rest of the 4 world , but can k eep America sa f er and cleaner here. 5 So please , ask your poli ti cians , reliable 6-5-0R I 6 po li ticians to clo se t he Limerick power pl ant. Let's 7 save America for ou r kids a nd de s ce ndants. I h ope you 8 w ill take my co n cerns ser i ously. And t hank you for 9 li stening. 10 (Appla use.) 11 FACILITATOR BARKLEY: Okay , thank you , Dr. 12 Wi nt er. The next three people I'd like to call is T om 13 Neafcy of Li m erick Townsh ip, f ollowe d by Dr. Anita 14 Baly, a nd then Tim Fen c hel of t he Schuylkill Ri ver 15 Heritage Fo un dation. 16 MR. NEAFCY: Good af ternoon, t hank you. 17 My name is T om Neafcy. I'm t he Chairman of Limeric k 18 Townsh ip Board of S up erv i sors and I wa nt to thank you 19 for this opportunity to speak at t his for um tod ay. 20 As the larg est pri v ate emp l oyer in the 21 region , the Board is thank ful for the 8 60 jobs tha t 22 Exelon provides , the positive impact of the i r-'r=-L-1=, F-1-SR I 23 operation, the vitality of our local community. T he 24 com munity an d local eco nomy are enhanced by the needed 25 services prov ided by the township , whic h includes the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgr o ss.com Appendix A A-73 60 1 roadway ne tw ork maintained by our Li m er ick Townshi p 2 Public Works , public safe ty provided by the Li m erick 3 and L infi eld F ir e Compa n ies, a nd our l ocal em ergency 4 m ed ical response, o ur public parks , ou r recreation 5 facili t ies and also t he police pro te ction that's 6 pr ovided by Limerick's 21 sworn o ffi cers. 7 Because of Li m erick Generating Stati on's 8 locat ion withi n our b or ders,the L imer i ck Town ship 9 Po l ice D epar tm ent 10 departm en t in 11 jur isdi ction ove r is the o nly m unicipal pol i ce P enn sy l vania with Tier 1 crit i ca l t he pr i mary lr=7._-1,.....-s =-R=-___,I i nfras t ructure *i Cont'sd 12 This Boar d prides it self on t he serv i ces prov i de d 13 dir ectly both to the res i dents and the bu sinesses of 14 this commu nity and the t ow nship's ab il ity to ma i ntain 15 th os e cu r rent l evels of service du r ing t hes e di f ficu lt 16 economic d ow ntur ns. We are tha nkful f or t he 17 gen eros ity of the Li m erick generating p lant and Exe l on 18 for be i ng good corpor a te neighb or s and the assistance 19 th ey pr ovi de to t he co mm u nity. Wi tho ut their 20 fi nancia l ass i stance that i mp act to provide those 21 services to the c omm un i ty would fall squa r el y on the 22 b acks of the taxpayers. Th ey ass ist in our fire 23 companies. They have b een corporate sponsors of our 24 Li merick Co mmun ity Days. A nd we are co nfid ent that 25 Limeric k gen erat ing fac ili ty an d Exelo n will con tin ue (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-74 61 1 th at support in the f uture an d be our go od corporate 2 neighbor. 3 We a ls o are in support of the relicensing 4 of the Lim e rick nuclear plant. Tha nk you. 5 (Applause.) 6 FACILITATOR BA R KLEY: Dr. Baly? 7 DR. BALY: Good af ternoon. I'm An it a 8 Baly. I'm a ret i red Lut heran pastor and my concern 9 to day is with the speed at whic h this appli cat i on 10 p rocess is goi ng. I mea n it seems to me t hat to 11 p redict w hat environ m ental fac t ors wi ll be in p la ce 13 12 years h ence a nd 18 years hence , po sits a kind of 13 p mn isci ence a nd pr escien ce that we shoul d attrib u te to 14 f\lmi ghty God, b ut certainly not to any of us hu man 15 16 I woul d favor a sl ower proc ess. As we 17 look around, we see th at the p opulation in this area 18 is get ting de nser al l the time. T he ro ads are not 19 bei ng impro ved. And t hat l eaves me wi th conc e rns 20 ab out how we w ould ef f ect an ev acuation were one 21 needed. I suspec t st rongly th at we couldn't p erform a 22 good evacuat ion to d ay. And I al so suspect that t he 23 p opulation will be increasing and the ro ads 24 deteriorating. In fact , ju st this m orning in the 25 Po tt stow n Mercury, th ey were r epor t ing on the hearing (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com 7-1-SR I Cont'd 8-1-LR I 8-2-os 1 Appendix A A-75 62 1 h at was held on Route 4 22 which is ou r main ro ad 2 aroun d here. A nd Barr y Seymour is quoted, he's the 3 xecutive Director of th e De l aware River Valley 4 R eg i onal Pla nning Co mm ission, an d he t ol d last week's 5 oru m audience tha t population projections anticipate 6 a 50 percen t increase in th e region a nd if we don't 7 n crease capacity on 422 , we will have v ir tual 8 all th e way to t he Berk s County l ine. 9 Maybe we'll im prove th at situation , bu t 10 it's way too early to k now if that will happen. And 11 so my plea a nd my c oncern is can we s low this down so 12 t hat we k now , in fact, what t he envir on mental i mpacts 13 are going to be cl oser to a time that the dec is ion is 14 made. T hank yo u. 15 (Appl ause.) 16 FACIL I TATOR B AR K LEY: T hank you. Ti m? 17 MR. FENCHEL: Good afternoon. My name is 18 T im Fenchel and I'm on the staff of the Schuylkill 19 R iver National a nd S tate Herit age Area. We are o ne of 20 4 9 congressional ly-designated H eritage Areas in the 21 country and our mi ssion is to use r ec r eati on , 22 conservation, educa ti on, cu ltural an d historic 23 preservation a nd tour i sm as tools for community 24 r ev i ta l ization and economic development w ith the 25 Schuylki ll R iver Valley. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 118-2-08 1 II Cont'd I Appendix A A-76 63 1 The Heri t age Area has had the o pp or tun i ty 2 for al m ost se v en ye ars now to partner with Exelon 3 Nuclear a nd the Limerick Generating Station on several 4 local and re gional pro j ects a nd pr ograms. Th ese 5 pr ograms have pr oven to have a positive impac t on our 6 local co mm un i ties , residents, a nd natural resources. 7 A nd I would like to take a few mome nts to high li gh t 8 t hose now. 9 In 2 005, Exelon N uc lea r appr o ac h ed us 10 about the po ssib i li ty of partnering to ge the r on a 11 g ra nt progr am that wo ul d wo rk to rest o re o ur area's 12 cr i tica l natura l res o urce, the Schuylkill Ri ver. The 13 river has b een det rim e nt ally i mp acted by h un dr eds of 14 years of ab u se and n eglect, pr ima rily as a result of 15 our nation's hi sto ry related to the I ndu st r ia l 16 Rev ol ut ion. But even mo re recent ly , due to 17 deforestat i on, fa rmi ng prac tices, and co ntinued open 18 space de vel opme nt. 19 B egi nn ing in 2006 , a ft er the creat i on of 20 gra nt pro gr am g uidel ines , an a dv isory commit t ee and a 21 necessary account i ng a nd r eporting st ru ctur es , Exel on 22 b egan ma king an n ual contributions to the Schuylkill 23 R iver R estora t ion Fund. The Sc h uy l kil l River H eritage 24 Area acts as the ad minis trator a nd the manage r of this 25 grant program , re di s tr i but i ng Exel on 's co n tribu tion s (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-77 64 1 to local and regiona l watershed groups , conservat i on 2 organizations, and local g over n me nt agenc i es f or 3 pr ojects a dd ressing t he qu ali ty a nd qu ant ity of 4 Schuylkill River w ater. Pr ojects f ocus ing on 5 agr ic u ltu ral re m ediation, a band oned mine drainage, and 6 stormwa t er run o ff are supported t hrough th is program. 7 To date, Exelo n ha s contr ibuted over $1.2 8 mill ion to the res torati on fund f or wate rs hed-wi de 9 projects. Tw enty-t wo g rants have been a warded a nd 11 10 projects have been co mplet ed. Th ese projects ha ve 11 made an im pac t on the water q ualit y and qu an tit y of 12 t he Schuy l ki ll Riv er which is a source of drinki ng 13 wa t er for ov er 1. 7 5 mi lli on people in sout heastern 14 Pe nn sylvania. 15 Exe lon's establi shment and c on tribution to 16 t he re st or ati on fu nd has be en a mo del p rogram and is 17 now a un i qu ely va l ued public/priva te p ar tn ers hip as 18 several new pa r tn e rs have j oi ned e ff ort s and m ad e 19 their ow n cont ribu tio ns to the fund. Both t he 20 Philad elph ia Water De p artment and the Part n ers hip for 21 th e De l awar e Es tuary h av e bro u ght fu nding to the 22 pr ogra m and su ppor t ed regional waters h ed pr ojects. 23 The co n tri bu tions made by Exe l on have b een the 24 catal y st to l everage additional funds we ll over 25 $600 , 000 for area res tora tion. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-78 65 1 The goal of th e Restoration Fu nd Advisory 2 Co mm i tte e is to be a ble to support a sustainable leve l 3 of half a mil lion do llars a nnu ally for th e fund a nd in 4 tu rn , conservation projects that will c on tin ue to 5 e ns ure th e futu re hea lth of th e Sc h uyl kill Riv er. 6 In a dd i tion to o ur wo rk on th e res t oration 7 fu nd , we have a ssisted Exe lo n Nuc l ear , East Cove ntr y 8 Town ship, and Che st er Cou nt y in a pla nnin g ef f ort to 9 begin the proc ess of res t ora tion a nd preservat i on of 10 t he h istoric Fric ks Loc ks Vil lage. Earli er th is year , 11 Exe l on Nuclear, t he current owners of t he v il lage , 12 si gned an agree m ent w it h East Cove n try T ownship to 13 stabil i ze , re h ab i litate, and pro tect severa l of 14 Ches t er Co u nty's ol dest bu ildi ngs. Exe lon ha s agreed 15 to spend $2.5 m il l ion to rest o re the exteri or of 16 several buildi n gs as stabiliz ed ru ins. A fe n ce wil l 17 be buil t around the groun ds and t he corporation is 18 donating four ho uses to the tow ns hip w ort h an 19 es timated $1 mil l ion. 20 In a ddition, the cor p oration has agree d to 21 c on tin ue to do rout in e ma i nt en ance on th e vi l lag e and 22 work w ith the local h is t or i ca l soc i et y to host g uided, 23 historic an d ed u cational tours for the p ub lic. 24 F rom our perspective, mu ch of the success 25 of this pa rtners hip can be assig ned to the h ar d work , (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-79 66 1 dedica t ion and p erso n al co mm i tm ent of Exelon sta ff and 2 m anage ment. Based on t he v er y positive c ommu nity 3 and i nv ol vement h ave experienced pro g rams we and 9-1-SR I 4 witnesse d first hand as a regiona l organization, we 5 w ou ld li ke to communicate our suppor t for t he 6 re lic ens i ng and co nt in ued op era ti on of Limeri ck 7 Gene rating S tation. Th ank you. 8 (A p pla use.) 9 FAC ILIT ATOR BARKLEY: Okay, t hank you. 10 T he next t hree pe op le I would like to call, B il l 11 Vogel , fo ll ow ed by Eileen Dautrich , is th at how yo u 12 s ay that? 13 MS. DAU TRICH: Dau trich. 14 FACILITATOR BARKLEY: D autrich. Okay. 15 And then Bill Albany. 16 MR. VO G EL: Hi , my name is Bill Vo gel. I 17 l ive in P ho e nixvil le. Un its 1 and 2 had an init ia l 18 li fe ex pectan cy of 40 years. T hey a re now asking to 19 increase that 20 ye a rs, a f ull o ne third increase. 20 Everything h as a li fe expec tancy, machi n ery, as well 21 as people. Demo gra ph i cally, my li fe ex pectancy is 74. 10-1-LR 1 22 If I was to get a one third ex tens i on , like t he 23 L imerick p lant wa nts, th at would take me to 1 11. What 24 do you think is going to h appen to me between age 74 , 25 my life span , my nam ep la te ca paci ty , and the y ear when (202) 234-4433 .. ... ""* '"'""'"'"" COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-80 67 1 I reac h 111? It's going to go down hill. T hat's 2 l if ecycle. Mach in ery has them. You don't n eed an 3 en gineer to te ll you that. Just l ike human be ings 4 have t hem. We b ecome less e ff ec t ive , less eff i cient, 5 less co m pete nt. 6 The si gnifi ca nt di ffere n ce is my fa il ure 7 will be con ta inable. Limerick's mo st like ly wi ll not. 8 If I drive o ver you with my car beca u se I no lo nger 9 see as well or h ave the re fl exes I on ce had , that's a 10 t ragedy for you, your f amily, f or me and my family. 11 T he s phere of t he tra gedy is conta inab le. If L imeri ck 12 Unit 1 or 2 fai ls, all hell breaks loo se , no 13 dis res pect. Th at's w hat a nuc lear f ailure is, h ell. 14 It aff ects everybody in t his r oom , ever ybody in the 15 commun ity, everybody in the tri-st ate a rea , not for a 16 week , but for deca des. It's very , very la st thi ng we 17 want to hap pen. 18 And I think we're putting our se lves in 19 harm's way by taki ng someth i ng th at had a li f espan of 20 40 years and ad di ng another 20 to it. It doesn't make 21 sense. The only way to rat i onali ze it is thro ug h our 22 p ersonal fear of b eing inconvenienced b eca u se we l ose 23 a very , very g ood so u rce of power. It's done a great 24 job for us. But like me, you get to a point where 25 your abil ity to pro vi de a great job is at an end and (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 10-1-LR I Cont'd 10-2-0R I Appendix A A-81 68 1 thi ngs start d eteriora ting. Let's no t put ourselves 2 in th at position. Let's make an intelligent decision 3 n ow and al low these two u nits to expire at th e ir 4 name plate t ime. Tha nk you. 5 (Applause.) 6 FACILITATOR BARKLEY: Th ank you, B ill. 7 Ei l een. 8 MS. DAUTRICH: Good afternoon. My nam e is 9 Ei l een Dautrich. I'm president of the Tri-C ou nty Area 1 10-2-0R I I Cont'd I 10 11 I'm happy to be here to day to I ,..,u......,....=-=-..., p rovide examples of how Limerick Ge n erati ng Sta tion is 1 11-1-SR I f=hamber of Co mm erce. 12 a valued c ommun ity and b usiness par t ner an d echo t he 13 state m ents already s har ed by seve ral others. 14 Th ey're one of t he tr i-county area's 15 l ar g est emplo yer, prov i ding pro fessio n al emplo ym ent 16 p pportunit i es for l oca l residents. Th ose l ocal 17 res i dents empl o ye d by Li m eri ck Generating Stati on are 18 su pporting the en tire tri -county bus ines s co mmun ity. 19 rr h ey' re pu rc h asing pe rs onal g oo ds an d services from 20 local sma ll bu sinesses. T he an nu al outage is a 21 tre men dous benefit to th e local e co nom y and our local 22 Li merick en co urages t he ir outa ge 23 employees to v isit an d purchase f rom tri-county area , 24 local b us i nesses , and sm al l bu si n esses. 25 In additio n to the jobs they provide local (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-82 69 1 r es id e nts, they're m aki ng a si g ni ficant i nv est men t in 2 our lo c al co mm u ni ties. Muni cipal it ies a nd r es idents 3 bene fit f rom ass istance r eceived from Lim er ick to 4 s tart, main tain, e xp a nd pa rks, r ec r ea t ion, a nd q ua lity 5 of life o pp or tuni ti es. 6 T he ir c orpora te culture of giv i ng back to 7 th e communi ty is p ra ct i ced by their hundr e ds of 8 e mpl o yees. N on profit o rganizati o ns are support ed by 9 Limeric k Generat i ng Stati on and t he effor ts of their 10 empl o yees. Fi nancia l donat i ons , as we ll as vol un teer 11 h ou rs and time are donated, en abling o ur lo ca l 12 non profits to pr o vide the much n eeded servic es that 13 impact t hose in n eed througho ut the tri-co unty area. 14 Th e Limeric k Generating Sta t io n is 15 c onf ide nt in the cle an and safe en vir on ment th ey 16 ma i nt ain in our c omm un i ty. T he commu n ity has been 17 invited to ex p erie n ce t he generating station 18 first hand. T he ch am be r ho sted a membership br eakf ast 19 a nd the sit e vice pr es ident , Bil l Mag u ire pr ovided t he 20 ke y note p rese nt a tion. He summa ri zed s afety m eas u res 21 and ad v ancem en ts at Lim er i ck and ans we red qu es t io ns 22 pe rtai ni ng to th e Li merick p lant and its s afety in the 23 wake of the ts unami in Jap an. 24 In ad dit ion , after o ur bre ak fast, C hamber 25 me mb ers were enc oura ged to a tt e nd the informa tiona l (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 1 11-1-S R I I Cont'd Appendix A A-83 71 1 see po licies and procedures that people t al k about and 2 t hey're put up on a shelf and t hey're followed at bes t 3 haphazardly with a wink and a nod and deviation fro m 4 th e policy is n ot addressed. 5 One of t he things that I'm cont inuously 6 impressed at LGS when I visit is t heir sound adherence 7 to po l icy and pr oc edure. They don't deviate from it. 8 I've been to nu m erous dri lls at the plan t, nu m erous 9 exer c ises at the pla nt , some of wh ich were run by t he 10 NRC and I've never seen t hem fail. They al ways come 11 out on t op. In f act, in 2009 , Limerick was se lect ed 12 as a si te f or t he fi rs t co m prehensive pilot exerc i se 13 involv i ng fe de ral, st ate , an d loca l law enf o rcem en t 14 SWAT teams to ac t ua lly go into the power blo ck and 15 c ond uc t tact i ca l ope r atio ns in there , an d that dr il l 16 was u sed as a boi l er pl ate to develop poli cies and 17 pr o cedures for implementation in power plants 18 throug hout the co u ntry. 19 One of the I'm so rry, I don't bel i eve 20 th at continued operations of the power pl ant wo uld 1 12-1-SR I 21 have any detri me ntal ef fect on public safety in the 22 southeast region. Tha nk you. 23 (Applause.) 24 F ACILITATOR BARKLEY: Okay , thank you. 25 I'd like to call the final three speakers who h ave (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.nealrgr o ss.com Appendix A A-84 72 1 signed up , Jo hn Mc Gow an , Ted Del Ga izo , and Timothy 2 Phillips. Joh n? 3 MR. McGOWAN : Thank you very much. My 4 n ame is John Mc Gowa n and I am a life-long r es id en t of 5 the Delaware Valley. I have l ived ha lf of my --or I 6 should say the L imer ic k Nucl ear Power Stat ion has been 7 operati ng for ha lf of my l ife. I own thr ee 8 ma nu fac t ur i ng com panies in the Ma l vern area an d empl oy 9 a number of people in t ho se faci l it i es who r ely 10 t remend o usl y on the Limerick Power Gener ating St ati on 11 to supply safe , re l ia ble el ec t rica l power to k eep us 12 op erating. 13 Today, I would like to say t ha t in all of 14 t he years t hat I've l ived in thi s area, I've n ever 15 wor r ied at a ll about the safe ty of the nuc le ar power 16 pl ant. I see it every day. And it b othe rs me not in 17 the least. I ha ve n ever seen any credib le ev id ence to lr:-13=---1-=---:: s::-R::::-'1 18 su ggest t hat there are s afety p rob lems with thi s 19 pl ant. In te rms of re li a bil ity, it is th e same. It 20 is run n ing 24/7 , 365 days a year an d it has been doing 21 so for a quarter of a cent u ry and I hope it co n tinues 22 to do so f or ma ny more years to come. 23 As far as it s environmenta l impact, I 24 th i nk it's pr etty widely kn own that nu clear power is 25 one of the c leanes t environmental ener g ies that we (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.nealrgr o ss.com Appendix A A-85 73 1 p ossess today throughout the w or ld and to d is mi ss it 2 is I t hi nk a foolish n otion. 3 The impact of th e Limerick p lant in our 4 r egion h as b ee n ex tra or dinarily p os itive. It 5 pr ovi d es , as we a ll know and hav e heard tod ay , lots of 6 jo bs, l ots of good jobs , tax r eve n ues for schoo ls , 7 local governme n ts and for t hose who li ve in th e area 8 to e nj oy t he fru its of publ ic servi ce s and it als o 9 provides a lot of char i table do nati o ns to the 10 co mmunity w hich is very im po rtant. 11 I think that to not keep this plan t 12 ru nn ing and no t con si d er a renewal of it s lic ense for 13 an extended period woul d be a tragic mis take fo r al l 14 of us and I would like to end this by saying th at t he 15 o nly m el tdown that wo uld co ncern me is the eco nom ic 16 o ne that certainly wo uld h appen to th is area s ho ul d 17 this p lant not continue to operate. 18 (Applause.) 19 FACILITA TOR BA R KL EY: Ted, go ahead. 20 MR. D EL GA IZO: Hi, my name is Ted D el 21 Ga i zo. I'm a r eg i stered pro fessio nal eng i neer in the 22 Co mm onwea lth of Pennsy lvan ia. I'm also president and 23 CEO of a small bus in ess e ngin eering firm in near by 24 Ext on , P enns ylv ania. 25 (202) 234-4433 My e xp erie nc e in nuc lear p ower g oes back NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 13-1-S E Cont'd Appendix A A-86 74 1 to the 196 0s where I spent 14 years in N av y submarines 2 a nd I personally operated , maintained, a nd refueled 3 nucl ear power plants during that period. 4 But I'm here tod ay as a pri v ate c itiz en , 5 as a resident of th e area and as a m ember of th e 6 Pennsylvania En ergy A lli ance to go on r ecor d and say I 7 s trongly favor l icense re ne wal for the L im er i ck 8 Gene rating Sta t ion. I say that because in my personal 9 experience I kno w in spite of s ome of the th ings 10 y ou've probably h eard here to day, nuclear pow er is 11 safe , reliable , secure and c le an. But in addi tion to 12 t hat, I wou ld l ike to go on rec ord, I would l ike my 13 nei ghbors to know we are lu cky to have t he Limerick 14 Generati ng Stati on in th is area. In the i nd u stry , it 15 has a top rep ut ation. It is one of the fi n est nu clear 16 p ower pla n ts in America. And Exelon, if not the best , 17 is certai nly one of the fi ne st nuc l ear op erat o rs in 18 the world. 19 I have no thing bu t con fide nce t hat E xe l on 20 w ill wor k together wi th the NRC, wi ll run through the 21 process and we will c ome up wi th the ri gh t conc l us ion 22 here which is lic ense renewal sh ould be granted to t he 23 L imerick Generating Station. I think we need to k ee p 24 L im erick operating as long as we can. 25 In additio n, in sp ite of some ot her things (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-87 76 1 openness in the th inking process t hat goes into place 2 for renewal of any nu clea r power plant. 3 And so f ro m my p erspective as a citizen, 4 as a bu s in ess person who h as worked in this community , 114-2-SR I 5 I und erstand the value t his is to the r egion. And for 6 I applaud the NRC f or what they're do i ng here. I 7 applaud Exelon fo r the g reat work that th ey're do in g 8 th ere and I encourage the renewa l process to take 9 p lace. Th ank you. 10 (A pplause.) 11 FACILITATO R BARKLEY: T hank you. W it h 12 t hat, I h ave all 15 people who had sig ne d up for this 13 meeting , have been cal l ed. Is ther e any on e else who 14 would li ke to make a short fol low-up remark or wo uld 15 li ke to still speak at this poi nt? 16 Okay , if not, I'd li ke to make two points 17 bef o re we w rap up. One, the NRC do es have public 18 meeting fee dba ck fo r ms wh i ch give us feedback on how 19 y ou think this m eeting was con d uct ed, so I would 20 greatly appreciate you filling out one of those forms 21 for us so tha t we can l earn how to improve. T he re is 22 another session of this meeting at 7 o'clock tonight. 