ML072540026
| ML072540026 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/30/2007 |
| From: | NRC/NRR/ADRO/DLR |
| To: | |
| Beltz G | |
| References | |
| NUREG-1437 S32 DFC | |
| Download: ML072540026 (458) | |
Text
NUREG-1437 Supplement 32 Generic Environmental Impact Statement for
Nuclear Plants Supplement 32 Regarding Wolf Creek Generating Station Draft Report for Comment U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC 20555-0001 AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference MaterialAs of November 1999, you may electronically access NUREG-series publications and other NRC records at NRC's Public Electronic Reading Room at http://www.nrc.gov/r eading-rm.html
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NUREG-1437 Supplement 32 Generic Environmental Impact Statement for
Nuclear Plants Supplement 32 Regarding Wolf Creek Generating Station Draft Report for CommentManuscript Completed: September 2007 Date Published: September 2007Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001 COMMENTS ON DRAFT REPORTAny interested party may submit comments on this report for consideration by the NRC staff.Comments may be accompanied by additional relevant information or supporting data. Please specify thereport number NUREG-1437, Supplement 32, draft, in your comments, and send themby December 26, 2007 to the following address:Chief, Rulemaking, Directives and Editing BranchU.S. Nuclear Regulatory Commission Mail StopT6-D59 Washington, DC 20555-0001Electronic comments may be submitted to the NRC by the Internet at WolfCreekEIS@nrc.gov.
For any questionsabout the material in thisreport, please contact:
C. JacobsU.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Phone: 301-415-3874 E-mail: cjj@nrc.gov September 2007 iii Draft NUREG-1437, Supplement 32 Abstract 1 2 3The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of 4renewing nuclear power plant operating licenses (OLs) for a 20-year period in its Generic 5Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 6Volumes 1 and 2, and codified the results in 10 CFR Part 51. In the GEIS (and its 7Addendum 1), the Staff identified 92 environmental issues and reached generic conclusions 8related to environmental impacts for 69 of these issues that apply to all plants or to plants with 9specific design or site characteristics. Additional plant-specific review is required for the 10remaining 23 issues. These plant-specific reviews are to be included in a supplement to the 11 GEIS.12 13This draft supplemental environmental impact statement (SEIS) has been prepared in response 14to an application submitted by Wolf Creek Nuclear Operating Corporation (WCNOC) to the NRC 15to renew the OL for Wolf Creek Generating Station, Unit 1 (WCGS) for an additional 20 years 16under 10 CFR Part 54. This draft SEIS includes the NRC staff's analysis that considers and 17weighs the environmental impacts of the proposed action, the environmental impacts of 18alternatives to the proposed action, and mitigation measures available for reducing or avoiding 19adverse impacts. It also includes the Staff's preliminary recommendation regarding the 20 proposed action.
21 22Regarding the 69 issues for which the GEIS reached generic conclusions, neither WCNOC nor 23the Staff has identified information that is both new and significant for any issue that applies to 24WCGS. In addition, the Staff determined that information provided during the scoping process 25was not new and significant with respect to the conclusions in the GEIS. Therefore, the Staff 26concludes that the impacts of renewing the OL for WCGS will not be greater than impacts 27identified for these issues in the GEIS. For each of these issues, the Staff's conclusion in the 28 GEIS is that the impact is of SMALL (a)significance (except for collective off-site radiological 29impacts from the fuel cycle and high-level waste and spent fuel, which were not assigned a 30single significance level).
31 32We address the remaining 23 issues that apply to WCGS in this draft SEIS. With exceptions of 33water use conflicts and impacts to associated ecological resources, potential environmental 34impacts of operating license renewal would be SMALL. For water use conflicts, the impact 35 would be SMALL to MODERATE.(b) If water use conflicts occur, associated impacts in the 36Neosho River due to impingement and habitat reduction on aquatic organisms, including 37threatened and endangered species, would be SMALL to MODERATE. Due to the increased 38 (a)Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.(b)Environmental effects are sufficient to alter noticeably but not to destabilize important attributes of the resource.
AbstractDRAFT NUREG-1437, Supplement 32 iv September 2007 potential for impingement and habitat reduction during periods with water use conflicts, 1cumulative impacts on aquatic organisms, including threatened and endangered species, would 2be SMALL to MODERATE.
3 4The NRC staff's preliminary recommendation is that the Commission determines that the 5adverse environmental impacts of license renewal for WCGSare not so great that preserving 6the option of license renewal for energy-planning decision makers would be unreasonable. This 7recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental 8Report submitted by WCGS; (3) consultation with Federal, State, and local agencies; (4) the 9Staff's own independent review; and (5) the Staff's consideration of public comments received 10 during the scoping process.
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30Paperwork Reduction Act Statement 31 32 This NUREG does not contain information collection requirements and, therefore, is not 33subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et 34 seq.).35 36 Public Protection Notification 37 38The NRC may not conduct or sponsor, and a person is not required to respond to, a request 39for information or an information collection requirement unless the requesting document 40displays a currently valid OMB control number.
41 September 2007 v Draft NUREG-1437, Supplement 32 ContentsAbstract..............................................................................................................................iii Executive Summary..........................................................................................................xxAbbreviations/Acronyms.................................................................................................xxv 1.0 Introduction ............................................................................................................1-1 1.1 Report Contents..............................................................................................1-2 1.2 Background.....................................................................................................1-3 1.2.1 Generic Environmental Impact Statement..........................................1-3 1.2.2 License Renewal Evaluation Process.................................................1-5 1.3 The Proposed Federal Action.........................................................................1-7 1.4 The Purpose and Need for the Proposed Action............................................1-8 1.5 Compliance and Consultations.......................................................................1-8 1.6 References.....................................................................................................1-9 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment ............................................................................................................2-1 2.1 Plant and Site Description and Proposed Plant Operation During the Renewal Term................................................................................................2-1 2.1.1 External Appearance and Setting.......................................................2-4 2.1.2 Reactor Systems.................................................................................2-8 2.1.3 Cooling and Auxiliary Water Systems.................................................2-8 2.1.3.1 Intake..................................................................................2-8 2.1.3.2 Discharge..........................................................................2-10 2.1.3.3 Service Water Systems.....................................................2-10 2.1.3.4 Makeup Water..................................................................2-11 2.1.4 Radioactive Waste Management Systems and Effluent Control Systems................................................................................2-12
2.1.4.1 Liquid Waste Processing Systems and Effluent Controls............................................................................2-13
ContentsDraft NUREG-1437, Supplement 32 vi September 2007 2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls............................................................................2-14 2.1.4.3 Solid Waste Processing....................................................2-15 2.1.5 Nonradioactive Waste Systems........................................................2-15 2.1.5.1 Nonradioactive Waste Streams........................................2-15 2.1.5.2 Pollution Prevention and Waste Minimization...................2-16 2.1.6 Facility Operation and Maintenance.................................................2-16 2.1.7 Power Transmission System.............................................................2-17
2.2 Plant Interaction with the Environment.........................................................2-18 2.2.1 Land Use...........................................................................................2-18 2.2.2 Water Use.........................................................................................2-20 2.2.3 Water Quality....................................................................................2-22
2.2.3.1 Surface Water...................................................................2-22 2.2.3.1.1 General and Regional Surface Water Quality Monitoring .......................................2-23 2.2.3.1.2 WCGS Pre-Operational Surface Water Quality Monitoring .......................................2-24 2.2.3.1.3 WCGS NPDES Monitoring ..........................2-24 2.2.3.1.4 WCGS Environmental and Radiological Monitoring....................................................2-28 2.2.3.2 Groundwater.....................................................................2-35 2.2.4 Air Quality.........................................................................................2-39 2.2.5 Aquatic Resources............................................................................2-42 2.2.5.1 Water Body Characteristics..............................................2-42 2.2.5.1.1 Wolf Creek and Coffey County Lake............2-42 2.2.5.1.2 Neosho River and John Redmond Reservoir......................................................2-45 2.2.5.2 Chemical Contaminants near WCGS...............................2-48 2.2.5.2.1 Surface Water Toxicity Testing....................2-48 ContentsSeptember 2007 vii Draft NUREG-1437, Supplement 32 2.2.5.2.2 Radionuclide Concentrations in Tissue Samples.......................................................2-50
2.2.5.3 Aquatic Biological Communities.......................................2-51 2.2.5.3.1 Wolf Creek and Coffey County Lake ...........2-51 2.2.5.3.2 Neosho River and John Redmond Reservoir......................................................2-59 2.2.5.4 Rare Aquatic Species........................................................2-65 2.2.5.4.1 Topeka Shiner..............................................2-65 2.2.5.4.2 Neosho Madtom...........................................2-67 2.2.5.4.3 Neosho Mucket Mussel................................2-69 2.2.5.4.4 Other State-Listed Species..........................2-69 2.2.5.4.5 Summary......................................................2-70
2.2.6 Terrestrial Resources .......................................................................2-70
2.2.6.1 Terrestrial Upland Plant Communities..............................2-70 2.2.6.1.1 WCGS Property............................................2-70 2.2.6.1.2 Transmission Line ROWs.............................2-71 2.2.6.2 Riparian and Wetland Plant Communities........................2-72 2.2.6.2.1 Coffey County Lake and Wolf Creek............2-72 2.2.6.2.2 Lime Sludge Pond.........................................2.74 2.2.6.2.3 John Redmond Reservoir and the Neosho River.............................................................2-74 2.2.6.2.4 Transmission Line ROWs.............................2-74 2.2.6.3 Terrestrial Fauna..............................................................2-75 2.2.6.4 Rare Terrestrial Species...................................................2-77 2.2.6.4.1 Piping Plover................................................2-79 2.2.6.4.2 Whooping Crane..........................................2-79 2.2.6.4.3 Least Tern....................................................2-80 2.2.6.4.4 Mead's Milkweed..........................................2-81 2.2.6.4.5 Summary......................................................2-82 2.2.7 Radiological Impacts .....................................................................2-82 2.2.8 Socioeconomic Factors.....................................................................2-84 ContentsDraft NUREG-1437, Supplement 32 viii September 2007 2.2.8.1 Housing.............................................................................2-85 2.2.8.2 Public Services.................................................................2-85 2.2.8.2.1 Water Supply................................................2-85 2.2.8.2.2 Education.....................................................2-88 2.2.8.2.3 Transportation..............................................2-88 2.2.8.3 Off-site Land Use..............................................................2-90 2.2.8.3.1 Coffey County...............................................2-90 2.2.8.3.2 Lyon County.................................................2-92 2.2.8.4 Visual Aesthetics and Noise.............................................2-93 2.2.8.5 Demography....................................................................2-93 2.2.8.5.1 Transient Population....................................2-95 2.2.8.5.2 Migrant Farm Worker...................................2-95
2.2.8.6 Economy...........................................................................2-96 2.2.8.6.1 Employment and Income..............................2-96 2.2.8.6.2 Unemployment.............................................2-97 2.2.8.6.3 Taxes...........................................................2-97 2.2.9 Historic and Archaeological Resources............................................2-98 2.2.9.1 Cultural Background.........................................................2-98 2.2.9.2 Historic and Archaeological Resources at the WCGS Site....................................................................................2-99 2.2.9.2.1 Previously Identified Resources...................2-99 2.2.9.2.2 Results of Walkover Survey.......................2-100 2.2.9.2.3 Potential Archaeological Resources..........2-100 2.2.10 Related Federal Project Activities and Consultations.....................2-100 2.3 References.................................................................................................2-101 3.0 Environmental Impacts of Refurbishment................................................................3-1 3.1 References ...................................................................................................3-4 ContentsSeptember 2007 ix Draft NUREG-1437, Supplement 32 4.0 Environmental Impacts of Operation.......................................................................4-1 4.1 Cooling System...............................................................................................4-2 4.1.1 Water Use Conflicts..........................................................................4-10 4.1.1.1 Impacts to Instream and Riparian Communities.............4-12 4.1.1.1.1 Instream and Riparian Impacts in Wolf Creek............................................................4-12 4.1.1.1.2 Instream and Riparian Impacts in the Neosho River................................................4-13
4.1.1.2 Availability of Water During License Renewal Term.......4-15
4.1.1.2.1 Availability of Water from Wolf Creek...........4-15 4.1.1.2.2 Availability of Water from Neosho River.......4-16
4.1.1.3 Summary of Impacts Related to Water Use Conflicts.....4-19
4.1.2 Entrainment of Fish and Shellfish in Early Life Stages.....................4-20 4.1.2.1 Coffey County Lake Cooling Water Entrainment.............4-20 4.1.2.2 Neosho River Makeup Water Entrainment......................4-21 4.1.2.3 Summary of Entrainment Impacts...................................4-23 4.1.3 Impingement of Fish and Other Aquatic Organisms.........................4-23 4.1.3.1 Impingement at Coffey County Lake Cooling Water Intake...............................................................................4-23
4.1.3.1.1 Impingement Monitoring...............................4-23 4.1.3.1.2 Assessment of Impingement Impacts..........4-25 4.1.3.2 Impingement at Neosho River Makeup Water Intake......4-33 4.1.3.2.1 Impingement Monitoring...............................4-33 4.1.3.2.2 Assessment of Impingement Impacts..........4-33
4.1.3.3 Summary of Impingement Impacts..................................4-36
ContentsDraft NUREG-1437, Supplement 32 x September 2007 4.1.4 Heat Shock.......................................................................................4-37 4.1.4.1 Cooling Water Discharge to Coffey County Lake............4-38 4.1.4.2 Coffey County Lake Discharge to Wolf Creek and the Neosho River...................................................................4-40 4.1.4.3 Summary of Heat Shock Impacts....................................4-41 4.1.5 Microbiological Organisms (Public Health).......................................4-41 4.2 Transmission Lines.......................................................................................4-42 4.2.1 Electromagnetic Fields-Acute Effects...............................................4-46 4.2.2 Electromagnetic Fields-Chronic Effects............................................4-47 4.3 Radiological Impacts of Normal Operations.................................................4-48 4.4 Socioeconomic Impacts of Plant Operations During the License Renewal Term ........................................................................................4-49 4.4.1 Housing Impacts...............................................................................4-51 4.4.2 Public Services: Public Utility Impacts.............................................4-52 4.4.3 Off-site Land Use During Operations................................................4-53 4.4.4 Public Services: Transportation Impacts During Operations...........4-55 4.4.5 Historic and Archaeological Resources............................................4-55
4.4.5.1 Site Specific Cultural Resources Information..................4-55 4.4.5.2 Conclusions.....................................................................4-56 4.4.6 Environmental Justice.......................................................................4-56 4.4.6.1 Minority Population in 2000.............................................4-57 4.4.6.2 Low-Income Populations 2000........................................4-59 4.4.6.3 Analysis of Impacts.........................................................4-59 4.4.6.4 Subsistence Consumption of Fish and Wildlife...............4-59 4.5 Groundwater Use and Quality......................................................................4-62 4.5.1 Groundwater Use Conflicts...............................................................4-63 4.5.1.1 Aquifers Associated with Wolf Creek, and between Wolf Creek and Neosho River.........................................4-64 4.5.1.2 Aquifers Associated with Neosho River..........................4-64 4.5.1.3 Groundwater Users Potentially Impacted........................4-65 4.5.1.4 Summary of Impacts Related to Groundwater Use ContentsSeptember 2007 xi Draft NUREG-1437, Supplement 32 Conflicts...........................................................................4-65 4.5.2 Groundwater Quality Degradation.....................................................4-66 4.5.2.1 Water Quality in Coffey County Lake..............................4-67 4.5.2.2 Potential for Infiltration to Groundwater...........................4-67 4.5.2.3 Potential for Groundwater Impacts..................................4-68 4.5.2.4 Summary of Impacts Related to Groundwater Quality Degradation.........................................................4-69 4.6 Threatened or Endangered Species.............................................................4-69 4.6.1 Aquatic Species................................................................................4-70 4.6.2 Terrestrial Species............................................................................4-72 4.6.3 Conclusions......................................................................................4-75 4.7 Evaluation of New and Potentially Significant Information on Impacts of Operations During the Renewal Term..........................................................4-75 4.8 Cumulative Impacts......................................................................................4-76 4.8.1 Cumulative Impacts on Aquatic Resources......................................4-76 4.8.2 Cumulative Impacts on Terrestrial Resources..................................4-78 4.8.3 Cumulative Human Health Impacts...................................................4-79 4.8.4 Cumulative Socioeconomic Impacts ................................................4-80 4.8.5 Cumulative Impacts on Groundwater Use and Quality.....................4-80 4.8.6 Conclusions Regarding Cumulative Water Use Impacts..................4-81 4.8.7 Conclusions Regarding Cumulative Impacts....................................4-82 4.9 Summary of Impacts of Operations During the Renewal Term....................4-82 4.10 References...................................................................................................4-83 5.0 Environmental Impacts of Postulated Accidents.....................................................5-1 5.1 Postulated Plant Accidents.............................................................................5-1 5.1.1 Design-Basis Accidents......................................................................5-2 5.1.2 Severe Accidents................................................................................5-3 5.2 Severe Accident Mitigation Alternatives.........................................................5-4 5.2.1 Introduction.........................................................................................5-5 5.2.2 Estimate of Risk..................................................................................5-6 ContentsDraft NUREG-1437, Supplement 32 xii September 2007 5.2.3 Potential Plant Improvements.............................................................5-8 5.2.4 Evaluation of Risk Reduction and Costs of Improvements.................5-8 5.2.5 Cost-Benefit Comparison....................................................................5-9 5.2.6 Conclusions......................................................................................5-10 5.3 References...................................................................................................5-10 6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management............................................................................................................6-1 6.1 The Uranium Fuel Cycle.................................................................................6-2 6.2 References.....................................................................................................6-9 7.0 Environmental Impacts of Decommissioning...........................................................7-1 7.1 Decommissioning...........................................................................................7-2 7.2 References.....................................................................................................7-4 8.0 Environmental Impacts of Alternatives to License Renewal....................................8-1 8.1 No-Action Alternative......................................................................................8-1 8.1.1 Land Use...........................................................................................8-2 8.1.2 Ecology ............................................................................................ 8-2 8.1.3 Water Use and Quality - Surface Water............................................8-3 8.1.4 Water Use and Quality - Groundwater..............................................8-3 8.1.5 Air Quality..........................................................................................8-3 8.1.6 Waste................................................................................................8-4 8.1.7 Human Health....................................................................................8-4 8.1.8 Socioeconomics................................................................................8-4 8.1.9 Socioeconomics (Transportation)......................................................8-4 8.1.10 Aesthetics..........................................................................................8-5 8.1.11 Historic and Archeological Resources...............................................8-5 8.1.12 Environmental Justice.......................................................................8-5 8.2 Alternative Energy Sources............................................................................8-6 8.2.1 Coal-Fired Generation........................................................................8-8 8.2.1.1 Land Use............................................................................8-9 8.2.1.2 Ecology.............................................................................8-10 8.2.1.3 Water Use and Quality......................................................8-10 ContentsSeptember 2007 xiii Draft NUREG-1437, Supplement 32 8.2.1.3.1 Surface Water..............................................8-10 8.2.1.3.2 Groundwater.................................................8-11 8.2.1.4 Air Quality.........................................................................8-11 8.2.1.5 Waste................................................................................8-15 8.2.1.6 Human Health...................................................................8-15 8.2.1.7 Socioeconomics................................................................8-16 8.2.1.8 Aesthetics.........................................................................8-17 8.2.1.9 Historic and Archaeological Resources............................8-18 8.2.1.10 Environmental Justice.......................................................8-18 8.2.2 Natural Gas-Fired Generation...........................................................8-21 8.2.2.1 Land Use..........................................................................8-22 8.2.2.2 Ecology.............................................................................8-23 8.2.2.3 Water Use and Quality......................................................8-24 8.2.2.3.1 Surface Water..............................................8-24 8.2.2.3.2 Groundwater.................................................8-24 8.2.2.4 Air Quality.........................................................................8-25 8.2.2.5 Waste................................................................................8-26 8.2.2.6 Human Health...................................................................8-26 8.2.2.7 Socioeconomics................................................................8-26 8.2.2.8 Aesthetics.........................................................................8-27 8.2.2.9 Historic and Archaeological Resources............................8-28 8.2.2.10 Environmental Justice.......................................................8-28 8.2.3 Nuclear Power Generation................................................................8-30 8.2.3.1 Land Use..........................................................................8-31 8.2.3.2 Ecology.............................................................................8-31 8.2.3.3 Water Use and Quality......................................................8-32 8.2.3.3.1 Surface Water..............................................8-32 8.2.3.3.2 Groundwater.................................................8-32 8.2.3.4 Air Quality.........................................................................8-33 8.2.3.5 Waste................................................................................8-33 8.2.3.6 Human Health...................................................................8-33 8.2.3.7 Socioeconomics................................................................8-33 8.2.3.8 Aesthetics.........................................................................8-34 ContentsDraft NUREG-1437, Supplement 32 xiv September 2007 8.2.3.9 Historic and Archaeological Resources............................8-34 8.2.3.10 Environmental Justice.......................................................8-34 8.2.4 Purchased Electrical Power..............................................................8-35 8.2.5 Other Alternatives.............................................................................8-36 8.2.5.1 Oil-Fired Generation.........................................................8-36 8.2.5.2 Wind Power......................................................................8-36 8.2.5.3 Solar Power......................................................................8-37 8.2.5.4 Hydropower.......................................................................8-38 8.2.5.5 Geothermal Energy...........................................................8-38 8.2.5.6 Wood Waste.....................................................................8-38 8.2.5.7 Municipal Solid Waste......................................................8-39 8.2.5.8 Other Biomass-Derived Fuels...........................................8-40 8.2.5.9 Fuel Cells..........................................................................8-41 8.2.5.10 Delayed Retirement..........................................................8-41 8.2.5.11 Conservation.....................................................................8-42 8.2.6 Combination of Alternatives..............................................................8-43 8.3 Summary of Alternatives Considered...........................................................8-45 8.4 References...................................................................................................8-46 9.0 Summary and Conclusions......................................................................................9-1 9.1 Environmental Impacts of the Proposed Action - License Renewal...............9-4 9.1.1 Unavoidable Adverse Impacts............................................................9-6 9.1.2 Irreversible or Irretrievable Resource Commitments...........................9-6 9.1.3 Short-Term Use Versus Long-Term Productivity................................9-6 9.2 Relative Significance of the Environmental Impacts of License Renewal and Alternatives...............................................................................9-7 9.3 Staff Conclusions and Recommendations......................................................9-9 9.4 References.....................................................................................................9-9 Appendix A Comments Received on the Environmental Review.........................................A-1 Appendix B Contributors to the Supplement.........................................................................B-1 Appendix C Chronology of NRC Staff Environmental Review Correspondence Related to Wolf Creek Nuclear Operating Corporation's Application for ContentsSeptember 2007 xv Draft NUREG-1437, Supplement 32 License Renewal of Wolf Creek Generating Station.........................................C-1 Appendix D Organizations Contacted...................................................................................D-1 Appendix E Wolf Creek Generating Station Compliance Status and Consultation Correspondence...........................................................................E-1 Appendix F GEIS Environmental Issues Not Applicable to Wolf Creek Generating Station................................................................................................................F-1 Appendix G Severe Accident Mitigation Alternatives (SAMAs) for Wolf Creek Generating Station............................................................................................G-1 Draft NUREG-1437, Supplement 32 xvi September 2007 Figures2-1 Location of WCGS, 50-Mile Radius...............................................................................2-2 2-2 Location of WCGS, 6-Mile Radius.................................................................................2-3 2-3 WCGS Property Boundaries and Environs....................................................................2-5 2-4 WCGS Facility Layout....................................................................................................2-6 2-5 WCGS Transmission Lines............................................................................................2-7 2-6 WCGS NPDES Outfall Locations.................................................................................2-27 2-7 Coffey County Lake Surface Water Tritium Data.........................................................2-33 2-8 Groundwater Sampling Location Map..........................................................................2-37 2-9 Surface Water Bodies Associated with WCGS ...........................................................2-43 4-1 Minority block groups in 2000 within a 50-mi radius of WCGS....................................4-58 4-2 Low-income block groups within a 50-mi radius of WCGS..........................................4-60 September 2007 xvii Draft NUREG-1437, Supplement 32 Tables2-1 WCGS Transmission Line ROWs.............................................................................2-17 2-2 Effluent Limitations - NPDES Permit for WCGS.......................................................2-25 2-3 Summary of 2006 WCNOC Surface Water Quality Monitoring Program..................2-29 2-4 Summary of 2005-2006 KDHE Surface Water Quality Monitoring Program.............2-31 2-5 Summary of 2005-2006 Tritium Concentrations in Surface Water and Fish Samples....................................................................................................................2-342-6 Summary of 2006 WCNOC Groundwater Quality Monitoring Program ....................2-38 2-7 Summary of 2005-2006 KDHE Groundwater Quality Monitoring Program...............2-38 2-8 Fish Species Occurring in the Wolf Creek Drainage.................................................2-52 2-9 Catch-per-unit-effort (CPUE) of Selected Fish Species in Coffey County Lake........2-55 2-10 Fish Species Occurring in the Neosho River.............................................................2-60 2-11 Protected Aquatic Species Potentially Occurring in the Vicinity of WCGS and the Associated Transmission Line ROWs.......................................................................2-66 2-12 Protected Terrestrial Species Potentially Occurring in the Vicinity of WCGS and the Associated Transmission Line ROWs..........................................................2-78 2-13 WCGS Permanent Employee Residence by County in 2006....................................2-84 2-14 Housing in Coffey and Lyon Counties, Kansas in 2000............................................2-85 2-15 Coffey County Public Water Supply Systems and Capacities...................................2-86 2-16 Lyon County Public Water Supply Systems and Capacities.....................................2-87 2-17 Traffic Counts for Roads in the Vicinity of WCGS, 2004...........................................2-90 2-18 Land Use in Coffey County, 2002.............................................................................2-91 2-19 Land Use in Lyon County, 2002................................................................................2-92 2-20 Population and Percent Growth in Coffey and Lyon Counties, Kansas from 1970 to 2000 and projected for 2010 to 2050...........................................................2-94 2-21 Demographic Profile of the Population in the WCGS Region of Influence................2-95 2-22 Major Employers in Coffey County in 2006...............................................................2-96 2-23 Income Information for the WCGS Region of Influence............................................2-97 2-24 Coffey County Tax Revenues, WCGS Property Tax, and WCGS Property Tax as a Percentage of Tax Revenues, 2000 to 2006.....................................................2-98 3-1 Category 1 Issues for Refurbishment Evaluation........................................................3-2 3-2 Category 2 Issues for Refurbishment Evaluation........................................................3-3 4-1 Category 1 Issues Applicable to the Operation of the WCGS Cooling System During the Renewal Term...........................................................................................4-2 4-2 Category 2 Issues Applicable to the Operation of the WCGS Cooling System During the Renewal Term.........................................................................................4-10 TablesDraft NUREG-1437, Supplement 32 xviii September 2007 4-3 Assumptions used in Estimating Impingement Totals...............................................4-25 4-4 Total Number of Fish Collected in Impingement Samples from the CWIS on Coffey County Lake (December 2004 - March 2006)...............................4-26 4-5 Estimated Monthly Impingement Mortality for the CWIS on Coffey County Lake - Based on WCNOC Assumptions (December 2004 - March 2006)...............4-28 4-6 Estimated Monthly Impingement Mortality for the CWIS on Coffey County Lake - Based on NRC Assumptions (December 2004 - March 2006).....................4-29 4-7 Total Number of Fish Collected in Impingement Samples for the MUSH on the Neosho River (November 1980 - October 1981)...........................................4-34 4-8 Category 1 Issues Applicable to the WCGS Transmission Lines During the Renewal Term...........................................................................................................4-43 4-9 Category 2 and Uncategorized Issues Applicable to the WCGS Transmission Lines During the Renewal Term................................................................................4-46 4-10 Category 1 Issues Applicable to Radiological Impacts of Normal Operations During the Renewal Term.........................................................................................4-48 4-11 Category 1 Issues Applicable to Socioeconomics During the Renewal Term...........4-50 4-12 Category 2 Issues Applicable to Socioeconomics and Environmental Justice During the Renewal Term.........................................................................................4-51 4-13 Category 1 Issues Applicable to Groundwater Use and Quality During the Renewal Term...........................................................................................................4-62 4-14 Category 2 Issues Applicable to WCGS Groundwater Use and Quality During the Renewal Term.....................................................................................................4-63 4-15 Category 2 Issues Applicable to Threatened or Endangered Species During the Renewal Term.....................................................................................................4-69 5-1 Category 1 Issues Applicable to Postulated Accidents During the Renewal Term............................................................................................................................5-3 5-2 Category 2 Issues Applicable to Postulated Accidents During the Renewal Term............................................................................................................................5-4 5-3 WCGS Core Damage Frequency................................................................................5-6 5-4 Breakdown of Population Dose by Containment Release Mode.................................5-7 6-1 Category 1 Issues Applicable to Uranium Fuel Cycle and Solid Waste Management During the Renewal Term.....................................................................6-2 7-1 Category 1 Issues Applicable to the Decommissioning of WCGS Following the Renewal Term.......................................................................................................7-2 8-1 Summary of Environmental Impacts of the No-Action Alternative...............................8-5 8-2 Summary of Environmental Impacts of Coal-Fired Generation at the WCGS Site (Once Through Cooling) and at an Alternate Site (Closed-Cycle Cooling)........8-18 Tables September 2007 xix Draft NUREG-1437, Supplement 32 8-3 Summary of Environmental Impacts of Natural Gas-Fired Generation at WGCS Site (Once Through Cooling) and at an Alternate Site (Closed-Cycle Cooling)........8-28 8-4 Summary of Environmental Impacts of New Nuclear Power Generation at an Alternate Site Using Closed-Cycle Cooling...............................................................8-35 8-5 Summary of Environmental Impacts of 585 MW (e) of Natural Gas-Fired Generation, 290 MW (e) Purchase Power, and 290 MW (e) Conservation..............8-44 9-1 Summary of Environmental Significance of License Renewal, the No Action Alternative, and Alternative Methods of Generation Using Once-Through Cooling....9-8 A-1 Individuals Providing Comments During Scoping Comment Period..........................A-2 E-1 Consultation Correspondence....................................................................................E-1 E-2 Federal, State, Local, and Regional Licenses, Permits, Consultations, and Other Approvals for Wolf Creek Generating Station............................................................E-2 F-1 GEIS Environmental Issues Not Applicable to Wolf Creek Generating Station (WCGS).......................................................................................................................F
-1G-1 WCGS Core Damage Frequency...............................................................................G-3 G-2 Breakdown of Population Dose by Containment Release Mode................................G-4 G-3 WCGS PSA Historical Summary................................................................................G-6 G-4 Fire Areas and Their Contribution to Fire CDF.........................................................G-10 G-5 SAMA Cost/Benefit Screening Analysis for WCGS..................................................G-19 September 2007 xx Draft NUREG-1437, Supplement 32 Executive Summary 1 2 3By letter dated September 27, 2006, Wolf Creek Nuclear Operating Corporation (WCNOC) 4submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the 5operating license (OL) for Wolf Creek Generating Station (WCGS) for an additional 20-year 6period. If the OL is renewed, State regulatory agencies and WCGS will ultimately decide 7whether the plant will continue to operate based on factors such as the need for power or other 8matters within the State's jurisdiction or the purview of the owners. If the OL is not renewed, 9then the plant must be shut down at or before the expiration date of the current OL, which is 10 March 11, 2025.
11 12The NRC has implemented Section 102 of the National Environmental Policy Act of 1969, as 13 amended (NEPA) (42 USC 4321) in Title 10 of the Code of Federal Regulations (CFR), Part 51 14(10 CFR Part 51). In 10 CFR 51.20(b)(2), the Commission requires preparation of an 15environmental impact statement (EIS) or a supplement to an EIS for renewal of a reactor OL. In 16addition, 10 CFR 51.95(c) states that the EIS prepared at the OL renewal stage will be a 17 supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear 18 Plant s (GEIS), NUREG-1437, Volumes 1 and 2.(a)19 20Upon acceptance of the WCGS application, the NRC began the environmental review process 21described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and conduct 22scoping. The Staff visited the WCGS site in September 2006, held a public scoping meeting on 23December 19, 2006, and conducted a site audit in March 2007. In the preparation of this draft 24supplemental environmental impact statement (SEIS) for WCGS, the Staff reviewed the WCGS 25Environmental Report (ER) and compared it to the GEIS, consulted with other agencies, 26conducted an independent review of the issues following the guidance set forth in NUREG-27 1555, Supplement 1, the Standard Review Plans for Environmental Reviews for Nuclear Power 28Plants, Supplement 1: Operating License Renewal, and considered the public comments 29received during the scoping process. The public comments received during the scoping 30process are provided in Appendix A, Part 1, of this draft SEIS.
31 32The Staff will hold public meetings in Burlington, Kansas in November 2007, to describe the 33preliminary results of the NRC environmental review, to answer questions, and to provide 34members of the public with information to assist them in formulating comments on this draft 35SEIS. When the comment period ends, the Staff will consider and address all of the comments 36received. These comments will be addressed in Appendix A, Part 2 of the final SEIS.
37 38This draft SEIS includes the NRC staff's preliminary analysis that considers and weighs the 39environmental effects of the proposed action, the environmental impacts of alternatives to the 40 (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.
Executive Summary Draft NUREG-1437, Supplement 32 xxi September 2007 proposed action, and mitigation measures for reducing or avoiding adverse effects. It also 1includes the Staff's preliminary recommendation regarding the proposed action.
2 3The Commission has adopted the following statement of purpose and need for license renewal 4 from the GEIS:
5 6The purpose and need for the proposed action (renewal of an operating license) is to 7provide an option that allows for power generation capability beyond the term of a current 8nuclear power plant operating license to meet future system generating needs, as such 9needs may be determined by State, utility, and, where authorized, Federal (other than NRC) 10 decisionmakers.
11 12The purpose of the Staff's environmental review, as defined in 10 CFR 51.95(c)(4) and the 13 GEIS, is to determine:
14
- 15. . . whether or not the adverse environmental impacts of license renewal are so great that 16preserving the option of license renewal for energy planning decisionmakers would be 17 unreasonable.
18 19Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 20there are factors, in addition to license renewal, that will ultimately determine whether an 21existing nuclear power plant continues to operate beyond the period of the current OL.
22 23NRC regulations [10 CFR 51.95(c)(2)] contain the following statement regarding the content of 24SEISs prepared at the license renewal stage:
25 26The supplemental environmental impact statement for license renewal is not required to 27include discussion of need for power or the economic costs and economic benefits of the 28proposed action or of alternatives to the proposed action except insofar as such benefits 29and costs are either essential for a determination regarding the inclusion of an alternative in 30the range of alternatives considered or relevant to mitigation. In addition, the supplemental 31environmental impact statement prepared at the license renewal stage need not discuss 32other issues not related to the environmental effects of the proposed action and the 33alternatives, or any aspect of the storage of spent fuel for the facility within the scope of the 34generic determination in § 51.23(a) ["Temporary storage of spent fuel after cessation of 35reactor operation-generic determination of no significant environmental impact"] and in 36accordance with § 51.23(b).