23 You're welcome to speak again to night. 24 And secondly, wh at I'd li ke to say is I 25 facilitate a l ot of m ee tings th rou ghout t he N or theast (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-88 27 1 meeting via co nference bridge. And due to the arrangements of the audio in this room it wasn't p ossib le to do it any other way than a cell ph o ne. So we're go i ng to go to him a nd ask him to make a statement f or the period and m ove fr om there. So our first speaker w ill be Mr. Thomas Saporito who is a seni or consulting associate and he act ually l ives in Florida. So as soon as we can work having him on t he m icropho ne we wil l have him make his statement. Are 1 we free to give it a try? MS. REGNER: Go ahead. Yes. Go ahead , 1 Mr. Sapor i to. 1 MR. SAPORITO: Is it my turn to speak? MS. REGNER: Yes. 1 MR. SAPOR I TO: O kay. Can you hear me 1 oka y? FACILITA TOR BARK LEY: As best we can , yes. 1 MS. REGNER: Yes , go ahead. 1 MR. SAPORI TO: All right. My name is 2 Thomas Saporito. I'm the senior cons ultant with Sap r odan i Assoc i ates and I'm l ocated in Ju piter , 2 Florida. I would like to comment on the NRC's 2 environmental review but b efore I do that I want to state that , you know, I'm very upset at the NRC's 2 refusal to honor my enforcement pe tition filed u nde r (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 16-1-0S I Appendix A A-89 28 1 10 CFR 2. 206 with resp ec t to the L imerick nuc l ear pl ant. The NRC denied that pet ition on the basis tha t I would have an o pportunity to in t ervene on this proce eding th rough the NRC's jud i cial process. However , that's not available to me. I m ade tha t q uite cl ear in t he 22 06 peti t ion. Now, I don't h ave standing as a United Sta t es ci t ize n because of my physica l location in Jup it er to interve ne in a pro cee ding in Pennsylvania w here this plan t is 1 loc ated. The NRC s taff is incorrect in their opini on and th ey ha ve a legal ob liga tion to h onor tha t 1 enforcement peti tion and to prov ide an oppor t un ity f or 1 me to address t he Pet it i on Review Bo ard. So I wa nt to put th at on the record and I'm asking t he NR C to l ook 1 into tha t iss ue. 1 Wi th respect to this envir on menta l petiti on the fel lo w who spoke ear lie r from t he NRC, I 1 don't recall his name. It was very hard f or me to 1 hear t hr o ugh this communication his name. Bu t anyway, 2 one of his comments wa s exceptionally incorrect an d he misin for med the p ub lic. And I'd l ike to correct tha t 16-1-0S I Cont'd I 2 statement. 16-2-LR I He stated that the NRC is ex tend i ng the 1--r-----' 2 o rigina l operat ing lice nse which was gr ante d by the NRC for a 40-year period of time that that initi al 40-2 year lice n se was no t based on safe ty co ns i derations or (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-90 29 1 echnical conside rati ons. But that's absolut el y not rue an d there was recently a year-long investigative 4 eport done by the Associated Press who in t erviewed 2:--:-:L R::::-ol safety engineers Cont'd 2xpert nuclear perso nn el , engineers , n th e nuc l ear industry who told t hem that the 40-year E i censes issued by th e NRC f or 104 n uclea r plants in 7 he U nited States was based on safety and t ech ni cal afety te chn i cal analys is. So these pr oceed in gs , c hese l icen se extension proceedings l ike th e one we're 1C :::urren t ly at are a rubber-stampi ng of these 20-year 11 icense extensions. Th is is in fact a foo t race 1L be t ween the Nuclear Reg u lato ry Co mmissi on a nd t he L' Un i ted St ates Congress where Congress wants to st op 14 this process , put a moratorium on the re-licen si ng 16-3-L R I 1" until the Fukush im a disasters can be fully understood 1E and the enhancement enacted in August for our power 17 ::>lants here. T his partic ul ar nuclear p lant, these 1c ::>lants , yo u know , their license is a lready good till 024. Why are we here now 12 years ahead of time 2C ry i ng to extend this license? And the only reason is 21 ::>ecause it's a fo ot ra ce the NRC's in with Co ngress 16-4-LRI 2.c nd nothing m ore. T his has nothing to do with 2 ::>rotecting public healt h and safety , it's the NRC's 24 ea l to continue to rubber-stamp these li cense 2." 2 xtensions withou t allowing ci tizens due p rocess like (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-91 1 30 I already talked ab out a nd wit h out doing a cost i nt e nse and t horo ugh en viron m ental rev iew. And with r es p ect to t he NRC's e nvir on m en tal review th e NRC in my v iew fail ed to prop er ly consider the embri tt lement of this nu cl ea r eactor vessel. When th ese nuclear re actors are :>perati ng th e ne utro ns c ause the me tal in th e reactor vessel to bec ome br i ttle o ver t ime. And a ft er n umer ou s years of operat io n these reactor vessels could cr ack beca use t hey're so bri ttle. But t he NR C j oesn' t pr o perly evaluate that and the NR C does n't equire the li ce n see to do des t ru c ti ve testing a nd analysis of t he react or's metal ves se l pr i or to ubber-st amping a 20-year extens i on to th ese l icen ses. Twenty years fr om n ow, oh actually 20 years f rom 2024 wh i ch will be 204 4 this reactor is go i ng to be even m ore cr it icall y brittle and the NRC's not going to u nderstand th e dynamics of t ha t and t he re act or co ul d cr ack and it's g oi ng to melt down because y ou can't eco v er f rom a l oss of coola nt acc ident of tha t mag n it u de. So that's one p oint. The ot h er p oint is the NRC's Commi ss i on I 16-4-LR I Cont'd 16-5-0S I :>ver there in Ro ckvi lle, in the Whit e Fl int Bu ilding , 16-6-0S I hey recently adop ted a new p olic y wit h respect to eva cuat ions. (202) 234-4433 T hey wan t th ese lic ense es to u pdate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-92 Appendix A A-93 32 1 would actual ly h ave the licensee shut down more of their other power p lan ts beca use of y ou would ne ed a demand. If you take wind energy which is plentiful up th ere in Pennsylvania and eve n the n ew solar panel which can operate when the sun isn't s hin ing on a cloudy day you could replace even m ore opera tin g power plants. So th ese renewable en ergy sou rces even w it h respect to wind energy si nce you have a co mm on grid t hroug ho ut the U nited St ates you can have wind farms 1 g enerate power to a common grid point and supply i ng t he p ower th at t hese nuc l ear p lants are now prov i ding. 1 The NRC's requ ired under the law to co nsider these 1 alte rna ti ves to exte nding t his l ice nse. And I would hope tha t the NRC's fi nal evalu ation and rev i ew shows 1 a complete and thorou gh ana l ysis of a ll these 1 renewable energy sources including installing on-demand hot water electric heater and doing an analysis 1 of how many megawatts you're going to take off the 1 gr id an d based on those evaluations make a licensing 2 determination whether or not this l icense sho u ld be extended. Becau se 20 years fr om now all these 2 renewable r esources are going to be all that much more 2 advanced a nd capable of supplying al l that much more power than they're cu rrent ly su pply i ng. So those are 2 my comment s and I would hope that the NRC takes them (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 16-7-AL I Cont'd Appendix A A-94 33 1 seriously and applies them to this li cense renewal. A nd I hope e veryb o dy h eard me. (Applause) MS. REGNER: Ca n you hear that? They're clapping. FACILITATOR BARKLEY: Okay , at this point I '1 1 call b ack Mr. Sapor it o later and t hank him for h is remarks and fo r being succinct in his remarks. It's awfully a wkward to provide comme nts v ia this avenue. Th e first th ree people I would like to call a re actual ly i ndividua ls who did not speak this af t er noon so I'd li ke to start wit h them. Firstly , Jef f Chumnuk , the n Daniel Ludewig, and th en fi na lly Catheri ne Allis on. So Je ff, if you could lead off. MR. CHUMNUK: Hi , my name is Jeff C humn uk and I'm a me m ber of Borough C ounc il w ith P ottstown Borough. A nd my co mm ents t on i ght are more I g uess from my perspec t ive as a ne wly elected of ficial with the gen erating station. Ab out a y ear ago I had the oppo r tun it y to go d ow n to the generating sta ti on and 1.-:-:::'--:--=:-=-. 17-1-SR I m eet with Joe Saffron and the first part of my meeting h ad to do with looking for some sup p ort for the P ottstown S oapbox D erby. Th ro u gh some conversation w hil e we (202) 234-4433 were stan ding ou tside NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 you know Jo e WW'W.nealrgross.com Appendix A A-95 34 1 e nli gh t ened me a l itt le b it on w hat Exelon and the generati ng sta t ion do for t he surroundi ng com m unities , wh ether it's supporting our fi refighters, po lice departme nt s and other ci vic o rganizati o ns. You know , from a Po ttst own p er spective they help us with our year ly bor ough cleanup, o ur Salvation Ar my and now t he S oa pbox Derby. Than k you. And we we re standi ng outside that day, it wa s pre t ty nice ou t, and our co nve rs ati on l ed to t he 1 power p lant i tse l f. We w ere st anding t here lo o king aro und, it's a pretty impre ssive sight. So I asked 1 him about, you know , pos sibly h av i ng a tour f or 1 mu n ici pal officials. He said he would look into it and see what he co uld do. A co u ple of months la te r he 1 got a group of abo ut 20 of us and gave us a tour of 1 the plant one eve n ing. A nd I h ave to say t ha t from the time we wa l ked thro ug h the fr o nt ga te s and p ast 1 the secur it y as our tour p rogr essed , you know , 1 th rou gh o ut the plan t safety was paramount. W heth er 2 y ou were having e xpl ained w hat th e di fferent co lo rs are on the di ffere nt pa ne ls and what t he y me an to 2 di fferent fa il safes, why you walk ce r tai n areas 2 certain ways a nd what li nes you ha d to stand beh ind , you kn ow , safety was paramount with them. You know , 2 from the e nv ironment, I'm loo king aro und and t his (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 17-1-SR I Cont'd Appendix A A-96 1 35 plac e is spotless. And I asked why and it's because t hey can't af for d to have dir t or lin t or fuzz ba lls around be cause of static e lectricity because it could crea te issues. So f ro m that aspect I thought it was a good to ur and it made me feel good ab o ut the safety aspects there. To fin i sh o ur tour we ended up in t he c on t rol r oo m upsta i rs. And I'd say maybe a dozen or so i nd i viduals up there m onito ring you know every thi ng go i ng on w it h in the plant and around t he pl an t. And again, e xplai ning the fa ilsafes and why they' re 1 ,...1-,J?'--1--s=-=R=--""1 It Cont'd double-, tr iple-chec k ed to e lim i nate hu ma n error. was j ust ve ry i mpr e ssive and as an el ected official to go down and t ake a t our of the pl ant and u nd erstand how it opera t es. I k now when I left I personal ly know how to issue a c onc e rn with the ge n erati ng stat i on. I know I fe lt a l ot better and a l ot safer go i ng home that night. And it was al so good to rea l ize , you know , as one of our region's largest emplo yers now th at they are w il l ing to give b ac k to the community and keep sa fety fir st. So th ank yo u, I just wan te d to mak e those comments. Dan iel? (202) 234-4433 (Applause) F ACILITATOR BARKLEY: T hank you, Je ff. NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.nealrgr o ss.com Appendix A A-97 1 36 MR. LU DE W IG: I 'm Dan Lu d ew ig. Just tw o q ues t ions. On e wo uld be what are we go i ng to do with lr.:':-:--::::-:-:-:"1 , 1 18-1-RW 1 th e 20 years of sp ent ro ds a nd how are y ou goi ng to ta k: e care ot th ose. And seco ndly, lt we don t get th e lice nse w hich I d oubt bu t what wo ul d --how wo uld we ge t el e ctric if t he l icense were c anceled? I don't kn ow who an sw e rs t his. FA C ILITATOR B ARKL EY: I'll ask Li sa to sp eak. MS. RE GNER: Y es , the sp en t fuel ro ds. Limeric k is l ice ns ed for an in d ividu al s pent fuel pool fac i lity. T hey o ff l oad t he spent fuel. Once they've c oo led to a c ertain l evel they w ill p ut t ho se into dry cas k storage and s to re tho se onsite. In the envir on me n ta l review that's loo ke d at g en e ri ca lly. Li me rick do es have st or age f or th e spent fuel ro ds. That's an o ng oing, it's o nsi te and p ar t of their r eactor oversig ht pr oc ess as well. So t he residen ts that work at t he p lant m on ito r the safe operat ion of th ose fac il it i es. T he sec ond q uestion, where wou ld th e po we r come f rom if Li me ri ck were s hut d own? T here are al ter n ate p ower facilit i es in the ar ea. Dave, y ou want to gi ve th at a t ry? MR. WRONA: I'm Da vid Wrona, a br a nch (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 18-2-0S I Appendix A A-98 38 1 Can everyone hear me in the back r ow? I am Cather in e Al li son and I w as born an d raise d in this area so as far as t he NRC w anting to kn ow h ow this impacts t he area I k no w it very well. I've also tr ave l ed t he w orld so , Europe , et ce t era. So did an yo ne no t be able to hear me, just rai se your ha nd. You're good? Okay. One th ing I wanted to sa y is the N RC t on i gh t is do ing a sc o ping basicall y for e nv ir o nmental 1 pu rp o ses for t he re-li ce nsing. W hat I w anted to say is for years eve ryone, I'm bein g general h ere , bu t 1 mo st pe op le have bee n tal kin g ab o ut the effects of 1 li ke , you kn ow, c ancer , yo u kn ow, the im pact on the clean air, c le an w ater w hich thi n gs we are al l 1 c on ce rne d ab o ut a nd a lo t of us jus t didn't do 1 anyth i ng about it even tho u gh we were very co ncerned. Now l at ely wi th the --u nf o rtunately it's 1 a reality now th at we have h urrica n es, m or e to r nadoes , 1 tsu nami s throug h out the world. And I hate to say it 2 bu t it is a reality now th at we h ave ter rorist at t acks and Lim er i ck is d efinite ly one. I don't wan t to be 2 bl owing t hi s out of proportion bu t it's just something 2 that I know t hat we've all been c on cer n ed about , not wanting to say yes , Li mer ick , an d al l the peop le that 2 bui lt th e power p lant and the company say oh, there's (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com lr-=1..,.-=-:--. 19-1-PA I Appendix A A-99 39 1 no impact to the ai r and th e wat er pollution an d so f orth. So we've kind of j ust b linde d our , yo u know , selves to that a nd let's bel ieve t hen, ok ay, let's 19-1-PA Cont'd ake a minute. L et's r eally be li eve that t here is no mpact in ou r cle an air, c lean wa t er a nd th ose type of hi ngs and ca n cer, et ce t era. Let's j ust go in to t he n ew rea l ity which is terrorist at tac ks which would h appen. Let's ju st say f or examp le ther e was hu man e rr or t here wi th the spe nt fuel r ods and s om ethin g h appened, or a rad iati on l eak. I j ust dr ov e toni gh t rom K ing of P russia. Talk ab o ut evacua tion when hese n atural disas t ers and realities hit us. One a cc i de n t, t wo hour backup, a lmo st no exaggerati on , on e housa nd cars. The re wi ll be no eva cuation. I don't want to be l ik e scare tactics he re but li ke I s aid , he wea ther and so f orth, na tu r al di sast ers h as r eally bee n hi tt i ng th e whole Unit ed St ates and the world ately so it's a reality. Ther e was floo d ing after th e hurricane h at we just had. Five d ays later there was roads l ase d in P ottstown, in No rth C oventry, E ast C oventry. There were , when I t ried to get ho me f rom work r ig ht Jn R oute 724, no ex aggeration again from all the back oads about 500 cars. Th ere wi ll be no evacuat ion and certainlv hope t hat p eop le understand I'm no t trvinq (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 19-2-0S I I Appendix A A-100 1 40 to be scare tactics. I see t his. I'm sure a l ot of y ou have seen this and been in th ese situations. All with a l it tle bit of flooding. What t his do es to the Cont'd r oads. Aoain there will be no evac u at ion. So from day one I thi nk power plants never s ho uld h ave b een built but n ow that they are 19-3-0R I here why i-"T"--...1 would we ever want to re-license. And as o ur gen t le man ca lle r just said, I believe his nam e was T homas , he w as very el oq uent. He was stating the fac t why are we re-li c ensi ng t hem , wha t, 12 years ahead of t ime. To me that is absurd. Like maybe a year bef o re or they h ave to do s om e studies, t wo years before. Why do they and l ove T homas's words , r'-:-: ,..._:-:--=-* 19-4-LR I I wan t us , rubber-stamp something? Twel ve years before h and to go into what , 2024 for Unit 1 was it and 2029 for U nit 2? Wh y do they need to push t his licens i ng re new al? You've got to stop and t hink. People, go home , think about that. I'm not an expert l ike evidently our ca l le r Tho mas was b ut again, I'm concerned a bout hu man l ife. This is what I have at the top here. We are alk ing abo ut human li fe. W hat's more im portant , not all this e le ctricity that we need for all our cell ph ones a nd everything. In a wa y we are responsible 19-5-0SI -For the fact that PECO an d all these other Exelon ompa nies are build ing power plants. (202) 234-4433 "* U"U;;);;) COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 I myse lf yo u WW'W.nealrgross.com Appendix A A-101 41 1 Know am gu1 1t y ot a lot ot tn1s bu t let s JUSt m aybe for a solution besides the wi nd and solar power and everything st op using all t his new techno logy. Yes , 4 you need it for some jobs and businesses , it's good for c er tai n thi n gs , bu t let's not overi nd ul ge where we E need so muc h elec tr icity that we are willing to risk 7 our lives. Cancer , poll u ted water. There's no dr i nk i ng wate r anym ore. People have to pay to buy c wa ter t hat co mes from natu ral s prings. But you're 1C us i ng pl astic bo t tl es , you c an't even trust t ha t. 11 But this whole world h as kind of jus t 1;; cha ng ed f rom you know nature. Let's ge t back to L' na t ure, let the --i nst ead of ha ving all th e young 14 t ee n agers on their ce ll ph ones t ext i ng , us i ng more 1" electric ity, t hat again it's going to cause cancer for lE them. Everyb od y has to st op and think why do we need 17 the power pl ants? We real ly don't and again, T hom as , 1c our wonderful cal l er menti o ned some al ter natives like 1 S the solar power , wind , but I'm just saying we are 2C usi ng so mu ch electricity and stupid little video 21 games on th e co m puters. P eople get on the co mpute rs 2.c for hours at a time doing nons ense. That's taking up 2 electricity where agai n why do you need a ll this 1 19-5-0S I I Cont'd I 24 cancer in your I no t th at electric ity? It could be causing 2:' c hild ren. (202) 234-4433 I am not that old but I'm NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-102 1 1 1 1 1 1 1 2 2 2 42 1 but I h ate to tell y ou I have so many frien ds a nd co workers and peop le that are only 35 , 40 , 50 years old , cancer. And why? We hav e to stop and think. Go ho me , don't j ust always , you know , ju st go watch TV and get on your comp uter. do i ng to ourselves, o ur grandchi l dren. Stop and think what we're Cont'd bodies , our children , our This is again, th is li censing renewal is com i ng down to human lives , the quality of our li ves. Again , why all t his can cer? Mi crowaves and electr i city. So I won't go on and on , but I jus t thi nk us as a group can't just all be ju st compla i nin g about the power co m panies , we are the o nes using t he electric i ty. T hat's all I'm saying. Maybe we should cut bac k and we won't need power p lants. Thank you. (Appla use) FACILITATOR BARKLEY: T ha nk you , Cat h erine. The next three pe ople I'd l ike to call would be Jeffrey N orton of the P. Energy Al li ance , then Bi ll Mag uire and then fi na lly Lorr a in e Ruppe. M r. Norton? MR. NORTON: Good evening. My name is J eff rey N orton and I'm h ere to represent the P enns ylv ani a Energy Al liance which is an i ndep en dent 2 grassroo ts diverse organization made up of community (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-103 43 1 leaders a nd orga ni zations who pr omote nuclear power as a cl ean , safe , reliable an d af f ordab le source of p ower. I'm go i ng to be ma king essent ially five po int s in su ppo rt of l ic e ns e renewal for L imer ick Generating Sta t ions and they are that , nu mb er one, nu clear e nergy low ers el ec t ricity pri ces, it prot ects our en v ironmen t agains t greenhouse gases, it strengt h en s our l ocal econom i es and it is safe. With regard to my first poi nt in lower in g ele c tricity pr ic es the Lim erick Gener ati ng St ation has redu ce d wholesale energy co sts in P ennsylv ania by $880 mi ll ion in 2 010 thus lo wering ele c tric it y pric es for all c on sume rs. It o perates aro u nd the clo ck the re by stabi lizi ng the n ation's elec tric ity dist rib ut i on system and t he electr ic ity ma rketpla ce. The aver age electricity pro d uct i on cost s at nuc le ar pl ant s have actua ll y decli ne d more than 30 pe rc e nt in the past 10 years due to vario us eff i cie n cies. Nucl ear p owe r is c heaper to pro du ce tha n oth er f orms of el ectrici ty generation such as coa l an d natural gas , an d helps m ode r ate t he pr i ce of el ectricity for cons u mers. My nex t po i nt is that L imer i ck Genera t ing Station and nuc l ear plants strengt h en our local economies an d it is a valuab le economic dr iver f or the Com m onwea lth of Pen n sy l va nia. Limeric k Generating (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 20-1-SR I Appendix A A-104 44 1 Station contri but es $113 mill ion an nua l ly in direct econom ic contributions to the Pen n syl v ania economy thr ough v arious em ployee wages and salaries , purchase of goods and services fro m other Pennsylvania businesses and in proper ty tax payments to the l ocal governme nts. Li m er i ck Generat in g Station also contributes generously as we've also heard and in fact 1 t emporary contrac t employees during a nnu al refuel i ng 1 o uta ges. A si gn ifi ca nt percen t age of the cu r ren t 1 n uclear p lant workforce wi ll reach retire m ent age in t he nex t 10 years cre a ting a deman d for high-paying 1 jobs in the nuc lear industry. Yes , Lime r ic k 1 Generating Stat i on is one of Pennsy l van ia's mos t valuable e conom ic and energy assets and the 1 com m onwea lth should embrace it. 1 My third point is that nu clear ener gy 2 protects our env ir onment from greenhouse gases and r educes the need to generate el ectrici ty from fossil 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 na tion's largest source of (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-105 1 45 carbon-free electricity a nd is critica l to our nation's en vi ro n mental , secu rity an d energ y goals. My next poi nt is that n uclear ener gy is safe. It's a lw a ys on , it's stable , it's a re li a bl e source of elec tr icity a nd t he sta tion here at Li m erick h as been b ui lt wi th multi ple red un da nt safe ty l ayers. And t he workforce is committed to b es t prac tices and c on tin uo us i mproveme nt. It is a lso impo rtant f or our nation's qu est to be en ergy-independ e nt. According to t he Bureau of Labor St atis t ics it's safer to work at a nuc lear plant tha n in industries suc h as ma nu facturi ng , rea l estate and fi n ance. And ac c ordi ng to the Department of Energy a p ers on receiv es mo re radiation exp o sure fl yi ng from Balt im ore to Los Angeles t ha n by st an ding near a nuc l ear p lant 24 ho urs for a ye ar. On a pe r sonal no te I've been i ns ide Li merick G enerating St a tion s everal times. I've als o live d within 30 mi les with my f our boys and w if e next to the Li meric k Generatin g St ation and al so T hree M ile Is l and. I feel sa fe , sec u re and co m fort a ble. That is w hy I'm in su pp o rt of th e re-lic ensi ng of the Lim erick Generating Station. Th ank yo u very much. (Appla use) FACILITA TOR BA R KLEY: Tha nk you. Mr. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 20-1-SR I Cont;'d Appendix A A-106 54 1 th ree people I'll cal l are Donna Cuth b ert , fo l lowe d by M ik e Galla g her an d then f ollowe d by Dr. Fre d Winter. Okay , Do n na. MS. CUTHBERT: You k now , after hear i ng some of th ese ge nt lemen speak to ni ght I f eel like I'm livi ng in f antasy la nd. For someb ody to get up h ere a nd ac tu ally say t hat th ere's no a dv erse im pacts f ro m Li mer i ck n uclea r power pl ant is in sanity. It is u nbe lievable. I have s pent the last 11 y ears 1 r eviewi ng pe r mits from Lim erick nu cl ear p owe r pla n t. They are a ma jor air polluter under the C lean Air Ac t 1 and to s ay th ey're no t do i ng it anymore, they just 1 a ske d for the conditi ons th at would all ow an eight fold inc re ase in dang e rous air po llution that ac t ua lly is 1 cla im ed to kill peo ple , thousa nds of deaths pe r year. 1 And t hey asked f or an ei gh t fo ld i ncrease. As a matter of f act , th e se are a ll the air 1 pol lut i on so u rces and the poll u tants they li st in 1 their own permit. If you ad d that to all t he 2 rad i ation emiss i ons there's a b road range of r adion uc li des. F or somebody to ju st cl aim that it's 2 only tr i tium going into the water is in sanity. It's 2 unbelievable what they ex p ect people to b elieve. I encourage everybod y to go bac k to the table we have 2 and take a good lo ok at that Sch u yl kil l Ri ver board. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 1-22-AM I Appendix A A-107 1 55 They are d estroyi ng the Schuy l kill Ri ver. There was never eno u gh water in th e Schu yl kill River to susta in this n uclear p lan t from th e very beginning a nd now we're seeing th e consequences of that a nd they put m ore and more p ol l ut i on in it. They wa nt to pump m in e water in to supplem ent t he fl ow f or Li m er i ck. I t's co ntam i nated and they d on't f ilte r it. And t hey're act u ally asking for a huge, f our ti mes Safe Dr i nk i ng Wa t er sta nd a rd inc re ase in to tal diss ol ved so lids whi ch carry a l ot of toxic po ll ut a nts. So t hey pu t radia tion into the ri ver 24 hours a day , 365 days a year , and now th ey're ask i ng for these hu ge i ncr eases and pe op le have the nerve to ge t up here and say tha t t hey h ave no env ir o nm e nt al im pacts. Fr ankly I've had enough of t hi s deception at the expense of pub l ic .l T The facts sh ow, w he n we lo oked at Ex elon's thi ng for env i ronment al ha rm s they say th ey were clean ene r gy. The facts s how Li m erick isn't c le an , it is il thy. It's not s afe , it's a ticking tim e bomb. And n uc l ear power , they say it's al ways on. Th at's not ru e eit her as evi d enced by shutdo wns , some fo r lo ng p eriods ca u sed by eart h quakes, t orn adoes, h urricanes , -F i res, h ea t an d drou gh t and more. It clearl y isn't always on in Japan. So when you t ake all of th is (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 1-23-SW I 1-24-PA I Appendix A A-108 56 1 toge th er and you look at all the ways tha t they po llute o ur environment with radiation and all the other toxics , every day Limerick operates o ur children face more risk. And that's what it's all about. It's about the health of o ur region. The sooner th is place closes the bet t er o ff we'll all be. Even if you l oo k at i nfant m or t al it y rates we have higher in f ant m or tal i ty ra t es and neonatal mortality rates far above st ate averages and even above Ph i ladelphia and Reading , and we've had t hese for qu i te awhi le. The fac t is when babies are r-:1--'-2':c5::-_-:-H:-:-H.,-,I t he m ost vulnerable in t he womb what el se would we expect? And by t he way , fo r those of you who have bee n say i ng th at ACE data is anecdotal t oda y I have news for you. T his infa nt m or tali ty report for example is state data reported by EPA in 2003. Every cancer statist ic that you see back there is based on Pe nnsy lva n ia Cancer Regis try s tatistics or CDC statistics. So it is not anecdotal , those are the cancer increases , those are the cancer above the nat i onal average that have ha ppened here si nce Limerick started operating. That is a fact. So it's not anecdotal and the fact of the m atter is I thought this was about the environment but apparently it's abo ut money. So I decided that (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-109 57 1 b etween the sessi o ns I was go i ng to cha nge th ing s around a l it t le bit. I could ta lk about t he envi ron m ental im pac ts of th is place f or a wh ole week it's so bad. And I've got all the d ocu m ents in our o ffic e to prove it. Let's ta lk abo ut, l et's t ake a mi nute now thou gh and we're go i ng to talk ab out t he co st. What is this p la ce ac t ua lly co st ing u s? Let's just think ab out c an cer f or examp le. We h ave so many can cers ab ove t he n ati o nal average. C hi ld hood can cer, 92.5 per c ent higher than t he natio nal average. T hi nk a bout that. We track the co st of on e child w it h 1-26-HH I c an ce r diagno sed at s ix mo nths to t wo years a nd up until t ha t time it w as $2.2 mi ll ion. H ow m an y mo re ki ds have that a bov e th e na t ional avera ge? Cost tha t o ut and how many oth er canc ers are ab ove the na ti onal av era ge? You do the math. Fig ure that out. H ow about th e custom e rs that pa id I hea r them t alk abo ut how g reat th e costs are for L imerick. We pa id f or L im erick from 1 985 to 20 10 in 1-21-os 1 our electric bi lls. And in f act the el ectric that w as s up po s ed to be too ch eap to meter turned o ut to be 55 p ercen t above the national average by 1 997. So that's h ow ch eap L imerick electric is. T he n you take the property t axes. T he y tried to ge t zero f or th eir p roperty tax es by the end (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 1-28-SE I Appendix A A-110 58 1 of the '90s a nd di dn't pa y any pr opert y taxes until th e ea rly 2000s at w hich tim e they paid $3 million 1-28-S E I inst ead of th e $17 million th ey were supposed to pay. Con'W So when you think about that no wonde r Exelon's wi ll ing to th row aro und a couple mi l lion in t he com m unity. T hey owe this community a l ot m or e than w hat t hev're aiv ina out. (A pplause) MS. RUPPE: So t hen t here's t he cost for t he pol luti on t hey're putti ng in the river. They're ask i ng for i ncrea ses in po llu tion. T hey want to pu t m ore mine water in. T hey want to i ncr ease the total disso lved sa l ts. Tha t's going to co st wa ter t reat m en t a lot of mo ney to try to f or ext ra .....,_......, ,.......,,..,...,..,., 4-1 0-S W I systems trea tment f or that. It can even break down their e quipm ent, some of the stuff that's coming o ut of t he mi n es. A nd when you think ab o ut it who ac tually ultimately pays th at cost? We do. We pay for increased cos ts f or ou r wa t er be cause t hey're having to do that at the wat er treat m ent s yste ms. And it seems to me that if yo u rea ll y take a good l ook at thi ngs L im er ick has g ot to be the maj or cause for t he radiation in Ph ila d elp hia's water. So all in all taken as a whole t hi s plac e h as unp rece de n ted e nv ir onm e nt al h arms. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 The re is no WW'W.nealrgross.com Appendix A A-111 59 1 question ab out that. Anybody th at doesn't believe it co me look at the permits with me and I'll show you exactly what's going on. I i nv i te anybody to do that. And t he one thi ng t hat's rea lly im po r tan t is that NRC and the nu clear in dus try are clai m ing tha t 4-11-08 1 age is no i ssue wh i le at t he same t ime t hey admit tha t some part s are too b ig and too expe nsive to replace. I f ra nk ly am real ly conce rned abou t NRC acco mm o dat i ng th e nu cle ar i ndu stry with w ea k ened reg ul ati o ns , la x 1 e nf o rceme n t, negl igen ce a nd unsubsta n tiated den ials. 4-12-08 1 It's hap pene d right h ere ev en wi th th eir fire sa fety 1 r egula t ions th at are --we're on w eake ne d fire safety 1 reg ula t ion s eve n th ough we k now t hat that can eve nt ually lead to a m elt down. I know my time's up. 1 Th ank yo u. 1 (Appla use) FACILITATOR BARKLEY: Thank yo u, Do nna. 1 M ik e? 1 MR. GAL LAG H ER: Okay , good evening. My 2 name's Mike Gallagher and I'm vice presi d ent of license r enewal f or E xe lon. I have the overall 2 r esponsib il i ty f or t he L ime rick li cense renewal 2 application. Exelo n has a great d ea l of experience in li cense r enewal. We've obtained re n ewed licen ses for 2 th e Peac h Bottom and TMI pl ants in Pennsylvania , al so (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-112 68 1 FACILITA T OR BARKLEY: We have an in spec t ion ongoing at that point rig ht now regar di ng th e Nor th Anna facil ity. So yes, it d id experience an earth q uake b eyond it s origi nal design. So far t he in spec t ions have revea l ed no --minim al da m age. I've o nl y heard of one pi ece of eq uipme nt that experien ced even visible signs of problems. But the over a ll analy sis , th is is cont inui ng a nd t he li ce n see h as to have pe rm ission fro m us to r esta rt af ter an exten si ve 1 i nspect ion. MR. ELY: My conc e rn is t hat t hi s ha st ened 1 li cense renewal proc ess is in appr op r iate for 1 engin eeri ng reas on s. I work ed in a var iet y of differe nt ar eas in the co nstruct ion of t hat p ower 1 plant and t here we re contin ua l dev i at i on s that w ere 1 provid ed , wh et her it was in-stora ge maint en a nce m on i toring of the conditi on of t he co m ponen ts tha t 1 were us ed to the act ua l constr u ct i on of that p lant. I 1 could cite you several exam pl es. 2 What I wo u ld l ike to as k of the pu b lic is that the pe op le that had w or ked at t hat nuc lea r po we r 2 p lant take a look at this l icensing renewal and 2 understand th at they need to review those fail u res and those dev i ations that were provide d to go ah ead with 2 th e construction of t hat pla nt w ith non-co n forma nc es (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 21-1-0S I Appendix A A-113 69 1 th at were reviewed, but not reviewed in light of wha t we understand an d kn ow today about earthquakes or other ano m alies. We need to have enoug h time to make th e eval uati on on th ose deviati ons. The cooling pools. The fue l pool girders th at are placed th ere. T here are rebar concrete reinforce d supports where a q uality engineer , he was supposed to be accepting t he very highes t grade of concrete to be placed in a 36-hour pour there and he didn't pay attention. And t he 1 cofferdam wa s bei ng bu i lt down in t he river and up come s this sand mix with a very low st rength and gets 1 pum ped up into those fuel pool gi rde rs in a l ayer a nd 1 t he e ngin ee r said we ll, b oy, t hat was a t err i ble mi stake , but it' 11 be okay. We need to go back and 1 t ake a look at all of th o se m is t akes and make sure 1 t hat they're no t writ t en off because a la yer in a structure un der load ca u sed by an earthquake , that's 1 an issue. It m ight not be an issue for the strength 1 of the fue l pool girders to suppor t those fuel pools 2 that when we see them in Japan and they catch fire b ecause t hey're ex tremely hot and you nee d to ad dress 2 that. I was on that po ur but I wasn't the engineer 2 that made th at error , but th ere's a number of e rro rs that were made. And I don't see or un d ersta nd that 2 th e NRC or th e review or the licensing application is (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 21-1-0S I Cont'd Appendix A A-114 70 1 t aking a look at those failures and those errors a nd 21-1-0S I addressing them in light of the k nowledge that we have Cont'd t oday. Some people don't und erstand abou t radiation and I read when the Japa n ese thing occurred and I heard on the n ews a radiologist t alking abou t oh, the radiation is s uch a low amount. It rea lly isn't the l ow amount of rad i ation exposure that we ge t inci den tally in stand ing nex t to a nuc lea r power plant. It's three t en-t h ou sa ndths of a gram of pluton i um that is death f or you if you breathe tha t dust p artic le. It's almost certain death. And t he problem becomes yo u can't hav e --and it's not go i ng to be a nuc lear bo mb. It's go i ng to ca t ch on fire if the f uel pool girders were to fail and you'll have a cloud of a material that in and of it self you might not have radiation exposure to it bu t that particle when it deposits i tself can be an issue much the same as fl uoride is what causes thyroid cancer when it's a radioactive fluoride. That's why we're very careful in b ui ld i ng a pl ant wi th no Teflon and no fl uor id e components. So we need to pay attention to some of that engineering and I'm not certain that that's being done. (202) 234-4433 I'd like to see an agency or for somebody to NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 21-2-HH I Appendix A A-115 1 1 1 1 1 1 1 2 2 2 71 1 contact me if th ey know abo ut a variety of di ff ere nt flaws that they saw during the construction. A nd my email ad dress is asqc h air@ya hoo.com. Yes, I wil l be th e chair of the Philadelphia section of th e Ame ri can Society f or Quality coming up and I've been past chair in t he past so yes, I'm very quality-orie nt ed and I'd apprec i ate any f eedback f ro m peop le that have is sues w ith t hat const r uction. Th an k you. (App lause) FACILITATOR BARK LEY: Okay. Th ank you , Dan. Jim Bec k erm an? MR. B EC KE RMAN: Good even i ng. My name is Jay Beckerman. I'm a resi den t of Pho eni xville. I found out abo ut this m eet ing because I s can a l ot of news pap er w ebs ites. I found t he not i ce of the m eeting on t he West Chester Da ily Loca l we bsite. Didn't 22-1-LR I it in the Ph oenixvi ll e paper, di dn't see it in the Philad elphia newsp a per , didn't hear about it on any of the loca l radio stati ons , didn't hear ab ou t it on cable, di dn't hear about it on any of the te levision. O nce a month , what is it the f ir st T uesday about 2: 00 I hear the siren th at we all hear. What should happen in terms of people ge tt ing notice is everybod y who's wit hin the pl ume a re a shoul d something 2 happen at Li meri ck shoul d find out about th is meeting (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-116 72 1 and I seriously doubt that th at actually h appened. I thi nk it was pure accide nt that I fo und it. S ome thing as serious as license renewal sh oul d get th e same kind of o utreach th at occu rs when L im erick does what it sh ould w hich is to mail ou t every year or t wo to all of t he possibly affected h omes the m aps and t he no tifi catio ns of how do y ou ev a cuate. If you're go in g to renew a pla nt w hich happens once every 20 years I don't u nderstand why the NRC do esn't requ i re the same 1 ki nd of out reach p ub l ic notifi ca ti on so people get a chance to come to o ne-time m ee t ings li ke th is. I 1 thi nk that is a basic fl aw in t he N RC's li censing a nd 1 re-lice n si ng procedure and I think it should address t hat. 1 The slide behind me document s exactly t wo 1 li braries that the docume nt s are go i ng to go in. Why not in my li brary in Phoen ixville? Why n ot in 1 Montgomery County and No rris t own and a ll of the oth er 1 public librar ies that are in a reas that can be 2 affected by the plum e should something happe n here? Why are the docu me n ts in such a r estr i cted ar ea? 2 I'd like to switch a l ittle bit. I've 2 b een researching, I didn't e ven k no w about th is ACE o rgani zation. Glad to find it. I've b een researching 2 on my own information about nuclear po wer plants and (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 22-2-LR I 22-3-LR I Appendix A A-117 1 73 th eir risks for quite awhile. An organization I ran across publis he d this b ook t it led Insurm ounta ble R isks. T he organization is ca lled t he In sti t ute for En ergy and Environmental R esearch. It's an am az ingly well-resea rched book. I do ubt very many peop le h ave r ea d it but you should. This organization is at l ea st as in t erested in al terna t ive e nergy s ources as it is in h av i ng pu t the ef fort in to d oc umen t what are t he problems w ith nuclear p ow er engineer i ng-wise. The man who's head of this o rgan ization is a nu clear sc i en ti st, a g uy named Arjun M akhi j ani. He's a PhD nuc lear sc ient ist. T he se are f irst-class resear chers , this is PhD-l ev el stuff writ ten for po pular c on sump tion. So I '11 be glad to m ake mo re detai l about t he book avai l ab le to anybody who wants to know. A few q ues tions I have, o ne t hat I've been thi nk i ng about for a l ong t ime. I wo nder how m any peop le here are aware of somet hing called t he P rice Anderson Nu clea r Indust ries Indem n ity Act. Wh o knows ab out that? T he title alone sho ul d giv e you some p ause. Why do we need a n uc l ear i ndust r ies i ndemn i ty act? What d oes it do? What it does is it pu ts a ceili ng of a few h un dr ed m illion dollars on the liab ilit y that nu clear power plant owners h ave f or the d amage t heir p lan ts wo uld ca use. It's basically a (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 22-4-0S I Appendix A A-118 1 74 s cne me , u1ey pay ln LO a poo.L. T ile prou.Lem lS Li laL ce il i ng was set a v er y lo ng time ago. It's tot a lly unrealistic in terms of th e risk in just the value of 22-4-0S I Cont'd h ouses in ar eas that are covere d by a p lan t lik e this. When th is plant was plan n ed the pop ulation in th e area that its plume would cover probably wasn't 20 percen t of what the p op ulation is now. Th at is I thi nk a va l id env ironmen t al concern. The environmen t in which this pl a nt opera t es h as cha n ged be c ause of in-migration, popula t ion i ncrease for all sorts of reas ons. Par t of that's been discussed ton i ght in 22-5-0S I t erms of evacua tion rou t es , would you be able to ge t people ou t were there an accide nt. The roads haven't changed very mu ch , the po pulat i on h as. T hat I thi nk is a valid e nv ironmental co ncern t hat surely ought to be addressed. The qu estion I ask abou t th e money lia bility is let's jus t go bac k to the P rice A nderson Act. The fact is t hat the n uc lea r in du s try d oes not pay m arket rates for ins ur ance to cover it for the l iabiliti es. This congress i onal a ct fr om way 22-6-0S I b ack in th e 1960s el i mi n ates th at need. Back then t he insurance i nd u stry didn't have the research to put a pri ce on what shou ld the L imericks of the world hav e to pay for a lia bility po licy. I t hink th ere's plenty (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-1 19 1 I of insurance ind us try experience now. So my quest i on would be if n uc lear plants are so safe why do we n eed th e Pr ic e Anderson Act? (Applause) MR. BECKERMAN: I l isten ed, I'm going to sw itch subjects aga in. I l is t ened to Mr. Gallagher and I h eard som ethi ng I really didn't e xpect to hear. He said t ha t th eir stu di es said t hat t his plant is now safe to run for 60 years. Th at s ounds to me like advanced no t ice to the public t hat t his isn't t he first renewal they're go i ng to ask for on this plan t. Mr. Gall ag her, are you go i ng to ask f or another one 20 years fr om n ow? FACILITATOR B ARK L EY: We ha ven't had any licen see at this point in t ime ask f or s om ethin g bey on d th at. MR. B ECKERMAN: You didn't make the statement. Mr. Ga l lagher did. FACILITA TOR BARKLEY: I know and I'm not going to have him add r ess th is fr om the au di e nce. This is a meeting wi th us. MR. BECKERMAN: And I would l ike to finally address an issue th at the speaker on the cell ph one b ro ug ht up. He tal k ed about embri ttlement of concrete ov er t he life t ime so f ar of the nuclear (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com Con t'd I 22-7-0S I Appendix A A-120 1 1 1 1 1 1 1 1 2 2 2 76 r eactor c on tai n me nt vessel. T hat's an in t er n al env ir on m ental m at t er. I d on't kn ow if it's q uite in the scope of what the NRC pla ns to talk abo ut or plans to l ook at, b ut some thing that I have not r ead abou t at all is an N RC requ ir ement f or d estruct ive t es ting. For inst ance, if you want to kn ow w hat a tr ee l ooks like on the ins ide you p ut a borehole in it and y ou pull a co re samp le out a nd you fi nd out what that tree look s like on th e insid e. If an engi neer wa n ts to k now w hat is t he q ua lity of the c on crete that was pou red for a ro ad --I used to work for Flori da De partm e nt of T ra nsport ation they bo re out a sa m ple nd th en you t ake a look at it. W hat I h aven't h ear d n ythi ng about e xcept gene ral iza ti ons is h as an y bo dy any des truct i ve even b or ehole t esting of these on tainm ent v esse ls and t heir su pport pouri ngs to fi nd 22-7-0S I Con'td p ut has th ere been in fact any dete rio r at i on of the 22-8-0S I oncrete, the re ba r and an y th ing el se t hat went in here. T he stuff that's buried in the concrete, t he lv i re , all of th ose thi n gs that are buried in the oncrete. If you haven't bo ther ed to open th at st u ff si nce th e plant was bui lt h ow on earth do you k now lv hat cond i tion it's in? S hou l dn't that be a equire m ent to do some d est ru ct i ve , open the botto m 2 esti ng , go all the way th ro ugh an d make sure wha t yo u (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-121 1 1 1 1 1 1 1 2 2 2 77 1 thi nk is there is w hat's t he re and in the condit i on th at it years? should be in to l ast f or another 20 or 40 22-a-osl Cont'd So t hese are qu es t ion s that I'd li ke t he N RC to go in to. I tha nk y ou very m uch f or list en ing. Overall it's been a very in forma ti ve presentation by both t he pr oponent s and people who have ques ti ons and I th ank you for th e opportu nity. I w ould li ke to s ee a m ee ting li ke this occu r at a big ger venue with more no tice. An example would be , as I've di s cu ssed w it h Ms. Regner is it? FACILITATOR B AR K LEY: R egner, y es. MR. BECK E RMAN: I didn't have h er na me c or rec t. The Phil ade l phia Ex po Cen t er wo ul d be mo re central to where the p lume area for this p lant is. It 1 s ri ght off 422. Th is is not h ard to get to, t hat's no t hard to get to. It's mu ch mo re in t he center of the pop u la ti on. T hank you v ery much. (Appl a us e) FACILITATOR BARKLEY: O kay , thank you. Mr. Cu th b er t? Again, fol l owing Mr. Cuthbert's re m arks it'll be Jim De rr to wr ap up the even i ng. DR. CUTH BERT: Goo d eve ni ng. My name is Dr. Lewis Cuthbert. I'm the president of ACE, the A lli ance for a Cl ean Envir on m ent. And my com m ents 2 this ev eni ng are going to diff er fro m this after no on (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3 7 01 WW'W.nealrgr o ss.com Appendix A A-122 78 1 b ecause they're go ing to be focusing on as a g eneral to pi c docu me n ted e vid e nce. We've heard a lo t of asser ti o ns , assum pt ions and cl aims thr oug hout the day m any of which would be v ery di ff ic ult to s ubst an tiate in o ur ex p er i ence. Based on an 11-y ear inv es tig ation conducted by t he Al l iance f or a Cl ean E nvir o nment we have fo rm ed a conclusion that we are pr e senting to th e Nuclear Re g ulat ory Co mm i ssion tod ay and t hat is very simp ly that L imerick nuclear power plan t mu st be 1 closed by t he NRC, not re-li censed un ti l 2049. And t hat's based on a su bs tant ial bo dy of evi dence in 1 t er ms of do cumen t ed en viron m ental harms , threats an d 1 risks that have in fact gott en into ou r air, o ur water , our so il , our f ood, o ur milk and o ur ch il dren. 1 The ev i de n ce is not re fu table. 