37 38The GEIS contains the results of a systematic evaluation of the consequences of renewing an 39OL and operating a nuclear power plant for an additional 20 years. It evaluates 92 40 Executive Summary September 2007 xxii Draft NUREG-1437, Supplement 32 environmental issues using the NRC's three-level standard of significance-SMALL, 1MODERATE, or LARGE-developed using the Council on Environmental Quality guidelines.
2The following definitions of the three significance levels are set forth in footnotes to Table B-1 of 310 CFR Part 51, Subpart A, Appendix B:
4 5SMALL - Environmental effects are not detectable or are so minor that they will neither 6destabilize nor noticeably alter any important attribute of the resource.
7 8MODERATE - Environmental effects are sufficient to alter noticeably, but not to 9destabilize, important attributes of the resource.
10 11LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 12important attributes of the resource.
13 14For 69 of the 92 issues considered in the GEIS, the analysis in the GEIS reached the following 15conclusions:
16 17 (1) The environmental impacts associated with the issue have been determined to apply 18either to all plants or, for some issues, to plants having a specific type of cooling system 19or other specified plant or site characteristics.
20 21 (2) A single significance level (that is SMALL, MODERATE, or LARGE) has been assigned 22to the impacts (except for collective offsite radiological impacts from the fuel cycle and 23from high-level waste and spent fuel disposal).
24 25 (3) Mitigation of adverse impacts associated with the issue has been considered in the 26analysis, and it has been determined that additional plant-specific mitigation measures 27are not likely to be sufficiently beneficial to warrant implementation.
28 29These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and 30significant information, the Staff relied on conclusions in the GEIS for issues designated as 31 Category 1 in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B.
32 33Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 34issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, 35environmental justice and chronic effects of electromagnetic fields, were not categorized.
36Environmental justice was not evaluated on a generic basis and must be addressed in a plant-37specific supplement to the GEIS. Information on the chronic effects of electromagnetic fields 38was not conclusive at the time the GEIS was prepared.
39 Executive Summary Draft NUREG-1437, Supplement 32 xxiii September 2007 This draft SEIS documents the Staff's consideration of all 92 environmental issues identified in 1the GEIS. The Staff considered the environmental impacts associated with alternatives to 2license renewal and compared the environmental impacts of license renewal and the 3alternatives. The alternatives to license renewal that were considered include the no-action 4alternative (not renewing the OL for WCGS) and alternative methods of power generation.
5Based on projections made by the U.S. Department of Energy's Energy Information 6Administration (DOE/EIA), coal and gas-fired generation appear to be the most likely power-7generation alternatives if the power from WCGS is replaced. These alternatives are evaluated 8assuming that the replacement power generation plant is located at either the WCGS site or 9some other unspecified alternate location.
10 11WCNOC and the Staff have established independent processes for identifying and evaluating 12the significance of any new information on the environmental impacts of license renewal.
13Neither WCNOC nor the Staff has identified information that is both new and significant related 14to Category 1 issues that would call into question the conclusions in the GEIS. Similarly, neither 15the scoping process nor the Staff has identified any new issue applicable to WCGS that has a 16significant environmental impact. Therefore, the Staff relies upon the conclusions of the GEIS 17for all of the Category 1 issues that are applicable to WCGS.
18 19WCGS's license renewal application presents an analysis of the Category 2 issues plus 20environmental justice and chronic effects from electromagnetic fields. The Staff has reviewed 21the WCGS analysis for each issue and has conducted an independent review of each issue.
22Two Category 2 issues are not applicable, because they are related to plant design features or 23site characteristics not found at WCGS. Four Category 2 issues are not discussed in this draft 24SEIS, because they are specifically related to refurbishment. WCGS has stated that its 25evaluation of structures and components, as required by 10 CFR 54.21, did not identify any 26major plant refurbishment activities or modifications as necessary to support the continued 27operation of WCGS for the license renewal period. In addition, any replacement of components 28or additional inspection activities are within the bounds of normal plant operation, and are not 29expected to affect the environment outside of the bounds of the plant operations evaluated in 30the U.S. Nuclear Regulatory Commission's 1982 Final Environmental Statement Related to 31Operation of Wolf Creek Generating Station, Unit No. 1.
32 33Fifteen Category 2 issues related to operational impacts and postulated accidents during the 34renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are 35discussed in detail in this draft SEIS. Two of the Category 2 issues and environmental justice 36apply to both refurbishment and to operation during the renewal term and are only discussed in 37this draft SEIS in relation to operation during the renewal term. For all of the fifteen Category 2 38issues and environmental justice, the Staff concludes that the potential environmental effects 39are of SMALL and SMALL to MODERATE significance in the context of the standards set forth 40in the GEIS. A SMALL to MODERATE impact was determined based on the potential for water-41 Executive Summary September 2007 xxiv Draft NUREG-1437, Supplement 32 use conflicts (plants with cooling ponds or cooling towers using makeup water from a small river 1with low flow). If water use conflicts occur, associated impacts in the Neosho River due to 2impingement and habitat reduction on aquatic organisms, including threatened and endangered 3species, would be SMALL to MODERATE. The Staff also determined that appropriate federal 4health agencies have not reached a consensus on the existence of chronic adverse effects from 5electromagnetic fields. Therefore, no further evaluation of this issue is required. For severe 6accident mitigation alternatives (SAMAs), the Staff concludes that a reasonable, comprehensive 7effort was made to identify and evaluate SAMAs. Based on its review of the SAMAs for WCGS 8and the plant improvements already made, the Staff concludes that WCNOC identified seven 9potentially cost-beneficial SAMAs. However, these SAMAs do not relate to adequate managing 10of the effects of aging during the period of extended operation. Therefore, they do not need to 11be implemented as part of the license renewal pursuant to 10 CFR Part 54. Mitigation 12measures were considered for each Category 2 issue for which the degree of impact was 13determined to be SMALL. For these issues, current measures to mitigate the environmental 14impacts of plant operation were found to be adequate, and no additional mitigation measures 15were deemed sufficiently beneficial to be warranted.
16 17Cumulative impacts of past, present, and reasonably foreseeable future actions were 18considered, regardless of what agency (Federal or non-Federal) or person undertakes such 19other actions. For purposes of this analysis, the Staff concluded that the cumulative impacts 20resulting from the incremental contribution of WCGS operation and maintenance of transmission 21line ROW would be SMALL for all resources, with the exception of some aquatic resources.
22The Staff concluded that water use conflicts (plants with cooling ponds or cooling towers using 23 makeup water from a small river with a low flow), would experience SMALL to MODERATE 24cumulative impacts. In addition, due to the increased potential for impingement and habitat 25reduction during periods with water use conflicts, cumulative impacts on aquatic organisms, 26including threatened and endangered species, would also be SMALL to MODERATE.
27 28If the WCGS operating license is not renewed and the unit ceases operation on or before the 29expiration of their current operating license, then the adverse impacts of likely alternatives will 30not be smaller than those associated with continued operation of WCGS. The impacts may, in 31fact, be greater in some areas.
32 33The preliminary recommendation of the NRC staff is that the Commission determine that the 34adverse environmental impacts of license renewal for WCGS are not so great that preserving 35the option of license renewal for energy planning decisionmakers would be unreasonable. This 36recommendation is based on (1) the analysis and findings in the GEIS; (2) the ER submitted by 37WCNOC; (3) consultation with other Federal, State, and local agencies; (4) the Staff's own 38independent review; and (5) the Staff's consideration of public comments received during the 39scoping process.
40 September 2007 xxv Draft NUREG-1437, Supplement 32 Abbreviations/Acronyms degree(s) ac acre(s)
AC alternating current ACC averted cleanup and decontamination AFW auxiliary feed water ALARA as low as reasonably achievable APE averted public exposure AOC averted off-site property damage costs AOE averted occupational exposure costs AOSC averted on-site costs ATWS anticipated transient without scram BA biological assessment BTU British thermal unit(s)
C Celsius CAA Clean Air Act CCW component cooling water CDF core damage frequency CET Containment Event Tree CEQ Council on Environmental Quality
CFR Code of Federal Regulationscfs cubic foot (feet) per second Ci curie(s) cm centimeter(s)
CO carbon monoxide
CO 2 carbon dioxide COE cost of enhancement COL Combined License CPUE catch-per-unit-effort CSET Containment Safeguards for Event Tree CVCS Chemical and Volume Control System CWA Clean Water Act CWIS Circulating Water Intake Structure CWS Circulating Water System CWSH Circulating Water Screenhouse Abbreviations and Acronyms Draft NUREG-1437, Supplement 32 xxvi September 2007DC direct current DOE U.S. Department of Energy DSM demand-side management DWR Division of Water Resources EDG emergency diesel generator EIA Energy Information Administration EIS environmental impact statement ELF-EMF extremely low frequency-electromagnetic field EO Executive Order EPA U.S. Environmental Protection Agency EPACT2005 Energy Policy Act of 2005 EPRI Electric Power Research Institute ER Environmental Report ERS Environmental Radiation Surveillance ESP Early Site Permit ESWS Essential Service Water System F Fahrenheit F&O Facts and Observations FES Final Environmental Statement FIVE fire-induced vulnerability evaluation fps foot (feet) per second FPS fire protection system FR Federal Registerft foot (feet) ft/mi feet per mile FWS U.S. Fish and Wildlife Service GEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437 GL Generic Letter gpm gallon(s) per minute HCLPF high confidence of low probability of failure HEPA high efficiency particulate air HLW high-level waste hr hour(s)
HRA Human Reliability Analysis HVAC heating, ventilation, and air conditioning Abbreviations and Acronyms September 2007 xxvii Draft NUREG-1437, Supplement 32 in. inch(es) IPE individual plant examination IPEE individual plant examination of external events ISLOCA Interfacing Systems Loss of Coolant Accidents KDHE Kansas Department of Health and Environment KDWP Kansas Department of Wildlife and Parks KEC Kansas Energy Council KEEP Kansas Energy Efficiency Program
kg kilogram(s) kg/yr kilograms per year KG&E Kansas Gas and Electric Company km kilometer(s) KSA Kansas Statutes Annotated KSHS Kansas State Historical Society
kV kilovolt(s)
kW kilowatt KWAA Kansas Water Appropriation Act kWh kilowatt hour(s)
KWO Kansas Water Office LCGS Kansas Power and Light La Cygne Generating Station LERF Large Early Release Frequency LLMW low-level mixed waste LOCA loss of coolant accident LOS level of service LPSI low pressure safety injection m meter(s) mm millimeters
m 3 cubic meter(s) mA milliampere(s) MAAP Modular Accident Analysis Program MACCS2 MELLCOR Accident Consequence Code System 2 MCL maximum contaminant level MDS Minimum Desirable Streamflow
mg milligram(s) mgd million gallons per day mg/L milligram(s) per liter
mi mile(s)
mL milliliter(s)
MMACR Modified Maximum Averted Cost-Risk Abbreviations and Acronyms Draft NUREG-1437, Supplement 32 xxviii September 2007mph miles per hour mrem millirem(s)
MSL mean sea level MTHM metric tonne MTU metric ton of uranium MUDS Makeup Discharge Structure MUSH Makeup Water Screen House MW megawatt MWd megawatt-days MW(e) megawatt(s) electric MW(h) megawatt hour(s)
MW(t) megawatt(s) thermal MWSF Mixed Waste Storage Facility NAAQS National Ambient Air Quality Standards NAS National Academy of Sciences NCP normal charging pump NEPA National Environmental Policy Act of 1969, as amended NESC National Electric Safety Code NGVD National Geodetic Vertical Datum NHPA National Historic Preservation Act NIEHS National Institute of Environmental Health Sciences
NO 2 nitrogen dioxide NO x nitrogen oxide(s) NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NSPS New Source Performance Standards ODCM Offsite Dose Calculation Manual OL operating license PAH polycyclic aromatic hydrocarbon PAYS Pay as You Save pCi/L picoCuries per liter pCi/kg picoCuries per kilogram
PM 2.5 particulate matter, 2.5 microns or less in diameter PM 10 particulate matter, 10 microns or less in diameter ppm parts per million PRA probabilistic risk assessment PSA probabilistic safety assessment PWR pressurized water reactor Abbreviations and Acronyms September 2007 xxix Draft NUREG-1437, Supplement 32radwaste radioactive waste RAI request for additional information RCP reactor coolant pump RCRA Resource Conservation and Recovery Act REMP radiological environmental monitoring program RLE review level earthquake ROI region of influence ROW right-of-way RPC long-term replacement power costs RRW risk reduction worth RWST refueling water storage tank s second(s) SAMA severe accident mitigation alternative SBO station blackout SCR selective catalytic reduction SECPOP sector population, land fraction and economic estimation program SEIS supplemental environmental impact statement SER Safety Evaluation Report SGTR Steam Generator Tube Ruptures
SO 2 sulfur dioxide SO x sulfur oxide(s) SOP standard operating procedure(s) sq mi square mile(s)
Sv person-sievert SWS Service Water System TD turbine driven TDS total dissolved solids TL total length TMDL Total Maximum Daily Load UHS ultimate heat sink U.S. United States USACE U.S. Army Corps of Engineers USCB U.S. Census Bureau USD Unified School District USGS U.S. Geological Survey V volt(s)
Abbreviations and Acronyms Draft NUREG-1437, Supplement 32 xxx September 2007WCGS Wolf Creek Generating Station WCNOC Wolf Creek Nuclear Operating Corporation Westar Westar Energy Inc. WET whole effluent toxicity WOG Westinghouse Owner's Group YOY young of year yr year(s)
September 2007 1-1 Draft NUREG-1437, Supplement 32 1.0Introduction 1 2 3Under the U.S. Nuclear Regulatory Commission's (NRC's) environmental protection regulations 4in Title 10 of the Code of Federal Regulations (CFR) Part 51, which implement the National 5Environmental Policy Act of 1969, as amended (NEPA), renewal of a nuclear power plant 6operating license (OL) requires the preparation of an environmental impact statement (EIS). In 7preparing the EIS, the NRC staff is required first to issue the statement in draft form for public 8comment, and then issue a final statement after considering public comments on the draft. To 9support the preparation of the EIS, the Staff prepared a Generic Environmental Impact 10Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 11(NRC 1996; 1999).(a) The GEIS is intended to (1) provide an understanding of the types and 12severity of environmental impacts that may occur as a result of license renewal of nuclear power 13plants under 10 CFR Part 54, (2) identify and assess the impacts that are expected to be 14generic to license renewal, and (3) support 10 CFR Part 51 to define the number and scope of 15issues that need to be addressed by the applicants in plant-by-plant renewal proceedings. Use 16of the GEIS guides the preparation of complete plant-specific information in support of the OL 17 renewal process.
18 19Wolf Creek Nuclear Operating Corporation (WCNOC) operates Wolf Creek Generating Station 20(WCGS) near Burlington, Kansas under OL NPF-42, which was issued by the NRC. This OL 21will expire on March 11, 2025. On September 27, 2006, WCNOC submitted an application to 22the NRC to renew the WCGS OL for an additional 20 years under 10 CFR Part 54 (WCNOC 232006a). WCNOC is a licensee for the purposes of its current OL and an applicant for the 24renewal of the OL. Pursuant to 10 CFR 54.23 and 51.53(c), WCNOC submitted an 25Environmental Report (ER) (WCNOC 2006b) in which WCNOC analyzed the environmental 26impacts associated with the proposed license renewal action, considered alternatives to the 27proposed action, and evaluated mitigation measures for reducing adverse environmental 28effects. Following a letter submitted by NRC on November 3, 2006 (NRC 2006a), WCNOC 29submitted supplemental environmental information in a letter report on November 17, 2006 30(WCNOC 2006c).
31 32This report is the draft facility-specific supplement to the GEIS (the supplemental EIS [SEIS]) for 33the WCNOC license renewal application. This draft SEIS is a supplement to the GEIS because 34it relies, in part, on the findings of the GEIS. The Staff will also prepare a separate safety 35evaluation report in accordance with 10 CFR Part 54.
36 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.
Introduction Draft NUREG-1437, Supplement 32 1-2 September 2007 1.1 Report Contents 1 2The following sections of this introduction (1) describe the background for the preparation of this 3draft SEIS, including the development of the GEIS and the process used by the Staff to assess 4the environmental impacts associated with license renewal, (2) describe the proposed Federal 5action to renew the WCGS OL, (3) discuss the purpose and need for the proposed action, and 6(4) present the status of WCNOC's compliance with environmental quality standards and 7requirements that have been imposed by Federal, State, regional, and local agencies that are 8responsible for environmental protection.
9 10The ensuing chapters of this draft SEIS closely parallel the contents and organization of the 11GEIS. Chapter 2 describes the site, power plant, and interactions of the plant with the 12environment. Chapters 3 and 4, respectively, discuss the potential environmental impacts of 13plant refurbishment and plant operation during the renewal term. Chapter 5 contains an 14evaluation of potential environmental impacts of plant accidents and includes consideration of 15severe accident mitigation alternatives. Chapter 6 discusses the uranium fuel cycle and solid 16waste management. Chapter 7 discusses decommissioning, and Chapter 8 discusses 17alternatives to license renewal. Finally, Chapter 9 summarizes the findings of the preceding 18chapters and draws conclusions about the adverse impacts that cannot be avoided; the 19relationship between short-term uses of man's environment and the maintenance and 20enhancement of long-term productivity; and the irreversible or irretrievable commitment of 21resources. Chapter 9 also presents the Staff's preliminary recommendation with respect to the 22 proposed license renewal action.
23 24Additional information is included in appendices. Appendix A contains public comments related 25to the environmental review for license renewal and Staff responses to those comments.
26Appendices B through G, respectively, include the following:
27 28 the preparers of the supplement (Appendix B), 29 30 the chronology of the NRC staff's environmental review correspondence related to this 31 draft SEIS (Appendix C), 32 33 the organizations contacted during the development of this draft SEIS (Appendix D), 34 35 WCNOC's compliance status in Table E-1 (this appendix also contains copies of 36consultation correspondence prepared and sent during the evaluation process) 37 (Appendix E), 38 39 Introduction September 2007 1-3 Draft NUREG-1437, Supplement 32 GEIS environmental issues that are not applicable to WCGS (Appendix F), and 1 2 NRC staff evaluation of severe accident mitigation alternatives (SAMAs) (Appendix G).
3 4 5 1.2 Background 6 7Use of the GEIS, which examines the possible environmental impacts that could occur as a 8result of renewing individual nuclear power plant OLs under 10 CFR Part 54, and the 9established license renewal evaluation process support the thorough evaluation of the impacts 10 of OL renewal.
11 121.2.1 Generic Environmental Impact Statement 13 14The NRC initiated a generic assessment of the environmental impacts associated with the 15license renewal term to improve the efficiency of the license renewal process by documenting 16the assessment results and codifying the results in the Commission's regulations. This 17assessment is provided in the GEIS, which serves as the principal reference for all nuclear 18power plant license renewal EISs.
19 20The GEIS documents the results of the systematic approach that was taken to evaluate the 21environmental consequences of renewing the licenses of individual nuclear power plants and 22operating them for an additional 20 years. For each potential environmental issue, the GEIS 23(1) describes the activity that affects the environment, (2) identifies the population or resource 24that is affected, (3) assesses the nature and magnitude of the impact on the affected population 25or resource, (4) characterizes the significance of the effect for both beneficial and adverse 26effects, (5) determines whether the results of the analysis apply to all plants, and (6) considers 27whether additional mitigation measures would be warranted for impacts that would have the 28same significance level for all plants.
29 30The NRC's standard of significance for impacts was established using the Council on 31Environmental Quality (CEQ) terminology for "significantly" (40 CFR 1508.27, which requires 32consideration of both "context" and "intensity"). Using the CEQ terminology, the NRC 33established three significance levels - SMALL, MODERATE, or LARGE. The definitions of the 34three significance levels are set forth in the footnotes to Table B-1 of 10 CFR Part 51, Subpart 35A, Appendix B, as follows:
36 37SMALL - Environmental effects are not detectable or are so minor that they will neither 38destabilize nor noticeably alter any important attribute of the resource.
39 40MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize, 41important attributes of the resource.
42 Introduction Draft NUREG-1437, Supplement 32 1-4 September 2007 LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 1important attributes of the resource.
2 3The GEIS assigns a significance level to each environmental issue, assuming that ongoing 4mitigation measures would continue.
5 6The GEIS includes a determination of whether the analysis of the environmental issue could be 7applied to all plants and whether additional mitigation measures would be warranted. Issues 8are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 9issues are those that meet all of the following criteria:
10 11(1) The environmental impacts associated with the issue have been determined to apply 12either to all plants or, for some issues, to plants having a specific type of cooling system 13or other specified plant or site characteristics.
14 15(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 16the impacts (except for collective off-site radiological impacts from the fuel cycle and 17from high-level waste and spent fuel disposal).
18 19(3) Mitigation of adverse impacts associated with the issue has been considered in the 20analysis, and it has been determined that additional plant-specific mitigation measures 21are likely not to be sufficiently beneficial to warrant implementation.
22 23For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 24required in this draft SEIS unless new and significant information is identified.
25 26Category 2 issues are those that do not meet one or more of the criteria of Category 1; 27therefore, additional plant-specific review for these issues is required.
28 29In the GEIS, the Staff assessed 92 environmental issues and determined that 69 qualified as 30Category 1 issues, 21 qualified as Category 2 issues, and 2 issues were not categorized. The 31two issues not categorized are environmental justice and chronic effects of electromagnetic 32fields. Environmental justice was not evaluated on a generic basis and must be addressed in a 33plant-specific supplement to the GEIS. Information on the chronic effects of electromagnetic 34fields was not conclusive at the time the GEIS was prepared.
35 36Of the 92 issues, 11 are related only to refurbishment, 6 are related only to decommissioning, 3767 apply only to operation during the renewal term, and 8 apply to both refurbishment and 38operation during the renewal term. A summary of the findings for all 92 issues in the GEIS is 39codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B.
40 Introduction September 2007 1-5 Draft NUREG-1437, Supplement 32 1.2.2 License Renewal Evaluation Process 1 2An applicant seeking to renew its OL is required to submit an ER as part of its application. The 3license renewal evaluation process involves careful review of the applicant's ER and assurance 4that all new and potentially significant information not already addressed in or available during 5the GEIS evaluation is identified, reviewed, and assessed to verify the environmental impacts of 6the proposed license renewal.
7 8In accordance with 10 CFR 51.53(c)(2) and (3), the ER submitted by the applicant must:
9 10 provide an analysis of the Category 2 issues in Table B-1 of 10 CFR Part 51, 11Subpart A, Appendix B in accordance with 10 CFR 51.53(c)(3)(ii) and 12 13 discuss actions to mitigate any adverse impacts associated with the proposed action and 14environmental impacts of alternatives to the proposed action.
15 16In accordance with 10 CFR 51.53(c)(2), the ER does not need to:
17 18 consider the economic benefits and costs of the proposed action and alternatives to 19the proposed action except insofar as such benefits and costs are either (1) 20essential for making a determination regarding the inclusion of an alternative in the 21range of alternatives considered or (2) relevant to mitigation, 22 23 consider the need for power and other issues not related to the environmental 24effects of the proposed action and the alternatives, 25 26 discuss any aspect of the storage of spent fuel within the scope of the generic 27determination in 10 CFR 51.23(a) in accordance with 10 CFR 51.23(b), or 28 29 contain an analysis of any Category 1 issue unless there is significant new information 30on a specific issue - this is pursuant to 10 CFR 51.23(c)(3)(iii) and (iv).
31 32New and significant information is (1) information that identifies a significant environmental issue 33not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B or 34(2) information that was not considered in the analyses summarized in the GEIS and that leads 35to an impact finding that is different from the finding presented in the GEIS and codified in 10 36CFR Part 51.
37 Introduction Draft NUREG-1437, Supplement 32 1-6 September 2007 In preparing to submit its application to renew the WCGS OL, WCNOC developed a process to 1ensure that (1) information not addressed in or available during the GEIS evaluation regarding 2the environmental impacts of license renewal for WCGS would be properly reviewed before 3submitting the ER and (2) such new and potentially significant information related to renewal of 4the license for WCGS would be identified, reviewed, and assessed during the period of NRC 5review. WCNOC reviewed the Category 1 issues that appear in Table B-1 of 10 CFR Part 51, 6Subpart A, Appendix B, to verify that the conclusions of the GEIS remained valid with respect to 7WCGS. This review was performed by personnel from WCNOC and its support organization 8who were familiar with NEPA issues and the scientific disciplines involved in the preparation of a 9license renewal ER.
10 11The NRC staff also has a process for identifying new and significant information. That process 12is described in detail in Standard Review Plans for Environmental Reviews for Nuclear Power 13Plants, Supplement 1: Operating License Renewal, NUREG-1555, Supplement 1 (NRC 2000).
14The search for new information includes (1) review of an applicant's ER and the process for 15discovering and evaluating the significance of new information; (2) review of records of public 16comments; (3) review of environmental quality standards and regulations; (4) coordination with 17Federal, State, and local environmental protection and resource agencies; and (5) review of the 18technical literature. New information discovered by the Staff is evaluated for significance using 19the criteria set forth in the GEIS. For Category 1 issues where new and significant information 20is identified, reconsideration of the conclusions for those issues is limited in scope to the 21assessment of the relevant new and significant information; the scope of the assessment does 22not include other facets of the issue that are not affected by the new information.
23 24Chapters 3 through 7 discuss the environmental issues considered in the GEIS that are 25applicable to WCGS. At the beginning of the discussion of each set of issues, there is a table 26that identifies the issues to be addressed and lists the sections in the GEIS where the issue is 27discussed. Category 1 and Category 2 issues are listed in separate tables. For Category 1 28issues for which there is no new and significant information, the table is followed by a set of 29short paragraphs that state the GEIS conclusion codified in Table B-1 of 10 CFR Part 51, 30Subpart A, Appendix B, followed by the Staff's analysis and conclusion. For Category 2 issues, 31in addition to the list of GEIS sections where the issue is discussed, the tables list the 32subparagraph of 10 CFR 51.53(c)(3)(ii) that describes the analysis required and the draft SEIS 33sections where the analysis is presented. The draft SEIS sections that discuss the Category 2 34issues are presented immediately following the table.
35 36The NRC prepares an independent analysis of the environmental impacts of license renewal 37and compares these impacts with the environmental impacts of alternatives. The evaluation of 38the WCNOC license renewal application began with the publication of a notice of acceptance for 39docketing, notice of opportunity for a hearing, and notice of intent to prepare an EIS and 40conduct scoping in the Federal Register (FR) (71 FR 70997; NRC 2006b) on December 7, 41 Introduction September 2007 1-7 Draft NUREG-1437, Supplement 32 2006. A public scoping meeting was held on December 19, 2006, in Burlington, Kansas.
1Comments received during the scoping period were summarized in the Environmental Impact 2Statement Scoping Process: Summary Report - Wolf Creek Generating Station (NRC 2006c).
3Comments that are applicable to this environmental review are presented in Part 1 of Appendix 4 A of this draft SEIS.
5 6 The Staff followed the review guidance contained in NUREG-1555, Supplement 1 (NRC 2000).
7The Staff and contractor retained to assist the Staff visited the WCGS Site on September 12 8through September 15, 2006, to gather information and to become familiar with the site and its 9environs. The Staff also reviewed the comments received during scoping, and consulted with 10Federal, State, regional, and local agencies. A list of the organizations consulted is provided in 11Appendix D. Other documents related to WCGS were reviewed and are referenced within this 12 draft SEIS.
13 14This draft SEIS presents the Staff's analysis that considers and weighs the environmental 15effects of the proposed renewal of the OL for WCGS, the environmental impacts of alternatives 16to license renewal, and mitigation measures available for avoiding adverse environmental 17effects. Chapter 9, "Summary and Conclusions," provides the NRC staff's preliminary 18recommendation to the Commission on whether or not the adverse environmental impacts of 19license renewal are so great that preserving the option of license renewal for energy-planning 20decision makers would be unreasonable.
21 22A 75-day comment period will begin on the date of publication of the U.S. Environmental 23Protection Agency Notice of Filing of the draft SEIS to allow members of the public to comment 24 on the preliminary results of the NRC staff's review. During this comment period, public 25meetings will be held in Burlington, Kansas, in November 2007. During this meeting, the Staff 26will describe the preliminary results of the NRC environmental review and answer questions 27related to it to provide members of the public with information to assist them in formulating their 28 comments.
29 301.3 The Proposed Federal Action 31 32The proposed Federal action is renewal of the OL for WCGS. The WCGS facility is located in 33Coffey County, in eastern Kansas, approximately 75 miles (mi) southwest of Kansas City. The 34plant has one Westinghouse pressurized water reactor (PWR) with a reactor core power of 353,565 megawatts thermal (MW[t]), and a design net electrical capacity of 1,165 megawatts 36electric (MW[e]). Plant cooling is provided by a cooling pond-based heat dissipation system that 37withdraws cooling water from and discharges it to a cooling pond, Coffey County Lake. The 38current OL for WCGS expires on March 11, 2025. By letter dated September 27, 2006, 39WCNOC submitted an application to the NRC (WCNOC 2006a) to renew this OL for an 40additional 20 years of operation (i.e., until March 11, 2045).
41 Introduction Draft NUREG-1437, Supplement 32 1-8 September 2007 1.4 The Purpose and Need for the Proposed Action 1 2Although a licensee must have a renewed license to operate a reactor beyond the term of the 3existing OL, the possession of that license is just one of a number of conditions that must be 4met for the licensee to continue plant operation during the term of the renewed license. Once 5an OL is renewed, State regulatory agencies and the owners of the plant will ultimately decide 6whether the plant will continue to operate based on factors such as the need for power or other 7matters within the State's jurisdiction or the purview of the owners.
8 9Thus, for license renewal reviews, the NRC has adopted the following definition of purpose and 10need (GEIS Section 1.3):
11 12The purpose and need for the proposed action (renewal of an operating license) is to 13provide an option that allows for power generation capability beyond the term of a 14current nuclear power plant operating license to meet future system generating needs, 15as such needs may be determined by State, utility, and where authorized, Federal (other 16than NRC) decision makers.
17 18This definition of purpose and need reflects the Commission's recognition that, unless there are 19findings in the safety review required by the Atomic Energy Act of 1954, as amended or findings 20in the NEPA environmental analysis that would lead the NRC to reject a license renewal 21application, the NRC does not have a role in the energy-planning decisions of State regulators 22and utility officials as to whether a particular nuclear power plant should continue to operate.
23From the perspective of the licensee and the State regulatory authority, the purpose of renewing 24an OL is to maintain the availability of the nuclear plant to meet system energy requirements 25beyond the current term of the plant's license.
26 271.5 Compliance and Consultations 28 29WCNOC is required to hold certain Federal, State, and local environmental permits, as well as 30meet relevant Federal and State statutory requirements. In its ER, WCNOC provided a list of 31the authorizations from Federal, State, and local authorities for current operations as well as 32environmental approvals and consultations associated with WCGS license renewal.
33Authorizations and consultations relevant to the proposed OL renewal action are included in 34Appendix E.
35 36The Staff has reviewed the list and consulted with the appropriate Federal, State, and local 37agencies to identify any compliance or permit issues or significant environmental issues of 38concern to the reviewing agencies. These agencies did not identify any new and significant 39environmental issues. The ER states that WCNOC is in compliance with applicable 40 Introduction September 2007 1-9 Draft NUREG-1437, Supplement 32 environmental standards and requirements for WCGS. The Staff has not identified any 1environmental issues that are both new and significant.
2 3 1.6 References 4 510 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 6Protection Regulations for Domestic Licensing and Related Regulatory Functions."
7 810 CFR Part 54. Code of Federal Regulations, Title 10, Energy,Part 54, "Requirements for 9Renewal of Operating Licenses for Nuclear Power Plants."
10 1140 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment , Part 12 1508, "Terminology and Index."
13 14Atomic Energy Act of 1954. 42 USC 2011, et. seq.
15 16National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et. seq.
17 18 Nuclear Regulatory Commission (NRC). 1996.Generic Environmental Impact Statement for 19License Renewal of Nuclear Power Plants. NUREG-1437 Volumes 1 and 2, Washington, DC.
20 21 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 22License Renewal of Nuclear Plants Main Report
,"Section 6.3 - Transportation, Table 9.1, 23Summary of findings on NEPA issues for license renewal of nuclear power plants." NUREG-24 1437 Volume 1, Addendum 1, Washington, DC.
25 26 Nuclear Regulatory Commission (NRC). 2000.Standard Review Plans for Environmental 27Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555, 28Supplement 1, Washington, DC.
29 30Nuclear Regulatory Commission (NRC). 2006a. Letter from Ms. V.M. Rodriguez, NRC, 31Washington, DC, to Mr. T.J. Garrett, WCNOC regarding License Renewal Application for Wolf 32Creek Generating Station, Unit 1, November 3, 2006.
33 34 Nuclear Regulatory Commission (NRC). 2006b. "Notice of Acceptance for Docketing of the 35Application, Notice of Opportunity for Hearing, and Notice of Intent to Prepare an Environmental 36Impact Statement and Conduct the Scoping Process for Facility Operating License 37Number NPF-42 for an Additional Twenty-Year Period; Wolf Creek Nuclear Operating 38 Corporation; Wolf Creek Generating Station, Unit 1."
Federal Register Volume 71, 39 pp. 70997-70999. December 7, 2006.
40 Introduction Draft NUREG-1437, Supplement 32 1-10 September 2007 Nuclear Regulatory Commission (NRC). 2006c.Environmental Impact Statement Scoping 1Process: Summary Report - Wolf Creek Generating Station, Burlington, Kansas. Washington, 2 DC.3 4Wolf Creek Nuclear Operating Corporation (WCNOC). 2006a. License Renewal Application, 5Wolf Creek Generating Station, Docket Number 50-482, Facility Operating License Number 6 NPF-42. Burlington, Kansas.
7 8Wolf Creek Nuclear Operating Corporation (WCNOC). 2006b. Applicant's Environmental 9Report - Operating License Renewal Stage, Wolf Creek Generating Station. Docket Number 10 50-482. Burlington, Kansas.
11 12Wolf Creek Nuclear Operating Corporation (WCNOC). 2006c. Supplementary Environmental 13Information to Support the Application for Renewed Operating License for Wolf Creek 14Generating Station, Docket Number 50-482. Burlington, Kansas.
15 September 2007 2-1 Draft NUREG-1437, Supplement 32 2.0 Description of Nuclear Power Plant and Site and 1 Plant Interaction with the Environment 2 3 4Wolf Creek Generating Station (WCGS) is located in Coffey County, Kansas, in the Neosho 5River Basin. The nearest large cities are Kansas City, Missouri approximately 75 miles to the 6northeast, and Topeka, Kansas approximately 55 miles to the north.
7 8The facility consists of one Westinghouse pressurized water reactor (PWR) producing steam 9that turns a turbine to generate electricity. Facility cooling is provided by a cooling pond system 10utilizing Coffey County Lake, a reservoir developed specifically to provide a source of cooling 11water for the facility. The plant and its environs are described in Section 2.1, and the plant's 12interaction with the environment is presented in Section 2.2.