1 So I'll be presenting as part of my remarks ton ig ht wh at I'm calling a short list of 14 1 r easons why the NRC m ay feel free to with m or e than 1 ad equa te j ustif i cation d en y th is permit. And I'm 2 goi ng to categor i ze each of them ve ry br ie fly w ithout any furt her d escrip tion or anal ysis. T he evid en ce 2 comes f rom a variet y of perm its, of ficial rec or ds and 2 repor ts , an d Ex elon's own re n ewal a pplic ati on which is si za bl e by th e ir own admission and in o ur exp erie nce 2 in taking a look at it. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com 1-29-0R I Appendix A A-123 79 1 The 14 i tems a ny of w hich in our j udgme nt sho uld be adequate a nd suff ic ient to d en y thi s permi t enewal i nc lude, nu mb er 1, rad i ation int o air and 1-30-RW I "ater from rout in e and acci d ental e mi ssions. Nu mber 2, major air pol lu ti on un d er h ealth-base d stan d ards of the Cl ea n Air Act. A Tit le 5 permit bei ng issued to 1-31-AM I this facility means by def inition that they are a maj or air po l lu t er un der th e federa l Clean A ir Act. Num be r 3, Schuylk ill River deplet ion a nd ma jo r 1-32-SW I dri nk i ng w ater contam ination. Ke ep in m in d this is a vital drin king wa ter sou rce for n ear ly 2 m illi on people from h ere to Phil a de lp hia. Nu mber 4 radi o active groun dwa t er cont amin ati on. Nu m ber s, 1-33-GW I radlatlon repor tl ng levels lncreased a ramatlCallY after t he Fukushima Japa n disaster. Number 6, 1-34-RW I docu ment ed a la rming canc er increases es pecially in our 1-35-HH I ch il dren since L im erick started op erating. Nu m ber 7, deadly high-level radi oac tive wastes t hat are packed 1-36-RW I in vul nerable fuel po ols on t his site a nd t he y are in fact unp rotected. T he y are abo ve groun d and unpr otected. Nu mbe r 8, lax fire safety r egula tions 1-37-0S I and mult iple vi ola t ions. Number 9, accidents and leaks fro m cor rod ing, d eteriorating e qu ipment p lus 1-38-0S I mil es of b urie d pipes and ca b les. Many prob l ems and sh u tdowns h ave al rea dy occurred at t hi s facil ity in NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WAS HINGTON , D.C. 20005-3 70 1 WW'W.nealrgr o ss.com Appendix A A-124 1 80 1 Cont'd its first 26 years of operation. They are a matter of record. Number 10 , increased risk of meltd ow ns from m ore freq ue nt and stronger earthquakes and ot her 1-39-o8 1 nat u ral disasters such as tornad oes an d fl oods , not to m ention 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 vu l nerab le 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 on a lo t of comments from a lot of ot her analys ts and elected offic ials, the need f or an updated evacuation pla n and i ncreased EPZ , a 10-mile radius. This p lan is seri o us ly o ut dated. It is by many expert's 1-41-08 1 ob servations fatally f law ed. There wi ll be no evacuati on in the event of a w orst case scenario. Several people spoke to that t his eve ning. T he popu l ati on in this area has increased m ore th an 180 percent si nce 1980 to 2010 , U.S. Census da ta. Updates are o bviously needed and they shou ld be reasonable , comprehens i ve , detailed an d accomm odate all of the demographics from 1 985 to to day and from today u nti l as far out as th e NRC is w illing to license this facility. I Nu m ber 13, i nc reased cost to the public. 1-42-08 1 (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. W ASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-125 81 1 We've h eard a littl e bit abo ut this this eve ning, m ore can cers, more illn esses , more eme rgency ro om v isits , more ho spit al izat io n from incr eased PM-10. Ma ssiv e 1 11-42-0S I r esear ch on what part ic ulate matter in te rms of PM-10 II Cont'd does to human b eings. And t here a re a few other thi ng s that co ntribute to those visits. The co sts a re astrono mical. One case that Donna m enti oned, $2. 2 milli on for a ch ildh ood can ce r ca se. You do t he math. And num be r 14 , the last i tem on my list. 1 We h ave had 26 years of in sults to o ur environmen t, and I ch oo se th at wo rd p urp o sely, insu l ts to 1-43-AL I o u r'r-""T""----' 1 env iron ment and costly n uclear po w er. We ca n replace 1 it w it h safe, cl ean, renew able en ergy bef or e 2 029. T hat is a matter of scien tific fact. 1 It is a scien ti fic certai n ty that ha rms, 1 th r eats and risks to o ur en vi ronm en t and to o ur co mmun i ty will increase continuou sly da ily unti l 1 Limerick's curre nt o perating li c enses ex p ir e in 2 029. 1 It w oul d be both unethical and ir re spo n sible for t he 2 NRC to cavalierly a pp rove a licen se renewal w ithout th e most rigo rous r ev i ew and ju sti fi cation in the 2 hist or y of this ag ency. NRC , you have a rare 2 oppor tu nity b efore you that most people and ag encies never are aff o rded. It's ca l led a do-over, a cha n ce 2 to c or rect a l itany of mi st akes and err ors associ a ted (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-126 82 1 w ith t his f aci lit y an d wi th y our agency sin ce 1985. Twent ieth cen t ury technol ogy a nd infrastructur e are no longer sufficien t ly reliable for any of you to assure us th at th ere is nothing to fear a nd no thi ng abou t w hich to be co n cerned. Den ial of d oc umented ev id ence is no longer an o pt ion. We'll be subm it ting ad diti on al packets of research do cum e nt atio n and ev i dence tonight al ong w it h my comments w hich w il l compl iment w hat I did earl i er to day. T he ma jo r 1 ca te gori es th at you'll be get ting f or a dd iti onal r eading an d review, me ltdown th r eats , eva cu ati on 1 plans, Ex el on's inacc u rate a nd un substa n ti ated c lai ms 1 and a criti cism of the NRC's o versig ht t rac k record in this c ommuni ty. Th ank you very mu ch an d please accep t 1 thi s for rev iew. 1 (Appl a us e) FACILI TA TOR BARK LEY: Okay , tha nk you, I 1 w ill. Th an k you. Mr. Derr? 1 MR. DERR: G oo d eve ning. I thou ght I 2 wou ld add some co m me nts just to make s ure my und e rst and ing is t hat this is e ss ent ially the N RC's 2 opportun i ty of liste ni ng f or things specifically to be 2 in clu d ed in the environmen tal site review of the re-li censing. And j ust a few th ings w hich are question 2 m arks th at l ots of f ol ks in t he community I think will (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com Appendix A A-127 83 1 be interested in. Most of these have b een touche d on. Mine wa t er issue, b etter d efinin g tha t qu ality an d fl ow partic ul arly in light of the likely pending ch anges in stormwater concerns and regulations 23-1-8VV I in the area. Ad ding th at f low to the Schuylk il l is go i ng to af fect a ll the munic ip al it ies aro und h ere who have to d eal with stor mwa t er. The emergency plan ning is an area w hi ch needs to be serio usly l oo ked a t. H ard and sof t 1 23-2-08 I i nfras t ru c tu re on t hat. Hopef ully tha t's s omet hi ng which is par t of the on going o pera t ional requ ire ments for pe rio dic revi ew and up date si nc e obvio usly t his is not a static environment we li ve in. Th at h as to be changed on an o ng oi ng basis. And then to --I'm sure hat the generic plan i nc l ude s a pretty good ::l i scussi on of fuel st o rage l ong-te rm and sh ort-te rm ::msite but ce rtain ly the site-spec i fic fu el st or age onsiderat i ons. And I want to sec o nd the comments by Mr. Ely of review of rec ords of non-con f or m ances and anything that was don e is part of the ini tial constructio n record. And basically that's those are the things th at we're go ing to be looking f or a b etter un dersta n di ng of. T ha nk you. (Applause) FACILITA TOR BA RKL EY: I did h ave o ne l ast (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TR A NSCRIBERS 1323 RHODE ISLAND AVE., N.W. WAS HINGTON , D.C. 20005-3701 WW'W.nealrgross.com 23-3-o8 1 23-4-08 1 Appendix A A-128 84 1 req uest for an ind i vid u al to sp eak. Sh e p ro mis es she'll o nly be two m inu tes so we'll have h er up and th en we'll wrap up the m eet i ng. Thank you. MS. CONFER: Hi, my name is Trac i Con f er. I'm with Energy Justice Netw o rk. We su ppor t clean e ner gy w hich we do not be lie ve nucl ear is. I would li ke to put ou r name behind all of Buzz Cu thbert's o mments and I wan t to add t hat I want the NRC to lo ok nt o po te ntial w ater depleti on issues from sh ale gas 1 racki ng upriver in bo th ri vers. I als o think t hat it would be ver y prudent to put a lo t of at t enti on on 1 t error i st attacks on t he fuel po o ls. And th o se are my 1 pr i ma ry c omme nts. Th an k you for yo ur time. (App lause) 1 FA C IL I TA TOR BARK LEY: Okay , t han k you. 1 W ith t hat I'd like to have Lisa Regner com e up for a mi nut e and give clo s ing re m arks. 1 MS. REGNER: I j us t wan ted to real quickly 1 th ank our senior res ident i nsp ector who came out 2 t on i ght out of the goo d ness of her h eart. Sh e do es not get pa id for this. Jo , wo uld you mind sta n din g 2 up? 2 (Applause) MS. REGNER: Than k you. Th is is one of 2 th e NRC inspectors who works at th e plant day in and (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 24-1-SW I 24-2-0S I Appendix A A-129 Mendiola, Doris From: Sent: To:
Subject:
Dear Ms. Regner:
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) 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_ Thank you for arranging the public meetings to discuss this serious matter. I trust you will take my AI ts into consideration and urge Exelon to provide other such forums with widespread notif i cation beforehand so that more interested citizens can participate. Sincerely, Camilla Lange 616 W. Schuylkill Road Apt. 164 Pottstown, PA 19465 camilla nge@verizon. net :*J ' :=1 c ,-! J "' I *. v. "* '-** ) :. c-. **--* *-.. --f" ---.. q :l 9 < 0 0 rn (/) .,!::: = /T'l:;d-f-o3 Appendix A A-130 Mendiola , Doris Fr om: S ent: To: Subjec t: Fo ll ow Up Flag: Fl ag Status: E ric Hamell [stripey7@yahoo .com] Wednesday , September 21 , 2011 7:38AM Regner, Lisa Limerick Fo ll ow up F lagged Please do NOT extend th e Limerick licenses! 126-1-0R I E ric H amel! P hiladelphia, PA /ZF/f. 6-9¥-J f" C0 JJ **-e 1-.-.l . r i* **I o: .-, ... .., .. -.;**: I -" *.) : ! c--:*-:.:: .. ..::. . ---'-j.*._ ;TI 9 CJ < 0 rn (/) ..!:: £-,;L.z::-:Os /9,!).r-7-o3 = 0-t*-) Appendix A A-131 Mendiola, Doris From: Sent: To:
Subject:
Follow Up Flag: Flag Status: steve fu rber [ctevewrx@ ya hoo.com] Tuesday , September 20, 2011 4: 17 PM Regner , Lisa Limera ck Renewal Follow up Flagged /,/ yr/ @ Kenewmg Ltmencl<'s licen se JUSt as controversies are ansmg w1th pushes to move trom dependence on Nuc lear 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 iss u es that may arise.
- I ask th at you please consider the future of our great state. I don't think oi l or nuclear ene r gy is the way. I truly believe in heart , that in order to protect the health of our population for the future, we must c hange our ways today. Sincerely, Steven Furber JJ :_1:1 c: il r-* > ;-q :..g (r) --...: .. ' :."**. r*t **..) .:'1; o-\ --hl ;**n 9 c: --i CJ a (/) .!:::
s = /7 o H-o 6 Appendix A A-132 RUL ES . :.J ;/ iECT IVES PUBLIC SUBMISSION
- 71 c; a= ll7 'i Page I of I As of: September 27 , 2011 Received:
September 22 , 2011 Status: Pending_Post Tracking No. 80f27eee Comments Due: October 28 , 2011 Submission Type: Web Docket: NRC-2011-0166 ,-,,-, * *I .. ,!-0 Notice of Receipt and Availability of Application for Re newal of Limerick Generating Station , Uni ts I and 2 Facility Operating Licen se Comment On: NRC-2 011-0166-0003 Exelon Generation Company, LLC; Notice of Intent to Prepare an Environmental Impact S tat eme nt and Conduct the Scopin g Process for Limerick Generating S ta tion, Units 1 and 2 Document: NRC-2011-0166-DRAFT-0002 Comment on FR Doc# 2011-21921 Submitter Information , 2)::u, J:V /f 7C.r/L 6-5 7-:JF:' Name: Charlene Padwom y Address: Ill 7 Oakdale Dr 0 Pottstown , pennsyvania , 19464-2 7 82 General Comment Thanks so much , Charlene Padworny _£-;/{'_.;::: _})5 =-,& -c:? 3 http s :1/fdms.eru lem ak in g.net/fd m s-web-age n cy I component/con tent s trearn e r?objectld=09 00006480f2 7 ee... 09/27/20 II Appendix A A-133 -*, Unired Scares Nucle<lr Rcguhuory <:nmmi.u inn Proterting People and the Environment LIMERICK GENERATING STATION Environmental Scoping Comments Division of License Renewal NRC-2011-0166 Written Comment Form Must be received on or before October 28, 2011. Please print clearly. Name: SW / U /A Po //, C k_ Title: JP s t d f IJ t J <; 1 (b I) .P tJ t rr.. (' .. .--.......... *n 0 *) ;rt .. ,:;) :*o,) c:.-0 Address: .)3 .£Ate L DR
- __ .. _-;--.._ City: !7-;--;--/
(:) LV b J State: --L B..L.%-'-----Zip Code: Jt/tif 5 .--Use other side if more space is needed. Comment Forms may be mailed to: Chief, Rules , Announcements , and Directives Branch Mail Stop: lWB-05-801 M U.S. Nuclear Regulatory Commission Wash i ngton , DC 20555-0001 5 u .U5J..-/Je-v't /J 3 Appendix A A-134 Gallagher, Carol :.; From: Joe Roberto Uoe@robertoandassociates.com] Wednesday, September 21, 2011 7:20 PM *-r ,J w .*--: Sent: To: Cc: Regner, Lisa ,... ; } , 1
Subject:
Joe Roberto . 1/ LIMERICK
Dear NRC:
First of all, let me ask why the lack of public notice regarding the public hearing to be held for Limerick Licensing Extension when in fact the current permit is through 2024 and Exelon is asking for another 20 year extension? Your first priority is NOT for the publically traded, for profit company to rush to get this public notice "done" as a requirement to extend the permit another 20 years out which is not due to expire for another 10+ years but to rather really so l icit input from the community and folks impacted. The NRC did not do so. There was one article in the local newspapers stat i ng that there would a public session and only saw the actual notice , by virtue of an article in the North Penn Reporter yesterday. This is not proper notice in general and not sure NRC did what is required. What is required and what have you done? And if proper notice was not done, I want another one(s) scheduled please. I, respectfully, am very interested in this answer. FEEL FREE TO READ THE FOLLOWING AT THE PUBLIC HEARING: Now, let's get to the big issue at hand. Limerick should NOT be approved for an extension with their permit for the following reasons:
- 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 J apan-and we see how they failed) and the fact that it si ts on an earthquake fault line.
- Th e NRC JUST a few weeks ago stated that " more informat i on needs to be done and studied" regarding further fortifying nuclear plants regarding earthquakes.
Thus, unti l you folks know exactly what needs to be done , etc. THERE IS NOTHING TO APPROVE as long as Limerick sits in it's current pos i tion.
- Do NOT think that earthquakes only happen on the West Coast-as we JUST had a 6+ earthquake less than a month a o. BY ONLY luck was there no dam a e to the I ant , environment or communit . When Limerick was built, there was no idea that the area would grow in population l ike it has. For safety reasons, just lo ok on any given day the traffic on Route 422-stacked and stuck for miles on end. Route 422 is the #1 route for evacuations and does not handle re ular commuter traffic l et alone entire communities.
- The NRC and USA Government STILL have not decided on where to store spent nuclear rods and as we each spent rod is sitting in baths on the Limerick s it , stacking up-expanding even a greater hazard to the commun i ty, environment, etc. SO put simp ly , there is ABOSLUTELY NO REASON to approve this request for YEARS until the US Government decides how the will handle such rods and such rods and ro erl stored.
- There are many other environmental friendly sources of energy and Limerick as anything but that. As a matter 30-6 fact, Limerick is a TIME BOMB, placed at the wrong location , on the wrong land , too close to majo r popul a tions , -OS run by a for profit company who can not even handle the basic maintenance issues of power lines, in an aged buil
- h n re I 6 o v s .!--13 e.-J/; ur
/hH-013 Appendix A A-135 *
- Let's also mention a fact that Category I Hurricane Irene, which could have been a Category 3, just zip p ed less 30-8-than 100 miles awa y from the site a few weeks ago and then Hurri c ane Lee wh i ch decided to travel further Eas AM came close to also causing chaos. Limerick is still TOO c lose to the disaster of Hurr i canes as well. Lastly, some who have a vested interest in working at the plant, etc. are quick to state that it is safe , etc.
now , nor has it ever been fool proof against disasters , technical glitches , etc. I OS us, ee 1rm y an many m t e commun1 y ee t e ex act same way, a ere IS o approve (especially so far in advance, with no answer on usage rods nor what needs to be done to pr event a meltdown due to a earthquake, etc.) or EVER since the population will only i ncrease and the facility age further. It is the wrong timing , wrong plant, wrong place, etc. for Limerick. Maybe Ex elon can put in as much effort and " energy" to develop so l ar fields, wind, etc ... They would rather beat the hell out of a high efficiency plant at any and al l cost to the en v ironmen t and community. This is where th e NRC does the right thing and says NO unt il a year before it expires. NRC n eed s to take a stand as you have the data and know what I have stated above is more than fair and true. Thank you for your time and attention. Regards , Appendix A A-136 !-C? /d& /?:o /) /"C..r.£ Delaware Tribe Historic Preservation Office 1420 C of E Drive , Suite 190 Emporia , KS 6680 I (620) 340-0111 bobermeyer @delawaretribe.org September 23, 20 II Chief , Rules, Announcements, and Directives Branch Division of Administration Services Office of Administration Mailstop TWB-05-BOJM U.S. Nuclear Regulatory Commission Wa s hington, DC 20555 Re: Request for scoping comments concerning the Limerick Generat in g Station, Units 1 and 2, License Renewa l Application Review
Dear Lisa Regner:
Thank you for informing the Delaware Tribe on the propo se d construction associated with the above referenced project. Our review indicates that there are no re li gious or culturally significant s ites in the project a rea. As such , we defer comment to your office 131-1-HA I as well as to the State Historic Preservation Office and/or the State Archaeologist. We wish to continue as a consulting party on this project and l ook forward to r eceiving a copy of the cu l tura l resources survey r eport if one is performed. We also ask that if any human remains are acci dentally unearthed durin g the course of the survey and/or the construction project that you cease development immediately and inform the Delaware Tr ib e of Indian s of the inadvertent discovery. If you have any questions , please fee l free to contact this office by phone at (62) 3 40-0 111 or by e-mail at bobermeyer@delawaretribe .org Sincerely, Brice Obermeyer Delaware Tribe Historic Preservation Office 14 20 C ofE Drive , Suite 190 Emporia, KS 66801 .-:-1 ) .-*, I __... ..._ I -n 0 ...; ... :.) -*1 I L-J ;'-] r:Y N -.....! :::c c .-1"'": " c.: . .*. ..!* .. . *:** .. "* ; -*r.c: < rn en ,/?" ==- 3 = :?C {3Af/?.:L) Appendix A A-137 StocRfiritfge-Munsee fJ'riba{ :Jlistoric Preservation Office . Slimy -'Tri6a{ :Historic Preserrlation Offiar 'W13447 camp 14 g_/c?&/zt91 / P.O. '&wfo; 'WI 54416 'J '?' 0 o .. ,1PJ . LJ-' . J g Project Number tb./YI t/J 0' ba ?i 'f'1 TCNS Number J ufi;} " Company Name { () [l(4 f !{ 1. We have received you letter for the listel:l project. Before we can proces s the request we need more information. The items needed are checked below. Additional Information Required: __ Site visit Historic *-,_ .. ....