13 142.1 Plant and Site Description and Proposed Plant 15 Operation During the Renewal Term 16 17Prior to development as a power facility, the site of WCGS consisted of undeveloped agricultural 18land. The WCGS facility buildings and adjacent areas occupy an area of approximately 135 19acres (ac) within a total area of nearly 11,300 ac owned by the Kansas Gas and Electric 20Company, Kansas City Power & Light Company, and Kansas Electric Power Cooperative 21(WCNOC 2006a). Additional site features contained within the 11,300-ac site boundary area 22include Coffey County Lake (5,090 ac), the dam and dikes for Coffey County Lake (60 ac), the 23Lime Sludge Pond (31 ac), and the Wolf Creek Environmental Education Area (500 ac) 24(WCNOC 2006a). The Wolf Creek Environmental Education Area, which is operated as a 25partnership between WCGS, private citizens, civic organizations, and local, State, and Federal 26governments, contains trails through a variety of natural Kansas habitats (WCNOC 2006a). The 27remainder of the property within the site boundary is leased as farmland and rangeland 28(WCNOC 2006a).
29 30The facility is situated in an area of limited topographic relief with local elevation differences of 31less than 100 feet (ft) from valley floors to upland areas (WCNOC 2006a). Topographic 32elevations within the site boundary range from 1,020 to 1,120 ft above mean seal level (MSL) 33(USGS 1979). The area within a 6-mile (mi) radius of the WGCS site is located entirely within 34Coffey County, including the towns of Burlington and New Strawn (WCNOC 2006a). The terrain 35is flat to gently rolling hills. The area within a 50-mi radius of the site consists primarily of rural 36agricultural land. The site location and features within 6-mi and 50-mi radii are illustrated on 37Figures 2-1 and 2-2, respectively.
38 Plant and the Environment Draft NUREG-1437, Supplement 322-2September 2007 2 Figure 2-1. Location of WCGS, 50-Mile Radius Source: WCNOC 2006a Plant and the Environment September 2007 2-3 Draft NUREG-1437, Supplement 32 2 Figure 2-2. Location of WCGS, 6-Mile Radius Source: WCNOC 2006a Plant and the Environment Draft NUREG-1437, Supplement 322-4September 2007The WCGS site is located on the Wolf Creek drainage, within the Neosho River drainage basin, 1and the local topography slopes to the south and west, towards the Neosho River. The John 2Redmond Reservoir, also on the Neosho River, is located approximately 3 miles west of the 3site. The closest population center to WCGS is the town of Emporia, 28 miles west-northwest 4(WCNOC 2006a). The cities of Topeka and Lawrence, Kansas and Kansas City, Missouri lie 5just outside of the 50-mi radius (WCNOC 2006a).
6 72.1.1 External Appearance and Setting 8 9WCGS is located on Coffey County Lake, a man-made lake constructed on Wolf Creek 10specifically to act as a cooling water reservoir for the facility (WCNOC 2006a). The facility can 11be accessed from Highway 75.
12 13The major features of the 11,300-ac WCGS site are the reactor containment building, turbine 14building, auxiliary building, control building, fuel handling facility, switchyard, radioactive waste 15building, training center, visitor's center (with associated Emergency Operations Facility and 16simulator), outdoor firing range, and other supporting buildings (WCNOC 2006a). The area 17within the site boundaries owned by WCGS includes the 500 ac Wolf Creek Environmental 18Education Area at the northern end of Coffey County Lake (WCNOC 2006a). The nearest 19residences are located within 0.5 mile west of Coffey County Lake, between Coffey County 20Lake and Highway 75. The closest communities are Burlington (population 2,790), located 3 21miles southwest of the facility, and New Strawn (population 425), located 3 miles northwest of 22the facility (WCNOC 2006a). The site boundary and general facility layout are depicted on 23Figures 2-3and 2-4, respectively.
24 25Three transmission line right-of-ways (ROWs) connect WCGS to the power grid. The 345-26kilovolt (kV) lines, ROWs, and the switchyard (including the generator output breakers) are 27owned, operated and maintained by Westar Energy, a corporation formed by the merger of 28Kansas Gas and Electric and Kansas Power and Light (WCNOC 2006a). All three transmission 29lines occur within 150-ft wide ROW corridors (WCNOC 2006a). The ROWs are approximately 30105 miles in length and cover a total area of approximately 1,900 ac (WCNOC 2006a). The 31corridors are primarily comprised of sparsely populated agricultural land. The transmission lines 32associated with WCGS are shown on Figure 2-5.
33 34In addition to the 345-kV transmission lines, the facility is connected to two 69-kV transmission 35lines. One of these is a 4-mi long tap into the existing Athens-Burlington 69-kV line, and the 36other is a 3-mi long connection to a Kansas Electric Power Cooperative power plant in Sharpe 37(WCNOC 2006a).
38 Plant and the Environment September 2007 2-5 Draft NUREG-1437, Supplement 32 2 Figure 2-3. WCGS Property Boundaries and Environs Source: WCNOC 2006a Plant and the Environment Draft NUREG-1437, Supplement 322-6September 2007 2 4 Figure 2-4.
WCGS Facility Layout Source: WCNOC 2006a Plant and the Environment September 2007 2-7 Draft NUREG-1437, Supplement 32 1 2 Figure 2-5. WCGS Transmission Lines Source: WCNOC 2006a Plant and the Environment Draft NUREG-1437, Supplement 322-8September 20072.1.2 Reactor Systems 1 2WCGS is a nuclear-powered steam electric generating facility that began commercial operation 3on September 3, 1985. The nuclear reactor is a Westinghouse PWR producing a reactor core 4power of 3,565 megawatts-thermal. The design net electrical capacity is 1,165 megawatts-5electric (WCNOC 2006a).
6 7The nuclear steam supply system at WCGS is a four-loop Westinghouse pressurized water 8reactor. The steam yields its energy to turn the turbines, which are connected to the electrical 9generator. The nuclear fuel is low-enriched uranium dioxide with enrichments of 5 percent by 10weight uranium-235 or less and fuel burnup levels of a batch average of approximately 48,000 11megawatt-days per metric ton uranium. WCGS operates on an 18-month refueling cycle. The 12reactor, steam generators, and related systems are enclosed in a containment building that is 13designed to prevent leakage of radioactivity to the environment in the improbable event of a 14rupture of the reactor coolant piping. The containment building is a reinforced concrete cylinder 15with a slab base and a hemispherical dome. A welded steel liner is attached to the inside face 16of the concrete shell to insure a high degree of leak tightness. In addition, the 4-ft thick concrete 17walls serve as a radiation shield for both normal and accident conditions (WCNOC 2006a).
18 19The containment building is ventilated to maintain pressure and temperatures within acceptable 20limits. The containment ventilation system also can purge the containment prior to entry.
21Exhaust from the ventilation system is monitored for radioactivity before being released to the 22plant vent. High efficiency particulate air (HEPA) filters can be used when needed to filter the 23air before releasing it. The containment building can be isolated if needed (WCNOC 2006a) 24 252.1.3 Cooling and Auxiliary Water Systems 26 27The WCGS operates as a cooling pond based facility, with Coffey County Lake being the water 28source for the circulating water system (CWS), and auxiliary water systems, including the 29service water system (SWS), and essential service water system (ESWS). Figure 2-4 shows 30the location of these systems on the Wolf Creek property. Coffey County Lake, which was 31formerly known as the Wolf Creek Cooling Lake, also serves as the receiving water for the 32discharges from these three systems. The Neosho River is the source of makeup water for 33Coffey County Lake.
34 35 2.1.3.1 Intake 36 37Condenser cooling water is withdrawn from Coffey County Lake through the circulating water 38intake structure (CWIS). The CWIS is located in the Circulating Water Screenhouse (CWSH), 39which is located in the southeast corner of the main plant area on the shore of Coffey County 40 Plant and the Environment September 2007 2-9 Draft NUREG-1437, Supplement 32 Lake. The screenhouse contains the major equipment associated with the CWS and the SWS.
1The ESWS, described below, is located in a separate building to the northeast of the CWIS.
2 3The CWIS sump floor is located at an elevation of 1058 ft above MSL. A steel plate is provided 4at the sump inlet of the CWIS as a weather protection device. This steel plate extends 5downward from the CWIS operating floor (1092 ft above MSL) to 1075 ft above MSL. The 6velocities of the circulating water and service water flow downstream of the steel plate are 7essentially independent of the lake water level. The circulating water and the service water flow 8from the lake past the steel plate and through bar grills (trash racks) into three separate bays 9where the traveling screens are located. The bar grills are used for removing larger debris while 10the traveling screens are designed to remove smaller debris.
11 12The bar grill, located at the inlet of the intake bays, consists of 1-inch (in.)-wide vertical bars 13spaced at 3-in. intervals. These bars have not been cleaned throughout the history of the plant.
14Behind the bar grill, there are six traveling screens with two traveling screens per bay. The 15traveling screens are of a vertical single entry/exit type with a standard 0.375-in. mesh. The 16traveling water screens are operated intermittently controlled by either a timer or a high-17differential-pressure sensor.
18 19Low and high pressure sprays wash debris and organisms off the screens. Typically the low 20pressure wash is used to remove debris and organisms on the screens, but a high pressure 21wash can be activated for cleaning or heavy fouling. From the screens, debris and organisms 22are directed to a concrete sluiceway, then to a basket on the outside of the building. From the 23sluiceway, there is an approximate 2 ft drop to the basket, which has 1 x 3-in. openings. Larger 24debris and organisms remain in the basket until they are manually removed. Cleaning of the 25basket occurs every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when there is heavy loading; at other times it may be a few days 26until the basket is emptied. Smaller debris and biological organisms pass through the basket 27grates and fall approximately 3 to 4 ft to the water surface. Some service water is also 28discharged into the grated area.
29 30The traveling screens are continuously turned if there are winds greater than 25 miles per hour 31(mph) from the south in October or November or if there is an out-of-season die-off. Records 32are not kept regarding the operation of the screens at Coffey County Lake or the Makeup Water 33Screen House (MUSH), but generally they are turned for 30 minutes every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
34 35The CWS operates continuously during power generation, including startup and shutdown.
36Three one-third capacity motor-driven, vertical, wet-pit circulating water pumps pump the 37circulating water from the cooling lake to the main condenser. They are designed to operate 38through the expected range of cooling lake levels. When lake water temperatures are greater 39than 50 degrees (°) F, three pumps provide the design flow rate of approximately 500,000 40gallons per minute (gpm). Under normal conditions, all three pumps operate at a total capacity 41 Plant and the Environment Draft NUREG-1437, Supplement 322-10September 2007of 1,178 cubic feet per second (cfs). Because condenser cooling is more efficient with colder 1intake water, only two pumps are operated with a design flow of 365,000 gpm when lake 2temperatures are below 50°F. At these pumping rates, design flow across the rotating screens 3at the point of impingement is less than 1.0 foot per second (fps).
4 5Based on a total flow rate of 1,256 cfs (circulating water and service water combined), the 6average inlet water velocities are 0.87 fps (approach velocity to the CWIS), 1.06 fps (velocity 7through the bar grills), 1.06 fps (approach velocity to the traveling screens), and 1.95 fps 8(velocity through the traveling screens).
9 10Wolf Creek Nuclear Operating Corporation (WCNOC) injects anti-scalants, dispersants, 11biocides, and corrosion inhibitors into the CWS to maintain the system and prevent fouling by 12corrosion and biological organisms. Addition of these constituents to the CWS is governed by 13the facility's National Pollutant Discharge Elimination System (NPDES) permit, which is 14described in Section 2.2.3.1.3.
15 16 2.1.3.2 Discharge 17 18The heated water discharged from the condenser is returned to the Coffey County Lake through 19the CWS discharge structure. The main circulating water pipes from the CWSH to the power 20block and from the power block to the discharge structure have an inside diameter of 144 in.
21The circulating water discharge structure has a discharge well that overflows into a 40-ft wide 22apron and then onto the surface of the lake.
23 24During the winter, operators may align the circulating water system to direct a fraction of the 25warmed discharge back to the circulating water intake structure to prevent freezing. Baffle dikes 26prevent short-circuiting of the discharge water to the intake.
27 28The discharged water takes approximately 38 days to travel from the discharge to the intake 29structure (WCNOC 2007).
30 31 2.1.3.3 Service Water Systems 32 33There are two independent station service water systems: the SWS and the ESWS. The SWS 34takes water from the circulating water intake structure and returns the warmed water to the 35circulating water discharge pipe. During normal plant operation, the SWS supplies water to the 36turbine plant auxiliary equipment, steam generator blowdown, nonregenerative heat exchanger, 37and the Chemical and Volume Control System (CVCS) chiller. The service water system is the 38normal water supply for the Demineralized Water Makeup System. The fire protection diesel 39and electric fire pumps also draw water from the CWS bays. During normal operation, the CWS 40 also provides water to the ESWS. Both the SWS and the ESWS incorporate the use of oxidants 41 Plant and the Environment September 2007 2-11 Draft NUREG-1437, Supplement 32 such as chlorine for control of biofouling. Per the facility NPDES permit, a maximum of 1.0 1milligram per liter (mg/L) total residual oxidants is allowed with up to 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of continuous 2chlorination (Hammond 2006).
3 4The flow rate is variable, but flow rates can be as high as 50,000 gpm. Three service water 5pumps are housed in the CWIS. Typically two service water pumps are operating at a total 6capacity of 90 cfs with one pump serving as a standby. Each service water pump is sized to 7deliver 25,000 gpm of service water at a discharge pressure of approximately 185 ft.
8 9The ESWS cools several safety-class systems and provides cooling for safe shutdown during 10an accident. During accident conditions, the ESWS takes water from the Ultimate Heat Sink 11(UHS), a specially designed impoundment within Coffey County Lake, at the Essential Service 12Water intake structure. Discharge goes to a separate discharge structure on the UHS. An 13underwater dam prevents draining of the UHS in the event of failure of the lake dam.
14 15The ESWS intake structure consists of two totally independent intake systems. Each has a 16forebay with the same type of bar grills as found in the CWIS; however, there are no vertical 17steel plates, used for ice protection, as seen in the CWIS. Each system also has a traveling 18screen similar to the CWIS and MUSH. Debris and organisms trapped on the traveling screens 19are diverted to a shared sluiceway that discharges to the outside of the building.
20 21Similar to the CWIS, the ESWS screens can be operated automatically or manually. Some 22service water is diverted to the ESWS consistently to keep the system clean. Heated effluent 23can also be direct to the intake for ice control. The ESWS is operated infrequently. No records 24were provided by WCNOC regarding the duration and frequency of operation.
25 26 2.1.3.4 Makeup Water 27 28Makeup water for Coffey County Lake is drawn from the Neosho River immediately downstream 29of the John Redmond Reservoir. A valve in a pipe through the dam is opened during pumping 30to maintain flow to the pumps. The MUSH is situated on the east bank of the river and contains 31three separate makeup water pumps, each with a dedicated bar grill and 3/8-in. traveling 32screens. Only two pumps can be used at a time. Each pump is designed to provide 60 cfs 33through a 54-in.-diameter supply line to Coffey County Lake. This supply line is designed for 34130 cfs with an optimum rate of 120 cfs.
35 36The design and operation of the bar grill and traveling screens is similar to the CWIS; however, 37there is no vertical steel plate prior to the trash racks, as seen in the CWIS. Two auxiliary raw 38water pumps are also available to supply the demineralizer system when service water is not 39operating. There are no provisions for returning fish that survive impingement to the Neosho 40 Plant and the Environment Draft NUREG-1437, Supplement 322-12September 2007River. However, the design intake velocity of less than 0.5 fps at a water level of 1007.5 ft 1above MSL minimizes fish impingement (WCNOC 2006b).
2 3From the MUSH, water flows through a 54-in.-diameter supply line to Coffey County Lake and 4discharges at the makeup water discharge structure on the western shore of the lake, 5immediately adjacent to the Coffey County boat ramp. The discharge structure consists of a 6stilling basin/sump wherein the makeup water pipeline discharges. From this sump, the makeup 7water flows over a weir and down a spillway to Coffey County Lake.
8 92.1.4 Radioactive Waste Management Systems and Effluent Control Systems 10 11WCGS radioactive waste (radwaste) systems are designed to collect, treat, and dispose of the 12radioactive and potentially radioactive wastes that are byproducts of plant operations. The 13byproducts are activation products resulting from the irradiation of reactor water and impurities 14therein (principally metallic corrosion products) and fission products resulting from defective fuel 15cladding or uranium contamination within the reactor coolant system. Operating procedures for 16radwaste systems ensure that radioactive wastes are safely processed and discharged from the 17plant within the limits set forth in Part 20 of Title 10 of the Code of Federal Regulations (10 CFR 18Part 20), 10 CFR Part 50, the plant's technical specifications, and WCGS's Offsite Dose 19 Calculation Manual (ODCM; Accession No. ML071270040).
20 21Radioactive wastes resulting from plant operations are classified as liquid, gaseous, or solid.
22Liquid radioactive wastes are generated from liquids received directly from portions of the 23reactor coolant system or were contaminated by contact with liquids from the reactor coolant 24system. Gaseous radioactive wastes are generated from gases or airborne particulates vented 25from reactor and turbine equipment containing radioactive material. Solid radioactive wastes 26are solids from the reactor coolant system, solids that came into contact with reactor coolant 27system liquids or gases, or solids used in the reactor coolant system or steam and power 28conversion system operation or maintenance (Accession No. ML0712000055).
29 30Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 31as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh 32fuel assemblies during routine refueling outages, typically every 18 months. Spent fuel 33assemblies are then stored in the spent fuel pool in the reactor building. WCGS also provides 34for on-site storage of mixed wastes, which contain both radioactive and chemically hazardous 35 materials (Accession No. ML0712000055).
36 37WCGS's ODCM contains the methodology and parameters used to calculate off-site doses 38resulting from radioactive gaseous and liquid effluents, and the gaseous and liquid effluent 39monitoring alarm and trip set points used to verify that the radioactive material being discharged 40meets regulatory limits (Accession No. ML071270040). The ODCM also contains the 41 Plant and the Environment September 2007 2-13 Draft NUREG-1437, Supplement 32 radioactive effluent controls and radiological environmental monitoring activities and 1descriptions of the information that should be included in the annual Radiological Environmental 2Operating Report and annual Radioactive Effluent Release Report required by Appendix I to 10 3CFR Part 50, and 10 CFR 50.36a, respectively.
4 5 2.1.4.1 Liquid Waste Processing Systems and Effluent Controls 6
7The liquid waste processing system collects, holds, treats, processes, and monitors all liquid 8radioactive wastes for reuse or disposal. The system is divided into several subsystems so that 9liquid wastes from various sources can be segregated and processed separately. Cross 10connections between the subsystems provide additional flexibility for processing the wastes by 11alternate methods. The wastes are collected, treated, and disposed of according to their 12conductivity and/or radioactivity (Accession No. ML0712000055).
13 14Liquid waste is collected in sumps and drain tanks and transferred to the appropriate subsystem 15collection tanks for subsequent treatment, disposal, or recycle. Liquid waste is processed by a 16series of components mounted on a skid employing various processes specifically designed to 17provide maximum decontamination factors. The processing methods used include; filtration, 18reverse osmosis, and/or demineralization. Following treatment, the processed wastes in the 19waste evaporator condensate tank, waste monitor tanks, or secondary liquid waste monitor 20tanks are analyzed for chemical and radioactive content prior to being discharged. Any planned 21releases from the system are evaluated in conjunction with all other radioactive liquid releases 22to ensure that the total release does not exceed the ODCM limits. The liquid effluent normally 23discharges from the plant into the circulating water discharge piping, which dilutes the effluent 24and transports it to the Coffey County Lake. Liquid releases to the lake are limited to satisfy the 25dose objectives of Appendix I to10 CFR Part 50.
26 27The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the WCGS radioactive effluent 28release reports for 2002 through 2006 for liquid effluents (WCNOC 2003a, 2004a, 2005a, 292006c, 2007a). There were 50 liquid batch releases as well as continuous releases in 2006.
30The amount of radioactivity discharged in liquid releases, excluding gases and tritium, totaled 310.010 curies in 2006. A total of 1,380 curies of tritium were released in 2006.
32 33Based on the liquid waste processing systems and effluent controls and performance from 2002 34through 2006, similar small quantities of radioactive liquid effluents are expected from WCGS 35and are not expected to increase during the renewal period. These releases would result in 36doses to members of the public that are well below the as low as reasonably achievable 37(ALARA) dose objectives of Appendix I to 10 CFR Part 50, as discussed in Section 2.2.7.
38 Plant and the Environment Draft NUREG-1437, Supplement 322-14September 2007 2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls 1 2The gaseous radwaste processing system and the plant ventilation exhaust system control, 3collect, process, store, and dispose of gaseous radioactive wastes generated as a result of 4 normal operation. The primary source of the radioactive gas is from the purge of the volume 5control tank with hydrogen. The operation of the system acts to reduce the fission gas 6concentration in the reactor coolant system which, in turn, reduces the escape of fission gases 7from the reactor coolant system during maintenance operations or through equipment leakage.
8Smaller quantities are received from the vent connections, from the reactor coolant drain tank, 9the pressurizer relief tank, and the recycle holdup tanks. In all buildings where there is a 10potential for radioactive gaseous material, the ventilation system is designed to control the 11release. Where needed, each building has a vent collection system for tanks and other 12equipment which contains air or aerated liquids. The unit vent receives input from several 13ventilation sub-systems; including the condenser evacuation system, reactor building, auxiliary 14building, and fuel building. The radwaste building has an open ventilation system, and the 15steam packing exhaust discharges outside the turbine building.
16 17The vent collection system receives the discharge of vents and other equipment in the radwaste 18and auxiliary buildings which contain air or aerated liquids. These components contain only a 19small amount of fission product gases. Prior to release through the radwaste or auxiliary 20building ventilation system, the gases are monitored and passed through a prefilter, high 21efficiency particulate filter, charcoal filter, and another high efficiency particulate filter in series 22which reduce any airborne particulate radioactive material to very low levels. This filter system 23provides for a decontamination factor of at least 10 for radioactive iodines and 100 for 24particulates.
25 26WCGS maintains radioactive gaseous effluents in accordance with the procedures and 27methodology described in the ODCM. The gaseous radwaste system is used to reduce 28radioactive materials in gaseous effluents before discharge to meet the ALARA dose objectives 29in Appendix I to10 CFR Part 50 (Accession No. ML071270040).
30 31The NRC staff reviewed the WCGS radioactive effluent release reports for 2002 through 2006 32for gaseous effluents (WCNOC 2003a, 2004a, 2005a, 2006c, 2007a). In 2006, WCGS made 68 33gaseous batch releases as well as continuous releases which contained a total of 2.07 curies of 34fission and activation gases and a total of 53.4 curies of tritium.
35 36These activities are typical of past years and are not expected to increase during the renewal 37period. See Section 2.2.7 for a discussion of the theoretical doses to the maximally exposed 38individual as a result of these releases.
39 Plant and the Environment September 2007 2-15 Draft NUREG-1437, Supplement 32 2.1.4.3 Solid Waste Processing 1 2The solid radwaste system is designed to collect, process, and package low-level radioactive 3wastes generated as a result of normal plant operation. It also is capable of storing the 4packaged waste until it is shipped off-site to a waste processor for treatment and/or disposal or 5to a licensed burial site. The solid radwaste equipment is located in the radioactive waste 6building. The system consists of a dry waste system, a resin handling system, a filter handling 7system, and a waste disposal system. Both wet and dry radioactive solid wastes are 8processed. Wet solid wastes include spent resins, filter cartridges, filter sludges, evaporator 9bottoms, waste from floor drain filters, and fuel pool filters. Dry solid wastes include 10contaminated rags, clothing, paper, small equipment parts, and solid laboratory wastes 11(Accession No. ML0712000055).
12 13In 2006, WCGS made a total of 19 shipments of solid waste. The solid waste volumes were 14623 cubic meters (m
- 3) of dry compressible waste, contaminated equipment, and spent resins, 15with an activity of 251.42 curies (WCNOC 2007a). The volumes reported are for non-16compacted wastes. Volume reduction by compaction is performed by a contractor at an off-site 17location. No irradiated fuel shipments were made in 2006. The solid waste volumes and 18radioactive material activity levels are typical of annual waste shipments for WCGS and are not 19expected to increase during the renewal period.
20 212.1.5 Nonradioactive Waste Systems 22 23WCGS generates solid, hazardous, universal, and mixed waste from routine facility operations 24 and maintenance activities.
25 26 2.1.5.1 Nonradioactive Waste Streams 27 28WCGS generates solid waste, as defined by the Resource Conservation and Recovery Act 29(RCRA), as part of routine plant maintenance, cleaning activities, and plant operations. This 30waste is not radioactive or hazardous and is disposed of in the Coffey County Landfill.
31 32Hazardous waste is nonradioactive waste that is listed by the U.S. Environmental Protection 33Agency (EPA) as hazardous waste or that exhibits characteristics of ignitability, corrosivity, 34reactivity, or toxicity (40 CFR Part 261). RCRA regulates the treatment, storage, and/or 35disposal of hazardous waste and requires a hazardous waste permit for facilities that treat or 36store large quantities of hazardous waste for more than 90 days and for entities that dispose of 37hazardous waste at the facility. RCRA regulations are administered in Kansas by the Kansas 38Department of Health and Environment (KDHE).
39 Plant and the Environment Draft NUREG-1437, Supplement 322-16September 2007WCGS generates a variety of hazardous waste streams including broken fluorescent lamps 1which contain low levels of mercury, oils, solvents, photographic chemicals, and paint waste.
2WCGS currently maintains a Kansas Generator classification meaning, the plant generates 3between 55 to 2,200 pounds of hazardous waste in a month. In 2006, WCGS generated 41,577.6 pounds of hazardous waste (WCNOC 2007a).
5 6Universal waste is hazardous waste that has been specified as universal waste by the EPA.
7Universal waste, including mercury-containing equipment, batteries, lamps, and pesticides, has 8specific regulations (40 CFR Part 273) to ensure proper collection and recycling or treatment.
9WCGS generates batteries and fluorescent lamps as universal wastes from normal facility 10operations. The batteries and lamps are accumulated in satellite areas and then shipped off-11site for disposal in accordance with universal waste regulations. In 2006, WCGS generated 12approximately 2,400 pounds of universal waste batteries and 240 pounds of universal waste 13lamps (WCNOC 2007a).
14 15Low-level mixed waste (LLMW) is waste that exhibits hazardous characteristics and contains 16low levels of radioactivity. LLMW has been regulated under multiple authorities. EPA or State 17agencies regulate the hazardous component of LLMW through RCRA and either the U.S.
18Department of Energy (DOE) or NRC regulates the radioactive component.
19 20WCGS generates LLMW from normal facility operation and maintenance. These wastes, when 21generated, are stored in appropriate containers and stored in the Mixed Waste Storage Facility 22(MWSF) in the Owens Corning Building. The MWSF meets the EPA requirements for storage 23of hazardous wastes and the NRC requirements for storage of radioactive wastes (WCNOC 24 2007a).25 26 2.1.5.2 Pollution Prevention and Waste Minimization 27 28Currently, WCGS has an approved site waste minimization plan in place. The plan has reduced 29the amount and toxicity of waste generated or reduced the volume of waste disposed of in a 30landfill. The plan includes a practice which recycles a large number of waste materials including 31the following: aluminum cans, office paper, used oil, antifreeze, scrap metal, fiberboard drums, 32laser printer toner cartridges and poly drums (WCNOC 2007a).
33 342.1.6 Facility Operation and Maintenance 35 36Maintenance activities conducted at WCGS include inspection, testing, and surveillance to 37maintain the current licensing basis of the facility and to ensure compliance with environmental 38and safety requirements. Various programs and activities currently exist at WCGS to maintain, 39inspect, test, and monitor the performance of facility equipment. These maintenance activities 40include inspection requirements for reactor vessel materials, boiler and pressure vessel in-41 Plant and the Environment September 2007 2-17 Draft NUREG-1437, Supplement 32 service inspection and testing, maintenance structures monitoring program, and maintenance of 1 water chemistry.
2 3Additional programs include those implemented to meet technical specification surveillance 4requirements, those implemented in response to the NRC generic communications, and various 5periodic maintenance, testing, and inspection procedures. Certain program activities are 6performed during the operation of the unit, while others are performed during scheduled 7refueling outages. WCNOC refuels WCGS on a nominal 18 month interval.
8 92.1.7 Power Transmission System 10 11As presented in Table 2-1, the applicant identified three 345-kV transmission lines that were 12constructed in conjunction with the construction of WCGS in order to connect the facility to the 13electric power grid. Prior to construction of WCGS, a 345-kV transmission line ROW extended 14from La Cygne (located approximately 60 miles east of WCGS) to Benton (located northwest of 15Wichita) and traversed the site. This line was rerouted around Coffey County Lake and 16connected to the WCGS switchyard by constructing a 7-mi segment around the lake on the east 17end of what became the Wolf Creek - Benton line and a 0.7-mi segment on the west end of 18what became the Wolf Creek - La Cygne line (Figure 2-5). Both of these lines have 150-ft-wide 19ROWs that are almost entirely on WCGS property. In addition, a new 345-kV transmission line 20was built in conjunction with the construction of WCGS, the Wolf Creek - Rose Hill line. This 21line extends southwest from WCGS for 98 miles within a 150-ft-wide ROW to the Rose Hill 22Substation located southeast of Wichita (WCNOC 2006a).
23 24 Table 2-1. WCGS Transmission Line ROWs 25 26Approximate Distance ROW Width ROW Area Transmission Line kVkm mi m ft hectares acres Wolf Creek to Rose Hill Substation345 157.7 98 45.7 150 721.1 1781.8 Wolf Creek to Pre-existing Benton Line 345 11.3 7 45.7 150 51.5 127.3 Wolf Creek to Pre-existing La Cygne Line 345 1.1 0.7 45.7 150 5.1 12.7 Total170 106 7787 1922 Based on: WCNOC 1980 Plant and the Environment Draft NUREG-1437, Supplement 322-18September 2007The three 345-kV transmission lines listed in Table 2-1 were originally constructed for the 1specific purpose of connecting the plant to the transmission system. As shown in the table, 2these lines are contained within approximately 106 miles of 150-ft-wide ROWs that include a 3total area of over 1,920 ac in Coffey, Greenwood, and Butler Counties. The transmission line 4ROWs primarily occur within agricultural and open range lands and cross numerous county, 5State, and Federal highways. They do not cross any national or State parks, wildlife refuges, or 6wildlife management areas. The Wolf Creek - Benton line crosses over several inlets and 7tributaries of Coffey County Lake, and the Wolf Creek - La Cygne and Wolf Creek - Rose Hill 8lines cross over one inlet of the lake east of the WCGS facility. The Wolf Creek - Rose Hill line 9also crosses the Neosho, Verdigris, Fall, Little Walnut, and Walnut Rivers, as well as many 10smaller creeks. It does not cross any major lakes or ponds outside of the WCGS property.
11 12WCGS does not own, operate, or maintain the transmission lines or the ROWs. The lines are 13owned and maintained by Westar Energy Inc. (Westar), which provides electricity to businesses 14and residents in eastern Kansas and operates and coordinates more than 33,000 miles of 15transmission and distribution lines (Westar 2007). The transmission lines were designed and 16constructed in accordance with the National Electrical Safety Code and other industry guidance 17applicable at the time the lines were built. The lines are subject to scheduled inspections and 18maintenance to ensure conformance to industry and regulatory standards.
19 20Two 69-kV lines from the WCGS are not shown on Table 2-1 because they are not within the 21scope of this evaluation. One of these lines extends 4 miles to tap into the Athens-Burlington 22line. This line was originally constructed to provide construction power. The second 69-kV line 23is a 3-mi-long radial line that connects to a substation in Sharpe. Transmission lines such as 24these that have voltages less than 98-kV are not within the scope of the evaluation of terrestrial 25ecology effects of the potential for acute and chronic electromagnetic field effects in Section 4.2.
26 272.2 Plant Interaction with the Environment 28 29Sections 2.2.1 through 2.2.8 provide general descriptions of the environment near WCGS as 30background information. They also provide detailed descriptions where needed to support the 31analysis of potential environmental impacts of operation during the renewal term, as discussed 32in Sections 3 and 4. Section 2.2.9 describes the historic and archaeological resources in the 33area, and Section 2.2.10 describes possible impacts associated with other Federal project 34 activities.
35 362.2.1 Land Use 37 38The WCGS facility occupies a 9,818 ac site, encompassing Coffey County Lake and the 39surrounding shoreline, within a total area of nearly 11,300 ac owned by the Kansas Gas and 40Electric Company, Kansas City Power & Light Company, and Kansas Electric Power 41 Plant and the Environment September 2007 2-19 Draft NUREG-1437, Supplement 32 Cooperative. The largest portion of the site property (5,090 ac) is occupied by the WCGS 1cooling pond (Coffey County Lake), with additional site features including the dam and dikes for 2Coffey County Lake (60 ac), the Lime Sludge Pond (31 ac), and the Wolf Creek Environmental 3Education Area (500 ac). The WCGS facility buildings and adjacent areas occupy 4approximately 135 ac on a peninsula along the eastern shore of Coffey County Lake, at the 5southern end of Oxen Lane (the "Plant Access Road"). Included are the reactor containment 6building, turbine building, auxiliary building, control building, fuel handling facility, switchyard, 7radioactive waste building, training center, visitor's center, outdoor firing range, and other 8supporting buildings. The area in the immediate vicinity of the reactor and associated buildings 9is fenced to restrict human access. A management plan has been developed for the outdoor 10firing range, which has been in use since 1983, to address lead in ammunition fired at the 11range. Recommendations are made in the plan to minimize lead contamination in the soil 12through management practices that reduce potential soil erosion and through modification of 13range use procedures (WCNOC 2004b).
14 15The remainder of the property within the site boundary is leased as farmland, for the production 16of soybeans, milo, corn, and wheat, and as rangeland (WCNOC 2006a). As of 2006, these 17leases included 1,422 ac for grazing, 540 ac for hay production, and 1,282 ac for cropland. In 18addition, a buffer zone of approximately 1,440 ac surrounding Coffey County Lake is maintained 19in native vegetation (grasses and woodland) for wildlife benefits (WCNOC 2006d). Figure 2-3 20depicts the WCGS site boundary and Figure 2-4 provides the general facility layout.
21 22The nearest residence is located 1.7 miles west of the reactor containment building, across 23Coffey County Lake, on Native Road SE (WCNOC 2006e). The closest communities are the 24cities of Burlington (population 2,790), located 3 miles southwest of the WCGS facility, and New 25Strawn (population 425), 2.5 miles northwest of the facility (USCB 2000).
26 27WCGS is located in and pays property taxes to Coffey County. The site property, including the 28WCGS facility, is zoned A-1 Agricultural by the county.(a)29 30Three 150-ft-wide transmission line ROWs, containing lines built to connect WCGS to the power 31grid, run for a total of approximately 105 miles and cover a total area of approximately 1,900 ac.
32These transmission lines are described in more detail in Section 2.1.7. The ROWs traverse 33land that is primarily agricultural and open range, in areas that are mostly remote and have low 34population densities. The ROWs do not cross any State or Federal parks, wildlife refuges, or 35 wildlife management areas (WCNOC 2006a).
36 (a)Special uses allowed in the A-1 Agricultural zoning district include power plants, both conventional and nuclear fueled, for commercial production and sale of energy (Coffey County Planning Board 2000).
Plant and the Environment Draft NUREG-1437, Supplement 322-20September 2007The Wolf Creek - Rose Hill line extends approximately 98 miles from WCGS in a southwesterly 1direction toward the Rose Hill substation east of Wichita, Kansas. The primary land use 2classifications traversed by this ROW are grazing lands (70 percent of the total ROW area) and 3cropland (24 percent), with the remaining area occupied by woodlands (4 percent), idle land (2 4percent), and roads (0.5 percent) (WCNOC 2007c).
5 6The portion of the LaCygne - Benton transmission line rerouted around Coffey County Lake is 7approximately 7.7-mi long. Land uses within the upland areas of this ROW are predominantly 8agricultural, including grazing land (31 percent), cropland (20 percent) and hay meadow (11 9percent), and wildlife habitat (native grasses, grass-brush, and brush habitats, 16 percent).
10Roads, gravel areas, and WCGS yard areas occupy 8 percent of the ROW area. Woodlands 11 cover 5 percent (WCNOC 2007c).
12 13Section 307(c)(3)(A) of the Coastal Zone Management Act (16 USC 1456(c)(3)(A)) requires that 14applicants for Federal licenses to conduct an activity in a coastal zone provide to the licensing 15agency a certification that the proposed activity is consistent with the enforceable policies of the 16State's coastal zone program. WCGS does not affect a coastal zone. Therefore, the 17requirements of the Coastal Zone Management Act are not applicable to renewal of the WCGS 18 license.19 202.2.2 Water Use 21 22For facility operations, WCGS uses water to supply a CWS, SWS, and ESW. The source of 23water for all three systems is Coffey County Lake, which was constructed and filled specifically 24to act as a cooling pond for the facility (WCNOC 2006a). The facility uses a cooling pond based 25system in which water from Coffey County Lake is withdrawn through an intake channel on the 26eastern shore of the lake, and heated discharge water is returned to the lake. The CWS intake 27structure is located on the south side of the facility and has a capacity of 500,000 gpm (WCNOC 282006a). The SWS withdraws water through the same intake channel as the CWS and has the 29capacity to withdraw up to 50,000 gpm (WCNOC 2006a). During normal operations, the ESWS 30is supplied by the SWS. However, a separate ESWS intake structure exists which is able to 31supply this system during accident conditions (WCNOC 2006a). All three water systems are 32closed systems in which the water is withdrawn from and returned to Coffey County Lake 33(WCNOC 2006a).
34 35Coffey County Lake covers an area of 5,090 ac and is designed to provide an adequate supply 36to WCGS during a 1 in 50 year drought (WCNOC 2006a). The lake was developed in the early 371980s by construction of an earthen dam across intermittent Wolf Creek and filled by water 38pumped from the Neosho River (WCNOC 2006a). The drainage area captured by the 39impoundment is 19.5 square miles (sq mi; Haines 2000 in WCNOC 2006a).
40 Plant and the Environment September 2007 2-21 Draft NUREG-1437, Supplement 32 The sources of makeup water for Coffey County Lake include natural flows within Wolf Creek 1upstream of the lake, and water pumped from the Neosho River from an intake immediately 2downstream of the John Redmond Reservoir. The facility does not use any groundwater wells 3for water supply, nor does it purchase water from local water systems except for potable 4purposes (WCNOC 2006a).
5 6The water used to maintain the water supply in Coffey County Lake is obtained through two 7different administrative mechanisms: water appropriations for the use of natural flows for 8beneficial uses, as permitted by the Kansas Department of Agriculture, and a purchase contract 9with the Kansas Water Authority for stored water within the conservation pool of the John 10Redmond Reservoir on the Neosho River. The specific sources of water, with their respective 11volumes, are as follows:
12 13 Under water appropriation file number 20,275, WCGS has access to all natural flows of 14Wolf Creek upstream of the Coffey County Lake Dam (State of Kansas 1977a in 15WCNOC 2006f). The reported average monthly stream flow in Wolf Creek prior to 16construction of the WCGS facility was approximately 8,100 gpm (NRC 1982).
17 Under water appropriation file number 14,626, WCGS is permitted to withdraw up to 55 18cfs (or 24,750 gpm) up to a maximum of 25,000 ac-ft/year (yr) of natural flow within the 19Neosho River (State of Kansas 1977b in WCNOC 2006b).
20 Under water appropriation file number 19,882, WCGS is permitted to withdraw up to 170 21cfs (76,500 gpm) up to a maximum of 57,300 ac-ft/yr of natural flow within the Neosho 22River (State of Kansas 1977c in WCNOC 2006f).
23 Through a contract with the Kansas Water Authority (formerly the Kansas Water 24Resources Board), WCGS may purchase water stored within the conservation pool of 25the John Redmond Reservoir during times when the elevation of the reservoir is at or 26below the conservation pool level of 1,039 ft above MSL (State of Kansas 1976 in 27WCNOC 2006f).
28 29Each of these sources of water is subject to volume restrictions based on administrative and/or 30physical limitations, including the amount of water actually present, the need to apportion the 31available water for all uses (including maintaining adequate streamflow in the Neosho River), 32and the physical capacities of the WCGS pumps and piping systems. Details regarding these 33limitations, as well as an evaluation of the potential for future water use impacts, are presented 34in Section 4.1.1.
35 36The physical means of acquiring the water is through pumps located at the MUSH, on the 37Neosho River at the outfall of the dam. When fully operational, the three MUSH pumps 38combined have a maximum pumping rate of 120 cfs (54,000 gpm) for pumping the 39appropriations water. This is same as the maximum flow capacity of the pipeline that transports 40the water to the Coffey County Lake (WCNOC 2006g). The water purchase contract also has 41 Plant and the Environment Draft NUREG-1437, Supplement 322-22September 2007physical and administrative limitations. The contract allows a maximum withdrawal rate of 120 1cfs. However, due to limitations in the flow capacity of the bypass pipe used to access the 2purchased water, the maximum withdrawal rate available through this mechanism is 70 cfs 3(31,500 gpm; WCNOC 2006g).
4 5In addition to the cooling and service water systems, the facility obtains potable water for use by 6employees. This water is obtained through the Rural Water District 3, which purchases the 7water from two sources: the City of Burlington, which withdraws its water supply through an 8intake on the Neosho River; and the Public Wholesale District 12, which draws water from 9Melvern Lake (WCNOC 2006a). The total volume of water obtained for potable supply 10purposes is approximately 600,000 to 700,000 gallons per month (WCNOC 2006a). The 11capacity of the Burlington water system is 2.1 million gallons per day (mgd; City of Burlington 122007), and the contracted capacity of Public Wholesale District 12 is 1.5 mgd (KWO 2002).
13Therefore, the volume represents 1 percent or less of the normal capacity of these water supply 14 systems. 15 162.2.3 Water Quality 17 182.2.3.1 Surface Water 19 20The surface water bodies of interest that may potentially be impacted by WCGS operations 21include Coffey County Lake, Wolf Creek, and the Neosho River. Coffey County Lake receives 22direct discharge from the facility's cooling and service water systems. Its water quality may be 23affected by activation products in the cooling water, corrosion products from facility piping 24systems, and/or biocides and corrosion control chemicals added to the water systems.
25Following discharge to Coffey County Lake, these constituents may increase in concentration 26due to evaporation in the lake.
27 28From Coffey County Lake, this water may migrate to Wolf Creek and the Neosho River, 29potentially resulting in impacts to those water bodies. Coffey County Lake water may be 30released to Wolf Creek through two mechanisms. First, when lake levels are high enough, a 31strong north wind can cause waves to break over the spillway of the dam resulting in a direct 32release to Wolf Creek (WCNOC 2007d). The second mechanism may be seepage of the lake 33water around the dam. Either mechanism would result in direct release of Coffey County lake 34water to Wolf Creek, which then flows to its confluence with the Neosho River approximately 4 35miles south of the dam.
36 37The effect of WCGS operations on surface water quality in the local area is monitored through 38the Radiological Environmental Monitoring Program (REMP) operated by WCGS, and the Wolf 39Creek Environmental Radiation Surveillance (ERS) Program operated by KDHE. In addition, 40more general, regional water quality monitoring studies are conducted by various Federal, 41 Plant and the Environment September 2007 2-23 Draft NUREG-1437, Supplement 32 State, and local agencies. Although these programs are not specifically designed to monitor the 1effect of WCGS operations, they provide additional data that may be useful in understanding the 2local environment in which WCGS operates. Subsections 2.2.3.1.1 through 2.2.3.1.4 below 3provide a summary of these studies and programs.
4 52.2.3.1.1 General and Regional Surface Water Quality Monitoring 6 7Surface water quality in John Redmond Reservoir, the Neosho River, and other local surface 8water bodies has been monitored by Federal, State, and local agencies for various purposes 9unrelated to WCGS operations. However, these studies provide data on the quality of surface 10water in the area prior to and during facility operations.
11 12Because the Neosho River and other water bodies act as a drinking water source for several 13communities, both the local municipalities and the KDHE conduct sampling and analysis of 14water obtained in this manner. The closest locations for which monitoring data exists include 15Public Wholesale District #12 on Melvern Lake, and the cities of Burlington and Iola on the 16Neosho River (KDHE 2007a). Melvern Lake is located outside of the drainages associated with 17WCGS. The water intake for the city of Burlington is located upstream of the confluence of the 18Neosho River and Wolf Creek, approximately 1.5 miles west of Coffey County Lake. The water 19intake for the city of Iola is located approximately 20 miles downstream of the confluence.
20 21The 2006 analytical report for the city of Burlington shows that some violations of drinking water 22standards occurred. These included exceeding Maximum Contaminant Levels (MCLs) for total 23trihalomethanes and halocetic acids, inadequate disinfection process for total organic carbon, 24 and a failure to monitor for the Interim Enhanced Surface Water Treatment Rule (City of 25Burlington 2007). No compliance issues were identified for the Iola and Melvern Lake systems 26and none of these issues are related to WCGS operations (KDHE 2007a).
27 28The Neosho River and John Redmond Reservoir are sampled for general water quality 29parameters by the KDHE Bureau of Air and Radiation and the Watershed Management Section.
30Data obtained from both of these sources indicates generally high quality water in both water 31bodies. Two Total Maximum Daily Load (TMDL) documents have been issued for John 32Redmond Lake - one for siltation, and one for eutrophication (KDHE 2007b). In addition, two 33TMDL documents have been issued for the Neosho River downstream of WCGS - one for 34copper, and one for pH (KDHE 2007b). None of these issues are expected to be related to 35 WCGS operations.(b) 36 (b) Personal communication of Robert Dover, Hydrologist, for Earth Tech with Tom Stiles, Chief, Kansas Bureau of Water Watershed Planning Section discussing total maximum daily load (TMDL) documents (March 27, 2007).
Plant and the Environment Draft NUREG-1437, Supplement 322-24September 20072.2.3.1.2 WCGS Pre-Operational Surface Water Quality Monitoring 1 2A surface water quality study was performed at the site prior to and shortly after operations 3began. This study was conducted from 1973 to 1987 and consisted of the sampling and 4 analysis of samples from John Redmond Reservoir, the Neosho River, and Coffey County Lake 5(at that time called Wolf Creek Cooling Lake). The samples were analyzed for general 6chemistry parameters and metals during pre-operational conditions and for two years following 7the beginning of operations (EA 1988). The study identified variations in analytical results that 8were attributed to natural seasonal differences (EA 1988). The study identified a trend of 9increasing iron, chromium, and copper concentrations in the cooling lake, but concluded that 10there were no observable trends or impacts that could be attributed to the facility after 2 years of 11operations (EA 1988). Analyses for these metals have not been conducted or reported in the 12Annual Environmental Monitoring Reports that date back to 1985. Therefore, there are no data 13upon which to evaluate the impact of the last 22 years of operations.
14 152.2.3.1.3 WCGS NPDES Monitoring 16 17Pursuant to the Federal Water Pollution Control Act (also known as the Clean Water Act 18[CWA]), WCGS effluent discharges are regulated by a NPDES permit. The first NPDES permit 19for the facility (Kansas Permit No. I-NE07-PO02, Federal Permit Number KS0079057) was 20issued by the State of Kansas in 1977. The permit has been renewed 7 times with the latest 21renewal occurring on December 30, 2004 (WCNOC 2006a). The current permit expires on 22December 31, 2008. The quantitative effluent limitations regulated under the WCGS NPDES 23 permit are shown in Table 2-2.
24 25There are nine separate outfalls regulated under this permit, which fall into three main 26 categories:
27 28 Outfall 003X is the regulated outfall for the largest volume of water, which is the 29circulation water and service water discharge to Coffey County Lake. This outfall has a 30permitted discharge flow volume of 704 mgd.
31 Outfall 004A is the outfall for the spillway of Coffey County Lake Dam into Wolf Creek.
32This outfall has a permitted discharge flow volume of 2.9 mgd.
33 Outfalls 001A, 002, 002A, 003A, 003B, 005A, and 006A are all permitted for discharge of 34relatively small-volume, miscellaneous water streams to Coffey County Lake. These 35include the outfall for the domestic waste stabilization pond (001A), the ESWS (006A), 36and other low volume or rarely used systems. The total permitted flow volume of all of 37 these outfalls into Coffey County Lake combined is 34.37 mgd.
38 39Outfalls 002 - 006 are shown on Figure 2-6.
40 Table 2-2. Effluent Limitations - NPDES Permit for WCGS 1 2Total Residual Oxidants (mg/L) Total Suspended Solids (mg/L)
Oil and Grease (mg/L)Fecal Coliform (cells/100 ml) Biochemical Oxygen Demand (mg/L)
OutfallNo.(Outfall Description) Flow (mgd)Avg. Monthly Max.Daily Avg. Monthly Max.Daily Avg. Monthly Max.Daily Apr. 31 to Oct. 31 Nov. 1 to Mar. 1 Avg. Monthly Max.Daily 001A (Domestic Waste Stabilization Pond)1.25NANA80120NANA2002000 3045 002 (Storm-water runoff through oil-water separator) 0.326NANANANANANANANANANA 002A(Miscellaneous wastes and draindown through power block sumps) NANANA301001015NANANANA 003X (Circulation water and service water) 704NA0.2NANANANANANANANA 003A(Radioactive wastewater) 0.300NANA30100NANANANANANA Plant and the EnvironmentSeptember 2007 2-25 Draft NUREG-1437, Supplement 32 Table 2-2.(contd)1 2Total Residual Oxidants (mg/L) Total Suspended Solids (mg/L)
Oil and Grease (mg/L)Fecal Coliform (cells/100 ml) Biochemical Oxygen Demand (mg/L)
OutfallNo.(Outfall Description) Flow (mgd)Avg. Monthly Max.Daily Avg. Monthly Max.Daily Avg. Monthly Max.Daily Apr. 31 to Oct. 31 Nov. 1 to Mar. 1 Avg. Monthly Max.Daily 003B (Water treatment plant and wastewater system discharge) 0.195NANA301001015NANANANA 004A(Discharge from Coffey County Lake to Wolf Creek)2.9NANANANANANANANANANA 005A (Lime Sludge Pond discharge) 5.8NANA301001015NANANANA 006A (Essential Service Water System discharge) 26.5NA1.0NANANANANANANANANotes: All outfalls have a pH limitation requiring the effluent pH to be between 6 and 9. Source: KDHE 2004, in WCNOC 2006a 3 4 5 6 7 Plant and the Environment Draft NUREG-1437, Supplement 32 2-26 September 2007 Plant and the Environment September 2007 2-27 Draft NUREG-1437, Supplement 32 Figure 2-6. WCGS NPDES Outfall Locations Source: WCNOC 2007h Plant and the Environment Draft NUREG-1437, Supplement 32 2-28 September 2007 The NPDES permit does not regulate the discharge of radionuclides from the facility.
1Supplemental Condition #7 in the permit states "All radioactive components of the discharge are 2regulated solely by the NRC under the requirements of the Atomic Energy Act and not by either 3 the EPA under the CWA or the KDHE under Kansas Water Pollution Control Regulations and 4Statutes" (KDHE 2004 in WCNOC 2006a).
5 6The NPDES permit also does not regulate the temperature of the discharge to Coffey County 7Lake. In a series of letters from December 1974 to April 1975 (KDHE 1974, Kansas Gas and 8Electric 1975, KDHE 1975a), KDHE concluded that construction of the facility had begun prior to 9the promulgation of Section 316(a) of PL 92-500 and that the facility was therefore exempt from 10the Federal limitation on the discharge of heat. In addition, another letter from KDHE (KDHE 111975b) concludes that Kansas Gas and Electric Company (the predecessor to WCNOC) will not 12be held responsible for degradation of the water quality in the cooling lake that causes the lake 13to become unsuitable for body contact sports or fishing. The same letter also concludes that the 14facility will not be held responsible for the loss of fish in the lake due to cold shock, 15impingement, or entrainment. However, the letter does require that the water quality in the 16cooling lake be maintained so that it does not adversely affect ground water quality (KDHE 17 1975b).18 19A review of recent NPDES Discharge Monitoring Reports and interviews with KDHE staff 20familiar with the NPDES compliance program verified that there have never been any violations 21or compliance issues related to the permitted discharges from WCGS. The Discharge 22Monitoring Reports (WCNOC 2007e) document that deficiencies are sometimes reported due to 23 discrepancies between the weekly sampling period versus a monthly compliance period.
24However, these do not represent actual exceedances of parameters in the discharge. KDHE 25staff indicated that one issue related to the location of sampling to demonstrate compliance for 26pH levels was resolved in about 2000, but that no other violations or incidents of non-27compliance had occurred during the facility's operating history.(c)28 29 2.2.3.1.4 WCGS Environmental and Radiological Monitoring 30 31Both WCNOC and the KDHE operate ongoing sampling programs to evaluate any potential 32impacts of facility operations on local surface water quality. Samples collected to monitor for 33potential releases of radionuclides to surface water include surface water samples, drinking 34water samples, shoreline sediment samples, bottom sediment samples, aquatic vegetation 35samples, and fish tissue samples.
36 37 (c)Minutes for meeting on water and ecological issues held on March 14, 2007. Participants included: NRC, Earth Tech, and KDEH. (Accession No. ML072250572).
Plant and the Environment September 2007 2-29 Draft NUREG-1437, Supplement 32 The WCNOC program is operated in accordance with the WCGS OCDM and the results are 1documented within the Annual Radiological Environmental Operating Reports. The most recent 2report was completed in April 2007 for the calendar year 2006 (WCNOC 2007f). The 3components of the 2006 WCNOC monitoring program related to surface water quality are 4described in Table 2-3.
5 6 Table 2-3. Summary of 2006 WCNOC Surface Water Quality Monitoring Program 7 8Sample Type Location Indicator or Control Number of Samples in 2006 Program Required by ODCM? Analytes Surface Water "JRR", on John Redmond Reservoir Control 12 Yes Gamma isotopic (monthly), tritium(quarterly) Surface Water "SP", located on Coffey County Lake, near the spillway Indicator 12 Yes Gamma isotopic (monthly), tritium (quarterly) Drinking Water BW-15, Town of Burlington, from Neosho River intake. Control 12 Yes Gamma isotopic, I-
131, gross beta(monthly), tritium(quarterly) Drinking Water NF-DW, Town of Neosho Falls, from Neosho River intake Indicator 12 Yes Gamma isotopic, I-131, gross beta(monthly),
tritium(quarterly) Drinking Water IO-DW, Town of Iola, from Neosho River intakeIndicator 12 No Gamma isotopic, I-131, gross beta(monthly),
tritium(quarterly)
Plant and the Environment Draft NUREG-1437, Supplement 32 2-30 September 2007 Table 2-3.(contd)1 2Sample Type Location Indicator or Control Number of Samples in 2005 Program Required by ODCM? Analytes Shoreline Sediment JRR (John Redmond Reservoir) Control 2 Yes Gamma isotopic Shoreline Sediment DC (Coffey County Lake Discharge
Cove)Indicator 2 Yes Gamma isotopic BottomSediment JRR (John Redmond Reservoir) Control 2 No Gamma isotopic BottomSediment DC (Coffey County Lake Discharge Cove)Indicator 2 No Gamma isotopic Bottom Sediment EEA (Environmental Education Area) Indicator 1 No Gamma isotopic BottomSediment MUDS (Makeup Discharge Structure) Indicator 1 No Gamma isotopic AquaticVegetation EEA (Environmental Education Area) Indicator 1 No Gamma isotopic Aquatic Vegetation MUDS (Makeup Discharge Structure) Indicator 2 No Gamma isotopic Fish Tissue JRR (John Redmond Reservoir) Control 6 (3 species collected in 2 sampling events Yes Gamma isotopic, tritium Fish Tissue Coffey County Lake Indicator 10 (5 species collected in 2 sampling events)Yes Gamma isotopic, tritium Source: WCNOC 2007f 3The KDHE ERS Program is similar in scope to the WCNOC annual program and the results are 4reported in the Reports of Radiological Environmental Monitoring of the Environs Surrounding 5Wolf Creek Generating Station. The latest available version of this report covers the time period 6from July 2005 to June 2006 (KDHE 2006a). A summary of the surface water-related 7components of the KDHE program is provided in Table 2-4.
8 Plant and the Environment September 2007 2-31 Draft NUREG-1437, Supplement 32 Table 2-4. Summary of 2005-2006 KDHE Surface Water Quality Monitoring Program 1 2Sample Type Location Indicator or Control Number of Samples in 2005-2006 Program Analytes Surface Water John Redmond Reservoir, at MUSH, below dam Control 12 Gamma isotopic, tritium. Surface Water Coffey County Lake, spillway Indicator 12 Gamma isotopic, tritium. Surface Water Coffey County Lake, public fishing area near Makeup Discharge
Structure (MUDS) Indicator 9 Gamma isotopic, tritium. Surface Water Neosho River, near Leroy Indicator 9 Gamma isotopic, tritium. Surface Water New Strawn City Lake Indicator 1 Gamma isotopic, tritium.
Shoreline Sediment John Redmond Reservoir Control 1 Gamma isotopic Shoreline Sediment Coffey County Lake Discharge Cove Indicator 1 Gamma isotopic Shoreline Sediment Wolf Creek Indicator 1 Gamma isotopic Shoreline Sediment Makeup Discharge Structure (MUDS) Indicator 1 Gamma isotopic Shoreline Sediment 6 samples at Coffey County Lake (2), Neosho River (1), Neosho River Burlington (1), Neosho River South of Leroy (1),
and Neosho River North of Burlington (1) Indicator 6 random locations selected for 1 sample each Gamma isotopic Bottom Sediment John Redmond Reservoir Control 1 Gamma isotopic BottomSediment Coffey County Lake Discharge Cove Indicator 1 Gamma isotopic BottomSediment Environmental Education AreaIndicator 1 Gamma isotopic Plant and the Environment Draft NUREG-1437, Supplement 32 2-32 September 2007 Table 2-4.(contd)1 2Sample Type Location Indicator or Control Number of Samples in 2005-2006 Program Analytes BottomSediment 9 samples at Coffey County Lake Indicator 9 random locations selected for 1 sample each Gamma isotopic AquaticVegetation John Redmond Reservoir below the dam Control 1 Gamma isotopic AquaticVegetation Coffey County Lake Makeup Discharge Structure (MUDS) Indicator 1 Gamma isotopic AquaticVegetation Coffey County Lake Discharge Cove Indicator 1 Gamma isotopic AquaticVegetation Environmental Education AreaIndicator 1 Gamma isotopic Aquatic Vegetation Wolf Creek 11 th Street BridgeIndicator 1 Gamma isotopic AquaticVegetation 7 samples at Coffey County Lake West End (3), Coffey County Lake 17 th Road Bridge (1), US75 near 8 th Road (1), 9 th and Trefoil (1), and 19 th and Iris (1) Indicator 7 random locations selected for 1 sample each Gamma isotopic Fish Tissue John Redmond Reservoir, below dam on Neosho RiverControl 4 (2 species collected in November sampling event, 2 species collected in May sampling event)
Gamma isotopic, tritium Fish Tissue Coffey County Lake Discharge Cove Indicator 8 (4 species collected in October sampling event, 4 species collected in May sampling event)
Gamma isotopic, tritiumSource: KDHE 2006a 3The primary conclusion from both the WCNOC 2006 Annual Radiological Environmental 4Operating Report (WCNOC 2007f) and the KDHE 2006 Report of Radiological Environmental 5Monitoring (KDHE 2006a) is that tritium, which is attributable to facility operations, has been 6detected in the surface water and fish tissue samples from Coffey County Lake. The historical 7trend of tritium concentrations in the Coffey County Lake surface water samples is presented in 8Figure 2-7. These results show that tritium concentrations in Coffey County Lake have risen 9
Plant and the Environment September 2007 2-33 Draft NUREG-1437, Supplement 32 1Source: WCNOC 2007e Figure 2-7. Coffey County Lake Surface Water Tritium Data Plant and the Environment Draft NUREG-1437, Supplement 32 2-34 September 2007 steadily since operations began in 1985. This trend is consistent with pre-operational estimates 1that liquid effluents would produce a tritium concentration in Coffey County Lake of 2approximately 23,000 picoCuries per liter (pCi/L; NRC 1975). The maximum and average tritium 3concentrations in Coffey County Lake surface water and fish samples from 2005 to 2006 are 4 provided in Table 2-5.
5 6 Table 2-5. Summary of 2005-2006 Tritium Concentrations in Surface Water and Fish Samples 7 8Surface Water, Coffey County Lake picoCuries per liter (pCi/l) Fish, Coffey County Lake picoCuries per kilogram-wet (pCi/kg-wet)
Sampling Program Maximum Tritium Concentration Average Tritium Concentration Maximum Tritium Concentration Average Tritium Concentration WCNOC 14,627 11,286 14,745 1 9,472 1 KDHE 12,704 10,700 12,864 2 6,709 21 - The analytical methods for the tritium analysis differ between the WCNOC and KDHE samples. WCNOC samples are analyzed for tritium content contained within the water of the fish tissue, while the KDHE samples are analyzed for tritium concentrations in both the fat and water of the tissue (KDHE 2006a). Therefore, results are not expected to be directly comparable. 2 - Results from two samples rejected because they exceeded tritium concentration in water in the lake. Sources: WCNOC 2007f and KDHE 2006a 9Both the WCNOC annual report (WCNOC 2007f) and KDHE annual report (KDHE 2006a) 10provide an evaluation of the risk posed to humans from exposure to tritium concentrations in the 11surface water and fish in Coffey County Lake. Both reports note that Coffey County Lake is not 12used as a drinking water source and the lake is not approved for any recreational activity other 13than fishing. The KDHE report provides a dose assessment for a standard man consuming 21 14kilograms per year (kg/yr) of fish from Coffey County Lake and calculates that the man would 15receive a committed effective dose equivalent of 0.017 millirems (mrem) (KDHE 2006a).
16WCNOC performs a similar calculation that results in a committed effective dose equivalent of 170.019 mrem. These calculations are compared to the 100 mrem regulatory limit for a member 18of the public (KDHE 2006a).
19 20With respect to other locations and other radionuclides, the KDHE report concludes that no 21other surface water samples from outside of the Coffey County Lake detected radionuclides 22attributable to WCGS operations. Similarly, none of the aquatic vegetation samples showed 23any radionuclides attributable to WCGS (although these samples were not analyzed for tritium).
24The report did conclude that sediment samples from Coffey County Lake had detected the 25fission product 137Cs (196 picoCurie per kilogram [pCi/kg] -dry; KDHE 2006a). In the KDHE 262004 to 2005 sampling program, sediment samples were also reported to contain the activation 27 product 60Co at a concentration of 264 pCi/kg-dry (KDHE 2005).
28 Plant and the Environment September 2007 2-35 Draft NUREG-1437, Supplement 32 2.2.3.2 Groundwater 1 2The WCGS facility is located in the Central Lowland physiographic province of Kansas. The 3geology of the area consists of Pennsylvanian sedimentary rocks including shale, sandstone, 4limestone, and coal beds (WCNOC 2006a). Groundwater in the area occurs in three different 5types of aquifers including:
6 7 Alluvial aquifers contained within unconsolidated Quaternary and Tertiary sand and 8gravel deposits along rivers and streams, including the Neosho River; 9 Weathered bedrock aquifers occurring within a weathered zone on the surface of the 10sedimentary rock units; and 11 Consolidated bedrock aquifers occurring within unweathered sandstones and 12limestones.
13 14In general, groundwater quantity and flow rates are highest within the alluvial aquifer. Near the 15facility, the width of alluvium adjacent within the Neosho River valley ranges from 1 to 10 miles 16and is approximately 20 ft thick (WCNOC 2006a). Yield from wells within this aquifer are up to 17100 gpm (WCGS 1980). The alluvial sands and gravels are hydraulically connected to the 18Neosho River, so water levels and water quality within the aquifer are directly tied to those 19 within the river (WCNOC 2006a).
20 21The weathered bedrock aquifer may be up to 40 ft thick and wells may yield up to 10 gpm (NRC 221975). This aquifer is hydraulically connected to the alluvial aquifer and local streams (WCNOC 232004c, in WCNOC 2006a).
24 25The consolidated bedrock aquifers are found within the sandstone and limestone units. These 26aquifers may yield from 1 to 10 gpm. Because of the interbedding of the sandstones and 27limestones with shales, vertical recharge to these aquifers may be limited and recharge may 28only occur in area where the units crop out (WCNOC 2004c, in WCNOC 2006a). At the facility, 29test holes drilled to evaluate the hydrogeology of the site identified a possible aquiclude at a 30depth of 40 ft (NRC 1975).
31 32Regional and local groundwater flow directions in all three aquifer units are southwest towards 33the Neosho River (NRC 1975).
34 35The use of groundwater within the local area is limited. The WCGS facility does not use 36groundwater for any purpose (WCNOC 2006a). None of the municipalities or public water 37supply systems within the local area use groundwater as a source of water (EPA 2005). A pre-38construction well inventory conducted in 1973 identified 198 wells within 5 miles of the facility.
39These wells are used mostly for domestic water supply and livestock purposes (WCNOC 402006a). A review of the Kansas Geological Survey well location database identified a total of 92 41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-36 September 2007 wells located within 2 miles of the facility and/or located between Coffey County Lake and the 1Neosho River (KGS 2007). Most of these wells appear to have been installed by WCNOC for 2investigation of the facility prior to construction, or they are monitoring wells associated with a 3Coffey County Landfill southwest of Coffey County Lake. The wells include the following:
4 5 5 wells installed by WCNOC, in the Environmental Education Area; 6 47 wells installed between 1977 and 1980, in the area of the facility and Coffey County 7Lake dam, that appear to have been installed as part of the investigation process for 8facility construction; 9 8 dewatering wells installed by WCNOC in 1991; 10 24 monitoring wells installed by Coffey County; 11 5 former domestic wells that are listed as plugged; 12 1 domestic well installed in 2001, as used for lawn and garden purposes only; 13 1 domestic well installed in 2002, listed as used for a closed-loop heat pump system; 14 and 15 1 domestic well installed in 1975 and possibly still used for domestic purposes.
16 17A groundwater quality study was performed at the site prior to and shortly after operations 18began. This study was conducted from 1973 to 1987 and consisted of the sampling and 19analysis of a total of 12 wells within 5 miles of WCGS (EA 1988). All sampled wells were pre-20existing, shallow wells for which no construction or depth data were provided.This study 21concluded that there were no observable impacts on groundwater quality after Coffey County 22Lake was filled or for 2 years after WCGS began operations (EA 1988).
23 24As discussed in Section 2.2.3.1, both WCNOC and the KDHE operate ongoing sampling 25 programs to evaluate any potential impacts of facility operations on the local environment. Both 26of these programs include periodic sampling of groundwater wells to evaluate any potential 27impacts to groundwater quality from facility operations. A map showing the locations of the 28wells included in both programs is provided in Figure 2-8.
29 30The WCNOC sampling program is described in the Annual Radiological Environmental 31Operating Report the most recent of report was completed in April 2007 for the calendar year 322006 (WCNOC 2007f). The components of the 2006 WCNOC monitoring program related to 33groundwater quality are described in Table 2-6.
34 Plant and the Environment September 2007 2-37 Draft NUREG-1437, Supplement 32 1 Figure 2-8. Groundwater Sampling Location Map Adapted from: WCNOC 2006g Plant and the Environment Draft NUREG-1437, Supplement 32 2-38 September 2007 Table 2-6. Summary of 2006 WCNOC Groundwater Quality Monitoring Program 1 2Sample Type Location Indicator or Control Number of Samples in 2006 Program Required by ODCM? Analytes Groundwater B12 (2 miles northeast) Control 4 Yes Gamma isotopic, I-131, tritium Groundwater C10 (3 miles west) Indicator 5 Yes Gamma isotopic, I-131, tritium Groundwater C49 (3 miles southwest)
Indicator8 (4 quarterly samples, and 4 duplicate samples labeled
L-49)Yes Gamma isotopic, I-131, tritium Groundwater J1 (4 miles south) Indicator4 Yes Gamma isotopic, I-131, tritium Groundwater F1 (2 miles southeast) Indicator4 No Gamma isotopic, I-131, tritium Groundwater G2 (3 miles southeast) Indicator4 No Gamma isotopic, I-131, tritium Groundwater J2 (4 miles south) Indicator 4 No Gamma isotopic, I-131, tritium Source: WCNOC 2007f 3A summary of the groundwater-related components of the 2005 to 2006 KDHE monitoring 4 program is provided in Table 2-7.
5 6 Table 2-7. Summary of 2005-2006 KDHE Groundwater Quality Monitoring Program 7 8Sample Type Location Indicator or Control Number of Samples in 2005-2006 Program Analytes Groundwater B12 (2 miles northeast) Control 1 Gross alpha, beta, gamma isotopic, tritium GroundwaterC10 (3 miles west) Indicator 1 Gross alpha, beta, gamma isotopic, tritium Plant and the Environment September 2007 2-39 Draft NUREG-1437, Supplement 32 Table 2-7.
(contd) 1 2Sample Type Location Indicator or Control Number of Samples in 2005-2006 Program Analytes GroundwaterL49 (not clear, but apparently the same as C-49, 3 miles southwest) Indicator 1 Gross alpha, beta, gamma isotopic, tritiumSource: KDHE 2006a 3The primary conclusion from both the WCNOC 2006 Annual Radiological Environmental 4Operating Report (WCNOC 2007f) and the KDHE 2006 Report of Radiological Environmental 5Monitoring (KDHE 2006a) is that there has been no release of radionuclides attributable to 6facility operations identified.
7 8In 2006, three monitoring wells were installed on the WCGS site: one installed within the 9auxiliary building (CTR-1) and two installed south of the power block (CTR-2 and CTR-3)(d)10(KDHE 2006a). These wells were installed to evaluate the potential for leakage from the buried 11effluent line. The results from these wells indicated tritium concentrations in groundwater of 12approximately 1,400 pCi/L (WCNOC 2007g). This concentration is interpreted to indicate that 13the effluent line is not leaking. The elevated tritium concentration in the water is attributed either 14to use of Coffey County Lake water for fire fighting exercises or infiltration of Coffey County 15Lake water to the groundwater (Earth Tech 2007c). These wells have been added to the KDHE 16monitoring program for 2006 to 2007 (KDHE 2006b). Additional groundwater monitoring is 17currently being planned and is to be completed by early 2008 (Earth Tech 2007c).