- Archeolpgical sllrv.ey Ehi!Se 1. * -* ., * * ** .,./>..... -= Literaturefte(:9p.d sear6h.
'maPli. , ' ' .,. * ;;" * * ., *' * }; -* Pictures ofthe!$'iie . * * . * * * * **** * * .*. * . ***, <">J j' . Any H ts toric PreseFVation .Office . . ...... __ Has the , site;been disturbed
- . . .. *
- Review fee !I!:USt-be*included with letter *, \ If site has beeirpre v iously disturbed please explain what the us.e it was . .., ... ,.: .. **-.. .., dtsturbed. :. * ,, . * . _ , '* ,.. :* Other colll11fel)ts..or information needed -: .*1 .. After reviewi!lg
.. your*ietter we fmd that: . "t.,. . : ... : _y "No -meTribe concurs with a Federal agen<;Y'S there are 132-1-HA I no National or listed properties within the area of potential or APE.3q.CFR , 800.4 (d) (1) '* * * ... * ... , 1.: :.:;i * "No arc::_pj-esentbut th.e,$.e4eral effec t on the Natio11al as defined 1*6(t.) * .. * * .*.: . * -. . , r**-. i' . '. "' '.'* ___ Nd Adverse Effect" written opinioris to a Federaiagency as to whether or not l the Tribe agrees with (or believes-that-there should be) a Federal agency finding that its: Federal undertaking would have Adverse Effect" 36 CFR 800.5(b) 6ovs.z: = rJ11-1-t!J/3 = /3-l)t--1-0 3 =-c/ Appendix A A-138 U.S. NUCLEAR R EG ULA TORY COMMISSION .. ]. I '*** NRC MEETING FEEDBACK .. --1* Meeting Date: .. -- - Station License Renewal Overview and Environmental 09/22/2011 Title: Scoping Comments Public Meeting . _....!,._.:,_ ,_ .......... -. .....:---. -*-*-***---...... ___________________ *--...... _________ _ In order to better serve tile public , we need to hear from the meeting partic i pants. Please take a few min ute s to fi ll out this feedback form and return it to NRC. 1. 2. 3. 4. 5. 6. 7. How did you hear about this [l NRC Web Page [] RadiofTY LJ NRC Mai l ing List D Other Were you able to find supporting information prior to the meet i ng? Did the meeting achie ve its stated purpose? -Has ttiis meeting helped you wiih your understanding of the to_pic?
- Were the mee ting starting time, duration, and location reasonably
_G()nvenient? --.k, _,_,-_,-_ . * .. ; ... : .. Were you given sufficient opportunity to ask quest i ons or express your views? Are you satisfied O>Jerall with th e N_Ry staff who partic i pated inthe meeting? -'.. --' *,_--No Somewhat X!§_ r'Piease exp l ain below) I i .,,**" [i6 1.1 [J 0 [] [J [] [_] [J i -] '--.; ** Continue Comments on the reverse. r.:> OPTIONAL Organizat i on Q Name Tel ep hone No. E-Mail - _______ -------C Check here if you would like s --------.----------------------.... ---... --... m emberofNRCsta fft ocon t acty ou OMS NO. 3150-0197 Expires: 0813112012 Publ ic Pro te:t ion Not if ication: If a means u sed to impose an inf ormat ion collection does no t di splay e curr$nlly v&l id OMS con tr ol num ber. the NR C rNlY no t conduc t 0t sPQr,sor. and a person i!. nol r equ ire d to tespond 10. the in formation co lledion. Pl ea se fold on the dotted lines with Business Reply side out, tape the bottom, and mail back to the NRC. Appendix A A-139 tr .... Mendiola, Doris
Subject:
FW: Response from "Comment on NRC Documents" y-pc., )4!J1/ -----Original Message----- /'/ From: Richard Kolsch !mail to: Rk l sch@aol.coml /.,!( /'0 Sent: Thursday, September 22, 2011 5:44PM @ To: INFOCOLLECTS Resource
Subject:
Response from "Comment on NRC Documents" / (} Below is the result of your feedback form. It was submitted by =o *' :_-, :r.J c: il *:-, ,--;-n l -, (.'..: '") -*1 *-* "J -,.-, ; r I N Richard Kelsch (Rklsch@aol.com) on Thursday, September 22, 2011 at 17: 44:25 --' :......_ :.:: , .--n '9 -I CJ < ..r::: rn 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 p lan of PECO to -LR either continue or close the plant and make arrangements for additional power to replace the closed plant. 2. A firm closure plan should be approved before license renewa 1 34-2-DC I is accepted. This plan must include what is to be done with the site, where the nuclear waste will be disposed of etc. The <UvQ OOU"' Uv <'0 """ U V.1-'v 0<'UVO OV O "VO OOv U OvVOvUvU> 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. Rad i oact i ve 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 re newal of a 34-4-HH 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 i mprovements 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 was started there was no traffic out here , now it is grid lock. 1 34-5-0S Limerick should fund new roads and bridge to alleviate traffic I *ams in order to have an orderly evacuation. 5. The plant is vulnerable to terrorist attacks. An airport is lo cated next to the facility. A plane could be flown ;J 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 aroun d A and downwind of the area uninhabitable for hundreds ofyears. organization: None address1: 1694 Kepler Rd. address2:
- 6 c),-1/Sf ;f?/lh/ / p-7)J--t _. L) I :3 ,£-Q" 2J 5 .:=-,!&ZJ.)..t-.?!
3 ;::: ;/-/]7J--T c ;<__) Appendix A A-140 .. .. *<(. I 6UJ I I September 24 , 20 I I r-,.e .. :5-a¥ 2461 E. High St.,tJnit F-lB Pottstown PA 19464 US NRC Mailstop: TWB-05-BOI M Washington DC 20555 USNRC Lisa Regner: 0) 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.) an d 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 s peakers had no concerns. The NRC would be remiss to consider a " thank you for mone y and jobs" as part of its evaluation of community-wide nuclear safety i ss ue s connected with Limerick's re-licensing request. . . . . . be addressed. Re-licensing should not even be a consideration! The NRC must full y inv estigate the r::-::-:::-:::c=-, environmental concerns pres e nted 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 , be g in to address the pollution issues i has already created as it seriously and carefully sh uts down its reactors. = .. ..;: Charles and Elizabeth Shank (610-323-6715) .. *
- 1 *: *. : *: -* : :r * :*. * *.: n "**** * * *.PtfV.---:JJs-
- /JJJH-0 3 **
Appendix A A-141 Mendiola, Doris From: Sent: To:
Subject:
naturalcat@comcast. net Wednesday , October 12 , 2011 5: 26 PM Regner , Lisa NRC 10 DOCKET 2011-0166 '? jc:;.-& /4? I I G) "7] .:;::1 c:: r .... *;l !-;*: *... ) C.F -----; ' -* I ; 1-! w -.. .--l :*n 9 ':9 < CJ , ,, Vl (/) vJ /7-2:;.1'--7'-CJ 3 6v>>Sr. --===pf);..,'-c/13 Appendix A A-142 -* .... Mendiola, Doris From: Sent: To: Cc:
Subject:
Dear Ms. Regner ,
7't rJ<:. sa.t/-7' r? Cynthia Gale [cgale@barbergale .com] Wednesday, October 12 , 2011 4: 31 PM Regner, Lisa Michael Gale TJ :l DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERJOD .. ::::::-1 . I CJ *-* \..*.) "':9 Vl w rTI (/) .. : J _ ..... _ .. .* .. ,_ 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: 1. Radiation Into Air and Water From Routine and Accidental Emissions 13 7 RW I 2. Major Air Pollution Under Health Based Standards of the Clean Air Act 13 7 AM 3. Schuylkill River Depletion and Major Drinking Water Contamination 37 SW; 37-4-GW 4. 5. 6. 7. 8. 9. Radioactive Groundwater Contamination l37 GW I Radiation Reporting Levels Increased Dramatically After Japan Disaster i37-6-0S I Alarming Cancer Increases , Espec i ally In Children , Since Lime r ick Started Operatin q 37-7-HHI Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On Site 1 37-8-RW 1 Lax Fire Safety Regulations i37-9-0S I Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles of Buried Pipes and Cable 10. Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaste 37-11 11. Threats From Ungua r ded Terrorist Attacks With Planes and Missiles , Cyber Attacks l3 7 0S I -PA 12. Need for an Updated Evacuation Plan and Increased I 13. Increased Costs to the Public-More Cancers and Other Costly Illnesses, More Emergency Room Vis i ts and Hospitalizations from Massive Increases in PM-10 and TDS , Treatment of Public Drinking Water , 137-14-HH I Environmental Clean-Up 14. Dangerous, Dirty , Harmful , and Costly Nuclear Power Is Not Needed. It Can And Should Be Repla r:;c::;e;.;;;d::-::--:-:--, With Safe , Clean, Renewable Energy. 1 37-15-AL I List Compiled By The Alliance For A Clean Environment-September 2011 5v..v s-'- = /7-Z>N-.?3 IT:vH-t::?/3 Appendix A A-143 Mendiola, Doris From: Sent: To:
Subject:
Hello Ms. Regner, 8jc7(p /?>> 1/ Schweg [schweg@gmail.com] Thursday, October 13 , 201110:21 AM Regner , Lisa Limerick License Renewal-NRC J.D. Docket 2011-0166
- n .T l ,-, *-I ll 0 w I'm writing to you to state my opposition to the relicensing of the Limerick Generating Station in Limerick 38-1-0R . . Respectfully , Jude Schwegel 79 South White Horse Road Phoenix v ill e, Pa 19460 If you want to be important-wo nderful. If you want to be recogni ze d-wo nderful. If yo u want to be greatwonderful.
But recognize that he who is greatest among you shall be your servant. That's a new definit io n of greatness. Every body can be great, becau se everybody can serve. You don't ha ve to have a college degree to serve. You don't have to ma ke your subject and your verb agree to serve. You do n't have to know about Plato and Aristotle to serve. You don't have to know Einstein's theory of relativity to serve. You don't have to know th e second theory of thermod y namics in physic s to serve. You only need a heart full of grace, a sou l generated by l ove. And you can be that serv ant. Exc erpted from The Drum Major Instinct se rmon of the Rev. Dr. Martin Luther King, Jr. Deli ve red at Ebenezer Baptist Church, Atlanta, Georgia, on 4 February 1968 Appendix A A-144 ( .. ' Mendiola, Doris From: Sent: To:
Subject:
Michael Gale [mgale@ba rbe rgale.com] Thursday , October 13 , 2011 9:26AM Regner, Lisa DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERIOD. II . And. gel the US manufacturing again making wind turbines, solar panels, =.] retrofitting older bui l dings to be energy efficient, not funding this an other budget-bust i ng toxic time bombs. *-; Lime rick Nuclear Plant's License Expires In 2029 -Exelon Wants To Run It Until 2049 Threats and Harms , Already Unacceptable After 26 Years , Are Increasing! _ ) 139-1-AL t ,-j ---........ Since 1985 Unp recedente d Environmental Harms Th reats and Risks From Limerick Include: ;TJ 1. Radiation Into Air and Water From Routine and Accidental Emissions i 39-2-RW I 0 2. 3. 4. 5. 6. 7. 8. Major Air Pollution Under Health Based Standards of the Clean Air Act i39-3-AM I Schuylkill River Deplet io n and Major Drinking Wa ter Contamination 139-4-SW; 39-5-GW Radioactive Groundwater Contamination 139-6-GWI Radiation Reporting Level s Incr eased Dramatically After Japan Disaster 139-7 -OS A larm ing Cancer Increases, Especially In Ch i ldren , Since Limerick Started Operating 139-8-HHI Deadly High Le vel Radioactive Wastes Packed In Vulnerable Fuel Pool s On Site i39-9-RW I Lax F ire Safety Regulations 139-1 0-0S I L*J :!? -F.= w
- 9. Accidents and L eaks From Corroding , Deteriorating Equipment Plus Miles of Bur i ed Pipes and Cables 139-11-0S 10. Inc rease d Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaster 9 39-12-PA 11. Threats From Unguarded Terrorist Attacks With Planes and Missiles , Cyber Attacks 139-13-0S
- 12. Need for an Updated Evacuation Plan and Increased EPZ I 39-14-0S I ::T J c r*--r.-*; (.J; 14. Dangerous.
Dirty, Harmful , and Cos tly Nuclear Power Is Not Needed. It Can And Should Be Rep l aced With Safe. Clean, 139-1 6-A L I Renewable Energy. *
- List Compiled By The Alliance For A Clean Environment
-September 2011 We sincerely hope you will act with your fellow citizens' health, and indeed longevity in mind. Sincerely , Michael Gale 172 north ha n over st reet pottstown. pa 1946 4 610-705<'.606 p mgale@barbergale .com http://www.barbergale .com dcsi f}Tlill!J su.-ttair UJ blc brands /301'7'-.v 3 Appendix A A-145 Mendiola , Doris
Subject:
FW: LIME R IC K From: Joe Roberto f ma ilto: joe@robertoandassociates.coml Sent: Mo nday , September 26, 2011 2:46PM To: Regner, Lisa
Subject:
RE: UMERI CK -:::IJ ' I 1 -' --0 ::r. c: *-* ,.-1*;, *.") .. '** L.J r:-** -a ,.:: ' 0 _, *P. rn w U) V1 .1 nanKs ana again, Since tnJS reactor nas u nti l LUL4 wny tne rusn, ana an1y one pub li c meet1ng. IT you nave not neara n, ou w ill. There is a major public outrage over th is one meet in g and not knowing about unti l too la te. People wan t ublic mee tin gs so that peop le hear that many are aga in st this plant rather tha n just submitting commen ts to t he NRC N hich appears to just rubber stamp license requests-which is not comforting to me and many. But I do thank y ou very tn uch for the courtesy, response and re v iew of poin ts. 1 30-13-LR I There is also someth ing t hat I did not comme nt on before-why was Li merick taken "o ffline" three times in as many l m on th s? Is NRC check in g? 1 30-14-0S Thanks , Appendix A A-146 .... . . Mendiola, Doris From: Sent: To: Cc:
Subject:
Melissa A ntrim [ma ntr im@boscovs.com j Friday, October 14 , 20 11 2: 18PM Regner , Lisa Antrim , Melissa home) D ock et 2011-0166 -Li mer ick Lic ense Renewal Via email: Li sa.Regner@NRC .gov U.S. NRC ejd-4 jcn;/l /'&r/(_JUfi Ms. Lisa Regner Mai l stop TWB-05-801 M Washington, D.C. 20555 0
Reference:
Re quest for Denial of Limerick Licen se Renewal -NRC I. D. Docket 2011-Q166
Dear Ms. Reg ner:
. _, ... -.:> , .. ..., -1 attended the recent meeting on the possible r enewal of LimencK Nu c lea r Plan t's l ic ense for 20 years past 1ts curr erif 024 a nd 2029 expiration da tes. I strongly believe, as do many of my l ocal fr i ends and family, that the Limerick Nuclear P lant must be closed , not r eli ce n sed. Approving Limerick Nu clear P lan t to be r elicensed until 2049 would be jeopardizing rn he health of thousands and thousands of people in ne i ghboring communities.
There is su b stantial evidence read il v vail ab le which j ustifies closing Limerick. Renewing this li cense could lead to a catast r ophic meltdown. 140-1-0R I Limerick was built to l ast 40 years. The ol de r any f acility gets , the more li Kely brea k downs an d equipment failure wi ll occur. When it's a nuclear power plant , meltdown could result fr om corrod i ng , deter i orat i ng , and aging pi pes , cables, and equ i pment -hon es tly , a number of things. M il es of deter i orating underground buried pi pes and cable s are a ma jor concern -h ow and how often are th ese inspected? Signs of mechanical damage and breakdown already exist -three unplanned shutdowns Ju ne 2011 , pr eceded by many others si nce 2007 , one with l oss of cooling water. While some parts can be r ep la ced , by t he nuclear i ndu s try's own adm issi on , some equipment is t oo big and expens i ve to replace. Limer i ck is sh o wing sig ns of stress and no one knows just how b ad this w ill be by the time the cu r rent li cens e is up. To add 20 more ye a rs to that , without having a clue as to what the con d it i on will be , wou ld be beyond care l ess. 140_2_08 I Over eight m illi on people live within 50 mil es of Li mer i ck Nuclear Pla nt. Safe e vacuation is not possible, even within the seriously fla w ed and i nad eq ua te cu rrent 10-mi le evacu ation plan. Until Limerick closes , NRC should expand th e evac uation plan (to 50 miles) and be su re there are enough shelters and supplies avai l able to accommodate t he milli on people within that rad i us. Exelon should pay for t he s upp li es. 40-3-0S It d oesn't take an accident or disaster for Limer i ck to poison the r eg i on's residents w1th ra 1alion. a 1a 1on r om Li mer ick's routine and a cc idental em i ss ions alone for the past 26 yea rs is r eason enough to deny Ex elon'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 radi a tion monit oring or tes ting at Limerick. Evidence shows testing done by E xe l on and DE P cannot be trusted. Exposure to radiation is known to cause cancer. It should be obv i ous to NRC that Limerick play ed a major ro le in ou r tragic, well documented cancer cr isis after Lime r icK started operat i ng in the mid 198.0s to the late 1990s. Fo ur can c er stud i es based on PA Cancer R eg i stry and CDC data showed skyrocketing rates for severa l cancers far higher than nat i onal and state averages , especially in ch il d ren. Ou r ch ildr en had the hi ghest levels of St ronti um-90 rad i at i on in their baby teeth of any group near any nuclear pl ant stud i ed. Limer i ck Nuc l ear Plant released SR-90 i nto our air and water that got into the m ilk, vegetat i on , and food since Limerick sta rt ed operat i ng. '"'4:-:0:-_-:-4-:-H-:+-.H,.., ' -dJ.3 Appendix A A-147 -. hyroid cancer increased by 128% from 1985 to 1997 -was a side note, with no fam ily history or other obvious ri sk actors in my life , I was re cently treated for thyroid cancer. Since my diagnosis , I have learned of many other locals like e. It's sea to think the choice of where we live could kill us. 40-5-HH 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 A ntr im 1 008 Reading Ave Boyertown , PA 19512 The information transmitted is intended only for the person or entity to which it is addressed and ma y contain confidentia l and/or privileged material. Any review, retran s mission, di sse mination or other u se of, or taking of any action in reliance upon, this information by per so ns or entities other than the intended recipient is prohibited. If you received t hi s in error , please contact the sender and delete the material from any computer. Appendix A A-148 ' ...... " Mendiola, Doris J:J 9 e!. . /t r .;t c; -:3-"'-'7 f' From: Michael Antrim [antrim89@gma il.com] (ii) -1 T S 0 en.* t: Friday , October 14,2011 2:3 5PM J(j D
Subject:
Limerick-NRC I. D. Docket 2011-0166 -::::::: ::;?.