18 192.2.4 Air Quality 20 21WCGS is located in the southeastern portion of Kansas, approximately 50 miles south of 22Topeka, in Coffey County. The climate is continental, characterized by rapid changes in 23temperature. The topography of the area is undulating with no particularly significant terrain 24features to cause orographic effects with respect to seasonal rainfall. Also, there are no large 25bodies of water in the vicinity to significantly influence the climate(WCNOC 2006a).This area 26is near the geographical center of the United States, in the middle of the temperate zone.
27Several rivers flow in an easterly direction to the Mississippi River in this rolling prairie upland.
28In the transitional spring and fall seasons, the numerous days of fair weather are interspersed 29with short intervals of stormy weather. Strong, blustery winds are quite common in late winter 30and spring. Autumn is characteristically a season of warm days, cool nights, and infrequent 31 (d)Minutes on meeting discussing tritium in surface and groundwater held on March 13, 2007. Participants included: NRC, Earth Tech, WCNOC, and others. (Accession No. ML072250572).
Plant and the Environment Draft NUREG-1437, Supplement 32 2-40 September 2007 precipitation, with cold air invasions gradually increasing in intensity as the season progresses 1 (NOAA 2004) 2 3The State of Kansas is generally characterized as having cold winters and warm summers. The 4weather can change suddenly with violent blizzards, thunderstorms, and tornadoes.
The mass 5of the North American continent drives the climate on local scales, with air temperatures to the 6south being less extreme than those to the north. For example, northern Kansas experiences 7colder temperatures than southern Kansas, but the differences are often slight. Cold air from 8the north moves across the flat American plains, moderating as it travels southward. The north 9part of the State has average January temperatures below 26°F, while the south is at 32°F. Hot 10winds from the south give the State warm summers, with the northwest having milder summer 11temperatures. The northwest part of the State has average July temperatures below 78°F, 12while the south is generally above 80°F. The highest temperature ever recorded in the State 13was 121°F at Fredonia on July 18, 1936 and on July 24, 1936 at Alton. The lowest recorded 14 temperature, -40°F, occurred at Lebanon on February 13, 1905 (NOAA 2007a).
15 16More specifically to the portion of Kansas where in the WCGS is located, the summers are hot 17with low relative humidity and persistent southerly winds. Oppressively warm periods with high 18relative humidity are usually of short duration. Winter temperatures average about 45
° cooler 19than the summer. Cold spells are seldom prolonged. Only on rare occasions do daytime 20temperatures fail to rise above freezing. The average annual temperature at Topeka is 55°F 21with a high monthly average of 79°F in July and a low monthly average of 28°F in January.
22Individual summers show wide departures from average conditions. While the hottest summers 23may produce temperatures of 100
°F or higher on more than 50 days, 25 percent of the 24summers pass with two or fewer 100
°F days (NOAA 2004).
25 26Precipitation amounts vary throughout the State of Kansas. The southeast usually gets 40 in. of 27rain a year and the western boundary of the State receives only 18 in. Snowfall in the State 28averages about 17 in. a year (NOAA 2007b).For the Topeka / WCGS area precipitation has 29shown a wide range for June, July, and August, varying from under 3 in. to more than 27 in.
30during the three summer months. Winter precipitation is often in the form of snow, sleet, or 31glaze. Storms of such severity that prevent normal movement of traffic or interfere with 32scheduled activity are not common. Seventy percent of the annual precipitation normally falls 33during the six crop-growing months of April through September. The rains of this period are 34usually of short duration, predominantly of the thunderstorm type. They occur more frequently 35during the nighttime and early morning hours than at other times of the day. Excessive 36precipitation rates may occur with warm-season thunderstorms. Rainfall accumulations over 8 37in. in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have occurred in Topeka.
38 39Severe weather and tornadoes have occurred in the area on several occasions causing major 40damage. A comparison of the tornado wind speed estimates for nuclear power plants within the 41 Plant and the Environment September 2007 2-41 Draft NUREG-1437, Supplement 32 United States shows that WCGS is among those with the highest potential wind speed for a 1given probability. For example, the range of wind speeds for tornadoes having a 1-in.-10
-5 2probability of striking a 200-ft long building at all nuclear power plants in the United States 3ranges from less than 65 to 168 mph. The predicted wind speed at WCGS is 167 mph with only 43 facilities having a higher projected wind speed of 168 mph (NRC 2007).
5 6The prevailing winds in southeast Kansas are likely to be from the north in the winter and spring, 7and tend to be more southerly the remainder of the year (NOAA 2004).
8 9Coffey County, in which WCGS is located, is part of the Southeast Kansas Interstate Air Quality 10Control Region.Kansas, including Coffey County, is currently in attainment for all pollutants, 11including ozone, carbon monoxide, lead, nitrogen dioxide, sulfur dioxide, and particulate 12(including PM 10 and PM 2.5) (KDHE 2006a).Under the Clean Air Act, the EPA established 13National Ambient Air Quality Standards (NAAQS) for specific concentrations for the above 14mentioned pollutants. Areas having monitored air quality as good or better then these 15standards (i.e., lower than the NAAQS) were designated attainment areas for the various 16pollutants. Areas having monitored pollutant levels greater then these standards were 17designated as non-attainment areas.
18 19The counties of Johnson and Wyandotte (Kansas City) located 49 and 67 miles, respectively, 20from WCGS, were previously designated as maintenance areas for the 1-hour ozone standard.
21A maintenance area is an area that was once designated as non-attainment and has been 22subsequently re-designated as attainment upon meeting the standards. On April 15, 2004, the 23EPA administrator implemented designation for areas of the country with respect to the more 24recent ozone 8-hour standard (69FR23858). The EPA rule for implementing the 8-hour ozone 25standard called for areas that were previously classified as maintenance under the 1-hour 26ozone standard (i.e., Kansas's Johnson and Wyandotte Counties) and were attainment for the 278-hour ozone standard to put in place a plan to maintain the 8-hour ozone standard for a ten 28year period. Thus, Kansas was required to develop a plan to maintain the 8-hour ozone 29standard for these two counties; essentially, classifying them as maintenance areas under the 308-hour ozone standard (WCNOC 2006a)
.The ozone monitoring results for 2004 showed that 31the nine ozone monitor sites in Kansas were well below the 1-hour ozone standard. A few of 32the sites were fairly close to, but still below, the 8-hour ozone standard (KDHE 2006a).
33 34There are no designated Class I Federal areas within a 50-mi radius of the WCGS. The closest 35non-attainment area for particulate (PM 2.5) and the 8-hour ozone standard is St. Louis, Missouri, 36approximately 235 miles from WCGS (WCNOC 2006a).WCGS operates under an Air Emission 37Source Class II Operating Permit issued by KDHE, Source ID No. 0310021. The facility 38operates an auxiliary boiler, an emergency fire pump, and a series of engine/generator sets 39used to produce electricity during emergency conditions only. Temporary boilers and internal 40combustion engines are operated at the facility on an "as needed" basis. This permit regulates 41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-42 September 2007 the emissions of nitrogen oxides (NOx) and sulfur dioxides (SO 2). No exceedances have 1occurred during the operational life of the facility.
2 32.2.5 Aquatic Resources 4 5The aquatic resources relevant to the operation of WCGS are those within the Neosho River 6Basin that are associated with Coffey County Lake and the transfer of water between it and the 7Neosho River and John Redmond Reservoir. The spatial relationships of these water bodies 8are shown in Figure 2-9. This section provides a description of the aquatic resources potentially 9affected by the operations of the WCGS.
10 11 2.2.5.1Water Body Characteristics 12 13 2.2.5.1.1 Wolf Creek and Coffey County Lake 14 15Wolf Creek is a small intermittent tributary of the Neosho River that begins to the north of Coffey 16County Lake (the "cooling lake") approximately 0.75 mile southwest of Halls Summit (WCGS 171974). WCGS (1980) reported Wolf Creek as having a drainage area of approximately 27.4 sq 18mi above the Coffey County Lake and including the lake itself in the 1980 "operating stage" 19Environmental Report. The total drainage area reported in the 1974 WCGS ER was 35 sq mi 20while the amount of drainage area downstream of the lake is approximately 8 sq mi. The 21gradient of Wolf Creek downstream of the lake is approximately 3.7 feet per mile (ft/mi; WCGS 22 1974).23 24Prior to construction of the lake, the creek's substrate was described as a mixture of silt, clay, 25sand, and gravel and often covered by leaf litter (Ecological Analysts, Inc. 1981). No 26information is available on the current creek substrate downstream of the dam. Wolf Creek is 27subject to brief periods of high flow following snowmelt or stormwater runoff and long periods of 28low or zero flow that may leave only pools of water (Ecological Analysts, Inc. 1981). Wolf Creek 29gains some water from the groundwater system, but the quantities are small because of the low 30permeability of the bedrock strata (WCGS 1974). The extreme changes in stream flows 31 significantly affect water chemistry and temperature. The quality of water in Wolf Creek was 32generally poor during pre-construction monitoring conducted from 1976 to 1980 (Nalco 33Environmental Sciences 1976 to 1978, Hazelton Environmental Sciences 1979 -1980). The 34total annual flow for Wolf Creek is approximately 12,985 ac-ft or 18 cfs (WCNOC 2006a). Wolf 35Creek contributes approximately one percent of the 1,865 cfs average Neosho River water flow 36measured at Iola (Putnam and Schneider 2005), which is downstream of the confluence of Wolf 37 Creek with the Neosho River.
38
Plant and the Environment Draft NUREG-1437, Supplement 32 2-44 September 2007 Coffey County Lake was created by erecting an earthen dam across Wolf Creek approximately 16 miles upstream from its confluence with the Neosho River (NRC 1975). The dam, along with 2five perimeter saddle dams, serves to impound Wolf Creek approximately 5 miles upstream 3from its confluence with the Neosho River (KG&E 1986). Filling of Coffey County Lake (then 4known as Wolf Creek Cooling Lake) began in October 1979 and was completed in June 1982 5using water from John Redmond Reservoir (EA 1988).
6 7The tops of the dams are at an elevation of 1,100 ft above MSL to allow for sufficient freeboard.
8Service and auxiliary spillways with ogee crests of 1,088 ft above MSL and 1,090.5 ft above 9MSL were constructed on the east abutment of the main dam to prevent overtopping of the 10dams by the probable maximum flood and wind and wave action. The normal operating 11elevation of Coffey County Lake is 1,087 ft above MSL. At this elevation the lake has a capacity 12of 111,280 ac-ft and covers 5,090 ac (WCNOC 2007c), with a maximum depth of 60 ft (KDWP 132007a) and an average depth of 21.5 ft (KG&E 1986). At this pool level, the lake is designed to 14provide adequate cooling water to the plant during a 1-in-50-year drought.
15 16The water level in the Lake is normally maintained by the watershed; however, during dry 17months, it is sometimes necessary to pump water to the lake from the Neosho River just below 18the John Redmond Reservoir dam. As previously discussed in Section 2.2.2, water is pumped 19from an intake in the Neosho River immediately downstream of John Redmond Reservoir when 20additional water is required to maintain adequate levels in Coffey County Lake. If the flow rate 21within the Neosho River is below 250 cfs downstream of the intake, then water may be 22purchased from the conservation pool within John Redmond Reservoir using a bypass pipe that 23can withdraw 70 cfs (WCNOC 2006a).
24 25WCGS has several dominant structures on Coffey County Lake including the CWS, UHS, Baffle 26Dikes A and B, and the dams on the south side of Coffey County Lake. The CWS is the most 27influential of these structures (KG&E 1986). This system is capable of dissipating facility 28operating heat using a transfer of up to 1,114 cfs of lake water through the system (KG&E 291986). The resulting maximum increase in discharged water temperature is 30°F, but the 30normal temperature increase ranges from 0.8°F to 7.6°F.
31 32Within the impoundment, two baffle dikes and two canals having inverts at 1,070 ft above 33MSL were built to prevent short circuiting of the water flowing from the circulating water 34discharge to the CWIS. The impoundment canals are 215 ft wide with slopes of the canal sides 35at 1 ft vertical per 3 ft horizontal. The volumetric flow rates in these canals are assumed to be 361,256 cfs at a water velocity of 0.87 fps when the impoundment water level is at 1,087 ft above 37 MSL.38 39The UHS lies to the southeast of WCGS and is an approximate 100-ac basin within Coffey 40County Lake that is confined by an armored, submerged dam (KG&E 1986). The UHS is 41 Plant and the Environment September 2007 2-45 Draft NUREG-1437, Supplement 32 designed to retain the water essential to station cooling in the event of a failure of the CWS or 1the main dam (KG&E 1986).
2 3During times of flooding, service and auxiliary spillways provide for controlled release of lake 4water to prevent overtopping of the Coffey County Lake dam. Although the dam has provisions 5 for releasing water to Wolf Creek (blowdown for chemistry control), such release is infrequently 6 performed.
7 8The service spillway and auxiliary spillway are on the east abutment of the main dam. The 9service spillway is an uncontrolled concrete ogee-crested semicircular spillway. Crest length is 10100 ft and crest elevation is 1,088 ft. This concrete service spillway is approximately 14 ft high 11and discharges water via a concrete chute to a stilling basin.
12 13The auxiliary (emergency) spillway is located near the west abutment of the main dam. The 14outlet is provided with a 60-in. diameter outlet pipe. A 30-in. diameter blowdown pipe branches 15from the outlet pipe. This blowdown system is designed to blow down water to regulate the 16water quality of Coffey County Lake.
17 18A strong north wind causes waves to break over the spillways, thus causing a release of water 19to Wolf Creek. Per the facility's NPDES permit, sampling must be conducted whenever a 20discharge occurs. Discharge occurs relatively infrequently. In 1997, there were six separate 21discharge events, 34 in 1988, 19 in 1999, three in 2000, one in 2001, none in 2002 to 2004, 22 seven in 2005, and two in 2006.
23 24The main dam on Coffey County Lake is classified as a high hazard, based on a new dam 25classification system for the State of Kansas. High hazard dams are to be inspected by the 26State every 3 years. Prior to the implementation of this classification system, every 3 years a 27registered professional engineer would inspect the dam for the WCNOC and submit a report of 28findings to the State.
29The plant also evaluates the degree of seepage through the dam on a regular basis.
30Measurements are taken at a seepage weir below the dam. These measurements are collected 31quarterly and recorded. Over the last four years (2002 to 2006), the measured seepage rate 32has been determined to be less than 0.01 cfs. According to plant personnel, Coffey County 33Lake is not routinely dredged in association with plant operations. The UHS has been dredged 34at least once since the plant went on-line. Dredging has occurred in association with the 35county-operated boat ramp on the west side of the lake.
36 37 2.2.5.1.2 Neosho River and John Redmond Reservoir 38 39The Neosho River rises northwest of WCGS in Morris County and flows generally southeasterly 40approximately 450 miles across Kansas and Oklahoma to its confluence with the Arkansas 41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-46 September 2007 River near Fort Gibson, Oklahoma. The Neosho River Basin in Kansas encompasses 1approximately 6,300 sq mi within 18 counties in southeastern Kansas (KWO 2004). The 2Neosho River has one major tributary in Kansas, the Cottonwood River, that originates in 3Marion County and flows east to join the Neosho River near Emporia, Kansas.
4 5Several city and county lakes and three Federal water reservoirs (Council Grove, Marion, and 6John Redmond), authorized by the Flood Control Act of 1950 and built in the 1960s (USACE 72007a,b,and c), occur within the Neosho River Watershed in Kansas. The reservoirs were built 8to provide flood relief and to serve as water supply reservoirs, but also provide important fish 9and wildlife habitat and create recreational opportunities. Council Grove Reservoir is a 3,310-ac 10impoundment on the northern portion of the Neosho River (KDWP 2007b) approximately 65 11river-mi upstream of the Neosho River-Wolf Creek Confluence. Marion Reservoir is a 6,160-ac 12impoundment on the Cottonwood River (KDWP 2007c) approximately 105 river-mi upstream of 13the Neosho River-Wolf Creek confluence. John Redmond Reservoir is a 9,400-ac 14impoundment on the Neosho River (KDWP 2007d) 3.5 miles west of WCGS and approximately 158 river-mi upstream of the Neosho River-Wolf Creek confluence. All three reservoirs are 16managed by the U.S. Army Corp of Engineers (USACE).
17 18The John Redmond Reservoir was created by the construction of John Redmond Dam 19approximately 3 miles north and 1 mile west of Burlington, Kansas. The dam and reservoir 20were completed for full flood control in September 1964 (USACE 2007b). John Redmond 21Reservoir has a surface area of 9,400 ac with an average depth of 6 ft and a maximum depth of 2212 ft (KDWP 2007d). The reservoir contains three types of water storage, separated by zones 23from the top to the bottom of the lake. The upper zone provides flood control storage and is 24empty until a flood event. The intermediate zone is the conservation pool that is used for water 25supply storage. The lowest zone designated for inactive storage is currently filled with sediment 26(USACE 2002). The current water supply conservation pool of John Redmond Reservoir is now 27at 1,039-ft national geodetic vertical datum (NGVD; USACE 2007b). The amount of water-28supply storage in the conservation pool has been reduced by unplanned sedimentation (USACE 29 2002).30 31 The reservoir bottom is shallow and flat, which allows for a rapid vegetative response when 32water is lowered (Jirak 2005). Management of John Redmond Reservoir currently involves a 33drawdown to 1,037 ft above MSL to encourage vegetation growth and a raise to 1,041 ft above 34MSL in the fall for waterfowl (Jirak 2005).
35 36The wide channel of the Neosho River as it enters John Redmond Reservoir contributes to the 37creation of a mudflat near the entrance. (USACE 2005). The mudflat has allowed for the 38collection of a logjam of woody debris (USACE 2005). This logjam has been accumulating at 39the entrance of the Neosho River into John Redmond Reservoir and is now estimated to be 1.5 40miles long from John Redmond Reservoir upstream (USACE 2005). It is possible that this 41 Plant and the Environment September 2007 2-47 Draft NUREG-1437, Supplement 32 logjam may represent an impediment to fish movement between the river and John Redmond 1Reservoir (Engineering-Environmental Management, Inc. 2002). However, rapid removal of the 2logjam could lead to increased sedimentation of the John Redmond Reservoir conservation 3pool. A Feasibility Study is currently being conducted to evaluate the ecosystem restoration of 4John Redmond Reservoir and will include evaluation of sediment deposition in John Redmond 5Reservoir, potential remediation of the Neosho River logjam, and alternatives to manage the 6excessive nutrient loads currently entering the reservoir (USACE 2007d).
7 8The Neosho River below the John Redmond Dam to the Kansas-Oklahoma State line is 9characterized by a meandering channel with a bed that typically consists of a combination of 10bedrock, cobble, gravel, sand, and silt (Juracek and Perry 2005). The gravel bottom of the 11Neosho River is an essential component of the in-stream habitat required for the survival of the 12 threatened Neosho madtom (Noturus placidus). 13 14The channel slope of the Neosho River below John Redmond Reservoir averages about 1.2 15ft/mi (Juracek and Perry 2005). The riverbank height varies from about 15 to 30 ft (USACE 161972, Juracek and Perry 2005) with a channel bank that consists of mostly cohesive silt and 17clay (Osterkamp and Hedman 1981, Juracek and Perry 2005) and is typically covered partially 18or completely by mature trees (Juracek and Perry 2005). Changes in the downstream flow from 19the John Redmond Dam have included a decrease in the magnitudes of peak flows and an 20increase in the magnitudes of low flows (Studley 1996).
21 22A study conducted by M. Wildhaber, et al. (2000) on the Neosho River, found that the water 23temperature was cooler, turbidity was higher, and the fredle index (a standard to evaluate the 24reproductive potential of spawning gravel) was marginally lower above the dam than below the 25dam. Dissolved oxygen increased downriver of the dam, but conductivity, alkalinity, and 26hardness were all higher above the dam.
27 28Streamflow gauging stations are operated on the Neosho River above and below WCGS by the 29U.S. Geological Survey. Annual mean flows for the Neosho at the gauging station at Americus, 30Kansas (28 miles upstream of John Redmond Reservoir) from 1964 to 2004 have ranged from 3128.2 to 1,106 cfs with the average flow being 322 cfs (Putnam and Schneider 2005). Average 32flows at the Neosho River gauging station near Burlington, Kansas (approximately 5 miles 33below the John Redmond Dam) from 1964 to 2004 ranged from 190 to 4,982 cfs and averaged 341,603 cfs for the same period. Flow at the Burlington station has been regulated since the 35installation and operation of the John Redmond Dam (Putnam and Schneider 2005). The 36annual mean flow at Iola, Kansas (the next station downstream of the Burlington station, 37approximately 50 river-mi from the Burlington station) from 1994 to 2004 ranged from 141 to 386,635 cfs and averaged 1,865 cfs (Putnam and Schneider 2005).
39 Plant and the Environment Draft NUREG-1437, Supplement 32 2-48 September 2007 The minimum desirable streamflow for the Iola station is 40 cfs during all times of the year 1(USGS 2007). A minimum flow of 40 cfs in the Neosho River at Iola during the months of July 2to March, 60 cfs in April, and 200 cfs in May and June is required by the Kansas Water 3Appropriation Act (Kansas Statutes Annotated [KSA] 82a-703c 2004). These volumes were 4established as the minimum flows allowable to avoid adverse impacts to the Neosho River 5instream and riparian habitats (WCNOC 2006a). The notably higher flows in the stations 6downstream of John Redmond Reservoir reflect the contribution of the Cottonwood River that 7merges with the Neosho River south of the Americus station and approximately 25 miles 8 northwest of John Redmond Reservoir.
9 10The annual precipitation in the Neosho River basin ranges from 30 in. in the western-most part 11to 42 in. in the southeastern portion of the basin (KWO 2004). The monthly flow data for the 12Neosho River basin reflects the seasonal pattern of precipitation that is heaviest between April 13and September. Stream flows at stations within the Neosho River basin are highest over the 14April to July period and lowest during the November to February period (Putnam and Schneider 15 2005).16 172.2.5.2 Chemical Contaminants near WCGS 18 19Contaminant concentrations in the aquatic environment at WCGS are monitored on an ongoing 20basis by WCNOC and KDHE. These agencies operate sampling programs to evaluate any 21potential impacts of facility operations to surface water, sediment, and aquatic life. Samples 22collected to monitor for potential releases of radionuclides to surface water include surface 23water samples, drinking water samples, shoreline sediment samples, bottom sediment samples, 24aquatic vegetation samples, and fish tissue samples. A summary of surface water and 25sediment quality, including a description of contaminants detected in surface water and 26sediment, is presented in Section 2.2.3. The results of analyses of plant and fish tissue and 27results from toxicity tests on water samples collected at WCGS are summarized below.
28 292.2.5.2.1 Surface Water Toxicity Testing 30 31As part of the NPDES permit requirements, acute whole effluent toxicity (WET) testing of 32surface water is conducted on a regular basis at various outfalls associated with WCGS. WET 33tests are conducted using the water flea (Ceriodaphnia dubia) and the fathead minnow 34 (Pimephales promelas). Results are available from November 2000 through June 2006 35(WCNOC 2000, 2001, 2002, 2003b, 2004c, 2005b, 2005c, 2006h).
36 37In November 2000, an effluent sample was collected from the point of discharge for outfall 003.
38At the time the sample was collected, the circulating water was being brominated and 39wastewater was being released from outfall 003A (radioactive wastewater discharge) and outfall 40003B (water treatment plant and wastewater system discharge). The test results are thus an 41 Plant and the Environment September 2007 2-49 Draft NUREG-1437, Supplement 32 indicator of the cumulative effects of these three events on the test species without 1consideration of mixing or dilution. The acute WET test was performed using 100 percent 2effluent and a series of dilutions for an exposure duration of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Acute toxicity was 3defined by statistically significant mortality of at least one of the two species. Significant 4mortality was not observed for either the water flea or fathead minnow exposed to 100 percent 5effluent (WCNOC 2000).
6 7Subsequent acute WET tests were conducted in April 2001, June 2002, May 2003, May 2004, 8June 2005, and June 2006. These acute tests were conducted in generally the same manner 9as the November 2000 test with some differences in the details. During the April 2001 test, the 10effluent sample was collected at outfall 003 while the circulating water was treated with a non-11oxidizing biocide (Calgon H-130M) and wastewater was released from outfalls 003A and 003B 12(WCNOC 2001). In June 2002, the effluent sample was collected from outfall 003 while a 13copper corrosion inhibitor was added to the circulation water and wastewater was released from 14outfall 003B only (WCNOC 2002). During the May 2003 event, effluent samples were collected 15from two outfalls: 003 and 006 (ESWS discharge). At the time of sample collection at outfall 16003, the biocide Calgon H-130M was added to the circulation water (WCNOC 2003b). In May 172004, an effluent sample was collected from outfall 003 while the biocide Calgon H-130M was 18added to the circulation water and wastewater was being released from outfalls 003A and 003B 19(WCNOC 2004c). The June 2005 and June 2006 acute WET tests were performed using an 20effluent sample collected from the outfall 003X (circulation water and service water discharge) 21point of discharge, which included three commingled discharges: disinfection of the circulation 22water system with an oxidizing biocide; release of steam generator blowdown from outfall 003A; 23and treatment of the fire protection system with the molluscicide Calgon EVAC (WCNOC 2005b, 242006g). Results from the acute WET tests conducted from April 2001 through June 2006 25indicated no significant mortality in any of the 100 percent effluent or dilution samples.
26 27In July 2005, a chronic WET test was performed on an effluent sample collected from outfall 28004A, the point of discharge from Coffey County Lake to Wolf Creek. This chronic WET test 29consisted of a 7-day static renewal larval survival and growth test on the fathead minnow and a 307-day static renewal survival and reproduction test on the water flea. As with the acute WET 31tests, the chronic test was conducted using 100 percent effluent and a series of dilutions. Test 32results indicated that the 100 percent effluent had no significant effect on larval survival or 33growth of the fathead minnow or survival or reproduction of the water flea (WCNOC 2005c).
34In summary, the acute and chronic WET tests conducted using effluent samples from outfalls 35003, 004, and 006 identified no significant toxicity to either of the two test species (water flea 36and fathead minnow) exposed to 100 percent effluent collected during events such as treatment 37of the circulation water and discharge of wastewater from outfalls 003A and 003B.
38 Plant and the Environment Draft NUREG-1437, Supplement 32 2-50 September 2007 2.2.5.2.2 Radionuclide Concentrations in Tissue Samples 1 2Radionuclide levels in fish and aquatic vegetation are generally monitored on a semiannual 3basis by WCNOC and KDHE. As discussed in Section 2.2.3.1.4, WCGS Environmental and 4Radiological Monitoring, the monitoring programs for the two agencies are similar in scope.
5Tables 2-3 and 2-4 in Section 2.2.3.1.4 summarize the sample locations, number of samples 6collected, analyses conducted, and additional information for the 2006 WCNOC monitoring 7program and 2005-2006 KDHE monitoring program, respectively.
8 9Fish samples for both monitoring programs were collected from the Coffey County Lake 10discharge cove (indicator samples) and from the Neosho River below John Redmond Reservoir 11(control samples). In the 2006 WCNOC study, five indicator species (channel catfish [
Ictalurus 12 punctatus], common carp [Cyprinus carpio carpio
], freshwater drum [Aplodinotus grunniens
], 13 smallmouth bass [Micropterus dolomieu], and smallmouth buffalo [Ictiobus bubalus]) were 14collected in May 2006 and five indicator species (channel catfish, common carp, smallmouth 15buffalo, white bass [Morone chrysops], and wiper [
Morone saxatilis x M. chrysops]) were 16collected in October 2006 in Coffey County Lake. Control species included three species 17(channel catfish, common carp, and white crappie [Pomoxis annularis]) collected in May 2006 18and three species (channel catfish, largemouth bass [Micropterus salmoides], and smallmouth 19 buffalo) collected in November 2006 in the Neosho River below John Redmond Reservoir 20(WCNOC 2007f). Water samples extracted from edible portions of the fish tissue samples were 21analyzed for gamma emitting radionuclides and tritium.
22 23Similar species were collected and analyzed for the KDHE report (KDHE 2006a). Four indicator 24species (channel catfish, common carp, walleye, and white bass) were collected in October 252005 and four indicator species (smallmouth bass, common carp, smallmouth buffalo, and 26channel catfish) were collected in May 2006 from the Coffey County Lake discharge cove. Two 27control species were collected during each of two sampling events on the Neosho River below 28John Redmond Reservoir. Channel catfish and common carp were collected in November 292005, and white crappie and common carp were collected in May 2006. Fish tissue samples 30consisted of edible portions of the fish. Gamma isotopic analysis was conducted on the water 31from the fish tissue, and tritium analysis was performed on the fat and water content of the fish 32 tissue.33 34KDHE and WCNOC results of the fish tissue sampling indicated that the only radionuclide 35related to WCGS operation detected in fish from the Coffey County Lake discharge cove was 36tritium. The maximum tritium concentration in fish tissue reported by KDHE was 12,864 pCi/kg-37wet, reported in terms of the 95% upper confidence limit by KDHE (KDHE 2006a). WCNOC 38reported a maximum detected concentration of 14,745 pCi/kg-wet, which was the actual 39maximum concentration detected (WCNOC 2007f). These results are presented in Table 2-5.
40Tritium concentrations in control samples ranged from non-detected values to 1,928 pCi/kg-wet 41 Plant and the Environment September 2007 2-51 Draft NUREG-1437, Supplement 32 (KDHE 2006a, WCNOC 2007f). The gamma isotope 40K was detected in all fish samples 1analyzed by WCNOC; however, these levels were considered naturally-occurring and not 2related to WCGS operations (WCNOC 2007g).
3 4Aquatic vegetation indicator samples for KDHE were collected (when available) from various 5locations in Coffey County Lake and from Wolf Creek below the Coffey County Lake dam.
6Control samples were collected from John Redmond Reservoir. KDHE samples were collected 7between July and September 2005 and April and June 2006. Indicator taxa collected were 8 arrowhead (Sagittariaspp.), pondweed (Potamogeton spp.), cattails (Typha spp.), bulrush 9 (Scirpusspp.), spikerush (Eleocharis spp.), American lotus (Nelumbo lutea), and naiad (Najas 10spp.). Algae samples were collected as the control (KDHE 2006a). WCNOC indicator samples 11(pondweed and naiad) were collected in May and November 2006 from two locations in Coffey 12County Lake. No WCNOC control samples were collected (WCNOC 2007f).
13 14Aquatic vegetation samples were analyzed for gamma emitting radionuclides for both WCNOC 15and KDHE samples. Two isotopes, 7 Be and 40 K, were detected in the majority of the samples; 16however, these isotopes are naturally-occurring and are common in the environment. No 17isotopes related to WCGS operation were detected in any aquatic vegetation samples (KDHE 18 2006a, WCNOC 2007f).
19 20In summary, the only radionuclide attributable to WCGS detected in tissue samples was tritium 21(detected in fish). The KDHE report concluded that the levels of radionuclides detected in the 22various media near WGCS are below regulatory levels and are generally small when compared 23with levels of naturally-occurring radionuclides (KDHE 2006a).
24 252.2.5.3 Aquatic Biological Communities 26 272.2.5.3.1 Wolf Creek and Coffey County Lake 28 29 Fish Community 30 31A total of 25 fish species was collected in Wolf Creek prior to the operation of WCGS in 1976 32(Hazelton Environmental Sciences 1979). Fish species recorded in Wolf Creek prior to building 33of the Coffey County Lake Dam are provided in Table 2-8.
34 35After completion of Coffey County Lake, WCGS embarked on a program to stock Coffey County 36Lake with a diverse population of predator fish. Fish species added to the lake included 37largemouth bass, smallmouth bass, channel catfish, blue catfish (Ictalurus furcatus
), bluegill 38 (Lepomis macrochirus), black crappie (Pomoxis nigromaculatus
), walleye, and wiper hybrids 39 (Morone saxatilis x M. chrysops) (WCNOC 2007). Gizzard shad (Dorosoma cepedianum
), 40 Plant and the Environment Draft NUREG-1437, Supplement 32 2-52 September 2007 Table 2-8.Fish Species Occurring in the Wolf Creek Drainage 1 2Family / Common Name Scientific Name Wolf Creek (1) Coffey County Lake (2)AtherinopsidaeBrook silverside Labidesthes sicculus XCatostomidae River carpsucker Carpiodes carpio XX Smallmouth buffalo Ictiobus bubalus X X Bigmouth buffalo Ictiobus cyprinellus X CentrarchidaeGreen sunfish Lepomis cyanellus XXOrangespotted sunfish Lepomis humilis X X BluegillLepomis macrochirus X X Longear sunfish Lepomis megalotis X X Smallmouth bass Micropterus dolomieu X Largemouth bass Micropterus salmoides X X White crappie Pomoxis annularis X X Black crappie Pomoxis nigromaculatus X ClupeidaeGizzard shad Dorosoma cepedianum X X CyprinidaeCentral stoneroller Campostoma anomalum XCommon carp Cyprinus carpio carpio X X Red shiner Cyprinella lutrensis X X Redfin shiner Lythrurus umbratilis XGolden shiner Notemigonus crysoleucas X X Ghost shiner Notropis buchanani X X Rosyface shiner Notropis rubellus XSuckermouth minnow Phenacobius mirabilis XBluntnose minnow Pimephales notatus XFathead minnow Pimephales promelas X X Slim minnow Pimephales tenellus XBullhead minnow Pimephales vigilax X FundulidaeBlackstripe topminnow Fundulus notatus XX Plant and the Environment September 2007 2-53 Draft NUREG-1437, Supplement 32 Table 2-8.
(contd) 1 2Family / Common Name Scientific Name Wolf Creek (1) Coffey County Lake (2)IctaluridaeBlack bullhead Ameiurus melas XXYellow bullhead Ameiurus natalis X Blue catfish Ictalurus furcatus X Channel catfish Ictalurus punctatus X X Flathead catfish Pylodictis olivaris X Moronidae White bassMorone chrysops X Striped bass Morone saxatilis X Wiper (white bass X striped bass hybrid)
Morone saxatilis x M. chrysops X PercidaeBluntnose darter Etheostoma chlorosoma XOrangethroat darterEtheostoma spectabile XLogperchPercina caprodes X WalleyeSander vitreus X Poeciliidae MosquitofishGambusia affinis XX SciaenidaeFreshwater drumAplodinotus grunniens X(1) An "X" indicates a species identified in Wolf Creek in 1976, prior to construction of Coffey County Lake. Adapted from Hazelton Environmen tal Sciences 1979. (2) An "X" indicates a species identified in Coffey County Lake, post-construction of Coffey County Lake. Adapted from WCNOC 2000.
3white bass, and white crappie larvae were inadvertently introduced to the lake during the filling 4of the lake with water from the Neosho River, resulting in populations of these fish in Coffey 5County Lake (WCNOC 2007). WCGS continues to actively manage Coffey County Lake to 6maintain a healthy gamefish population and to control gizzard shad numbers (WCNOC 2007).
7 8Coffey County Lake is a popular fishing lake that is managed by the Coffey County Sheriff's 9Office. Table 2-8 presents a list of the fish species known to occur in Coffey County Lake.
10Table 2-9 presents a summary of some of the fisheries monitoring data (expressed as catch-11 Plant and the Environment Draft NUREG-1437, Supplement 32 2-54 September 2007 per-unit-of-effort [CPUE]) collected from Coffey County Lake since 1983. Predator species that 1are considered important at WCGS to control impingement of gizzard shad include species that 2are also important for recreational purposes. These include channel catfish, white bass, wiper 3hybrids, smallmouth bass, largemouth bass, white crappie, and walleye. The following are 4descriptions of these fish species that are considered important to Coffey County Lake.
5 6Channel catfish (Ictalurus punctatus
)7 8Channel catfish are found in all large rivers in Kansas and are stocked in most reservoirs and 9ponds (KansasFishes.com 2007a). Channel catfish feed primarily from sundown until midnight 10on insects, crayfish, mollusks, and other fishes as well as scavenging for dead animals and 11parts of plants (KansasFishes.com 2007a). Spawning activity occurs from May through July 12when water temperature reaches 75 ºF (KansasFishes.com 2007a). Channel catfish build nests 13or use other structures for nests (Etnier and Starnes 1993). Channel catfish deposit eggs in 14nests preferring obscure areas beneath rock overhangs, deeply cut banks, and hollow logs 15(KansasFishes.com 2007a). Males will tend to the eggs until the young hatch, but will often 16devour the eggs when disturbed (KansasFishes.com 2007a).
17 18 White bass (Morone chrysops
)19 20White bass are common to reservoirs in Kansas (Colvin 1993 in WCNOC 2006b). They prefer 21pelagic (open water) habitats, are highly mobile, and are common in the vicinity of the 22circulating water intake (WCNOC 2006b). Their statewide population has increased because of 23stocking and habitat creation through the damming of major rivers for the creation of reservoirs 24(KansasFishes.com 2007b). White bass breed in the spring. Adults form schools and meet 25other schools at their spawning areas in tributaries of river or lakes or choppy water near 26shorelines (KansasFishes.com 2007b). Spawning takes place over a hard bottom of sand, 27gravel, or rubble (KansasFishes.com 2007b). Eggs are demersal and adhesive (Etnier and 28Starnes 1993). Newly hatched larvae also tend to hug the bottom (Etnier and Starnes 1993).
29 30Survival rates for Coffey County Lake white bass were unavailable, but average survival in 31regional reservoirs ranged from 21 to 52 percent and averaged 35 percent (Colvin 1993 in 32WCNOC 2006b). White bass forage in the early morning, late afternoon, and sometimes after 33dark (KansasFishes.com 2007b). Young white bass eat insect larvae and larval fish, and adults 34feed on insect larvae and a wide array of fishes (KansasFishes.com 2007b). Growth rates in 35Coffey County Lake, as well as regionally (Colvin 1993 in WCNOC 2006b), indicate that white 36bass take approximately three years to reach 12 in. (305 millimeters [mm]) total length (TL), 37which is the current minimum length for recreational harvest.
38 Plant and the Environment September 2007 2-55 Draft NUREG-1437, Supplement 32 Table 2-9. Catch-per-unit-of-effort (CPUE) of Selected Fish Species in Coffey County Lake 1 2 Gizzard Shad Gizzard Shad (YOY)WhiteBass Wiper Smallmouth Bass Largemouth Bass WhiteCrappie Walleye 1983 (2) 7 - (2) 23 (2) 15 - (3) 24.5 (4) 0 (2) 4 1984 25 - 18 11 - 45.0 6 29 1985 3 - 6 22 - 45.3 5 26 1986 32 - 25 14 (3) 1.3 34.5 5 9 1987 10 - 18 21 8.5 18.8 12 16 1988 12 - 28 26 10.5 22.0 9 19 1989 18 - 17 23 14.8 32.3 4 22 1990 10 - 34 12 12.0 14.0 5 13 1991 14 - 45 22 20.5 5.5 4 19 1992 19 - 17 9 10.8 8.3 6 22 1993 11 - 52 8 15.0 5.0 5 12 1994 9 - 61 11 12.5 2.0 4 23 1995 25 - 29 11 6.3 2.0 5 16 1996 9 (5) 22.9 19 3 10.8 0.3 9 20 1997 19 77.0 60 8 5.5 1.3 4 28 1998 18 39.9 45 6 10.5 1.5 3 16 1999 15 9.9 37 4 11 3.3 6 14 2000 18 29.4 36 13 21.5 3.0 (6) 9 28 2001 (1) - - - - - 2.0 - - 2002 11 3.5 32 4 2.0 1.0 6 8 2003 10 1.9 54 9 8.0 2.0 7 14 2004 12 5.5 33 6 34 0.8 - 20 2005 11 0.3 37 4 16 0.0 13 9 (1) Fall gill net, Fyke net, and electrofishing data were not collected in 2001 due to the September 11 events.(2) Data from fall standard gill netting. Units equal number per gill-net-complement-night > or = stock size. (3) Data from spring electrofishing. Units equal number per hour shocked > or = stock size. Shocking efforts starting in 2004 targeted prime habitats rather than standard locations as completed during prior years. (4) Data from spring Fyke netting. Units equal number per trap-net-night > or = stock size. (5) Data from smallmesh gill net. Units equal number per net complement of one 0.5 and one 0.75 mesh net.(6) Data beginning in 2000 were from fall Fyke netting. Netting not completed during 2004 due to adverse weather. Units equal number per trap-net-night > or = stock size. - Not collected Adapted from: WCNOC 2006b 3 Wiper hybrids (Morone sp.)4 5Wiper hybrids are striped bass (Morone saxatilis) and white bass (Morone chrysops) crosses 6(Daniels 2007). Other common names for wipers include sunshine bass, white rocks, rocket 7bass, or stripers. The hybrid is distinguishable from the striped bass by the broken horizontal 8
Plant and the Environment Draft NUREG-1437, Supplement 32 2-56 September 2007 lines that run along the sides of its body (Daniels 2007). Hybridization produces fish with a 1greater tolerance to extremes in temperature and dissolved oxygen than either of its parents 2(Daniels 2007). Most wipers are hatchery spawned and their densities are controlled by 3WCNOC stocking, which was based on shad control needs (WCNOC 2006b).
4 5Smallmouth bass (Micropterus dolomieu) and largemouth bass (Micropterus salmoides
)6 7Both the smallmouth bass and largemouth bass utilize nests for spawning (Etmier & Starnes 81993). Smallmouth bass naturally inhabit clear, cool, rocky streams and have not bred well 9outside of this habitat (Kansas Fishes 2007c), though they have been introduced to reservoirs 10(Cross and Collins 1995). In lakes and reservoirs, they typically occur in moderately deep water 11 and along undercut banks and rocky ledges (Tomelleri and Eberle 1990). In Coffey County 12Lake, smallmouth bass have been found to be the dominant shoreline predator and to be 13abundant along areas of riprap (Haines 1998).
14 15Largemouth bass occur in lakes, reservoirs, and ponds and also are native to rivers in eastern 16Kansas. They are more tolerant of warm, slightly muddy water than is the smallmouth bass, 17and they prefer muddy rather than rocky bottoms (Cross and Collins 1995). Largemouth bass 18have experienced a long-term decline in Coffey County Lake (WCNOC 2006b) that is typical of 19aging reservoirs (Kimmel and Groeger 1986, Willis 1986 in WCNOC 2006b).
20 21 White crappie (Pomoxis annularis
)22 23White crappie is an important recreational species, but it is not a species sought after for 24consumption because it has a low creel limit (WCNOC 2006b). White crappie is one of the most 25common fishes in Kansas and its numbers are increasing due to construction and stocking of 26lakes and ponds (KansasFishes.com 2007e). In lakes, white crappie usually occur in schools in 27moderately deep water offshore entering shallow, brushy areas before spawning in spring, and 28again as the water cools in autumn (KansasFishes.com 2007e). O'Brien et al. (1984 in 29WCNOC 2006b) determined that crappie 80 to 170 mm (3 to 7 in.) TL were wholly pelagic, 30preferring deeper, open waters similar to those adjacent to the WCGS cooling water intake 31(WCNOC 2006b). This preference makes white crappie more susceptible to impingement.
32 33White crappie utilize nests for spawning (Etnier and Starnes 1993) and these nests are found in 34relatively large "beds" (KansasFishes.com 2007e). White crappie have very high reproductive 35potential, which often leads to overpopulation and stunting in small lakes and impoundments 36(KansasFishes.com 2007e). Crappie feed mostly on small crustaceans and insects as young, 37and then, at approximately six in. in length, their diet changes to mostly fishes 38(KansasFishes.com 2007e). Gizzard shad is a major forage item for white crappie (Cross and 39Collins 1995, Muoneke et al. 1992 in WCNOC 2006b), making it an important species for Coffey 40County Lake (WCNOC 2006b).
41 Plant and the Environment September 2007 2-57 Draft NUREG-1437, Supplement 32 Annual survival rates for the white crappie were found to range from 23 to 29 percent in three 1Kansas reservoirs after length limits were instituted (Mosher 2000 in WCNOC 2006f) and the 2rate was 46 percent for Lake Carl Blackwell in north-central Oklahoma (Muoneke 1992 in 3WCNOC 2006b). Annual survival rates for Coffey County Lake have not been calculated, but 4the large, longer-lived crappie present in Coffey County Lake suggest that the survival rate is 5 likely to be high (WCNOC 2006b).
6 7 Walleye (Sander vitreus
)8 9The walleye is an important species both for WCGS operations and recreation (WCNOC 102006b). Walleye spawn at night over rock, rubble, gravel, and similar substrates 11(KansasFishes.com 2007f). Walleye eggs are dispersed upon release and are adhesive before 12water hardening but non-adhesive after hardening (Etnier and Starnes 1993). Walleyes prefer 13to feed on other fish, such as yellow perch (Perca flavescens
), shad, and minnows, as well as 14insects, and will consume snails, frogs, and small mammals if other resources are scarce 15(KansasFishes.com 2007f). Catch curve regressions, developed from fisheries monitoring data 16on Coffey County Lake for 2003 and 2004, indicate total annual survival estimates for walleye 17adults of 41 and 17 percent, respectively (WCNOC 2006b) and includes natural fishing, and 18 power-plant-related mortality.
19 20Gizzard shad (Dorosoma cepedianum
)21 22Gizzard shad are the primary forage for the majority of large, lake-dwelling, predator species in 23Kansas (KansasFishes.com 2007g). Large schools of shad can be observed schooling near the 24water surface in state lakes and reservoirs as they roam eating plankton (KansasFishes.com 252007g). Shad spawn in shallow bays, coves, or sloughs with no care given to the young, but 26growing to 4 in. in length during the first year of life (KansasFishes.com 2007g). Eggs are 27simply dispersed throughout the water column (Etnier and Starnes 1993). Gizzard shad are 28susceptible to sudden changes in water temperature. Large "kill offs" of gizzard shad can be 29observed in Kansas in the fall season as cold fronts invade the State and cause drastic water 30temperature changes (KansasFishes.com 2007g).
31 32 Invertebrates 33 34Macroinvertebrate communities in Wolf Creek were monitored near WCGS from 1973 through 351978 (Hazelton Environmental Sciences 1979). Wolf Creek exhibited the greatest benthic 36species diversity of any of the water bodies near WCGS. This diversity was attributed to the 37variety of microhabitats, substrates, and current velocities (NRC 1975). The primary benthic 38macroinvertebrate taxa collected in Wolf Creek were from the family Chironomidae (non-biting 39widges) and the class Oligochaeta (aquatic worms), with significant but occasional contributions 40from the families Sphaeridae (pill clam) and Simuliidae (black fly). Oligochaeta (aquatic 41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-58 September 2007 earthworms) were represented by Naididae and Tubificidae (WCGS 1980). The most abundant 1 Chironomids were Hydrobaenus
,Chironomus
, Plypedilum , and Procladius (WCGS 1980).
2These genera indicate poor water quality (Plafkin et al. 1989). 3 4Benthic macroinvertebrates collected in Coffey County Lake during early operation of WCGS 5(1981 to 1987) indicated lower species richness than that of the Neosho River (70 taxa versus 6the 179 in the Neosho River), which is typical of midwestern reservoirs (EA 1988). Aquatic 7midges (Diptera) accounted for 41 percent of all the taxa identified for the Coffey County Lake 8benthos. The oligochaete families Naididae and Tubificidae contributed 10 and 17 percent of 9the taxa identified, respectively (EA 1988). Quantitative dissimilarities of the fauna detected at 10the different sample locations reflected differences in sampling depths, substrate composition, 11and organic matter content (EA 1988). Data collected by EA (1988) indicate poor water quality 12during the 1980s, however these data are approximately 20 years old and may not reflect 13current biological conditions. Although macroinvertebrate abundance declined after the initial 14filling of Coffey County Lake, these declines were attributed to the maturing of the lake and not 15to the operation of WCGS (EA 1988).
16 17Several species of freshwater shellfish (mollusks and crustaceans) may occur in Wolf Creek, 18including fingernail clams (Musculium transversum and Sphaerium spp.) (EA 1988).
19 20 Plankton 21 22Baseline monitoring of the phytoplankton community in Wolf Creek was conducted quarterly 23from 1973 to 1975 and bimonthly from1976 to1978 (Hazelton Environmental Sciences 1979).
24Wolf Creek has intermittent flows that require sampling of isolated pools of water during low 25water periods. Each of these shallow pools represents a distinct habitat with unique 26physicochemical characteristics (Hazelton Environmental Sciences 1979). Annual mean 27phytoplankton density ranged from 1,104 to 14,156 units/milliliter (ml; reporting units were cells 28or groups of cells, depending on the taxa being counted) from 1973 to 1978 (Hazelton 29Environmental Sciences 1979). Pennate diatoms and flagellated algae, particularly 30cryptomonads (Cryptomonas) and euglenoids (Euglenas and Trachelomonas) were common 31(WCGS 1980). Other algal groups that were seasonally abundant included centric diatoms 32 (Stephanodiscus and Cyclotella
), green algae (Chlorophyta), and rarely blue-green algae 33(Oscillatoria) (WCGS 1980). Identification of periphyton populations indicated 237 taxa 34representing 62 genera in samples collected from Wolf Creek and the Neosho River (NRC 35 1982). The diatoms of genera Diploneis ,Gomphonema , and Gyrosigma and the species 36 Navicula symmetrica
,Nitzschia dissipata , and Suriella ovata, as well as blue-green algae, were 37common only in Wolf Creek (NRC 1982).
38 39Zooplankton populations in Wolf Creek were monitored from 1973 to 1978 (WCGS 1980).
40Maximum seasonal densities of 829,746 organisms/m 3 of zooplankton were measured for Wolf 41 Plant and the Environment September 2007 2-59 Draft NUREG-1437, Supplement 32 Creek in 1976 when annual precipitation was low and the minimum annual population of 15,600 1 organisms/m 3was measured in 1974 when annual precipitation was high (WCGS 1980).
2Hazelton Environmental Sciences (1979) reported dominant zooplankton taxa collected in Wolf 3Creek included copepod nauplii, cyclopoid copepodites, Trococyclops prasinus mexicanus
, 4Diaptomus siciloides, and the genera Keratella , Synchaeta , and Brachionus
.5 6In Coffey County Lake, phytoplankton, carbon fixation rates, and zooplankton biomass were 7monitored bimonthly from 1981 to 1987 (EA 1988). Average annual chlorophyll concentrations 8declined by 30 percent from 1981 to 1982, remained stable from 1982 to 1984, and returned to 9levels close to initial 1981 levels from 1985 to 1986 (EA 1988). The annual value in 1987 10declined by approximately 35 percent to 6.6 milligrams (mg)/m 3 and was below the historical 11range of 7.5-11 mg/m 3 (EA 1988). Some temporal and spatial patterns of phytoplankton were 12 noted, but were not consistent throughout the study period (EA 1988). Generally, chlorophyll 13concentrations were higher in the late summer or early autumn and lower in the deepwater area 14near the main dam (EA 1988). Carbon fixation rates were strongly influenced by the 15phytoplankton crop and ambient conditions, such as temperature (EA 1988).
16 17Zooplankton dry weight biomass declined from 1981 to 1984, increased in 1985 and 1986, and 18declined again in 1987 (EA 1988). The average annual dry weight in 1987 of 123 mg/m 3 was 19less than that observed during lake filling in 1981, but greater than the 66 mg/m 3 minimum of 201984 (EA 1988). Spatial and temporal trends were not consistent during the 1981 to 1987 21sampling period. The plankton studies indicated conditions typical of a new lake with the 22increases in plankton from 1985 to 1986 attributed to natural factors and the start-up effects of 23WCGS operations that altered lake circulation (EA 1988).
24 25An invasive species, the Asiatic clam (Corbicula fluminea) was first detected in Coffey County 26Lake in 1991 (Hammond 2006). Since that time WCGS has had a monitoring program to 27determine the population density and distribution of the clam in Coffey County Lake. As 28recently as 2006, another invasive bivalve, the zebra mussel (Dreissena polymorpha) was not 29detected in Coffey County Lake. However, the zebra mussel was observed in a lake 30approximately 70 miles from WCGS in 2003 (Hammond 2006).
31 322.2.5.3.2 Neosho River and John Redmond Reservoir 33 34 Fish Community 35 36WCNOC conducted pre-operational and operational monitoring studies of Neosho River fish 37populations from 1973 to 1987 (WCNOC 2007). These studies were conducted from the 38tailwaters of John Redmond Reservoir to below the confluence with Wolf Creek (WCNOC 392007). These studies identified 52 species representing 12 families (EA 1988). A list of the fish 40 Plant and the Environment Draft NUREG-1437, Supplement 32 2-60 September 2007 species found in the Neosho river is presented in Table 2-10. Thirteen species were reported 1consistently for each year of study sampling. These 13 species included gizzard shad, 2 3 Table 2-10.Fish Species Occurring in the Neosho River (1)4 5Family / Common Name Scientific Name Atherinopsidae Brook silverside Labidesthes sicculus Catostomidae River carpsucker Carpiodes carpio QuillbackCarpiodes cyprinus Blue sucker Cycleptus elongatus Smallmouth buffalo Ictiobus bubalus Bigmouth buffalo Ictiobus cyprinellus Black buffalo Ictiobus niger Golden redhorse Moxostoma erythrurum Shorthead redhorse Moxostoma macrolepidotum Centrarchidae Green sunfish Lepomis cyanellus Orangespotted sunfish Lepomis humilis BluegillLepomis macrochirus Hybrid sunfish Lepomis macrochirus x L. megalotis Longear sunfish Lepomis megalotis Spotted bass Micropterus punctulatus Largemouth bass Micropterus salmoides White crappie Pomoxis annularis Clupeidae Gizzard shad Dorosoma cepedianum CyprinidaeCentral stoneroller Campostoma anomalum GoldfishCarassius auratus auratus Red shiner Cyprinella lutrensis Common carp Cyprinus carpio carpio Gravel chub Erimystax x-punctatus Redfin shiner Lythrurus umbratilis Plant and the Environment September 2007 2-61 Draft NUREG-1437, Supplement 32 Table 2-10. (contd)1 2Family / Common Name Scientific Name Golden shiner Notemigonus crysoleucas Ghost shiner Notropis buchanani Rosyface shiner Notropis rubellus Sand shiner Notropis stramineus Suckermouth minnow Phenacobius mirabilis Bluntnose minnow Pimephales notatus Fathead minnow Pimephales promelas Slim minnow Pimephales tenellus Bullhead minnow Pimephales vigilax FundulidaeBlackstripe topminnow Fundulus notatus IctaluridaeBlack bullhead Ameiurus melas Yellow bullhead Ameiurus natalis Channel catfish Ictalurus punctatus StonecatNoturus flavus Freckled madtom Noturus nocturnus Neosho madtom Noturus placidus Flathead catfish Pylodictis olivaris LepisosteidaeLongnose gar Lepisosteus osseus Shortnose gar Lepisosteus platostomus MoronidaeWhite bass Morone chrysops Wiper (white bass X striped bass hybrid)
Morone saxatilis x M. chrysops PercidaeBluntnose darter Etheostoma chlorosoma Orangethroat darter Etheostoma spectabile Logperch Percina caprodes Slenderhead darter Percina phoxocephala WalleyeSander vitreus Plant and the Environment Draft NUREG-1437, Supplement 32 2-62 September 2007 Table 2-10. (contd)1 2Family / Common Name Scientific Name Poeciliidae Mosquitofish Gambusia affinis SciaenidaeFreshwater drum Aplodinotus grunniens (1) Species identified in the Neosho River from 1973 to 1987. Adapted from EA 1988.
3common carp, golden shiner (Notemigonus crysoleucas), ghost shiner (Notropis buchanani
), 4 red shiner (Cyprinella lutrensis), river carpsucker (Carpiodes carpio
), smallmouth buffalo, 5channel catfish, white bass, green sunfish (Lepomis cyanellus), orangespotted sunfish (Lepomis 6humilis), white crappie, and freshwater drum (EA 1988). The shorthead redhorse (Moxostoma 7macrolepidotum
), blue sucker (Cycleptus elongatus), flathead catfish (Pylodictis olivaris
), and 8 mosquitofish (Gambusia affinis) were collected each year after electrofishing was initiated in 91977, while the Neosho madtom (Noturus placidus) was encountered each year except 1978 10after kick seining at a location immediately downstream of the Neosho River these /Wolf Creek 11confluence (EA 1988). In all years, collections were dominated by Cyprinids (minnows and 12common carp) and Clupeids (gizzard shad) (WCNOC 2007). Relative abundance of fish 13species and other groups, such as Ictalurids, Catastomids, and Centrarchids, showed relatively 14no change in abundance from the preoperational period of 1977 to 1982, to the operational 15period of 1985 to 1987 (WCNOC 2007). Changes that were noted in the abundance of fish 16populations in the Neosho River were attributed to changes in water flow of the river determined 17by the amount and timing of precipitation received (WCNOC 2007).
18 19Fish communities in the Neosho River and Wolf Creek differed, and likely still do differ, because 20of flow characteristics and the age of the water bodies. Stormwater runoff is the primary water 21source for Wolf Creek and discharges from John Redmond Reservoir provide the majority of the 22flow in the Neosho River (WCGS 1980). Gizzard shad accounted for almost 20 percent of the 23Neosho River seine catch versus 3 percent of the Wolf Creek catch (WCGS 1980). Likewise, 24orangespotted sunfish accounted for 17 percent of the Wolf Creek catch versus less than 1 25percent of the Neosho River catch (WCGS 1980).
26 27More recently in the John Redmond Reservoir, the principal species of fish identified have 28included white crappie, white bass, channel catfish, flathead catfish, and various sunfish species 29(USACE 2007b). The sportfish population is typical of a turbid, high-flow-through impoundment 30(Jirak 2005). Rough fish, such as carp and buffalo, dominate the total biomass in the lake (Jirak 312005). John Redmond Reservoir has a very poor crappie fishery (Jirak 2005). Crappie 32populations did well during the early 1980s when John Redmond Reservoir water levels were 33 Plant and the Environment September 2007 2-63 Draft NUREG-1437, Supplement 32 managed more aggressively, but have declined since the water-level management ceased in 1the late 1980s (Jirak 2005). White bass populations in John Redmond Reservoir may be 2hindered by the logjam at the entrance of John Redmond Reservoir, particularly if water flows 3are low in the spring during spawning runs (Jirak 2005). Channel catfish populations for John 4Redmond Reservoir are average for the nature of the reservoir (Jirak 2005). John Redmond 5Reservoir has a good population of flathead catfish of all sizes (Jirak 2005). Wipers in John 6Redmond Reservoir appear to be large and anglers report good catches (Jirak 2005).
7 8 Invertebrates 9 10In the Neosho River, 179 macroinvertebrate taxa were identified in samples collected from the 11Neosho River during preconstruction and early operation of WCGS (1973 to1987). Sampling 12indicated a dominance of midges (Diptera), mayflies (Ephemeroptera), aquatic worms 13(Oligochaeta), and caddisflies (Trichoptera; EA 1988). No long-term patterns or empirical or 14statistical differences were found suggesting a change to the benthos in the Neosho River 15resulting from the construction and/or operation of WCGS (EA 1988).
16 17 In 1986, immature Asiatic clams (Corbicula fluminea) were collected in a sample from the 18Neosho River for the first time since monitoring began in 1974 (EA 1988). Surveys of C.19fluminea in the Neosho River near WCGS indicated that it remains established below the dam 20at Burlington, Kansas (EA 1988). Distribution of this mussel further upstream appears to be 21limited by inhabitable substrate types (EA 1988). Another invasive bivalve, the zebra mussel 22 (Dreissena polymorpha) has not yet been detected in the Neosho River (Haines 2006).
23However, the zebra mussel was observed in a lake approximately 70 miles from WCGS in 2003 24 (Hammond 2006).
25 26Several species of native freshwater mussels may occur in the Neosho River Basin. Several of 27these species are State-listed. These species include: butterfly (Ellipsaria lineolata), deertoe 28 (Truncilla truncata
), fat mucket (Lampsilis siliquoidea
), fawnsfoot (T. donaciformis), flutedshell 29 (Lasmigona costata), Neosho mucket (Lampsilis rafinesqueana
), Ouachita kidneyshell 30 (Ptychobranchus occidentalis
), rabbitsfoot (Quadrula cylindrica
), round pigtoe (Pleurobema 31 sintoxia), spike (Elliptio dilatata), creeper (Strophitus undulatus), Wabash pigtoe (Fusconaia 32 flava), washboard (Megalonaias nervosa
), wartyback (Quadrula nodulata
), yellow sandshell 33 (Lampsilis teres); fingernail clams (Musculium transversum) and Sphaerium transversum), giant 34 floater (Anodonta grandis), and pocketbook (Lampsilis ovata) (EA Engineering, Science, and 35Technology, Inc. 1988, Obermeyer 2000).
36 37In John Redmond Reservoir, the benthic macroinvertebrate community included as dominant 38 generaLimnodrilus
, Coelotanypus
,Chironomus
, Procladius , and Tanypus (WCGS 1980). In 39the benthic community of the John Redmond Reservoir tailwaters, Chironmidae was the most 40 Plant and the Environment Draft NUREG-1437, Supplement 32 2-64 September 2007 numerous and diverse group (NRC 1982).
Cricotopus
, Procladius, and Polypedilum were 1dominant genera (NRC 1982).
2 3 Plankton 4 5The phytoplankton community of the Neosho River immediately downstream of John Redmond 6Reservoir is strongly influenced by releases from John Redmond Reservoir (EA 1988). During 7moderate to high flows, chlorophyll concentrations immediately upstream and downstream of 8the confluence with Wolf Creek were very similar to those observed in the tailwaters of John 9 Redmond Reservoir (EA 1988). During low flow conditions, chlorophyll and carbon fixation 10rates were often different at a location immediately upstream of Wolf Creek than those observed 11at other locations (EA 1988). Chlorophyll concentrations in the Neosho River near WCGS 12ranged from less than 1 to almost 144 mg/m 3 for sampling conducted between 1973 and1987 13(EA 1988). The annual mean density of phytoplankton in the Neosho River near WCGS ranged 14from 1,973 to12,063 units/ml from 1973 to 1978 (Hazelton Environmental Sciences 1979). The 15annual mean carbon fixation rates ranged from 0 to 226 mg C/m 3 for sampling conducted 16between 1973 and 1987 (EA 1988).
17 18Centric diatoms (predominately Stephanodiscus astraea, S. hantzschii, S. minutus, Cyclotella 19atomus, C.a meneghiniana and Thalassiosira pseudonana), green algae (predominately 20Dictyosphaerium, Ankistrodesmus, Oocystis, Chlamydomonas, Crucigenia, and Tetrastrum
), 21 and cryptomonads (predominately Cryptomonas, Rhodomonas, and Chroomonas) dominated 22the phytoplankton of the Neosho River from 1973 through 1978 (Hazelton Environmental 23Sciences 1979). Large populations of centric diatoms are generally associated with reservoirs 24and lake environments (Hazelton Environmental Sciences 1979). Pennate diatoms 25 (predominatelyNitzschia and Navicula) were also frequently seen in the Neosho River samples 26(Hazelton Environmental Sciences 1979). Pennate diatoms are associated with shallow river-27reservoir systems (Hazelton Environmental Sciences 1979). Other algal divisions of seasonal 28importance included chloromonads, euglenoids, and chrysophytes (Hazelton Environmental 29Sciences 1979). Blue-green algae were usually insignificant constituents in the reservoir 30tailwater and river phytoplankton communities (Hazelton Environmental Sciences 1979).
31 32Identification of periphyton populations from 1975 to1978 indicated 237 taxa representing 62 33genera in samples collected from Wolf Creek and the Neosho River (NRC 1982). The diatoms 34Navicula tripunctata and S. spp.,andtwo green algae were dominant in the Neosho River (NRC 35 1982).36 37Zooplankton densities in the Neosho River were related to John Redmond Reservoir 38zooplankton densities, the volume of John Redmond Reservoir releases, and seasonal factors 39(Hazelton Environmental Sciences 1979). Major taxa included immature copepods, Bosmina 40 Plant and the Environment September 2007 2-65 Draft NUREG-1437, Supplement 32 logirostris and Diaptomus siciloides , and rotifers Keratella, Polyarthra
,Synchaeta, and 1 Brachionus (Hazelton Environmental Sciences 1979).
2 32.2.5.4 Rare Aquatic Species 4 5Table 2-11presents aquatic species that are Federally or State-listed as endangered or 6threatened (or are candidates for listing) in counties within which WCGS (Coffey County) and its 7associated transmission lines (Coffey, Butler, and Greenwood Counties) are located. As 8discussed in Section 2.1.7, of the three transmission lines evaluated in this draft Supplemental 9Environmental Impact Statement (SEIS), two are located almost entirely on WCGS property and 10cross only portions of Coffey County Lake: the 7-mi line from Wolf Creek to the pre-existing 11Benton line and the 0.7-mi line from Wolf Creek to the pre-existing La Cygne line. Thus, only 12the 98-mi Wolf Creek-Rose Hill line crosses the Neosho River and other water bodies that may 13support rare species. Only this line is discussed below. The species included in Table 2-11are 14those that meet the following criteria:
15 16 The species has a Federal or State legally protected status of threatened or endangered 17in Coffey, Greenwood, or Butler Counties, based on its listing status from the U.S. Fish 18and Wildlife Service (FWS) and Kansas Department of Wildlife and Parks (KDWP); and 19 20 Records maintained by the FWS and KDWP indicate that the species has been recorded 21as occurring currently or historically in at least one of these counties.
22 23Listed aquatic species that meet these criteria include two fish, five mussels, and one snail 24(Table 2-11). The two Federally listed aquatic species and one species that is a candidate for 25Federal listing are discussed below. None of these species have Federally designated critical 26habitat in the vicinity of the study area.
27 282.2.5.4.1 Topeka Shiner 29 30The Topeka shiner (Notropis topeka) is a small, stout-bodied minnow 3 in. or less in length. It 31was listed by the FWS in 1998 as endangered and by the State of Kansas in 1999 as 32threatened. Although historically this species was common in small prairie streams in the prairie 33region of the central United States, it has experienced major reductions in distribution and 34numbers throughout its historic range and is now restricted to a few headwater tributaries of the 35Missouri and Mississippi Rivers in portions of Minnesota, Iowa, Missouri, South Dakota, 36Nebraska, and Kansas. The FWS has attributed the decline of this species primarily to habitat 37loss and degradation resulting from a variety of factors, such as climate change, intensive 38cultivation, pollution, impoundments, and highway construction, as well as increased predation 39and competition from introduced fish species (Mammoliti 2004).
40 Plant and the Environment Draft NUREG-1437, Supplement 32 2-66 September 2007 In Kansas, the Topeka shiner exists almost exclusively in small headwater streams in, or very 1near, the Flint Hills. These include a number of tributaries of the Cottonwood River, Big Blue 2River, Lower Kansas River, and Smoky Hill River (Mammoliti 2004). The Cottonwood River is a 3tributary of the Neosho River. Topeka shiner populations in the Cottonwood/Neosho drainage 4in Butler, Chase, and Greenwood Counties are more than 40 miles upstream of WCGS in small 5streams that are unaffected by WCGS operations.
6 7 Table 2-11. Protected Aquatic Species Potentially Occurring in the Vicinity of WCGS and the Associated Transmission Line ROWs Federal State Scientific Name (a) Common Name (a) Status (b)Status (c)Fish Notropis topeka Topeka shiner LE T Noturus placidus Neosho madtom LT T Mollusks Cyprogenia alberti western fanshell mussel -- E Lampsilis rafinesqueana Neosho mucket mussel C E Lasmigona costata flutedshell mussel -- T Pleurocera acuta sharp hornsnail -- T Ptychobranchus occidentalis Ouachita kidneyshell mussel -- T Quadrula cylindrica rabbitsfoot mussel -- E (a) Species listed are those that (1) have Federal or State legally protected status of threatened or endangered in Coffey, Butler, or Greenwood Counties; and (2) have been recorded as occurring currently or historically in at least one of these counties. (b) Federal legal status in Kansas -- definitions: LE Listed endangered LT Listed threatened C Candidate (not legally protected) (c) State legal status definitions: E Endangered: any species of wildlife whose continued existence as a viable component of the State's wild fauna is determined to be in jeopardy. T Threatened: any species of wildlife which appears likely, within the foreseeable future, to become an endangered species. SNC Species in need of conservation: any nongame species deemed to require conservation measures in an attempt to keep the species from becoming a threatened or endangered species. Sources: KDWP 2004c and 2007e; FWS 2007a, 2007b, and 2007c Plant and the Environment September 2007 2-67 Draft NUREG-1437, Supplement 32 The preferred habitats of the Topeka shiner typically are small, low-order, prairie streams with 1good water quality, relatively cool water temperatures, and low fish diversity. These streams 2usually have perennial flow influenced by groundwater or springs, but they may become 3intermittent during summer (Mammoliti 2004). Such habitats are not present in John Redmond 4Reservoir, Coffey County Lake, Wolf Creek or the Neosho River, and the Topeka shiner has not 5 been found in these water bodies.
6 7Critical habitats for the Topeka shiner have been Federally designated in Iowa, Minnesota, and 8Nebraska (FWS 2004). The State of Kansas has designated critical habitats for the Topeka 9shiner in several counties, including Butler and Greenwood Counties. The critical habitats in 10these counties are all within the Cottonwood River watershed. All of these critical habitats are 11upstream of WCGS and could not be affected by the operation of the facility (WCNOC 2006a).
12The Wolf Creek - Rose Hill transmission line ROW within Greenwood and Butler Counties 13traverses the Verdigris, Fall, and Walnut River watersheds, but not the Cottonwood River 14watershed to the north. No populations of the Topeka shiner are known to occur within Coffey 15County and it contains no critical habitats for this species (KDWP 2004a). In addition, the 16Topeka shiner has not been found in studies of other streams traversed by the Wolf Creek -
17Rose Hill transmission line (KDWP 2006). Thus, the Topeka shiner is not expected to occur in 18John Redmond Reservoir, Coffey County Lake, Wolf Creek, the Neosho River, or any of the 19water bodies within the transmission line ROW.
20 212.2.5.4.2 Neosho Madtom 22 23 The Neosho madtom (Noturus placidus), a small catfish usually less than 3 in. long, is listed as 24threatened by both the FWS and the KDWP. Its typical habitat is riffles and sloping gravel bars 25with moderate to swift currents in relatively clear rivers of moderate size (KDWP 2004b). It 26prefers a substrate of fine gravel but has been reported in areas with bottoms that have large 27stones and cobbles or are sandy. It feeds on aquatic insects and has a lifespan of 3 to 4 years 28 (FWS 1991).