Reference:
Request for Denial of Limerick License Renewal -
Dear Ms. Regner:
i Ti NRC I.D. Docket 2011-01-66 possible renewal of Limerick Nuclear Plant's license for 20 years past its current 2024 and 2029 exp ir ation dates m ore than 12 years ahead of time , worries me a great dea l. It's hard to understand why something this major would be so far in advance. It's IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth this be renewed so early? It's a l engthy process that could begin earlier, but in no way should some thi ng this mportant be rushed through now. Why not wait unti l closer to the expirat io n dates , and then seek approva l? I this is how the origina l gu i delines were set up -but those are l ong outdated. Approv i ng Limerick Nuc l ear P lant to be relicensed unti l 2049 would be jeopardizing the health of millions. Renewing this li cense could be catastroohic o mi llio ns. Someone has to speak up; someone has to step up. 1 41-1-LR I 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. 14 1-2-0S I The older any facil i ty gets , the more likely breakdowns and equ i pm en t failure will occur. Limer i ck 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 chi ldren. 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 t ime to day. Just remember, it would be careless , unethical and i mmoral for NRC to approve ' re quested license extensions for Limerick Nuclear Power Plant. Limeric k Nuc le ar Plant must be closed by 2029. 41-4-0R . Sincerely , * * /'--SUVSI 8D/-/-c 3 Appendix A A-149 Mendiola, Doris From: Sent: To:
Subject:
Dear Ms. Regner:
joanmcglone@comcast.net Sunday ,Oc tober16 , 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(2-1-operate for 30 yrs. and should now be safely ,1>hut down. Statistics regarding nuclear accidents at OS I similar aging structures are well documented. Those two towers are ticking timebombs and the knows this and needs to shut them down. Following the Japanese nuclear disaster our Lime ric k nuclear plant hit the statistical at risk list aaain. The increased risk of cancer is well-founded in the literature also. Why does the NRC think they can play God with people's lives? It is no l onger H debatable , shut it down before our very lives are jeopardized!!! So-called quality of life issues addressed as part of public debate, e.g. "the power is always on" I 42-3-0R 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 \ .) -(l .-' ----i*-n r--l C:> c-> -i -....J --;:) :::3.: -!'? 00 :::0 c:: r*-rr1 UJ :-:t J 0 --1 < rn (f) Appendix A A-150 .......... **.l.* . ...:.* . /J.TAile. rn -r w £3 .-{) s -13 6 1
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- . _ ... .......... .;"..:_ . j, o I olllo 1 o o lo j, 1 j, j, ,j , j 00 0 11 ,j J '-) ' '1:> jl i -r;i H J I( -..> <:. -l1 1 1 "-5 \ ' 1 I \ 43-1-0R Appendix A A-151 Mendiola, Doris
Subject:
Attachments:
Original Message-----
FW: *Limerick License Renewal-NRC I. D. Docket 2011-0166 Limerick.odt From: Angelbosley <anqelbosley@aol.com> To: Lisa.Regner <Lisa.Regner@NRC.gov> Cc: AngeiBosley <AnqeiBosley@aol.com> 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 Ji 9f" ::D ll 6 .-........ -) .i -: *--:::;;: ---. *-\l *::J *,) --l ;-.) .r::: '9 V1 co :::0 c r* IT1 r---:-.:: ... J* .. * == /h.tY'-o 3 (/-A-1/{L) Appendix A A-152 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 lik e to vo ice my concern to a ll of you through this letter. There are so many reasons why you as a group s hould already know that it would be in the best interest of the men , women, children, babies , fetu ses, 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 /c orporations want to expand and become bigger and run their businesses long past the time that they shou ld truly be a ll owed in order to keep people safe, always comes back to the issue of money, offerings, bribe s, donations , etc. in the end. When these things occur, people and bu si nesses tum a " blind eye" so to speak to the dangers of allowing a business li ke 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 I 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 be lieve that they wou ld be honest about the results? Seriously?? 1 44-2-0S I There is concern that shou ld be faced regarding the Schuylkill Rtver and the atlects it ts gomg to have 44-3-I on the public if it becomes depleted and/or toxic due to the contaminates going in it. It is disgus t ing sw 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 fac ing 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 ri g ht for humanity. 144-4-0RI 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 avai l able 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 toda y's society. 144-5-AL I Have n't we already see n some of the damage that a terrorist attack can cause for our country and for o thers? Do you really need to risk more possible attacks on a power plant that is n ot fully e quipped for 44-6 hat kind of attack or for some other natural disasters that can occur. This plant is not prepared for -P A !tacks with planes missiles and other threats such as a cyber attack. There should al so be a co nc e rn or accidents and l eaks from corroding and deteriorating equipment at the site from over the years 144-7-0S Appendix A A-153 (Page 2 of3) which could cause parts of it to be shut down for periods of time , as well as the miles of bu r ied pipes and cables. There are many concerns that should be fully looked at and considered, and just with minimal thought to them , it shouldn't take a "rocket scientists" so to speak to figure out that it is not in the best interest of the public or environmen t 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 cance r 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 increa se d 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 incre ase d 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. Perm i ssible adiation l evels does not mean that they are safe levels for everyone in the community. Most ermissible levels are based on the average healthy adu lt. They are not l evels that were based or esearched for fetuses , infants, toddlers and children or pets. Fetuses, inf ants , children, pet s and the lderl y and immuned compromised individuals are at most risk of health problems. There is a broad ange of dan g erous radionuclides routinely released into our air and wa te r from the Limerick Nuclear lant as well as any accidental releases. Permissible radiation levels does not mean that they are safe adiation l evels it on l means that the are allowed. 44-7-OS Cont'd I have children as well as other loved ones that have or have had allergies , asthma , learning disabilitie
- i,-H_H__,_..J speech di sa bilities , behavioral disabilities, thyroid conditions, cancers, skin disorders and irritation, etc. I expect you to do what is morall y right now for me , my family , my neighbor s, 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 l onger 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 sa fe for humani tv and for my children and for the future of generations to come. Please he lp women have a chance to carry a baby fu ll term without complications due to any po ss ible air and water pollution that may have been caused by allowing more radiation into the environment when there are safer alternatives for energy. 1 44-12-AL I Appendix A A-154 (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 P A 19464 CC: Friends, Family and some community members Appendix A A-155 October 8, 2011 U.S. NRC Ms. Lisa Regner Mailstop TWB-05-801 M Washington, D.C. 20555 Lisa.Regner@NRC.gov C?j c:J-tjZEJij 1cpf7( .. : 53./j9'f' 8 .JJ -n *. .. ) -, I I ---*---.... I n CJ ; > r-.J .::> t."J -< '" -"'= ;] i>? w '--J
Subject:
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, not relicensed, for many valid reasons. Approval for Limerick Nuclear Plan t 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. 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 :::J c r-* n-: cr .. -; *** .. ..... _
- r: C') =:; .c* ri9 (/) 1 45-1-0R I released. ]45-2-PA 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 l plant , meltdown could result from corroding, deteriorating, and aging pipes , cables , and 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 .-:'::,.......,.--=:::-
- such fuel pools. Deadly radioactive spent fuel rods are jam packed into Limerick's vulnerable 4 5-4-0S fuel pools five stories high. Cyber attacks, now declared an act of war , could wipe out sys t ems 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
/9-L>JY-0.3 Appendix A A-156 .... *., !" .,. evacuation is merely an illusion, even within the seriously flawed and fundamentally inadequate current 1 0-mile evacuation plan. Until Limerick closes, NRC should expand the evacuation plan (minimally to 50 miles) and be sure there are enough shelters and supplies available to accommodate the over 8 million people within the 50 miles. Exelon should pay for the supplies. Unless this is done, Limerick should be closed as soon as possible. But, 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 the past 26 years is reason enough to deny Exelon's request. It's not credible for NRC to claim continuous 1 45-6-HH 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. NKv 1s ramng 10 acKnow*eage oov1ous neann narms rrom umencK*s commuous aaamve, cumulative, and synergistic radiation releases which get into our 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 45-7-HHI 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 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 children had the highest levels of Strontium-90 radiation in 45-8-HH I 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. Thyroid cancer increased by 128% from 1985 to 1997. Other cancers rose dramatically as well. 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 24n. 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 us if drinking 45-9-SW I water will remain safe even until 2029 when Limerick's original license expires. Limerick contaminated groundwater. Radioactive leaks and spills over the years were never cleaned up. More radioactive leaks can be expected in the Mure through earthquakes , 45-10-GWI deterioration , and corrosion. Many residential wells are very close to Limerick. 1 45-11-0R I Sincerely, Appendix A A-157 1618 Benjamin Dr. Ambler, PA 19002 Oct. 21 , 2011 Ms. Lisa Regner Project Manager NRC Environmental Review Project
Dear Ms. Regner:
am writing to express my opposition to the re-licensure of Limerick nuclear power generating
- station, is located about 20 miles from my home. Th e re are severa l reasons why this re-l icen su re is not in he best interests of people living in the surrounding community.
l iT tnls ncense renewal IS gramea, tms p1ant wn1 contmue operatmg untu at wmcn ttme 1t Will oe over sixty years old. Cracks in concrete and corrosion in piping wi ll inevitabl y develop as this facility ages. While some of this " wear and tear" may be evident to visual inspe c tion , some of it will also occ ur in less accessible places, such as in underground piping systems. The Associated Pre ss has shown that tritium leak s in underground piping systems frequently go undetected-so metimes for years-in aging nuclear power plants.' While no leaks of thi s kind have so far been documented at Limerick , the odds of these sorts of problems developing will only increase with every successive decade of the plant's working life. While the problems associated with age will develop in any nuclear power plant over time , there are additional problem s with the reactors at Limerick. Limerick's reactors are boiling water reactors similar to those that catastrophically melted down last s pring in Japan. Although these reactor s ha ve a later containment design, .they have the same fundamentally flawed reactor pres s ure vessel de sig n as th ose that failed at Fukushima." In the BWR de s ign , the contro l rods come up through the bottom of the pressure vessel, instead of dropping down from above as in other reactor designs. While the reactor pressure vessel itself is made of very thick steel , the bottom of the BWR pressure vessel contains 60 holes through which the rods enter the vessel.'" In the event of a meltdown , however , these same holes can provide a "path of least resistance" through which the hot molten fuel can escape with relative ease; it then only has to melt through connecting pipes that are much thinner and weaker than the metal of the pre ss ure vesse l it se lf.'v This apparently occurred at Fukushima, where authorities now admit th at reactor fuel unde rwe nt not merely a " melt-down ," but a " melt-through," breaching the inner pressure vesse l and in the proce ss releasing considerable amounts of radioactive material into the environment.v 1 46-1-0R I 146-2-0S I 1 46-3-0SI vne m1gm oe remprea to a1sm1s s tne co mpan so n wnn on me grounas umencK tn Penn sy lvania is unlikely to experience a simi l ar combination tsunami and earthquake. While the tsunami is not an issue , however , recent analysis by the Nuclear Re g ulatory Commission suggests that earthquakes po se a more significant threat to the Limerick react ors than was recognized at the time of their construction and initial licensure. (incidentally , it now appears that at l east one of Fukushima' s reactors was significantly damaged by the earthquake e ve n befor e the tsunami s truck.)vi According to t he NRC's own data , Limerick's two reactors are the third and fourth most likely in the country to sus tain core damage in the event of an earthquake. vii There is a fault li ne ca ll ed the Ramapo fault line that runs 1 46-4-PA I sl ightly north of Limerick, and two small earthquakes associated with thi s fault line occurred as recently as February 2009.viii The unexpected quake that shook Virginia's North Anna nucl ear plant with over two times the amount of fo rc e that it was designed to withstand should make us take very serious ly the NRC's data regard in g Limerick's greater than previously recognized vulnerability to earthquake dam age.;' These concern s are compounded by the fac t that the manufacturer of Lim e rick's co ntr ol rods, GE Hitach i, Appendix A A-158 Questions about the Limerick reactors' ability to withstand accidents and natural di sasters are all the mo re pressing because so many people cou ld potentiall y be affected if so mething catas trophic were to occur. Since 1990, the population within a ten-mile radius of the plant has increased by 45%, from 178 ,047 to 257,625." In addition, Phi l adelphia, with a population of 1 ,526,006, is only about 28 miles away. H ow much more might these populations increase by 2049? Bearing in mind that the NRC advised Americans within a 50 mile radiu s of Fukushima to evacuate last spring, one can only imag ine how difficult it woul d be to carry out such evacuations if the unthinkabl e were ever to occu r at Limerick. Finally, my concerns regarding the impact of thi s nuclear power plant on my community are not limited to catastrophic scenarios that might potentially occur. There have been some recent studies publi she d in health journals that show a higher incidence of illness-particularly among children-in communities surrounding nuclear power plants."' While these s tudie s were conducted in a variety of locations , they seem to be consistent with som e of the data th at Pott s town's l ocal All ia nce for a Clean Environment presents on its website regarding in,creased cancer and leukemia rat es-a lso especially among children-in the greater Pottstown area."" For all of these reasons, I am asking the Nuclear Regulatory Association to deny Exelon's request to extend Limerick's operating license for an extra twenty years. Thank you for your time. Sincerely, Lori Molinari 46-5-0S I 46-6-HH I Appendix A A-159 Mendiola, Doris From: Sent: To: Cc:
Subject:
Regner , Lisa Thursday, October 27 , 2011 10:17 AM Gallagher , Carol Mendiola, Doris Limerick Comment dictated to PM (docket NRC-2011-0166) Environmental Scoping comment dictated to PM (L. Regner) on October 27 , 2011: I'm against it for two reasons: I' am fu ll y aware of the amount of cancer th at 1s preva l en t 1n th 1s area. 1 147-2-HH I Doris Meyers Read back to Ms. Meyers twice by PM to ensure accuracy of dictated statement. Lisa M Regner, Se nior Project Manage r Divi s ion of License Renewal Office of Nu c lear Reactor Regulation U.S. Nuclea r Regulatory C ommi s sion lisa.Regner@NRC.Gov Office: 0 11 H-23 Mail Stop: 0 11 F-1 (301) 415-1906 --.-o r: ) -*: I ' ----......_ .Tl .. *:J ;& ,F)(5 3-1 n 8 .) <.--. ::0 c: r 1"':-n*-'-, (.1. *-1 --. ****. : .. ) '* C.J .. . h 9 -I ;.< vJ rn (/) c-0 5..=:. .&:JJ/-.I-d.:3 Appendix A A-160 Mendiola, Doris From: Sent: To:
Subject:
Hello Ms. Re ner: quteasz@comcast. net Thursday, Octobe r 27 , 2011 3: 03 PM Regner , Lisa Limerick Nuclear Plant Re lic ens i ng Just a quick note requesting the NRC to NOT allow the relicensing of the Limerick , r.Pa-:-.-':-' 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 relicens i ng. 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???? gain, WHY THE HURRY??? 48-3-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.!!! Excelon lied to us then and the will distort the facts now. 48-4-0S 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 Appendix A A-161 "'" II r.-'\ . " 11 ... T ? J /il 10: lj 7 B 936 Shenkel Road Pottstown, P A 19465 October 25 , 2011 o '.-= r, n 1;--D. I 1 1_1 , -,\ ;-U.S. NRC C/0 Lisa Regner, License Renewal Mailstop TWB-0505-BOl M Washington , D. C. 20555
Dear Lisa,
NRC: Re: Limerick License Renewal NRC I.D. Docket 2011-0166 As a physician, I am writing to help you understand that nuclear reactors are not safe. I att e nded the medical clinic in Hiroshima right after the bombing and saw the radiation horrors caused by nuclear bombing. I have kept a close watch on similar problems by nuclear energy in the medical field since then , not onl y worldwide , but because of our nearby nuclear power plant. Here are some concerns. Incidentally , baby teeth studies have revealed Strontium 90 radioactive particle s which can affect the child's immune system for more illne s s.
- 6-8-HH We can't control the u se of nuclear in the r es t of the wor l d, but we can ke ep the U.S. safer by eliminatin g nuclear energies.
Fortunately , man y of our European allies including 6-9-0R I Australia have decided to phase out reactor s. We should join them to reduce human suffering. Also this can reduce our increasing co s ts of health care! lease listen to this ad v ice a fter years of doing my best for Americ a. Rely on more and ruly safe and renewable sources like solar , wind and geothermal power. A patriotic dut)'-,----' imerick Power Pl a nt is ranked in the top 3 ri s ki es t nuclear power pl a nts in the U.S.A. I 6_11_0 R imerick Power Plant must be closed not relicen s ed. . Sincerely your s, Is! Fred S, Winter Fred S. _Winter , M.D. 6v tVS J ....E-;rt rJ> 6 =/}2;) H -,::/ 3 Appendix A A-162 ttr/(33-l @ Anthony Gonyea Onondaga Nation Hemlock Rd. Box 3198 via Nedrow, NY 13120 Oct. 15, 2011 JJ --, I I .-) .. :::1 . -, c .. -.** "! :.*I (,/"'; ... ') -David J Wrona US Nuclear Regulatory Commission Washington, DC 20555-0001
- i 'r: ') ;3 *::r: .. ..._ i" l .:=J 1...11 V1 RE: 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 i () n, (/) send updates and information until then. [49-1-HA I 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. Anthony Gonyea A Faithkeeper for the Onondaga Nation Onondaga Nat i on Historic Preservat i on Office Sect i on 106 Representative Q])/7'-£/ 3 ==-y: Appendix A A-163 Mendiola, Doris From: Sent: To:
Subject:
Hi, %!7i Deb Penrod (deb24532@comcast.net] Thursday , October 27 , 2011 8: 06 PM Regner , Lisa greet i ngs from a SUPPORTER of Limerick nuclear plant ., , ... ) --* 0) VI N 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. (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 clea r 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 l ost 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 vacc i nation 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 = /J D-0'-t?J 3 d7 Appendix A A-164 Mendiola, Doris From: Sent: To:
Subject:
DocKoenig@aol.com Thursda y, October 27, 2011 8:49 PM Regner , Lisa Fwd: Nuclear Limerick From: DocKoenig@aol.com To: LisaRegner@nrc.gov Sent: 10/27/2011 7:36: 13 P.M. Eastern Daylight Time Sub j: Nuclear Limerick g;/c?c:, Hello Lisa Limerick should not .be licensed. or relicensed at this ti me. doing it because the plant has issues that they are trying to hide. The evacuation pia is a joke because we would not get out of our dr i veways. It would not have worked 10 1'-5-::-1--::-1-::-0::-:: S:-11 years ago and certainly with the population growth it would be much 6utV.5.Z: 1 51-2-0S I ' :n ; ,") c: JJ ,.-* r* "-;-] :, u: ) -I .. ..) -C.J -::;. .. L. r-. -c: _, Tl < JTl ;::J V1 (/) N .= /J"))H-c!J3 (!-1--!.E'-.:Z..) Appendix A A-165 Mendiola, Doris From: Sent: To:
Subject:
- John & Jo yce Webber [jbwebberp c@comcast.net)
Fr i day , October 28 , 2011 2:41 PM Regner , Lisa E xlo n Limerick Relicensing As a resident of New Hanover Twp., Montgomery County, PA (less than 5 miles from E xelo n's Limerick Nuclear Power Plant), I urge you to vote AGAINST the premature relicensing of that facility. 52-1-0R
- 2) It has now gone far beyond its limitations.
- 2. r _,tC S.3 / ([" p1 Tfi e ,.., "o"" d t fi e f oo, h ty fi., e>ploded wrt fi fi om" '" d I 0 (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 pe r mission to begin tran s port i ng them to another facil i ty.
(5) It is one of the six most dangerous plants in the country b ecause of its proximity to an earthquake fault. j 6) Th e surroun d ing area h as ab norma lly h ig h cancer rates among adul ts an d chr ld ren. 1152-6-HHI 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 licens es that do no expire until 2024 & 2029! Plea se consider the thousands and thou sa nds 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 : ' 5o,vs-.z: /?eY;&-r /7-bf-f-??/3
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(?-/-f.e-9 Appendix A A-166 Mendiola, Doris S3/j9e' :::CI c: r*-From: Anita Baly [ajbaly@yahoo.com] Friday , October 28 , 2011 3:06 PM Regner , Lisa --: -** ,:,..*. Sent: To:
Dear Lisa,
Limeriok Pl*m Reli"'"""' AG""
Subject:
It was good to meet you at the September 22, 20 II hearing the NRC held at Sunny brook. ,-..) V1 w 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 wo rk on the relicensing question for this facility for at least ten years. wait could only ensure better information. The public cannot possibly benefit from a decision to rene w 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 u rge the NRC to wait and see r::-:::-:L=--> how any of it affects the prospect of continuing the se 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 kno w more about how well nuclear plants in general and the Limerick facility are faring as they continue to age. If so meone 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 alread y 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 he re in the Limerick plant's territory--is refurbishing the plants so they can withstand earthquakes.
It has b ee n widely report e d--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 earthq u akes. Now we do. I understand that Congress is now or soon will be considering increasin g earthquake preparedness capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC wo u ld encourage t hem to do le ss than thev should to make th e nlant s safer. 18-6-PA 1 There can be no good reasons for relicensing now. Plea se wait as long as possible to do that. Better information helps everyone who wants an outcome that is right and socia ll y beneficial--not just profitable for Ex elon. Thank you for your consideration. Anita Baly = Appendix A A-167 bP/:71. _,-__ ChaL'"/L&. __ ______ __ _____ ___ _ _________ _ .. ________ ____________________________ .. _ _ , ______________ ______ eA_ __ ___________________ .. --*--_______ _ -------------------*--------* ----------*-. _ _z-_ _ m;::JJd!e
- ,ou _(D _/.ltrc* ..
_,;?S e _-fhe-_ ;{/vc/ea,.-. ' _ _i6_ ___ . -/__-'?*_ --J.."P. __ I_At!..L!?!y ... 7f_ <-./2t1UJ?r:: be. 7(J£? --* __ __ : ___ ________ _ I! _ ______ g/_c:.,_/J-e_e.c/ __ . _ /Zc!U. ElvA/3.L;i:. __ _!____ _ ____________ __ 1_ _ __ _ ¢:£aa(J:Y.t.S _ace. __ a __ **----________________ . _ . *-, ft-/G72x5 = /3-Y--t--/-:5 .---------* . --------* -* *- Appendix A A-168 MONTGOMERY COUNTY PLANNING COMMISSION box 3 11
- norristown
- pennsylvania
- 19404-0311
- 610-278-3722 office location: suite 201
- one montgomer y plaza
- swede & airy streets
- norr i stown pa FAX 610-278-3941
- Web s ite www.planning.montcopa.org JJ -Tl il ) : 1 ' ; ... October 25, 2011 -:; :::!1 Chief, Rules Announcements, and Directives Branch Mail Stop: TWB-05-B01M US Nuclear Regulatory Commission Washington, DC 205550001 RE: Environmental Scoping Comments Limerick Nuclear Generating Station Division of License Renewal NRC-2011-0166
Dear NRC Staff:
......_ __ , :-ll 1>? :-::J V1 V1 We have examined information presented by NRC staff at the Public Hearing held in_Pottstown on September 22 and the information posted on 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 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 Comprehensive Plan *and overall county development Below we have itemizeci is , sues with respect to land use change and growth around the 'power plan,t, 'transportation and evacuation capacity, Schuylkill River; and county trruls that we feel warrant consideration in the ;.;IJ r== r--: (./'. '** i i""! fT l (/). environmental impact study. /J?)H-?J13 £--/(J2)S 7 3 ::=. /! (2/-//(..1L) Appendix A A-169 NRC Staff 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 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 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 m this location as well. Other lands in Lower Pottsgrove Township near the Liinerick Power Station have also been proposed for similar types of uses. * ..
- 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 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. * * * * ** and Evacuation Caoacitv:
- * '
- if he 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 ma y have
- nadequate capacity to continue to serve as a safe evacuation corri dor for the region. lf he county transportation plan recognizes the need for various road improvement s fu o ng the US 422 , Corridor 1;o address current and future traffic demands. The first !P riority projects in the plan include *interchange improvements
- at the Township Line !R oad/ Evergreen Road intersection which is also the primary access route to the !P lant; needed widening and r eco nstruction of the highway east of the power station !b etween Route 29 and US Route 202 in King of Prussia , reconstruction
- of US Route in the v icinity of Pottstown, and the reconstruction and widening of the Route 422 !B ridg e ac ross the Schuylkill River at Betzwood.