29 30The Neosho madtom is native to the Neosho River Basin of Kansas, Oklahoma, and Missouri, 31including its tributaries the Cottonwood and Spring Rivers. The largest populations are believed 32to be those of the Neosho and Cottonwood Rivers in Kansas. Smaller populations are found in 33the Spring River in Kansas and in adjacent areas of Oklahoma (Ottawa and Craig Counties) and 34Missouri (Jasper County). Within this limited range, the Neosho madtom has experienced 35population declines resulting from factors such as drought-related habitat degradation, removal 36of gravel bars, and water pollution from feedlot runoff. Habitat loss also has resulted from the 37construction of mainstream impoundments in Kansas and Oklahoma that inundated Neosho 38madtom habitat (FWS 1991).
39 Plant and the Environment Draft NUREG-1437, Supplement 32 2-68 September 2007 KDWP has designated portions of the Neosho, Cottonwood, and Spring Rivers as critical habitat 1for the Neosho madtom, including the main stem of the Neosho River from its point of discharge 2from the John Redmond Reservoir to the Kansas-Oklahoma border (KDWP 2004b). This is the 3only portion of the Neosho madtom critical habitat that is crossed by the Wolf Creek - Rose Hill 4transmission line ROW.
5 6Researchers from the FWS and U.S. Geological Survey (USGS; Wildhaber et al. 2000) 7compared densities of the Neosho madtom and several other catfish species from the family 8Ictaluridae at locations upstream and downstream of John Redmond Reservoir. The study 9utilized data from an 8-year period (1991 to 1998) to assess the effects of the dam and reservoir 10on population trends as well as habitat, hydrology, and water quality. The study found that 11Neosho madtom densities (fish per 100 square meters) were significantly higher above John 12Redmond Reservoir than below the dam, and it concluded that the lower downstream densities 13may result from the decreased turbidity and increased substrate size created by the operation of 14the dam and flood control reservoir (Wildhaber et al. 2000).
15 16In addition to the removal of particulates, the study found that the presence of John Redmond 17Dam and Reservoir changed annual flow regimes below the dam, resulting in lower minimum 18flows, more frequent low-flow events, lower short-term (1-day and 3-day) maximum flows, 19reduced variability in flow rates, increased winter flows, increased long-term (30-day and 90-20day) maximum flows, increased length and variability in duration of high-flow events, and a later 21date of maximum annual flow below the dam. Thus, the Neosho River below John Redmond 22Reservoir has become characterized by lower minimum flows, lower short-term flows, and 23higher long-term flows as a result of management of the reservoir to maintain water levels in the 24reservoir and minimize downstream flooding. The study results suggested that minimum flows 25and their timing are critical to the reproductive success of the Neosho madtom and may be 26critical to its overwinter survival. Certain minimum flows and the timing of the spring water rise 27appeared to be critical to reproduction and certain minimum flows in late-summer and fall 28appeared to improve overwinter survival of young-of-the-year madtoms. The FWS and USGS 29researchers recommended that additional data be collected on changes in water quality and 30habitat downstream of the dam and, in order to test their hypotheses about the effects of the 31flow regime, they also recommended that populations be monitored for several years while 32flows below the John Redmond Dam are increased during critical periods (Wildhaber et al.33 2000).34 35In the 1970s, biologists conducting baseline surveys for WCGS occasionally collected Neosho 36madtoms in kick-seine samples from the Neosho River upstream and downstream of the Wolf 37Creek-Neosho River confluence. After WCGS became operational in 1985, Neosho madtoms 38continued to be collected in Neosho River kick-seine samples. Over the period from 1985 to 391991, a total of 110 Neosho madtoms was collected (and released unharmed) from Neosho 40River monitoring stations. In 1992, flooding hindered seining and no Neosho madtoms were 41 Plant and the Environment September 2007 2-69 Draft NUREG-1437, Supplement 32 collected. In 1993, WCGS discontinued its monitoring of fish in the Neosho River (WCNOC 1 2006a).2 32.2.5.4.3 Neosho Mucket Mussel 4 5 The Neosho mucket (Lampsilis rafinesqueana) is a freshwater, riverine mussel (family 6Unionidae) that has been a candidate for Federal listing since 1984 and has been designated as 7an endangered species by the State of Kansas since 1992 (FWS 2005, Obermeyer 2000). The 8Neosho mucket generally is larger than other mussel species in its habitat, with a shell that is 9light to dark brown and approximately 4 in. long. Its typical habitat is characterized by shallow, 10clean, flowing water in riffles and runs with fine to medium gravel substrates (KDWP 2004c, 11Obermeyer 2000). Potential host fish for the parasitic larval life stage (glochidia) of the Neosho 12mucket in southeast Kansas include largemouth, smallmouth, and spotted basses (Obermeyer 131999). The Neosho mucket has been found only in the Illinois, Neosho, and Verdigris River 14basins of Kansas, Oklahoma, Missouri, and Arkansas. The species has disappeared from 15approximately 62 percent of its historic range, with the worst losses in the Kansas and 16Oklahoma portions of its range. Its range and habitat have been reduced by factors such as 17sedimentation, pollutants (for example, nutrients, pesticides, and metals from mining), sand and 18gravel mining in rivers and floodplains, and the impoundment of rivers by dams (FWS 2005).
19The Neosho mucket once was found in streams across eastern Kansas but now is largely 20restricted to the Neosho and Verdigris Rivers and their tributaries and a short segment of the 21Spring River in Cherokee County in the southeast corner of Kansas (KDWP 2004c, Obermeyer 222000). KDWP has designated sections of these rivers as critical habitat for the species, 23including the Neosho River from John Redmond Dam downstream to the Kansas/Oklahoma 24border (Obermeyer 2000). This is the only portion of the Neosho mucket critical habitat that is 25crossed by the Wolf Creek - Rose Hill transmission line ROW.
26 272.2.5.4.4 Other State-listed Species 28 29In addition to the three species that are both Federally and State-listed, five of the protected 30aquatic species potentially occurring in the vicinity of WCGS or the Wolf Creek - Rose Hill 31transmission line ROW are mollusks that are State-listed as endangered or threatened (Table 2-3211). The Ouachita kidneyshell (Ptychobranchus occidentalis), rabbitsfoot (Quadrula cylindrica 33cylindrica), and western fanshell (Cyprogenia aberti) are freshwater, riverine mussels that are 34State-listed as endangered species. KDWP has designated critical habitat for these mussels in 35sections of several rivers, including the Neosho River from John Redmond Dam downstream to 36the Kansas/Oklahoma border (Obermeyer 2000). The flutedshell mussel (Lasmigona costata
)37is a State-listed threatened species for which KDWP has designated critical habitat in the 38Neosho River beginning at Kansas State Highway 57, which is downstream of the Wolf Creek 39confluence, and extending downstream to Neosho County (KDWP 2004c). The sharp hornsnail 40 (Pleurocera acuta) does not have designated critical habitat in Kansas. Although Butler County 41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-70 September 2007 is in its known historic range, the sharp hornsnail is not currently known to occur in lakes or 1streams in the Wolf Creek - Rose Hill transmission line ROW (KDWP 2004c).
2 32.2.5.4.5 Summary 4
5Of the two Federally-listed species and one Federal candidate species in Table 2-11, two 6species (Neosho madtom and Neosho mucket mussel) have been confirmed in the vicinity of 7WCGS or along the associated transmission line ROWs. The Neosho madtom and the Neosho 8mucket mussel occur in the Neosho River both upstream and downstream of its confluence with 9Wolf Creek. Species that are State-listed as threatened or endangered and have State-10designated critical habitat in the Neosho River downstream of John Redmond Dam are the 11Ouchita kidneyshell, rabbitsfoot, western fanshell, and flutedshell mussels. With the exception 12of these six species, no aquatic species that is Federally or State-listed as threatened or 13endangered is known to occur or to have designated critical habitat in the vicinity of the WCGS 14site or along the associated transmission line ROW. None of these Federally or State-listed 15species are likely to occur in Coffey County Lake.
16 172.2.6 Terrestrial Resources 18 19 2.2.6.1 Terrestrial Upland Plant Communities 20 212.2.6.1.1 WCGS Property 22 23The lands on WCGS property outside the immediate area surrounding the station facilities are 24managed to achieve a balance between agricultural production and conservation. Some land 25areas have been reserved for educational purposes and maintained as natural communities for 26wildlife habitat, including a strip around the shoreline of Coffey County Lake. The remaining 27land has been leased for grazing, hay, and crop production. In 2005, approximately 1,422 ac 28were leased for grazing, 508 ac were leased for hay production, and 1,282 ac were leased for 29crops such as soybeans, milo, corn, and wheat. WCNOC's agricultural leases require 30conservation practices such as contour plowing, construction and/or maintenance of terraces to 31reduce soil erosion, and at harvest, leaving grain around field edges for wildlife (WCNOC 32 2006d).33 34Grazing restrictions, pasture rotation, and controlled burning are used to ensure continued 35health of the native rangeland on WCGS property (WCNOC 2005a). Fire has always been an 36essential part of prairie communities, and prescribed burning is used on grasslands at WCGS to 37control woody brush invasion, control less desirable cool-season grasses or weeds, increase 38wildlife value, and increase prairie vigor and production. Controlled burning was completed on 39approximately 1,197 ac in 2005. Most grassland units at WCGS are scheduled to be burned 40once every 3 years (WCNOC 2006d).
41 Plant and the Environment September 2007 2-71 Draft NUREG-1437, Supplement 32 A 200- to 400-ft wide strip surrounding the Coffey County Lake shoreline has been managed 1since 1980 as a buffer zone of natural vegetation between the lake and the agricultural areas.
2Agricultural activities are not allowed in this area and previously cultivated lands have been 3allowed to advance through the stages of natural succession. Native grasses have been re-4established in some portions of the lakeside buffer zone. Land management activities here 5include controlled burning, tree and brush control in native grass prairie areas, and noxious 6 weed control (WCNOC 2006d). Native prairie at WCGS is categorized as "bluestem prairie" 7and is typically composed of tall grasses and many species of forbs (NRC 1975). Most forested 8areas on WCGS property are in lowlands and riparian areas upstream and downstream of 9Coffey County Lake. The characteristics of these lowland/riparian forests are described below 10in Section 2.2.6.2 (WCNOC 2007c).
11 12The Wolf Creek Environmental Education Area covers approximately 500 ac near the north end 13of the site property. It includes five trails that guide visitors through a variety of habitats, 14including native tall grass prairie, native and planted forests, wetlands, and wildlife food plots. In 15addition to the natural areas, there are shelterbelts, planted trees, restored native grasses, 16developed wetlands, and planted winter food plots for wildlife. The Wolf Creek Environmental 17Education Area is the result of a partnership between private citizens, civic organizations, local, 18State and Federal governments, and WCGS (WCNOC 2006a).
19 20The area surrounding the WCGS property consists mainly of rangeland and farmland, with 21occasional forested areas in bottomlands along the Neosho River and other streams. The 22rangeland is vegetated, mostly by native and tame (introduced) grasses, mixed grass-brush, 23and managed pastures. There are no Federally designated or proposed critical habitats for 24threatened or endangered terrestrial species in the vicinity of WCGS or its associated 25transmission lines (WCNOC 2006a).
26 272.2.6.1.2 Transmission Line ROWs 28 29The transmission lines included in this assessment are those with voltages exceeding 98 kV 30that were originally constructed for the specific purpose of connecting WCGS to the existing 31transmission system. These lines are described in more detail in Section 2.1.7. These 32transmission lines extend approximately 106 miles and their ROWs cover a total area of 33approximately 1,922 ac. The ROWs cross land that is primarily agricultural or open range and 34the areas are mostly remote with few human residents. The lines also cross numerous county, 35State, or U.S. highways. ROWs that pass through farmland generally are used as farmland.
36The ROWs do not cross any State or Federal parks, wildlife refuges, or wildlife management 37areas. State and Federal lands in the vicinity of the WCGS transmission line ROWs are 38associated with the John Redmond Reservoir to the west: the John Redmond Wildlife Area, 39which is managed by the KDWP, and the Flint Hills National Wildlife Refuge, an 18,500-ac 40 Plant and the Environment Draft NUREG-1437, Supplement 32 2-72 September 2007 refuge located on the upstream portion of John Redmond Reservoir on land owned by the U.S.
1Army Corps of Engineers and managed by the FWS (WCNOC 2006d).
2 3Wolf Creek - Rose Hill Transmission Line 4 5The Wolf Creek - Rose Hill 345-kV line extends approximately 98 miles from WCGS in a 6southwesterly direction to the Rose Hill substation east of Wichita. The ROW is 150 ft in width, 7which results in a total of approximately 1,782 ac within the ROW. Land uses in the area 8traversed by this ROW include cropland (402 ac, 24 percent of the total ROW area), grazing 9lands (1,187 ac, 70 percent), woodlands (63 ac, 4 percent), idle land (27 ac, 2 percent), and 10roads (9 ac, 0.5 percent). It should be noted that the land use acreages and percentages above 11were calculated in pre-construction studies, which estimated that the length of the Wolf Creek -
12Rose Hill line would be 93 miles. The Wolf Creek-Rose Hill line passes approximately 6 miles 13south of the John Redmond Wildlife Area and 9 miles south of the Flint Hills National Wildlife 14 Refuge (WCNOC 2007c).
15 16La Cygne - Benton Transmission Line (rerouted portion) 17 18The portion of the La Cygne - Benton 345-kV transmission line that was rerouted around Coffey 19County Lake, which includes sections of the Wolf Creek - Benton line and the Wolf Creek - La 20Cygne line, is approximately 7.7-mi long. Most of this line was constructed on WCGSproperty.
21The ROW is 150-ft wide and covers nearly 140 ac. Land uses within the upland areas of this 22ROW include cropland (27 ac, 20 percent of the total ROW area); grazing land (43 ac, 31 23percent); hay meadow (15 ac, 11 percent); woodland (7 ac, 5 percent); wildlife habitat such as 24native grasses, grass-brush, and brush habitats (23 ac, 16 percent); and roads, gravel areas, 25and WCGS yard areas (11 ac, 8 percent) (WCNOC 2007c).
26 27 2.2.6.2 Riparian and Wetland Plant Communities 28 29The WCGS site encompasses approximately 9,818 ac located in Coffey County approximately 303.5 miles east of the Neosho River and 5 miles east of John Redmond Reservoir. The site 31includes the 5,090-ac Coffey County Lake, which was formed by the construction of an earthen 32dam across Wolf Creek, and the 31-ac Lime Sludge Pond.
33 342.2.6.2.1 Coffey County Lake and Wolf Creek 35 36The riparian areas of Wolf Creek upstream and downstream of Coffey County Lake are typical 37of the oak-hickory forests found in east-central Kansas. They are medium to tall, multilayered, 38broadleaf deciduous forests typically occurring on the first and second terraces adjacent to 39 streams (NRC 1975). Within the oak-hickory forest, lowland woods occupy the riparian areas of 40Wolf Creek. Studies were conducted during the initial licensing process for WCGS 41 Plant and the Environment September 2007 2-73 Draft NUREG-1437, Supplement 32 (KG&E 1982) to identify the plants composing the lowland woods along Wolf Creek. Hackberry 1(Celtis occidentalis) was dominant or codominant within the Wolf Creek woodlands. Common 2associate species were bur oak (Quercus macrocarpa), white bitternut hickory (Carya 3cordiformis), silver maple (Acer saccharinum), black walnut (Juglans nigra), American elm 4(Ulmus americana), green ash (Fraxinus pennsylvanica), and Kentucky coffee tree 5(Gymnocladus dioica). Analysis of the distribution of tree species in the lowland woods showed 6 that silver maple, American elm, green ash, and sycamore (Platanus occidentalis) were more 7common within the frequently inundated areas, while hackberry, eastern redbud (Cercis 8 canadensis), Kentucky coffee tree, hickories (Carya spp.) and oaks (Quercusspp.) occurred on 9higher, more well-drained sites (KG&E 1982).
10 11The shrub component of the Wolf Creek riparian woodland community is comprised of species 12such as coralberry (Symphoricarpos orbiculatus), poison ivy (Rhus radicans), wild gooseberry 13(Ribes missouriense), hackberry, and elms. The ground layer includes typical herbaceous 14floodplain species such as spreading chervil (Chaerophyllum procumbens), wood nettle 15 (Laportea canadensis), Virginia wild rye (Elymus virginicus), clearweed(Pilea pumila), and 16 fescue(Festuca obtusa) (NRC 1982).
17 18The shoreline and shallow water habitats of Coffey County Lake have been colonized by 19species typical of wet soils or periodically flooded habitats. The shoreline vegetation includes 20species tolerant of various degrees of inundation and wet soil conditions, such as cottonwood 21 (Populus deltoides), black willow (Salix nigra), and buttonbush (Cephalanthus occidentalis
). In 22more frequently flooded, shallow-water areas, emergent aquatic plants such as cattails (Typha 23 spp.), smartweeds (Polygonum spp.), and water primrose (Ludwigia peploides) are common.
24Emergent and submersed plants growing in shallow but slightly deeper water include American 25 lotus(Nelumbo lutea), pondweeds (Potemogeton spp., primarily p.nodosus and p. foliosus), 26 and naiad (Najas minor) (WCNOC 2007c)
.27 28As the water level of Coffey County Lake fluctuates, mudflat areas develop. Plants colonizing 29these areas predominantly are common herbaceous species, with some woody species. Two 30types of plant communities typically occupy the mudflats. In poorly drained areas, plants 31adapted to wet, marshy areas initially dominate, such as sedges (Carex spp.), cattails, 32 arrowhead(Saggitaria latifolia), and black willow. Other herbs common on wet mudflats include 33fall panic grass (Panicum dichotomiflorum), common cocklebur (Xanthium strumarium
), and 34smartweeds. In areas where inundation is infrequent (4 to 5-yr intervals), these pioneer 35communities gradually transition to communities dominated by flood-tolerant woody species, 36such as black willow, buttonbush, and cottonwood (WCNOC 2007c).
37 38Since WCGS operation began in 1985, activities have been performed to protect and enhance 39riparian areas on the station property. These have included the construction of approximately 4025 ac of shallow-water, ephemeral wetlands; protection of old-growth, oak-hickory woodland; 41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-74 September 2007 planting of bottomland forest; establishment of native grasses for buffers along the shoreline of 1Coffey County Lake; preservation of areas for natural succession; and exclusion of livestock 2(WCNOC 2007c).
3 42.2.6.2.2 Lime Sludge Pond 5 6The Lime Sludge Pond is a 31-ac unlined pond located north of the switchyard and adjacent to 7Coffey County Lake. It was originally constructed to receive lime sludge but was never used for 8that purpose. The pond provides shoreline and shallow water habitats supporting communities 9similar to those described above for the lake (WCNOC 2006a).
10 112.2.6.2.3 John Redmond Reservoir and the Neosho River 12 13The wetlands and shallow coves of John Redmond Reservoir are dominated by smartweeds, 14 bulrush (Scirpusspp.), cattail, spike-rush (Eleocharisspp.), and sedges. Some stands of silver 15maple, black willow, and eastern cottonwood also are present. On the mudflats exposed during 16reservoir drawdown, weedy annuals such as cocklebur
, foxtail grass (Setaria spp.), and 17 barnyard grass (Echinocloa spp.) are common species (USACE 2002).
18 19The riparian areas of the Neosho River upstream and downstream of John Redmond Reservoir 20were characterized in USACE (2002). The riparian woodlands along this reach of the Neosho 21River are bottomland hardwood forests dominated by American elm, green ash, eastern 22cottonwood, black willow, black walnut, sycamore,silver maple, bur oak, box elder (Acer 23 negundo),and hackberry. Downstream from John Redmond Reservoir, most of the floodplain 24vegetation along the Neosho River and its major tributaries can be described as riparian 25woodland. Islands, point bars, and first terraces are dominated by species more tolerant of wet 26soil, such as eastern cottonwood, silver maple, and box elder. Second terraces, which are 27slightly higher in elevation, support eastern cottonwood, green ash, American elm, black walnut, 28hackberry, and bur oak (WCNOC 2007c).
29 30The understory of the riparian woodland of the Neosho River floodplain includes coralberry, 31greenbriar, rough-leaf dogwood (Cornus drummondii), American plum (Prunus americana), and 32 wild grape (Vitisspp.). Downriver from John Redmond Reservoir, islands, point bars, and 33 riverbanks are invaded rapidly by sandbar willow (Salix interior), rough-leaf dogwood, and 34buttonbush, which eventually are replaced by black willow, silver maple, and eastern 35cottonwood (WCNOC 2007c).
36 372.2.6.2.4 Transmission Line ROWs 38 39Riparian and wetland communities are a small component of the natural communities present 40within the transmission line ROWs.
41 Plant and the Environment September 2007 2-75 Draft NUREG-1437, Supplement 32 Wolf Creek - Rose Hill Transmission Line 1 2The Wolf Creek - Rose Hill 345-kV line traverses a total of approximately 4,950 ft (18.2 ac) of 3riparian woods and 480 ft (1.8 ac) of stream channel. Thus, a total of approximately 1 mile of 4riparian communities and waterways is traversed by the 98-mi line, representing approximately 5one percent of the total ROW area. Major rivers and associated watersheds traversed by the 6Wolf Creek - Rose Hill transmission line include the Neosho River, primarily in Coffey County, 7the Verdigris and Fall Rivers, primarily in Greenwood County, and the Walnut River, primarily in 8Butler County. Riparian vegetation communities along these rivers are substantially similar to 9the community described above for the Neosho River (WCNOC 2007c).
10 11La Cygne - Benton Transmission Line (rerouted portion) 12 13The portion of the La Cygne - Benton 345-kV transmission line rerouted around Coffey County 14Lake is approximately 7.7-mi long and mainly on WCGSproperty. The ROW is 150-ft wide and 15covers nearly 140 ac. There are approximately 12 ac of riparian (bottomland woodland), 16surface water, shoreline, and wetland habitats included in the ROW, or 8.7 percent of the total 17ROW area (WCNOC 2007c).
18 19 2.2.6.3 Terrestrial Fauna 20 21The diversity, abundance, and distribution of terrestrial fauna in the vicinity of WCGS, and within 22the transmission line ROW, generally are governed by the available food and habitat provided 23by the upland, riparian, and wetland vegetation communities described above. WCGS property 24and the transmission line ROWs in Coffey, Greenwood, and Butler counties encompass habitat 25types common to eastern and south-central Kansas.
26 27Principal classes of fauna that typically utilize these habitats and can be expected to occur 28within the study area include mammals, reptiles, amphibians, and birds.
29 30Mammals that occur in terrestrial habitats of the region include the nine-banded armadillo 31 (Dasypus novemcinctus), eastern cottontail (Sylvilagus floridanus
), Virginia opossum (Didelphis 32 virginiana), raccoon (Procyon lotor), striped skunk (Mephitis mephitis
), coyote (Canis latrans
), 33 red fox (Vulpes vulpes), badger (Taxidea taxis), white-tailed deer (Odocoileus virginianus
);34insectivores such as the big brown bat (Eptisicus fuscus
), red bat (Lasiurus borealis
), eastern 35 mole (Scalopus aquaticus), and southern short-tailed shrew (Blarina carolinensis); and rodents 36such as the woodchuck (Marmota monax), thirteen-lined ground squirrel (Spermophilus 37tridecemlineatus
), gray squirrel (Sciurus carolinensis), pocket gopher (Geomys bursarius
), and 38 western harvest mouse (Reithrodontomys megalotis). Aquatic habitats in the area may be 39 inhabited by the muskrat (Ondatra zibethicus
), beaver (Castor canadensis
), and mink (Mustela 40 vison) (USACE 2002, WCNOC 2007c).
41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-76 September 2007 Reptiles that occur in terrestrial habitats of the region include the ornate box turtle (Terepene 1 ornata ornata
), three-toed box turtle (Terepene carolina triunguis), collared lizard (Crotaphytus 2 collaris), Great Plains skink (Eumeces obsoletus), southern prairie skink (Eumeces 3 obtusirostris), gopher snake (Pituophis catenifer), speckled kingsnake (Lampropeltisgetula 4 holbrooki), prairie kingsnake (Lampropeltis calligaster
), red-sided garter snake (Thamnophis 5sirtalis parietalis), western massasauga (Sistrurus catenatus tergeminus), and osage 6 copperhead (Agkistrodon contortrix phaeogaster). Aquatic reptiles inhabiting water bodies in 7the area include the snapping turtle (Chelydraserpentina), painted turtle (Chrysemys picta
), and 8 northern water snake (Nerodiasipedon sipedon). Amphibians that occur in terrestrial and 9aquatic habitats of the region include the American toad (Bufo americanus), Woodhouse's toad 10 (Bufo woodhousii), Great Plains toad (Bufo cognatus), northern cricket frog (Acris crepitans
), 11southern leopard frog (Rana sphenocephala), bullfrog (Rana catesbeiana
), and smallmouth 12 salamander (Ambystoma texanum) (Conant and Collins 1998, USACE 2002, WCNOC 2007c).
13 14Common birds that inhabit the terrestrial habitats of the area include raptors such as the bald 15 eagle (Haliaeetus leucocephalus), red-tailed hawk (Buteo jamaicensis), northern harrier (Circus 16 cyaneus), prairie falcon (Falco mexicanus), American kestrel (Falco sparverius
), turkey vulture 17 (Cathartes aura
), barred owl (Strix varia), and great horned owl (Bubo virginianus). Passerine, 18or perching, birds include the American crow (Corvus brachyrhynchos), eastern meadowlark 19 (Sturnella magna
), American goldfinch (Carduelis tristis), red-winged blackbird (Agelaius 20phoneniceus), northern mockingbird (Mimus polyglottos), eastern kingbird (Tyrannus tyrannus
), 21barn swallow (Hirundo rustica), horned lark (Eremophila alpestris
), American robin (Turdus 22migratorius), northern cardinal (Cardinalis cardinalis), brown thrasher (Toxostoma rufum
), field 23 sparrow (Spizella pusilla), and eastern bluebird (Sialia sialis). Upland game birds occurring in 24the area include the wild turkey (Meleagris gallopavo), northern bobwhite (Colinus virginianus
), 25 and mourning dove (Zenaida macroura) (USACE 2002, WCNOC 2007c).
26 27Common birds that inhabit the aquatic habitats of the area include waterfowl (ducks and geese) 28and a variety of other water birds, such as shorebirds and wading birds. The main use by 29waterfowl of the lakes, ponds, and wetlands in the area is for resting and foraging during fall and 30spring migration; little nesting activity takes place in the vicinity (USACE 2002). Waterfowl 31commonly observed in the area during migration include the mallard (Anas platyrhynchos
), 32 wood duck (Aix sponsa), northern shoveler (Anas clypeata), blue-winged teal (Anas discors
), 33 green-winged teal (Anas crecca), cinnamon teal (Anas cyanoptera), lesser scaup (Aythya 34 affinis), redhead (Aythya americana), ring-necked duck (Aythya collaris), common merganser 35 (Mergus merganser), Canada goose (Branta canadensis), snow goose (Chen caerulescens
), 36and white-fronted goose (Anser albifrons). Shorebirds that occur in the area during migration 37include the greater yellowlegs (Tringa melanoleuca), lesser yellowlegs (Tringa flavipes
), 38semipalmated sandpiper (Calidris pusilla), solitary sandpiper (Tringa solitaria
), western 39 sandpiper (Caladris mauri
), willet (Catoptrophorus semipalmatus
), ring-billed gull (Larus 40 delawarensis
), herring gull (Larus argentatus), Forster's tern (Sterna forsteri), and black tern 41 Plant and the Environment September 2007 2-77 Draft NUREG-1437, Supplement 32 (Chlidonias niger), while the killdeer (Charadrius vociferus) and spotted sandpiper (Actitis 1 macularia) may breed in the area. Other water birds that may occur in the vicinity include the 2white pelican (Pelecanus erythrorhynchos
), American coot (Fulica americana), pied-billed grebe 3 (Podilymbus podiceps), horned grebe (Podiceps auritus), and double-crested cormorant 4 (Phalacrocorax auritus), and wading birds such as the great blue heron (Ardea herodias) and 5 green heron (Butorides virescens) (USACE 2002, WCNOC 2007c).
6 7A wildlife monitoring program was begun at WCGS in 1982 to monitor and assess waterfowl, 8water bird, and bald eagle usage of Coffey County Lake and the Lime Sludge Pond. This 9program included transmission-line collision surveys to assess avian collision mortality and 10determine potential mitigation needs. Upon completion of monitoring in 1986, sufficient data 11had been collected to determine that avian collisions with transmission lines were minimal, and 12no endangered or threatened species were found (WCNOC 2006a). Consequently, the scope 13of the wildlife monitoring program was reduced (WCNOC 1988). The current program, in 14accordance with the Avian Protection Plan (WCNOC 2006i) consists of annually reviewing 15waterfowl and bald eagle survey data collected by the KDWP and then determining if changes 16to the wildlife monitoring program are warranted (WCNOC 2005d).
17 18Wildlife and habitat management at WCGS involves cooperation between WCGS biologists, the 19 FWS, and KDWP. For example, four ospreys (Pandion haliaetus) were released each year 20from 1996 to 2001 at the Wolf Creek Environmental Education Area in cooperation with KDWP 21in an attempt to establish a nesting population. Also, in an attempt to establish a nesting 22population of the American peregrine falcon (Falco peregrinus anatum), five juveniles were 23released at WCGS in 2004, and five more were released in 2005 (WCNOC 2006a).
24 25 2.2.6.4 Rare Terrestrial Species 26 27Table 2-12presents terrestrial animal and plant species that are Federally or State-listed as 28endangered or threatened (or are candidates for listing) in the counties within which WCGS 29(Coffey County) and its associated transmission lines (Coffey, Butler, and Greenwood Counties) 30are located. The species included in Table 2-12are those that meet the following criteria:
31 32 The species has a Federal or State legally protected status of threatened or endangered 33in Coffey, Greenwood, or Butler Counties, based on its listing status from the FWS and 34KDWP; and 35 36 Records maintained by the FWS and KDWP indicate that the species has been recorded 37as occurring currently or historically in at least one of these counties.
38 Plant and the Environment Draft NUREG-1437, Supplement 32 2-78 September 2007 Table 2-12. Protected Terrestrial Species Potentially Occurring in the Vicinity of WCGS and the 1Associated Transmission Line ROWs 2 3 Federal State Scientific Name (a) Common Name (a) Status (b)Status (c)Mammals Spilogale putorius eastern spotted skunk -- T Birds Charadrius alexandrinus snowy plover -- T Charadrius melodus piping plover (PS 1: LT) T Falco peregrinus peregrine falcon -- E Grus americana whooping crane LE E Haliaeetus leucocephalus bald eagle
--2 E Sterna antillarum least tern (PS 3: LE) E Plants Asclepias meadii Mead's milkweed LT -- (a) Species listed are those that (1) have Federal or State legally protected status of threatened or endangered in Coffey, Butler, or Greenwood Counties; and (2) have been recorded as occurring currently or historically in at least one of these counties. (b) Federal legal status in Kansas -- definitions: LE Listed endangered LT Listed threatened (PS) Partial status: listing status in only a portion of the species' range, as specified in footnotes below 1Piping plover status in Kansas is threatened; only populations in the Great Lakes region are endangered 2Bald eagle was federally delisted on August 8, 2007.
3Least tern status is endangered only for the population that breeds in the interior of the United States (c) State legal status definitions: E Endangered: any species of wildlife whose continued existence as a viable component of the State's wild fauna is determined to be in jeopardy. T Threatened: any species of wildlife which appears likely, within the foreseeable future, to become an endangered species. SNC Species in need of conservation: any nongame species deemed to require conservation measures in an attempt to keep the species from becoming a threatened or endangered species. Sources: KDWP 2004c and 2007e; FWS 2007a, 2007b, and 2007c Plant and the Environment September 2007 2-79 Draft NUREG-1437, Supplement 32 Listed terrestrial species that meet these criteria include six birds, one mammal, and one plant 1(Table 2-12). The peregrine falcon, one of the species State-listed as endangered, has been 2released at WCGS (a total of ten juveniles in 2004 and 2005) as part of a program to establish a 3nesting population (WCNOC 2006a). The four Federally-listed species are described below.
4None of these species have Federally designated critical habitat in the vicinity of the study area.
5 62.2.6.4.1 Piping Plover 7
8The piping plover (Charadrius melodus) is a small, migratory shorebird about 7 in. long that 9forages near water and preys on invertebrates. Itbreeds in three geographic regions of North 10America: the northern Great Plains, the Great Lakes, and the Atlantic Coast. The northern 11Great Plains breeding population of the piping plover is Federally-listed as threatened. The 12piping plover is State-listed as threatened in Kansas. The breeding range of the northern Great 13Plains population includes southern Alberta, northern Saskatchewan, and southern Manitoba in 14Canada, and eastern Montana, North and South Dakota, southeastern Colorado, Iowa, 15Nebraska, and north-central Minnesota. The majority of breeding pairs in the United States are 16in the Dakotas, Nebraska, and Montana. Fewer pairs nest in Minnesota, Iowa, and Colorado, 17and there is occasional nesting in Oklahoma and Kansas (FWS 2002). Piping plovers return to 18their breeding grounds in northern Great Plains in March or April and depart by September to 19winter along the Gulf Coast. Northern Great Plains breeding and nesting habitats for the piping 20plover include sandbars and islands in river channels; sparsely vegetated sand or gravel 21shorelines, peninsulas, and islands of lakes and reservoirs; and alkali wetlands and lakes (FWS 222007b). In Kansas, nesting has been recorded on sand bars along the Kansas River in the 23northeastern part of the State (KDWP 2004c).
24 25Habitat destruction or degradation and poor breeding success due to predation are principal 26reasons for the decline in piping plover populations. Construction and operation of reservoirs on 27the Missouri and other river systems have reduced sandbar habitat and caused water 28fluctuations affecting the remaining sandbars. Plovers using the reduced sandbar areas that 29remain are susceptible to predation and human disturbance. Critical habitat has been 30designated by the FWS for piping plover breeding habitat in Minnesota, Montana, North Dakota, 31South Dakota, and Nebraska, but not in Kansas (FWS 2007b). KDWP has no current records 32of the piping plover in Coffey, Greenwood, or Butler Counties (FWS 2007c), but it designates 33Coffey County as being within the known historic range of the piping plover (KDWP 2004c).
34 352.2.6.4.2 Whooping Crane 36 37 The whooping crane (Grus americana) is Federally and State-listed as endangered. It is the 38tallest North American bird. Males approach 1.5 meters (5 ft) when standing erect. It is a 39wading bird with an omnivorous diet that varies by season and includes insects, frogs, rodents, 40small birds, minnows, and berries in summer; crabs, clams, and a few plants in winter; and 41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-80 September 2007 frogs, fish, plant tubers, crayfish, insects, and agricultural grains during migration. The 1whooping crane is a long-lived species currently estimated to have a maximum longevity in the 2wild of at least 30 years (CWS and FWS 2007). It feeds and roosts in wetlands and upland 3grain fields and nests in marshy areas among cattails, bulrushes, and sedges. During migration 4through Kansas, it prefers resting areas in wetlands, in level to moderately rolling terrain away 5from human activity and where low, sparse vegetation allows it an open view (KDWP 2004c).