A passenger train lin e is also !P ropo sed as a first priority in the transportation' plan to provide service through the jw estem 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 !P roperty. O,ther improvements including the wi&ning and expansion of US Rou te 422 rom Pottsto&n tO Route 29 and additionhl interchange improvements at Township !L ine/ Evergreen' Road 'are' proposed as seccindaiy priorities iri 'tlie CO'\lnty plan. In . !a ddition *to these itn.pr 9 veinents', several othei-*localired improvements mat ma y impact !e vac uation feasibility a:te'prbposed irt'the' co unty plan .* : ' . ' . ' ' ' . . --.J 54-2-0S I 1 54-3-os l Appendix A A-170 .. ... ,.. _, NRC Staff October 25, 2011 Due to tundmg limitatiOns m Pennsylvania, these proJects are not likely to move forward at this time .. The envir.onmental impact review should consider the capacity of the roadway facilities to service the Limerick }'lant as well as provide sufficient evacuation .*of the area in the eVent of a disaster*. Possible mitigation strategies 'to be considen!d in the environmental assessment review cotlld include the role of Exelon in funding road needed in area to ensure safe evacuation and access to the , planf ln any type of disaster. . . ; . SchuylklllRlver;, ... , .. ,,,_,.:: *:c-,: '*' ..... , ... ** .* ;. '**, . . . .. . Since the last i_mpacistaternenJ ,was
- 973, hiu=i been* 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. of non-* profit organizations and local govert:lment, 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 54-3-0S I Cont'd down stream ladders, in iJ1 e':'en grow further in the 1 54_4_8 W 1 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 ..
process was. initially approved .by the. River . Basin .Commission (DRBG)jn and th,rough, *;;;_series o*f docket amendments. Future river -water use is dependent upon the .ability of this water make up system to qualitY. and flow , parameters set by DRBC.* It is important.to evaluate. 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-'ameters. 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.source 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 I 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 County Space a tra,il along the thrm,;,gh the power plant property .. , This trail.isprqposed as the Schuylkill East Trail, which would be developed as \.Inpave , dtrail.
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. St{ltiqn .. .... J'hgugh trail route. wi:iuld
- appear to raise significant safetY
- ii:s to j:>ower Appendix A A-171 NRC Staff October 25, 2011 station, appropriate elements could be into any trail system to limit its threat to plant's security.
We have found that trails can enhance the overall security of an 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 evacuate people and provide access for emergency response. This trail and the portions of the Limerick Power Station site should be considered iri 'the environmental assessment. ,-. 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 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. Sincerely,* *' . . . ! . . Michael M. Stokes Assistant Director mstokes.@montcopa.org (610) 278-3729 * * * : . ; . * '* .. . c. Thomas Sullivan, Public Safety DepaJ1:!nent ; . ' ... ; '** ' _i. -, :* ***"'!* ... . . ., . ' . *' . 54-6-0S I Cont'd 54-7-LR I Appendix A A-172 COUNTY OF MONTGOMERY Commissioners JAMES R. MATTHEWS CHAIRMAN JOSEPH M. HOEFFEL BRUCE L. CASTOR , Jr THOMAS M. SULLIVAN DEPARTMENT DIRECTOR 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
Dear NRC Staff:
Montgomery County Department of Public Safety Operations Center 50 Eagleville Road Eagleville, PA 19403 (610)631-6500 FAX (610)631-6536 www.dps.montcopaorg ) .. *! 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. * [Th e 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 ... --j-!j c; associated with daily operations of the plant. However, in light of events in Japan and recent activity in this area, the NRC should clarify the risks associated with plant operations in times of 1 55-1-0S I 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 e concur that the NRC require Exelon to conform to the Montgomery County Comprehensive Plan o not only ensure cooperation in the community, but also in the region. Additionally, it is also 1 55-2-0S I that Exelon be included in pending roadway infrastructure improvements projects as both a take holder and possible source of funding.
- 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 155-3-os l account for the transient population present in the hotels that have accompanied this development.
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.
- 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 noted in the updated ETE. Special attention for improvement should be given to the local, county and 155-4-0S I 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. JJs -:::: J9 !Y-7-2J .3 0-H;:<;z.j Appendix A A-173
- 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 55-5-0 S I to screening of vehicles and personnel This can cause delay in patient care to potentially life *
- threatening illnesses . While recreation utilization is of importance and a major mission within this county, homeland security must be of a concern with any open access within the vicinity of LGS. However, we concur that with 1-: 5::-:5=---=7
- -_-,1 support of local law enforcement and a commitment from LGS to control and monitor access, trail OS put ma y be accomplished.
- In an attempt to promote and increase community outreach, the NRC should consider requiring Exelon to reopen the LGS Inf ormation 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 generat ion from the public. The LGS Information Center, although 5 5-8-0S I 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. If you have any questions please feel free to contact me. Director of Public Safety CX:::: R. Graf, CO.O. M Stokes, Assistant Director of Planning S. Mickalonis, Deputy Director for Emergency Mgt. J. Wilson, Radiological Planning Specialist Appendix A A-174 THE EART H'S BEST DE F ENSE October 28, 20 II Via El ectr o nic Mai l M s. C indy Bl adey C hief , Rules, A nnouncements , and D ir ecti v es Branch Office of Administration U.S. N uclear Regulatory Com mi ssion Wash i ngton, D.C.20555-000 I El ectronic Ma il: cind y.bl adey@nrc.gov RE: Na tural Resources Defe n se Counci l Co mments on L imeri ck EIS Scopi ng Process NRC Do cket ID N RC-20 11-016 6
Dear Ms. Bl adey:
The Na tur al Resources Def ense Co uncil (N RD C) comments to da y on the Nu clear R eg ulat ory Co mmi ssion's (NRC) No ti ce of Int e nt To Prepare an Env ir onme ntal impact Stateme nt and Co nduct the Scoping Process fo r Limerick Generat in g Station, Un its I and 2, (he r einafter " Limerick E IS Scoping Pr oc e ss"). 76 Fed. Re g. 53498 (August 26 , 20 II). S ummary of Co mm e nt s Our co mments s pecifica lly a dd ress the NR C's National Envi ronmental P olicy A ct ((NEPA) 42 U.S. C. § 4321, et seq ,) ob li gat i ons and th e ne ed for any en v ironmental anal ysis the age nc y conducts to include an up-to-date "Sev ere Acciden t Miti g ation A ltern a ti v es" (SA MA) analy sis th at fu ll y incorpora tes current i nsi g ht s into se v ere nuc lear acc i de nt caus a tion and mit i gation. While we rec og n ize th at, as a pri va te entity, the relicensing a pplicant , Exe l on Generation Co mpan y, is not directl y bound by NEPA , the same is not true for the NR C. Given tha t the app li can t's ER g enera ll y serves as the basis for the Co mmission's eve ntu al Draft En viro nmental I mp act Stateme nt (Dr aft EI S), and Exelon su ggests it need not revi se and u pdate i ts SAMA analysi s, we are rais i ng thi s N EP A concern at this ea rly st age in hopes that this matter m ay be addressed before the agency m oves to re li cense a facilit y based on a l egally in s ufficien t NEPA rev i ew. Appendix A A-175 C'ommPnf<: The original SAMA analysis for the Limerick Generating Station (LGS) is a 1989 report that wa 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 infom1ation relevant to environmental concerns and bearing on the licensing of [LGS]". As the original LGS SAMDA effort in 1989 was the first mandated effort to focus on SAMAs, 2 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. It has been noted 3 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 effot1 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. 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 4 and aided by an industry-supplied guidance document 5 , most modem-day SAMA analyses are designed using a fairly prescriptive set of initial assumptions , baseline calculations , and benefit arithmetic recipes that employ the use of sophisticated codes in their evaluation of potential risk and the benefit of removing this risk. 1 Limerick Ecology Action v. NRC, 869 F.2d 719 (3'd Cir. 1989) 2 Or SAMDAs in this case , and we use the tenns interchangeably for the purposes of these comments. 3 Global Implications of the Fukushima Disaster for Nuclear Power, T. Cochran, M. McKinzie (NRDC). World Federation of Scientists ' International Seminars on Planetary Emergencies. Erice, Sicily. Aug 2011. 4 NUREGIBR-0184 Regulatory Analysis Technical Evaluation Handbook, Jan 1 99 7 'NEI 05-01 [Rev A] Severe Accident Mitigation Alternatives (SAMA) Analysis-Guidance Document, N ov 2005 156-1-PA I Appendix A A-176 The most common code used is the MELCOR accident consequence code system (MACCS2)6 , 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 e xpanded and improved in the intervening twenty-two years since the initial SAMDA analysis for LGS. 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 SAM As, 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. 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 notewmthy severe accident mitigation strategies bearing on the site in question, or serve to remedy gaps and omissions in the original SAMDA analysis. 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 E xelon referred to these considerations as representing an "abundance of caution." We disagree. 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. 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. 7 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 6 NUREG/CR-6613, Vol. 1, CodeManualforMACCS2, User'sGuide, D. Chanin & M.L. Young, May 1998 7 Joseph M. Farley Nuclear Plant -Application for L icense Renewal, A ppendix D. EnvironmentalReporl, Attachment F. Se vere Ac c identMitigationAltematives , Sept 2003 56-1-PAI Cont'd I Appendix A A-177 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, 8 the SAMA analysis found eleven potentially cost-beneficial options from an initial set of thirty-three. 56-1-PA I In an NRC report discussing insights on SAMAs in connection with plant license ren ew als, 9 th<I'-C_o_n_t_'d _ _. agency authors list numerous pot e ntially cost-ben e ficial SAMAs relating to station blackouts, protection and support systems , procedures and training, and external eve nts such as flood , fire and seismic ha z ards. 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. Finally, NRDC believes that in addition to a comprehensively updated SAMA analysis, the lic e nsee or agency must conduct a study that, as part ofthe supplemental environmental impact statement, pr ese nts postulated accid e nt scenarios showing th e full rang e 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 whether to continue plant operations after the existing licenses expire, thereby continuing to rur 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 futur e electricity service needs over the license extensio period. The SAMA analyses are inadequate in this regard because they only address isolated issues in< 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 the y tend to mask the full range of accident consequences that policy makers may wish to avoic. R ece ntly , NRDC produced an analysis, of the typ e we believe should be included in th e Limerick NEPA analysis, to inform ongoing relicensing efforts at the Indian Point nuclear plan site 10 In order to illustrate the full extent of a major accident, the NRDC study used the U.S. Department of Defense computer model HP AC (Ha za rd 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, a nd to estimate the rough magnitude of financia 8 Thr ee Mile Island Nu cl ea r Station Unit l -Lic ense Renewal Application, Environmental Appendix E. SAM4 ANALYSIS 9 Perspectives on Severe AccidentMitigationAltemativesfor U.S. Plant Li cen se Renewal, I. Gosh, R. Palla, D. Helton, U.S NRC, Sept 2009 (Accession No.: ML092750488) 10 Nuclear Accident at India n Point: Consequences and Costs, M. McK inzie, Oct 2011 (http :1 /www. nrdc. org/nuclear/ind.ianpoint/files/NRD C-1336 _Indian _Point_ FSr8mediwn. pdf) 11 Hazard Prediction and Assess ment Capability (HPAC), version 4.0.4. Washington, D.C.: Defense Threat Reduction Age n cy, Apr 200 4 Appendix A A-178 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 t endure the continuing risk of severe nuclear plant accidents. Regardless of Exelon's own corporate understanding of its legal obligations , NEP A is clear in it 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.12 NEP A 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. Most specifically, NEP A 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 additional20 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. 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 pali of these documents. These analyses must 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 ofthe full spectrum of reasonable accident mitigation alternatives must be considered as part of the Draft Supplemental Environmental Impact Statement, and issued for public comment. 56-1-PA I Finally , we have grave misgivings regarding the future time-dependence, accuracy , 1:--::--:-::::-o relevance of the licensee's current ER, as presumptively incorporated in the NRC's planned i56-2-LR I 12 40C.F.R § 1508.8 Appendix A A-179 SEIS for LGS license extension, given that such license extension will not become effective unti the current unit operating licenses expire in 2024 (for Unit 1) and 2029 for U nit 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. 56-2-LR I Intervals of 12 and 17 years are not required for corporat e planning purposes and are far too lom J Cont'd to credibly sustain the accuracy and relevance of NEP A analyses, or for the NRC to accurately project both the future condition ofthe 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 NEP A reviews of their operations and facility plans ever five years. Using this federal standard for timeliness, the NRC's NEP A 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 dat e s. We further note , given the ex-tended timeframes for expiration of the existing LGS operating icenses, that they easily encompass the five year timeframe that the Commission has set out for ormulation and implementation of NRC staff safety recommendations to be undertaken 'without unnecessary delay" in the wake of the Fukushima accident. In light of these important 1 56-3-0S I nuclear safety developments , we seek no reason why this proposed NEPA analysis, and hence he entire licensing proceeding that it is required to support, could not be deferred for at least five years, until the Commission has completed its decision-making and schedule for implementation of post-Fukushima safety upgrades. As noted above, to ensure th e tim e liness and accuracy of th e NEP A analysis, the deferral could be even longer (on the order of 7 years for Unit 1 ), to allow or the inclusion of the results of the extended mlemakings contemplated under the Commission's regulatory response to the Fukushima accident. Preparation of the applicant's ER, and the NRC's subsequent SEIS, could then take account of th e se required safety modifications and enhanced severe accident coping strategies , and th e se would be reflected in a significantly revised SAMA analysis. In th ese comments , we are not formally advocating such a deferred pathway for the LGS relicensing proceeding , but merely note its plausibility and inherent advantag es for all parti es to the proc ee ding. Without such a deferral , the only sensible alternative course is to ensure the incorporation of the most up-to-date nuclear safety knowledge -"new and significant information" -regarding BWR Mark 2 reactors and severe accident mitigation into the current licensing proceeding. Appendix A A-180 Thank you for your consideration of these comments. Please do not he s itate to contact us at (202) 289-6868 if you have an y questions. Sincerely , G eoffrey H. ettus C. Jordan W ea ver , Ph.D. Program Scientist ..... C hristopher E. Paine Director , Nuclear Program Appendix A A-181 Mendiola, Doris From: lorraineruppe@aol .com Sent: To:
Subject:
Friday , October 28, 2011 6: 33 PM Regner, Lisa Fwd:Faultlines close to Limerick Nuclear Plant JJ l :n -c Ms. Regner, Please include this for the record concerning rel i censing of Limerick Power Plant. ----Original Message-----From: lorraineruppe <lorraineruppe@aol.com> To: letters <letters@pottsmerc .com> Sent: Mon, Oct 24 , 2011 9: 09 pm Letter to Editor 7.?/1<.
- 0) .. \ ' I *,*, I ----' .T.l ,-:_=i r-:-1 u:: . .::,: ' .. * .. : ,. '* ' ' *. I ::.:: "1 -.. rr*, 0 -H < rn N (f) Cl I Exelon is rushing the timeline to reissue a license(18 years ahead of time) to run Limer i ck Nu clear Plant into the unknown , I yet it took more than 5 months for the NRC to get back to me concerning an al ready known survey of fault lines. 1 4-1 3-LR 1 It took five months for the Nuclear Regulatory Commiss i on to answer my quest i on concerning how close the nearest fault I line is to Limerick Nuclear Plant. No wonder! Two faults are dangerously close. Cha l font Fault is only 9 miles East. 14_14_GE I Ramapo Fault is 17 miles Northwest.
This is alarming! 1 The 9-21-11 Mercurv article said" whether or not earthauake risk is a factor in the current rel i censina r eauest f or 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 r isks are far greater for Limerick than previously real i zed-increased by 141%. We now know Limerick is 3rd on nation's earthquake risk lis ,_t .Plus , evidence shows earthquakes i n the East can be far stronger than Limerick's " design basis" can withstand. 14-15-P A 1 There's a good chance that an earthquake can exceed Limerick's des i gn basis , causing a severe nuclear accident, jeopardizing the health , safety and financial well being of our ent i re region. The Virginia 8-24-11 earthquake caused shaking in PA at L imerick Nuclear Plant .Si nce January there have been 2 small earthquakes in Philadelphia, only 21 mi l es from Limerick. Shaking and breaking in mi l es of Limerick's buried underg r ound pipes and cables can lead to nuclear disaster. It's disquieting that NRC uses a " visual inspection" to determine damage on buried pipes. Pr oblems 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 fi res and earthquakes. To save money , Exelon typically con c ludes Lim e rick 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. The warning was tied t renewed focus on earthquake risk. I t's difficult to see how Limer i ck's design flaws can be fixed , even if Exelon WOU LD spend the money. There is no proof whatsoever Limerick's design can withstand ot her threats rang i ng from hurr i canes, tornadoes, flo o ds, o ter r orist attacks to an impact from a jet airliner. We need precaut i on before there is a catast r ophe. NRC should close Limeric k as soon as poss i ble . .£R--:?;;6 =-13 'JJH-o 3 c;2LL Appendix A A-182 Mendiola, Doris From: Sent: To:
Subject:
sunbeamsky [sunbeamsky@aol.com) Monday , October 31, 2011 2:28 PM Regner, Lisa power plant re newal /j '/d,P/L o-'8 /) 0 :J J .> -il ..._:-:;: . ;-l ; . . ::.::* .... *--*-:_, . .__ :.::.: :*TI i___j N 0 ===-ft JJd'-7-z; 3 Appendix A A-183 Mendiola, Doris From: Sent: To: Cc:
Subject:
Good Morning Smokowicz , April (Aprii.Smokowicz@graphicpkg .com) Wednesday , November 02, 2011 8: 49AM Regner , Lisa msworkdog@verizon. net Pottstown Mercury art i cle 10/27/11 I know this is late according to your article, but I wanted to s till send you some information. I feel that there is a lot of people that had not known to report anything because of not kno w 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 sh e 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 wh at ot h er information you would need but I would be happy to get you w hatever you might need. . :JJ ;-j --. J -** I --*--il 0 :n **-c: r*--L:.1 n-; cr ...... ; , .. -t< r.***: i 0 'f? =:_i < .1::: rn en 5ovsr ;f Appendix A A-184 . . % .F/,--33-¥ *'** :::. Appendix A A-185 .,. ..... . Uni t ed St a res Nuc:lc;n ReguLuor.y Co m mh;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. Name "\i e \r cr;_ SfJwi' c\?( Title:
- C \JC 1 z.e f\ Organization
- (f.l'\.1 t-rcL-* s of H-Me r; cO...... Address: 2 <{(' c;-IJ'] /J-otifl-tJ 1/ Y 5 -h City: fJv Tkio [# /"1 State: I It r Zip Code: . /'1 I# 0--Comment Forms may be maileq to: Chief , Rules, Announcements , an9 D ir e ctiv*94.
Mail Stop: TWB-05-B01M U.S. Nu cl ear Regulatory Commissio Washington, DC 20555-0001 Appendix A A-186 7 {)u t'"'-/1¥<..1;-+v (IH_/If41' iA e. :J-, 1/b><-}o j, _,_ ,JMfec -/-;/17 Comment(Cont/hlued)
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APPENDIX B 1 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 2 RENEWAL OF NUCLEAR POWER PLAN TS3
B-1 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 1 RENEWAL OF NUCLEAR POWER PLANTS 2 The table in this appendix summarizes the National Environmental Policy Act (NEPA) issues for 3 license renewal of nuclear power plants identified in Table B -1 in Appendix B, Subpart A, to 4 10 CFR Part 51. Data supporting this table are contained in NUREG -1437, Generic 5 Environmental Impact Statement for License Renewal of Nuclear Plants. Throughout this 6 supplemental environmental impact statement (SEIS), "generic" issues are also referred to as 7 Category 1 issues, and "site-specific" issues are also referred to as Category 2 issues. 8 Table B-1. Summary of Issues and Findings 9 Issue Type of Issue Findings Surface Water Quality, Hydrology, and Use Impacts of refurbishment on surface water quality 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.
Appendix B B-2 Issue Type of Issue Findings Discharge of chlorine or other biocides Generic 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 once -through 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 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) Refurbishment 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.
Appendix B B-3 Issue Type of Issue Findings Thermal plume barrier to migrating fish Generic 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 -thr ough 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 shellfish in early life stages Site-specific SMALL, MODERATE, OR LARGE. The impacts of entrainment are small at many plants but may be moderate 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).
Appendix B B-4 Issue Type of Issue Findings Heat shock Site-specific 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 shellfish in early life stages Generic SMALL. Entrainment of fish 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. 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).
Appendix B B-5 Issue Type of Issue Findings Groundwater quality degradation (Ranney wells) Generic 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) 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 Refurbishment impacts 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 impact s 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. Appendix B B-6 Issue Type of Issue Findings Impacts of electromagnetic fields on flora and fauna Generic 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. Floodplains and wetland on power line right -of-way Generic 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 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 Air quality during refurbishment (nonattainment and maintenance areas) 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 SMALL. Production of ozone and oxides of nitrogen is insignificant and does not contribute measurably to ambient levels of these gases. Land Use Onsite land use Generic 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. Power line right -of-way Generic 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 Radiation exposures to the public during refurbishment Generic 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. Occupational radiation exposures during refurbishment Generic 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. Appendix B B-7 Issue Type of Issue Findings Microbiological organisms (occupational health) Generic SMALL. Occupational health impacts are expected to be controlled by the continued application of accepted industrial hygiene practices to minimize worker exposures. Microbiological organisms (public health)(plants using lakes or canals, or cooling towers or cooling ponds that discharge to a small river) Site-specific 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). Noise 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 SMALL. Radiation doses to the public will continue at current levels associated with normal operations. Occupational radiation exposures (license renewal term) Generic 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 Housing 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). Public services: public safety, social services, and tourism and recreation Generic SMALL. Impacts to public safety, social services, and tourism and recreation are expected to be of small significance at all sites.
Appendix B B-8 Issue Type of Issue Findings Public services: public utilities Site-specific 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). Public services: education (refurbishmen t) 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). Public services: education (license renewal term) 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). Issue Type of Issue Findings Historic and archaeological resources Site-specific 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). 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. Postulated Accidents Design-basis accidents Generic SMALL. The NRC staff has concluded that the environmental impacts of design -basis accidents are of small significance for all plants.
Appendix B B-9 Issue Type of Issue Findings Severe accidents Site-specific 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 Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high-level waste) 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 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 Issue Type of Issue Findings Offsite radiological impacts (collective effects) [continued from previous page] Generic 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).
Appendix B B-10 Issue Type of Issue Findings Offsite radiological impacts (spent fuel and high-level waste disposal) Generic 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
100 millirem annual dose limit is about 3x10 -3. 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, Appendix B B-11 Issue Type of Issue Findings Offsite radiological impacts (spent fuel and high-level waste disposal) [continued from the previous page] Generic 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). Nonradiological impacts of the uranium fuel cycle 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.
Appendix B B-12 Issue Type of Issue Findings Low-level waste storage and disposal Generic 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.
Appendix B B-13 Issue Type of Issue Findings Decommissioning Radiation doses Generic 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. 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 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. Water quality Generic 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
APPENDIX C 1 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 2
C-1 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 1 The Atomic Energy Act of 1954, as amended (42 USC § 2011 et seq.), authorizes the 2 U.S. Nuclear Regulatory Commission (NRC) to enter into agreement with any state to assume 3 regulatory authority for certain activities (see 42 USC § 2012 et seq.). For example, through the 4 Agreement State Program, Pennsylvania assumed regulatory responsibility over certain 5 byproduct, source, and quantities of special nuclear materials not sufficient to form a critical 6 mass. The Bureau of Radiation Protection, Pennsylvania Department of Environmental 7 Protection, administers the Pennsylvania State Agreement Program. 8 In addition to carrying out some Federal programs, state legislatures develop their own laws. 9 State statutes supplement, as well as implement, Federal laws for protection of air, water 10 quality, and groundwater. State legislation may address solid waste management programs, 11 locally rare and endangered species, and historic and cultural resources. 12 The Clean Water Act (33 USC § 1251 et seq., herein referred to as CWA) allows for primary 13 enforcement and administration through state agencies, given that the state program is at least 14 as stringent as the Federal program. The state program must conform to the CWA and to the 15 delegation of authority for the Federal National Pollutant Discharge Elimination System 16 (NPDES) program from the U.S. Environmental Protection Agency (EPA) to the state. The 17 primary mechanism to control water pollution is the requirement for direct dischargers to obtain 18 an NPDES permit, or in the case of states where the authority has been delegated from the 19 EPA, a State Pollutant Discharge Elimination System permit, under the CWA. In Pennsylvania, 20 the Pennsylvania Department of Environmental Protection issues and enforces NPDES permits. 21 One important difference between Federal regulations and certain state regulations is the 22 definition of waters that the state regulates. Certain state regulations may include underground 23 waters, whereas the CWA only regulates surface waters. The Delaware River Basin 24 Commission regulates the Groundwater Protection Area in Southeastern Pennsylvania. 25 C.1. Federal and State Environmental Requirements 26 Limerick Generating Station, Units 1 and 2 (LGS) is subject to Federal and state requirements 27 for its environmental program. 28 Table C-1 lists the principle Federal and state environmental regulations and laws applicable to 29 the review of the environmental resources that could be affected by this project that may affect 30 license renewal applications for nuclear power plants. See Table C-2 of this supplemental 31 environmental impact statement for LGS's compliance status with these requirements. 32 Appendix C C-2 Table C-1. Federal and State Environmental Requirements 1 Law/regulation Requirements Current operating license and license renewal Atomic Energy Act (42 U.S.C. § 2011 et seq.) This Act is the fundamental U.S. law on both the civilian and the military 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 Code of Federal Regulations (10 CFR) Part 51, Energy "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." This part contains environmental protection regulations applicable to the NRC's domestic licensing and 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 Act (16 USC § 1451 et seq.) The Coastal Zone Management Act (CZMA) was established to preserve, protect, develop and where possible, restore or enhance, the resources of the Nation's coastal zone. Water resources protection Clean Water Act (CWA) (33 USC § 1251 et seq.) and the NPDES (40 CFR 122) The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters. Appendix C C-3 Law/regulation Requirements Wild and Scenic River Act (16 USC § 1271 et seq.) 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 Water Act (P.L. 206, No. 43 and 25 PA Code 109) The Pennsylvania Safe Drinking Water Act protects the public health and safety by assuring that public water systems provide a safe and adequate 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 Recovery Act (RCRA) (42 USC § 6901 et seq.) RCRA gives EPA authority to control hazardous waste. Before a material can be classified as a hazardous waste, it first must be a solid waste as 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.
Appendix C C-4 Law/regulation Requirements Pollution Prevention Act (42 USC § 13101 et seq.) 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. Protected species Endangered Species Act (ESA) (16 USC § 1531 et seq.) 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. C.2. Operating Permits and Other Requirements 1 Table C-2 lists the permits and licenses issued by Federal, state, and local authorities 2 for activities at LGS. 3 Appendix C C-5 Table C-2. Licenses and Permits 1 Permit Number Dates Responsible Agency Operating license NPF-39 Issued: 08/8/1985 Expires: 10/26/2024 NRC Operating license NPF-85 Issued: 08/25/1989 Expires: 06/22/2029 NRC NPDES Permit PA0051926 Issued: 03/31/2006 Expires: 03/31/2011 (administratively continued) Pennsylvania Department of Environmental Protection (PADEP) NPDES Permit PA0052221 Issued: 07/1/2009 Expires: 06/30/2014 PADEP 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 Issued: 11/7/1975 (Rev. 12-11/02/2004) Expires: No expiration date indicated DRBC Submission of project for DRBC approval and determination as to whether project impairs or conflicts with the DRBC comprehensive plan D-69-52 CP Issued: 02/18/1981 Expires: No expiration date indicated DRBC Submission of project for DRBC approval and determination as to whether project impairs or conflicts with the DRBC comprehensive plan D-77-110 CP Issued: 10/24/1984 Expires: No expiration date indicated DRBC Submission of project for DRBC approval and determination as to whether project impairs or conflicts with the DRBC comprehensive plan D-65-76 CP Issued: 12/18/1981 Expires: No expiration date indicated DRBC Title V Operating Permit TVOP-46-00038 Issued: 12/07/2009 Expires: 12/07/2014 PADEP Approval of design modifications, operation, and maintenance of Bradshaw Reservoir Dam D09-181A Issued: 12/30/1986 Expires: 12/30/2036 PADEP Appendix C C-6 Permit Number Dates Responsible Agency Maintenance Dredging Permit 19616 Issued: 07/16/1976 Expires: No date listed on permit PADEP Maintenance Dredging Permit 19615 Issued: 07/16/1976 Expires: No date listed on permit PADEP General Permit No. 11 for Maintenance Dredging 044610317 Issued: 12/07/2010 Expires: No expiration date indicated PADEP Permit to operate a public water system or a substantially modified facility 4696508 Issued: 03/25/1997 Expires: No date listed on permit PADEP Permit to operate a public water system or a substantially modified facility 4606501 Issued: 06/30/2006 Expires: No date listed on permit PADEP Permit to operate a public water system or a substantially modified facility 4609503 Issued: 11/20/2009 Expires: No date listed on permit PADEP Notification of regulated waste activity to obtain an EPA identification number for hazardous waste PAD000797951 Issued: 01/01/2001 Expires: N/A EPA Certificate of registration/permit to operate storage tanks None Issued: 02/04/2011 Expires: Renewed Annually PADEP Hazardous Materials Certificate of Registration 070810 750 001SU Issued: 06/09/2010 Expires: 06/30/2013 U.S. Department of Transportation Fire Marshall approval for storage and handling of flammable and combustible liquid 172,943 Issued: 02/25/1972 Expires: No date listed on approv al Pennsylvania Department of Labor and Industry, Boiler Section Fire Marshall approval for storage and handling of flammable and combustible liquid 186,609 Issued: 08/15/1977 Expires: No date listed on approval Pennsylvania Department of Labor and Industry, Boiler Section Fire Marshall approval for storage and handling of flammable and combustible liquid 186,610 Issued: 08/15/1977 Expires: No date listed on approval Pennsylvania Department of Labor and Industry, Boiler Section
Appendix C C-7 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. 46 -0128, Cert. 003 Issued: 08/31/2010 Expires: Renewed Annually PADEP Permit to operate encroachment E 09-77A Issued: 02/12/1988 Expires: 02/11/2038 PADEP Approval for disposal of licensed material generated by licensee's activiti es N/A Issued: 07/10/1996 (NRC) Issued: 03/23/1998 (PADEP) Expires: No date listed on approvals NRC and PADEP Source: Exelon 2011 C.3. Reference 1 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 2 Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating 3 License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) 4 Accession No. ML11179A104. 5
APPENDIX D 1 CONSULTATION CORRESPONDENCE 2
D-1 CONSULTATION CORRESPONDENCE 1 D.1. Background 2 The Endangered Species Act of 1973, as amended; the Magnuson Stevens Fisheries 3 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 4 (NHPA) require that Federal agencies consult with applicable State and Federal agencies and 5 groups before taking action that may affect threatened or endangered species, essential fish 6 habitat, or historic and archaeological resources, respectively. This appendix contains 7 consultation documentation. 8 Table D-1 lists the consultation documents sent between the U.S. Nuclear Regulatory 9 Commission (NRC) and other agencies. The NRC staff is required to consult with these 10 agencies based on the requirements of the statutes listed above. 11 Table D-1. Consultation Correspondence 12 Author Recipient Date of Letter/email Wrona, D., NRC M. Roberts, U.S. Fish and Wildlife Service (USFWS) 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
Appendix D D-2 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 Obermeyer, B., Delaware Tribe Historic Preservation Office D. Wrona, NRC September 23, 2011 ML11279A113 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
APPENDIX E 1 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE2
E-1 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 1 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 2 Regulatory Commission (NRC) and external parties as part of its environmental review for 3 Limerick Generating Station, Units 1 and 2 (LGS). All documents, with the exception of those 4 containing proprietary information, are available electronically from the NRC's Public Electronic 5 Reading Room found on the Internet at the following Web address: http://www.nrc.gov/reading -6 rm.html. From this site, the public can gain access to the NRC's Agencywide Documents 7 Access and Management System (ADAMS), which provides text and image files of NRC's 8 public documents in ADAMS. The ADAMS accession number for each document is included in 9 the following list. To locate a reference in ADAMS, click on the "Simple Search" tab at the top of 10 the web page, and enter the ADAMS accession number in the search box. 11 E.1. Environmental Review Correspondence 12 Table E-1 lists the environmental review correspondence in date order beginning with the 13 request by Exelon to renew the operating license for LGS. 14 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 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) ML11206A206 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) ML11214A048
E-2 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 Game Commission ML11234A650 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, Delaware Nation ML112340045 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 ML1123400 45 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
Appendix E E-3 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 2-Response to NRC Request for Additional Information, Dated February 28, 2012, Related to the License Renewal Application" ML12088A366 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
APPENDIX F 1 DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 2 IMPACT ANALYSIS 3
F-1 DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 1 IMPACTS ANALYSIS 2 F.1. Description of Projects Considered 3 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 4 in Sections 4.1 -4.9, are combined with other past, present, and reasonably foreseeable future 5 actions regardless of what agency (Federal or non -Federal) or person undertakes such other 6 actions. The U.S. Nuclear Regulatory Commission (NRC) staff (staff) used the information in 7 the environmental report (ER); responses to requests for additional information (RAIs); 8 information from other Federal, State, and local agencies; scoping comments; and information 9 gathered during the visits to the Limerick Generating Station, Units 1 and 2 (LGS) site to identify 10 other past, present, and reasonably foreseeable actions. Other actions and projects that were 11 identified during this review, and considered in the staff's independent analysis of the potential 12 cumulative effects, are described in Table F-1. 13 Table F-1. Projects and Actions Considered in the Cumulative Impacts Analysis 14 Project Name Summary of Project Location Status Moser Generating Station Oil Plant 60 MW, 3 unit oil -fired peaking plant Lower Pottstown Township, approximately 2 miles (mi) west (W) of LGs Operational (Exelon Corp. 2012); (Exelon 2011) Linfield Energy Center 616 MW, 3 unit natural gas plant 3 mi northwest (NW) of LGS Air-quality permitted in 2002, but project "withdrawn" and not constructed (EJN); (Enviro 2002) Schuylkil l Generating Station 196 MW, 3 unit oil power plant 29 mi NW of LGS Operational (Exelon Corp. 2012) Cromby Generation Station 2 unit fossil fuel power plant located on the Schuylkill River 8 mi south (S) of LGS Both units were retired from service in 2011 (Exelon Corp. 2012) Titus Coal Plant 261 MW, 5 unit coal power plant 18 mi NW of LGS Operational (GEO 2012a) Ontelaunee Energy Center Gas Plant 728 MW, 3 unit gas power plant 23 mi northeast (NE) of LGS Operational (GEO 2012b) Montenay Montgomery LP Waste Plant 32 MW, 1 unit waste power plant 17 mi southeast (SE) of LGS Operational (GEO 2012c) Grays Ferry Cogeneration Gas Plant 193 MW, 2 unit gas power plant 29 mi SE of LGS Operational (GEO 2012d) Appendix F F-2 Project Name Summary of Project Location Status Chester Generating Station Oil Plant 56 MW, 3 unit oil power plant 20 mi southwest (SW) of LGS Operational (GEO 2012e) 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 Generation Station Coal Plant 1,589 MW, 8 unit coal power plant 20 mi SE of LGS Operational (GEO 2012h) Florida Power & Light Energy Marcus Hook Gas Plant 836 MW, 4 unit gas power 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 discharges 1.7 mgd to the Schuylkill River 3 mi SE of LGS Operational (EPA 2012a) East Vincent Municipal Authority Sewage/wastewater treatment plant that discharges .5 mgd to the Schuylkill River 4 mi S of LGS Operational (EPA 2012a) North Coventry Municipal Authority Sewage/wastewater treatment plant that discharges 1.5 mgd to the Schuylkill River 2 mi W of LGS Operational (EPA 2012a) Phoenixville Borough Sewage Treatment Plant Sewage/wastewater treatment plant that discharges 4 mgd to the Schuylkill River 9 mi SE of LGS Operational (EPA 2012a) Lower Frederick Township Sewage Treatment Plant Sewage/wastewater treatment plant that discharges .2 mgd to the Perkiomen Creek 7 mi NE of LGS Operational (EPA 2012a) Appendix F F-3 Project Name Summary of Project Location Status Schwenksville Borough Authority Sewage Treatment Plant Sewage/wastewater treatment plant that discharges .3 mgd to the Perkiomen Creek 7 mi NE of LGS Operational (EPA 2012a) Pottstown Water Treatment Plant Sewage/wastewater treatment plant withdraws up to 5 mgd from the Schuylkill River 2 mi W of LGS Operational (EPA 2012b) Pennsylvania American Water Company, Shady Lane Water Treatment Plant Sewage/wastewater treatment plant that discharges .111 mgd to the Schuylkill River 2 mi S of LGS Operational (EPA 2012a) JBS Souderton Inc., Industrial Waste Wate r Treatment Plant 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) 15 mi NE of LGS Operational (DRBC
2011) Warwick Drainage Company Public wastewater collection, treatment, and disposal that discharges .0135 mgd to the French Creek (Schuylkill River Tributary) 8 mi NW of LGS 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 Sanatoga Quarry Quarry 3,650 feet NW, directly adjacent to Schuylkill River and contiguous with the LGS plant site property Operational (Exelon 2011) 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) Appendix F F-4 Project Name Summary of Project Location Status 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) Independent Spent Fuel Storage Installation (ISFSI) The ISFSI provides dry storage for spent fuel at the LGS site At LGS Operational (Exelon 2011) Recticon/Allied Steel Corp. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) site 1 mi S of LGS CERCLA site (EPA) Occidental Chemical Corporation Remediation Site (Formerly Firestone Tire and Rubber Manufacturing Facility) Occidental Chemical Corporation is remediating under the oversight of EPA 2.5 mi W of LGS Superfund site (Exelon 2011)
Appendix F F-5 F.2. References 1 [DRBC] Delaware River Basin Commission. 2012. DOCKET NO. D -1996-021-4, JBS 2 Souderton, Inc., Industrial Wastewater Treatment Plant, Franconia Township, Montgomery 3 County, Pennsylvania. Available at 4 <http://www.state.nj.us/drbc/library/documents/dockets/1996 -021-4.pdf> (accessed 5 7 July 2012). 6 [EJN] Energy Justice Network. Linfield Energy Center. Available at 7 <http://www.energyjustice.net/map/displayfacility-68986.htm> (accessed 11 July 2012). 8 [Enviro] Enviro.blr.com. 2002. Environmental Compliance News. "DEP Issues Air Plan Approval 9 to Florida Power and Light for Its Linfield Energy Center Project." April 10, 2002. Available at 10 <http://enviro.blr.com/environmental -news/air/air -permitting/DEP -Issues-Air-Plan-Approval-to-11 Florida-Power-and-/> (accessed 11 July 2012). 12 [EPA] U.S. Environmental Protection Agency. 2012a. Envirofacts. Air Facility System (AFS). 13 Available at 14 <http://ofmpub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=420 15 2900003> (accessed 11 July 2012). 16 [EPA] U.S. Environmental Protection Agency. 2012a. Envirofacts, Permit Compliance System 17 (PCS) and Integrated Compliance Information System (ICIS) databases. Available at 18 <http://www.epa.gov/enviro/facts/pcs -icis/index.html > (accessed 11 July 2012). 19 [EPA] U.S. Environmental Protection Agency. 2012b. Envirofacts. Comprehensive 20 Environmental Response, Compensation, and Liability Information System (CERCLIS). 21 Available at 22 <http://ofmpub.epa.gov/enviro/cerclisquery.get_report?pgm_sys_id=PAD002353969 > 23 (accessed 11 July 2012) 24 [Exelon Corp] Exelon Corporation. 2012. Energy Diversity for Pennsylvania. Available at 25 <http://www.exeloncorp.com/community/locations/pennsylvania.aspx > (accessed 11 July 2012). 26 [Exelon] Exelon Generation Company, LLC. 2011. Applicant's Environmental Report -Operating 27 License Renewal Stage, Limerick Generating Station, Units 1 and 2, Docket Numbers 50 -352 28 and 50-353, License Numbers NPF -39 and NPF -85. Exelon Generation Company, LLC. 29 Agencywide Documents Access and Management Systems Accession No. ML11179A104. 30 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012a. Available at 31 <http://www.dcnr.state.pa.us/stateparks/findapark/evansburg/index.htm > (accessed 32 8 August 2012). 33 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012b. Available at 34 <http://www.dcnr.state.pa.us/stateparks/findapark/fortwashington/index.htm > (accessed 35 8 August 2012). 36 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012c. Available at 37 <http://www.dcnr.state.pa.us/stateparks/findapark/norristown/index.htm > (accessed 38 8 August 2012). 39 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012d. Available at 40 <http://www.dcnr.state.pa.us/stateparks/findapark/marshcreek/index.htm > (accessed 41 8 August 2012). 42 Appendix F F-6 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012e. Available at 1 <http://www.dcnr.state.pa.us/stateparks/findapark/frenchcreek/index.htm > (accessed 2 8 August 2012). 3 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012f. Available at 4 <http://www.dcnr.state.pa.us/stateparks/findapark/ridleycreek/index.htm > (accessed 5 8 August 2012). 6 [GEO] Global Energy Observatory. 2012a. Available at 7 <http://globalenergyobservatory.org/geoid/1737 > (accessed 11 July 2012). 8 [GEO] Global Energy Observatory. 2012b. Available at 9 <http://globalenergyobservatory.org/geoid/4624 > (accessed 11 July 2012). 10 [GEO] Global Energy Observatory. 2012c. Available at 11 <http://globalenergyobservatory.org/geoid/4351 > (accessed 11 July 2012). 12 [GEO] Global Energy Observatory. 2012d. Available at 13 <http://globalenergyobservatory.org/geoid/3386 > (accessed 11 July 2012). 14 [GEO] Global Energy Observatory. 2012e. Available at 15 <http://globalenergyobservatory.org/geoid/2651 > (accessed 11 July 2012). 16 [GEO] Global Energy Observatory. 2012f. Available at 17 <http://globalenergyobservatory.org/geoid/4778 > (accessed 11 July 2012). 18 [GEO] Global Energy Observatory. 2012g. Available at 19 <http://globalenergyobservatory.org/geoid/5080 > (accessed 11 July 2012). 20 [GEO] Global Energy Observatory. 2012h. Available at 21 <http://globalenergyobservatory.org/geoid/530 > (accessed 11 July 2012). 22 [GEO] Global Energy Observatory. 2012i. Available at 23 <http://globalenergyobservatory.org/geoid/3221 > (accessed 11 July 2012). 24 [GEO] Global Energy Observatory. 2012j. Available at 25 <http://globalenergyobservatory.org/geoid/320 > (accessed 11 July 2012). 26
NRC FORM 335 (12-2010) U.S. NUCLEAR REGULATORY COMMISSION
- 1. REPORT NUMBER NRCMD 3.7 BIBLIOGRAPHIC DATA SHEET (See in s tructions on the reverse) 2. TITLE AND SUBTITLE Generic Environmental Impac t Statement for License Renewal of Nuclear Plants Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Draft Report 5. AUTHOR(S)
See Chapter 10 (Assigned by NRC, Add Vol., Supp., Rev., and Addendum Numbers, if any.) NUREG-1437, Supplement 49 3. DATE REPORT PUBLISHED I 4. FIN OR GRANT NUMBER 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 le ss) 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 eva l uates the environmental impacts of the proposed action and al ternatives 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 no t great enough to deny the option of li cense renewal for energy planning decisionmakers. This recommendation is based on the fo ll owing:
- the analysis and findings in NUREG 1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants;
- th e environmental report submi tt ed by Exelon;
- consultation with Federal, state, and local agencies;
- the NRC's environmental review; and
- consideration of pub l ic comments received during the scoping process 12. KEY WORDS/DESCRIPTORS (List words or phrase s that will assist researchers in locating the report.) Lim e rick Generating Station, Un i ts 1 and 2 Limerick Exelon Generation Company, LLC Exelon Supplemental to the Generic Environmental Impact Statement , SEIS Generic Environmental Impac t Statement, GElS National Environmenta l Pol i cy Act, NEP A License Renewal NUREG-1 437, 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
UNITED STATES NUCLEAR REGULATORY COMMISSIONWASHINGTON, 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}}