6 7The whooping crane was listed as endangered in the U.S. in 1973. Population declines of the 8whooping crane historically were caused by habitat loss (mainly destruction of nesting habitat in 9prairies due to agricultural development), shooting, and displacement by human activities.
10Current threats include the limited genetic potential of the population (the wild population was 11estimated at 338 in February 2006), loss and degradation of migration stopover habitat, 12construction of additional power lines, and degradation of the coastal ecosystems where it 13winters (CWS and FWS 2007). The historical breeding range of the whooping crane included 14the northern Great Plains and the birds historically wintered along the Gulf of Mexico. Currently, 15the only self-sustaining wild population breeds in the Northwest Territories of Canada and 16winters at the Aransas National Wildlife Refuge on the coast of Texas (FWS 2007b). Birds from 17this population migrate through central Kansas in the spring (March - April) and fall (October -
18November) (KDWP 2004c) as part of their annual migration that covers 4,000 kilometers (2,485 19 miles) (CWS and FWS 2007).
20 21Two areas in central Kansas, Cheyenne Bottoms State Waterfowl Management Area in Barton 22County and Quivira National Wildlife Refuge in Stafford, Reno, and Rice Counties, have been 23Federally designated as critical habitat for migrating whooping cranes under the Endangered 24Species Act (FWS 2007b). These two critical migratory habitats are on the approximate center 25line of a 200-mi-wide migration corridor that crosses central Kansas in a north-south orientation.
26The corridor was delineated by the FWS by mapping confirmed sightings of whooping cranes 27reported by individuals through 1999 and data from radio-tracking of whooping cranes during 28the period 1981 to 1984. The corridor encompasses approximately 94 percent of all sightings 29through 1999 (CWS and FWS 2007). The two critical habitats are more than approximately 160 30miles west of WCGS and 80 miles northwest of the western terminus of the WCGS - Rose Hill 31transmission line ROW. WCGS is approximately 60 miles east of the migration corridor, while 32the terminal end of the transmission line ROW extends approximately 30 miles inside the 33corridor. There are no current records of the whooping crane in Coffey, Butler, or Greenwood 34Counties (FWS 2007c), but KDWP designates Coffey and Greenwood Counties as being within 35the known historic range of the whooping crane (KDWP 2004c)
.36 37 2.2.6.4.3 Least Tern 38 39Interior populations of the least tern (Sterna antillarum) in the United States are Federally listed 40as endangered. Interior populations are those more than 50 miles from the coasts. The least 41 Plant and the Environment September 2007 2-81 Draft NUREG-1437, Supplement 32 tern is State-listed as endangered in Kansas. The least tern is the smallest North American 1tern. It feeds by hovering and diving for small fish. The least tern winters in Central and South 2America and is found in Kansas only during migration and the summer nesting season. Its 3preferred nesting habitats are sparsely vegetated sand and gravel bars within wide, 4unobstructed, river channels. It also has been recorded nesting in sand and gravel pits, dredge 5islands, and along lake shorelines. The interior population of the least tern has declined 6primarily due to loss of habitat resulting from dam construction and river channelization on major 7rivers throughout the Mississippi, Missouri, and Rio Grande River systems (FWS 2007b).
8Because of dams, river flows often are not conducive to the creation and maintenance of 9sandbars with sparse vegetation. Other disturbances, such as housing construction, 10development, and recreational activities that disturb nest sites, also threaten least tern 11populations (FWS 2007b).
12 13The Final Environmental Statement (FES) related to the operation of WCGS stated that the 14least tern was observed at John Redmond Reservoir in 1977, but the FES did not specify 15whether the occurrence referred to migratory or nesting terns (NRC 1982). One to six least 16terns were observed on a few occasions at Coffey County Lake during the mid-1980s, but the 17terns were presumed to be transients and nesting of least terns has not been recorded at Coffey 18County Lake (WCNOC 2006b). There are no current records of the least tern in Coffey, 19Greenwood, or Butler Counties (FWS 2007c). Of these three counties, KDWP designates only 20Coffey County as being within the known historic range of the least tern (KDWP 2004c).
21 222.2.6.4.4 Mead's Milkweed 23 24 Mead's milkweed (Asclepias meadii) is Federally-listed as threatened. The State of Kansas 25does not include plant species in its list of threatened and endangered species and does not 26provide legal protection to this species. Mead's milkweed is a perennial herb of the tallgrass 27prairie. It produces a single cluster of greenish-white flowers at the top of a 2-ft stalk in May and 28early June. Mead's milkweed has low reproductive rates but is a long-lived plant that may 29persist indefinitely unless destroyed by humans, animals, or pathogens. Studies based on 30growth of seedlings suggest that Mead's milkweed may require 15 years or more to mature from 31a germinating seed to a flowering adult. The habitat of Mead's milkweed principally is mesic to 32dry mesic upland, tallgrass prairie, generally in full sun and on slopes of less than 20 percent 33 (FWS 2003).
34 35Mead's milkweed was listed as threatened in 1988. Its populations have declined due to the 36fragmentation and destruction of tall-grass prairie as a result of intense agricultural use, urban 37growth, development, recreational use of sites, and hay mowing that disrupts the reproductive 38cycle. Mead's milkweed continues to be threatened by these factors as well as effects of habitat 39fragmentation that include the loss of genetic diversity, lack of pollinators, and increased insect 40predation (FWS 2003).
41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-82 September 2007 Mead's milkweed formerly was widespread over much of the eastern tallgrass prairie region of 1the central United States. It has been extirpated from Wisconsin and Indiana and currently is 2known to occur at approximately 170 sites within 34 counties in eastern Kansas, Missouri, 3south-central Iowa, and southern Illinois. Kansas populations are in the eastern counties from 4north of the Kansas River south to Neosho County in the southeastern corner of the State.
5Almost all of the Mead's milkweed population sites in Kansas are on privately owned land that is 6being used as prairie hay meadows. Mowing of these prairies typically occurs in late June to 7early July and results in the removal of immature fruits, thus preventing the plants from 8completing their life cycle (FWS 2003). The FWS Mountain-Prairie Region records this species 9as occurring in Coffey County (FWS 2007c). Surveys to determine the presence of Mead's 10milkweed on WCGS property or within the transmission line ROWs have not been performed.
11The presence of tallgrass prairie communities on these properties within Coffey County 12indicates that habitat with the potential to support Mead's milkweed may be present, although 13the plant is not currently known to occur in these areas.
14 152.2.6.4.5 Summary 16 17Of the four Federally-listed terrestrial species in Table 2-12, only one species (the least tern) 18have been confirmed in the vicinity of WCGS or along the associated transmission line ROW.
19Least terns were recorded at Coffey County Lake in the 1980s, but nesting has not been 20observed there. With the exception of this species and the State-listed peregrine falcons 21released in the vicinity of Coffey County Lake, no other terrestrial species that is Federally or 22State-listed listed as threatened or endangered has been recorded as occurring in the vicinity of 23the WCGS site or along the associated transmission line ROWs.
24 252.2.7 Radiological Impacts 26 27WCGS conducts an annual REMP in which radiological impacts to employees, the public, and 28the environment in and around the Wolf Creek site are monitored, documented, and compared 29to the appropriate standards. The objectives of the REMP are to:
30 31 Measure and evaluate the effects of facility operation on the environs and verify the 32effectiveness of the controls on radioactive effluents; 33 Monitor natural radiation levels in the environs of the WCGS site; and 34 Demonstrate compliance with the requirements of applicable Federal regulatory 35agencies, including technical specifications and the ODCM.
36 37Radiological releases are summarized in two WCGS reports: the Annual Radiological 38Environmental Operating Report (WCNOC 2003c, 2004d, 2005e, 2006g, 2007e) and Annual 39Radioactive Effluent Release Report (WCNOC 2003a, 2004a, 2005a, 2006c, 2007a). Limits for 40all radiological releases are specified in the WCGS ODCM and are used to meet Federal 41 Plant and the Environment September 2007 2-83 Draft NUREG-1437, Supplement 32 standards and requirements. The REMP includes monitoring of the waterborne environment 1(surface, sediment from shoreline); airborne environment (radioiodine and particulates, direct 2radiation); and ingestion pathways (milk, fish, food products). During 2006, there were no plant-3related activation, corrosion, or fission products detected in airborne particulate and radioiodine 4filters, ground water, drinking water, shoreline sediment, broadleaf vegetation, crops, terrestrial 5vegetation, aquatic vegetation, soil, or deer samples. Activation, corrosion, or fission products 6attributable to plant operation were detected during 2006 in surface water, fish, and bottom 7sediment samples. However, the reported data on the radionuclides detected in environmental 8samples were below applicable NRC reporting levels and showed no significant or measurable 9impact from the operations at WCGS. The KDHE also performs sampling and analysis of 10selected environmental media in conjunction with WCGS. Historical data on releases from 11WCGS and the resultant dose calculations demonstrate that the doses to a maximally exposed 12individual in the vicinity of WCGS were a small fraction of the limits specified in 10 CFR Part 20; 13Appendix I to 10 CFR Part 50; and EPA radiation standards in 40 CFR Part 190. For 2006, 14dose values were calculated based on actual liquid and gaseous effluent release data and 15conservative models to simulate the transport mechanisms. The results are described in the 162006AnnualRadioactive Effluent Release Report (WCNOC 2007a). A summary of the 17calculated maximum dose to an individual located at the WCGS site boundary from liquid and 18gaseous effluents released during 2006 is as follows:
19 20 The calculated whole-body dose to the maximally exposed off-site member of the 21general public from liquid effluents was 0.149 mrem, well below the 3-mrem-dose criteria 22 in Appendix I to 10 CFR Part 50.
23 The calculated whole-body dose to the maximally exposed off-site member of the 24general public from gaseous effluents was 0.038 mrem, well below the 5-mrem-dose 25criteria in Appendix I to 10 CFR Part 50.
26 27In addition to the routine REMP, the applicant established an on-site groundwater monitoring 28program in March 2006. The program is designed to monitor the on-site environment for 29indication of leaks from plant systems and pipes carrying liquids with radioactive material. The 30results were reported in the WCGS 2006 Annual Radioactive Effluent Release Report (WCNOC 312007a). The data showed that, except for tritium, no radioactive material from the plant was 32detected in the groundwater samples. The level of tritium in the wells ranged from 197 pCi/l to 332,280 pCi/l, which is well below the reporting level of 20,000 pCi/l. More detailed information on 34water monitoring is contained in Section 2.2.3.
35 36The applicant does not anticipate any significant changes to the radioactive effluent releases or 37exposures from WCGS operations during the renewal period and the impacts to the 38environment are, therefore, not expected to change.
39 Plant and the Environment Draft NUREG-1437, Supplement 32 2-84 September 2007 2.2.8 Socioeconomic Factors 1 2This section describes current socioeconomic factors that have the potential to be directly or 3indirectly affected by changes in operations at WCGS. WCGS and the communities that 4support it can be described as a dynamic socioeconomic system. The communities provide the 5people, goods, and services required by WCGS operations. WCGS operations, in turn, create 6the demand and pay for the people, goods, and services in the form of wages, salaries, and 7benefits for jobs and dollar expenditures for goods and services. The measure of the 8communities' ability to support the demands of WCGS depends on their ability to respond to 9changing environmental, social, economic, and demographic conditions.
10 11The socioeconomics region of influence (ROI) is defined by the areas where WCGS employees 12and their families reside, spend their income, and use their benefits, thereby affecting the 13economic conditions of the region. The ROI consists of a two-county area (Coffey and Lyon 14counties), which is where approximately 72 percent of WCGS employees reside. The following 15sections describe the housing, public services, off-site land use, visual aesthetics and noise, 16population demography, and the economy in the ROI surrounding the WCGS site.
17 18WCGS employs a permanent workforce of around 1,100 employees (WCNOC 2007h).
19Approximately 91 percent live in Anderson, Coffey, Franklin, Lyon and Osage Counties, Kansas 20(Table 2-13). The remaining 9 percent are divided among 13 counties in Kansas with numbers 21ranging from 1 to 27 employees per county. Given the residential locations of WCGS 22employees, the most significant impacts of plant operations are likely to occur in Coffey and 23Lyon counties where approximately 72 percent of the WCGS employees reside. The focus of 24the analysis in this draft SEIS is therefore on the impacts of WCGS in these two counties.
25 26 Table 2-13. WCGS Permanent Employee Residence by County in 2006 27 28County Number of WCGS Personnel Percentage of Total Anderson 66 6.5 Coffey 562 55.1 Franklin 70 6.9 Lyon 170 16.7 Osage 56 5.5 Other 96 9.4 Total 1,020 100 Source: WCNOC 2007h 29WCGS schedules refueling outages at 18-month intervals. During refueling outages, site 30employment increases by 700 to 960 workers for approximately 40 days of temporary duty.
31 Plant and the Environment September 2007 2-85 Draft NUREG-1437, Supplement 32 Most of these workers are assumed to be located in the same geographic areas as the 1permanent WCGS staff.
2 32.2.8.1 Housing 4
5Table 2-14lists the total number of occupied housing units, vacancy rates, and median value in 6the region of influence. According to the 2000 Census, there were over 18,600 housing units in 7the ROI, of which approximately 17,000 were occupied. The median value of owner-occupied 8units was $60,700 in Coffey County, which was lower than Lyon County. The vacancy rate was 9higher in Coffey County (10 percent) and lower in Lyon County (7.2 percent).
10 11In 2005, the total number of housing units in Coffey County grew by more than 163 units to 12 4,039 (USCB 2007a).
13 14 Table 2-14.
Housing in Coffey and Lyon Counties, Kansas in 2000 15 16Coffey Lyon ROI Total 3,876 14,757 18,633 Occupied housing units 3,489 13,691 17,180 Vacant units 387 1,066 1,453 Vacancy rate (percent) 10.0 7.2 7.8 Median value (dollars) 60,700 67,900 64,300 Source: USCB 2007a and USCB 2007b 172.2.8.2 Public Services 18 192.2.8.2.1 Water Supply 20 21Approximately 72 percent of the WCGS employees reside in Coffey County (55 percent) and 22Lyon County (17 percent), with almost 30 percent residing in the City of Burlington (WCNOC 232006a). All of the major public water suppliers in Coffey and Lyon Counties, including 24municipalities and rural water districts, obtain their drinking water supply from surface water 25sources (Table 2-15 provides public water supply information for the Coffey County community 26water systems, including average daily use and maximum daily capacity. A population of 27approximately 8,600 is served by these water suppliers (EPA 2007). The city of Burlington, 28which supplies treated water to most of the other public water supply systems in the county, 29obtains its water supply from the Neosho River. Burlington built a new water treatment plant in 302006 that has a design capacity of 3 mgd.(e) It is intended to meet projected future demands in 31the county, including the accommodation of small, outlying communities currently without public 32 (e)Interview with City of Burlington officials on March 13, 2007.
Plant and the Environment Draft NUREG-1437, Supplement 32 2-86 September 2007 water. The city is part of the Cottonwood and Neosho River Basins Assurance District Number 13 and holds water rights to 2.2 mgd (USACE 2002). Water right holders would receive 2additional water from Federal reservoirs during times of drought (KWO 2001).
3 4 Table 2-15.
Coffey County Public Water Supply Systems and Capacities 5 6Water System (1)Water Source Type (1)Average Daily Consumption (mgd) Maximum Daily Capacity (mgd) City of Burlington Surface water 0.6 to 0.7 a 1.8 a Coffey County Rural Water District 2 Purchased surface water NA NA Coffey County Rural Water District 2E Purchased surface water NA NA Coffey County Rural Water District 3 Purchased surface water NA NACity of Gridley Purchased surface water NA NACity of Lebo Purchased surface water NA NACity of LeRoy Purchased surface water NA NACity of New Strawn Purchased surface water NA NA City of Waverly Purchased surface water NA NA NA - Not applicable (1) Source: EPA 2007 a Interview with City of Burlington officials on March 13, 2007.
7Table 2-16 provides public water supply information for the Lyon County community water 8systems, including average daily use and maximum daily capacity. A population of 9approximately 34,000 is served by these water suppliers (EPA 2007). The city of Emporia, 10which supplies treated water to most of the other public water supply systems in the county, 11obtains its water supply from the Neosho River. The city is part of the Cottonwood and Neosho 12 Plant and the Environment September 2007 2-87 Draft NUREG-1437, Supplement 32 River Basins Assurance District Number 3 and holds water rights to 20 mgd, with 1 mgd from 1the Cottonwood River available for peak season.(f)2 3 Table 2-16. Lyon County Public Water Supply Systems and Capacities 4 5Water System (1)Water Source Type (1)Average Daily Consumption (mgd) Maximum Daily Capacity (mgd)
City of Admire Purchased surface waterNANA City of Allen Purchased surface waterNANA City of Emporia Surface water 10 to 12 b 15 bGreen Acres Mobile Home Park Purchased surface waterNANA Cit y of Hartford Purchased surface waterN A N ALyon County Rural Water District 1 Purchased surface waterNANALyon County Rural Water District 2 Purchased surface waterNANALyon County Rural Water District 3 Purchased surface water NA NA Lyon County Rural Water District 4 Purchased surface water NA NA Lyon County Rural Water District 5 Purchased surface waterNANA City of Olpe Purchased surface waterNANACity of Reading Purchased surface waterNANANA - Not applicable (1) Source: EPA 2007 b Interview with City of Emporia officials on March 14, 2007.
6 (f) Interview with City of Emporia officials on March 14, 2007.
Plant and the Environment Draft NUREG-1437, Supplement 32 2-88 September 2007 The Kansas Water Office coordinates the water planning process within the State and has 1developed the Kansas Water Plan (KWO 2004) for use in the management, conservation, and 2development of the water resources of the State. Coffey and Lyon Counties are for the most 3part located in the Neosho Basin, one of the 12 major river basins in the State. The estimated 4174,000 persons residing in the basin in 2000 is projected to grow to nearly 195,000 by 2040.
5Surface water is the primary water supply source in the basin (nearly 80 percent, based on year 62000 water use). Over 48 percent of the water used in the basin is for municipal use, 32 7percent is for industrial use, almost 12 percent for recreation, and 7 percent for irrigation.
8 9One of the major water management issues addressed by the Kansas Water Plan is public 10water supply. The Plan focuses on ensuring adequate supplies of water within the basin to 11 meet future needs for water quality and quantity. An evaluation of capacity development for 12public water supply systems in the Neosho Basin, to determine their technical, financial, and 13managerial capabilities to provide safe drinking water, identified twelve systems that had high 14ranked needs for improvement. Two of these systems are in Coffey County (Coffey County 15Rural Water Districts 2 and 2E) and one is in Lyon County (Green Acres Mobile Home Park).
16These three systems together serve a population of approximately 2,100. No drought 17vulnerable public water suppliers were identified in Coffey or Lyon Counties (KWO 2004).
18 19 2.2.8.2.2 Education 20 21Public school systems in Coffey and Lyons Counties are organized by districts, with three 22separate school districts in each county. WCGS is located in the Burlington School District, 23Unified School District (USD) Number 244, which serves 835 students and relies on a 2006 to 242007 operating budget of over $13.7 million in expenditures (KSDE 2006a). The three public 25school districts serving Coffey County, including Burlington USD 244 in the center as well as 26Lebo-Waverly USD 243 in the north and LeRoy-Gridley USD 245 in the south, have a total 2006 27to 2007 enrollment of 1,728; all three school districts have been experiencing declining 28enrollment (KSDE 2006a, 2006b, 2006c). The 2006 to 2007 expenditure per student ranges 29from $12,479 in Lebo-Waverly to $15,817 in Burlington (KSDE 2006a, 2006b, 2006c). The 30public school districts in Lyon County have a total 2006 to 2007 enrollment of 5,958 with the 31majority of students (4,850) attending schools in the Emporia USD 253 district, which has a 32stable student population while the other two districts are facing declining enrollment (KSDE 332006d, 2006e, 2006f).
34 35 2.2.8.2.3 Transportation 36 37Figures 2-1 and 2-2 show the WCGS site and highways within a 50-mi radius and a 6-mi radius 38of WCGS. At the larger regional scale, the major highways serving WCGS are:
39 Plant and the Environment September 2007 2-89 Draft NUREG-1437, Supplement 32 (1) Interstate 35, located 13 miles north of WCGS, and Interstate 70, which can be 1accessed 55 miles north at Topeka; 2 3(2) U.S. Highway 75, which is located approximately 3 miles west of WCGS and runs 4through the city of Burlington; and 5
6(3) U.S. Highway 169, 15 miles east of WCGS in Anderson County, and U.S. Highway 54, 7which crosses U.S. Highway 75 20 miles south of Burlington in Woodson County.
8 9Local road access to WCGS is via 16 th Road from the east and 17 th Road from the west, both of 10which intersect with the facility access road, Oxen Lane, north of WCGS. These are two-lane 11 paved roads. Approximately 6 miles northwest of WCGS, 17 th Road intersects with U.S.
12Highway 75, which is the major north-south highway in Coffey County. Employees traveling 13from the north, west, and south would use 17 th Road and/or U.S. Highway 75 to reach WCGS.
14Employees from the east would likely use 16 th Road. During shift changes, there is some 15congestion near the intersection of 17 th Road and U.S. Highway 75. However, the intersection 16remains clear at all other times (WCNOC 2006a).
17 18 TheGeneric Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), 19NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999)(g) uses the Transportation Research Board's 20level of service (LOS) classification system, which characterizes operational conditions on a 21roadway, to describe existing conditions for local transportation networks. "The Kansas 22Department of Transportation makes LOS determinations for roadways involved in specific 23projects. However, there are no current LOS determinations for the roadways" in Coffey 24 County.(h) Table 2-17 provides available daily traffic counts for roads in the vicinity of WCGS 25from the Kansas Department of Transportation.
26 27Coffey County is served by two railroads, Union Pacific at LeRoy and Burlington-Northern-Santa 28Fe at Lebo (Coffey County 1999). There is rail service to WCGS via a 13-mi spur to the Union 29Pacific system near Aliceville, southeast of the site.
30 (g) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.(h) Personal communication with Hugh Bogle, Kansas Department of Transportation, District 4. June 26, 2007.
Plant and the Environment Draft NUREG-1437, Supplement 32 2-90 September 2007 Table 2-17. Traffic Counts for Roads in the Vicinity of WCGS, 2004 1 2 Road Name/
Number Location Annual Average Daily Traffic Volume Year 17 th Road 1.5 miles west of U.S. 75 5092004 17 th Road 2.0 miles east of U.S. 75 1,155 2004Oxen Lane Near intersection with17 th Road 1,0822004 16 th Road At intersection with Trefoil Road 825 2004U.S. 75 Near intersection with 17 th Road 4,790*2006Sources: KDOT 2004 and 2007
- Traffic volume in 2004 at this location was 5,190.
32.2.8.3 Off-site Land Use 4 5WCGS is located in central Coffey County. Current land use surrounding the WCGS property is 6predominantly rangeland and farmland (WCNOC 2006a). The area within the vicinity of WCGS 7(i.e., within a 6-mi radius of the site) is located entirely within Coffey County and includes the 8cities of Burlington approximately 3 miles to the southwest and New Strawn approximately 2.5 9miles to the northwest, as well as the eastern portion of the John Redmond Reservoir (see 10Figure 2-2). Burlington is the principal city and county seat of Coffey County. Since most 11WCGS employees reside in Coffey and Lyon Counties, land use in these two counties is 12discussed in the following sections.
13 142.2.8.3.1 Coffey County 15 16Coffey County occupies an area of 630 sq mi and is not located in a metropolitan area (USCB 172007a). Land use in the county is primarily agriculture (83 percent), mainly cropland (48 18percent) and rangeland (31 percent). Non-agricultural land use, such as residential, 19commercial, and industrial, is concentrated in or near the cities and occupies 17 percent of the 20county land area. Publicly owned property in Coffey County includes the John Redmond 21Wildlife Area, managed by the KDWP, and the 18,500-ac Flint Hills National Wildlife Refuge 22located on the upstream portion of John Redmond Reservoir (WCNOC 2006a). Table 2-18 23provides the acreage and percent of total for each land use category in Coffey County.
24 Plant and the Environment September 2007 2-91 Draft NUREG-1437, Supplement 32 Table 2-18. Land Use in Coffey County, 2002 1 2 Land Use Acres Percent of TotalAgricultural 335,835 83.3 Cropland 193,375 48.0 Woodland 7,466 1.9 Rangeland /Pastureland 123,296 30.6 House lots, ponds, roads, wasteland, etc. 11,698 2.9 Non-agricultural 67,205 16.7 Total 403,040 100 Sources: USDA 2004 (agricultural land uses) and USCB 2007a (total land area) 3 4 5Land use in the unincorporated areas of Coffey County (i.e., outside of city limits) is regulated 6by the county, primarily through zoning and subdivision regulations. Nearly all of the land in 7Coffey County is zoned for agricultural use, primarily A-1 Agricultural, with the areas 8surrounding the six cities zoned A-2 Agricultural Transitional. The A-1 Agricultural district is 9established to encourage the compact development of the urban areas, to preserve productive 10farm and ranch land, and to permit limited nonagricultural uses and low-density dwellings that 11would not be incompatible to the rural area and require minimum public services. The A-2 12Agricultural Transition district is established to retain certain rural characteristics, but to also 13serve as a transition area to accommodate many of the nonagricultural uses normally located in 14a rural area while anticipating an increasing amount of urbanization including low-density 15dwellings (Coffey County Planning Board 2000). Control of land use in the cities rests with the 16individual municipalities, which have zoning authority for the lands within their boundaries. The 17cities of Burlington, Lebo, New Strawn, and Waverly have zoning ordinances.
i The cities of 18Burlington and Lebo also have a Comprehensive City Plan (Kansas State Library 2007a and 192007b). Coffey County does not have a comprehensive plan to guide land use. The Southeast 20Kansas Regional Planning Commission is the regional planning agency responsible for overall 21coordination of planning in the communities of southeast Kansas, including Coffey County.
22However, this agency is focused on promotion of economic growth and development and does 23not address land use in its planning activities (SEKRPC 2007).
24 i Interview with Coffey County officials on March 13, 2007.
Plant and the Environment Draft NUREG-1437, Supplement 32 2-92 September 2007 2.2.8.3.2 Lyon County 1 2Lyon County has a land area of 851 sq mi and is located in the Emporia, Kansas micropolitan 3area (USCB 2007b). The county, located northwest of Coffey County, includes the City of 4Emporia, which is the county seat and the closest population center to WCGS. The major land 5use in Lyon County is agriculture (91 percent), primarily cropland (48 percent) and rangeland 6(37 percent). The remaining 9 percent of the county is occupied by non-agricultural land uses.
7Residential uses are concentrated around the City of Emporia, as well as scattered throughout 8rural Lyon County along rural water system supply lines and arterial roads and highways (Lyon 9County Planning Board 2001). Table 2-19 identifies the acres in each land use category in Lyon 10County and the percent of the total land area that each category occupies.
11 12 Table 2-19. Land Use in Lyon County, 2002 13 14Land UseAcresPercent of Total Agricultural493,853 90.7 Cropland 261,814 48.1 Woodland 10,642 1.9 Rangeland/Pastureland 201,208 36.9 House lots, ponds, roads, wasteland, etc. 20,189 3.7 Non-agricultural 50,704 9.3 Total544,557 100 Sources: USDA 2004 (agricultural land uses) and USCB 2007b (total land area) 15The Lyon County Planning Board, in cooperation with the Board of County Commissioners, 16adopted the latest update of the Lyon County Comprehensive Plan in 2001 (Lyon County 17Planning Board 2001). The Comprehensive Plan includes broad goals that set the direction for 18the future of the county, including agricultural, development, and housing goals, as well as more 19detailed objectives to guide future development. As in Coffey County, Lyon County and the 20cities within the county guide land use through local zoning bylaws. The Lyon County 21Comprehensive Plan provides a framework in which residential, non-farm development is 22directed toward the Emporia-Lyon County Metropolitan Planning Area and along designated 23urban access corridors in order to protect and conserve good agricultural land. Commercial and 24industrial development is encouraged in areas where public services are available or easily 25 extended.26 Plant and the Environment September 2007 2-93 Draft NUREG-1437, Supplement 32 2.2.8.4 Visual Aesthetics and Noise 1 2The WCGS plant structures can be seen from the surrounding area, which has flat to gently 3rolling topography. The main vertical components of the WCGS building complex are the 4domed reactor containment building (approximately 234 ft tall) and the turbine building 5(approximately 150 ft tall). The upper portion of the reactor containment and turbine buildings 6can be seen from U.S. Highway 75 located 2.75 miles west of the facility. Motorists traveling on 7a number of local roads, some of which pass within 1.5 miles, can see various facility structures 8(WCNOC 2007i). Overhead transmission lines pass over local roads as well as numerous 9county, State, and U.S. highways on their way to connect to the regional electric power grid. As 10described in Section 2.1.7 of this draft SEIS, these lines are contained within approximately 106 11miles of 150-ft-wide ROWs that include a total area of over 1920 ac in Coffey, Greenwood, and 12 Butler Counties.
13 14Noise levels produced by WCGS operations have not been measured (WCNOC 2007j).
15However, the facility is bordered by undeveloped rangeland and Coffey County Lake, reducing 16the noise levels that may reach local residents. Also, most equipment is located inside facility 17buildings, which acts to reduce noise levels observed off-site. Higher noise levels are 18associated with testing of on-site alarms and off-site warning sirens. The nearest residence is 19located 1.7 miles west of the reactor containment building, across Coffey County Lake, on 20Native Road SE. According to Coffey County officials, there have been no noise issues 21concerning the plant, even from close neighbors.(j) The only issue is the sirens, which are 22 tested weekly.
23 242.2.8.5 Demography 25 26According to the 2000 Census, approximately 13,095 people lived within a 32-kilometer (20-mi) 27radius of WCGS, which equates to a population density of 10 persons per sq mi (WCNOC 282006a). This density translates to the least sparse Category 1 (less than 40 persons per sq mi 29and no community with 25,000 or more persons within 20 miles) using the GEIS measure of 30sparseness. Approximately 176,301 people live within an 80-kilometer (50-mi) radius of WCGS 31(WCNOC 2006a). This equates to a population density of 23 persons per sq mi. Applying the 32GEIS proximity measures, WCGS is classified as proximity Category 1 (no city with 100,000 or 33more persons and less than 50 persons per sq mi within 50 miles). Therefore, according to the 34sparseness and proximity matrix presented in the GEIS, the WCGS ranks of sparseness 35Category 1 and proximity Category 1 result in the conclusion that WCGS is located in a low 36population area.
37 (j) Interview with Coffey County officials on March 13, 2007.
Plant and the Environment Draft NUREG-1437, Supplement 32 2-94 September 2007 Table 2-20 shows population projections and growth rates from 1970 to 2050 in Coffey and 1Lyon counties. The growth rate in Coffey County showed a 6 percent increase for the period of 21990 to 2000. Beyond 2000, the population is expected to remain relatively unchanged and 3slightly decrease at a very low rate beyond the year 2010. In Lyon County, the population grew 4between 1990 and 2000 and is also expected to decrease slightly through 2050.
5 6 Table 2-20.
Population and Percent Growth in Coffey and Lyon Counties, 7Kansas from 1970 to 2000 and projected for 2010 to 2050 8 9Coffey County Lyon County Year PopulationPercent Growth (a)PopulationPercent Growth (a)1970 7,397-32,071-1980 9,370 26.7 35,108 9.5 1990 8,404-10.3 34,732-1.1 2000 8,865 5.5 35,935 3.5 2010 8,939 0.8 35,263-1.9 2020 8,795-1.6 34,742-1.5 2030 8,690-1.2 35,096 1.0 2040 8,629-0.7 35,076-0.1 2050 8,567-0.7 35,056-0.1- = No data available. (a) Percent growth rate is calculated over the previous decade. Sources: 1970 - 2000, USCB 2007a and USCB 2007b; projected population data for 2010 and 2020, Kansas Division of the Budget, http://da.state.ks.us/budget/ecodemo.htm (accessed July 12, 2006); projected population data for 2030 to 2050 (calculated).
10 11The 2000 demographic profile of the region of influence population is included in Table 2-21.
12Persons self-designated as minority individuals comprise 18.9 percent of the combined total 13population of these two counties. This minority population is composed largely of Hispanic or 14Latino residents who reside in Lyon County.
15 Plant and the Environment September 2007 2-95 Draft NUREG-1437, Supplement 32 Table 2-21.Demographic Profile of the Population in the WCGS Region of Influence 1 2Coffey County Lyon County Region of Influence Race (2000) (percent of total non-Hispanic population)White 96.3 77.3 81.1 Black or African American 0.2 2.2 1.8 American Indian and Alaska Native 0.5 0.4 0.4 Asian 0.3 2.0 1.7 Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0 Some other race 0.0 0.1 0.1 Two or more races 1.1 1.3 1.3 EthnicityHispanic or Latino 137 6,010 6,147 Percent of total population 1.5 16.7 13.7 Minority Population (including Hispanic or Latino ethnicity)Total minority population 330 8,149 8,479 Percent minority 3.7 22.7 18.9 Source: USCB 2007a and 2007b 3 2.2.8.5.1 Transient Population 4 5Within 80 kilometers (50 miles) of WCGS, colleges and recreational opportunities attract daily 6and seasonal visitors who create demand for temporary housing and services. In 2000 in 7Coffey County, 1.9 percent of all housing units are considered temporary housing for seasonal, 8recreational, or occasional use. By comparison, temporary housing accounts for only 0.5 9percent and 0.9 percent of total housing units in Lyon County and Kansas, respectively (USCB 10 2007b).11 12 2.2.8.5.2 Migrant Farm Worker 13 14Migrant farm workers are individuals whose employment requires travel to harvest agricultural 15crops. These workers may or may not have a permanent residence. Some migrant workers 16may follow the harvesting of crops, particularly fruit, throughout the midwestern U.S. rural areas.
17Others may be permanent residents near WCGS who travel from farm to farm harvesting crops.
18 19Migrant workers may be members of minority or low-income populations. Because they travel 20and can spend a significant amount of time in an area without being actual residents, migrant 21workers may be unavailable for counting by census takers. If uncounted, these workers would 22be "underrepresented" in U.S. Census Bureau (USCB) minority and low-income population 23 counts.24 25Coffey and Lyon counties host relatively small numbers of migrant workers. According to 2002 26Census of Agriculture estimates, 147 temporary farm laborers (those working fewer than 150 27 Plant and the Environment Draft NUREG-1437, Supplement 32 2-96 September 2007 days per year) were employed on 75 farms in Coffey County, and 428 were employed on 188 1farms in Lyon County (USDA 2002).
2 3 2.2.8.6 Economy 4
5This section contains a discussion of the economy, including employment and income, 6 unemployment, and taxes.
7 8 2.2.8.6.1 Employment and Income 9 10Between 2000 and 2005, the civilian labor force in the Coffey County area increased 13.5 11percent to the 2005 level of 5,261. The civilian labor force in the Lyon County area grew 6.6 12percent to the 2005 level of 20,519 (USCB 2007b).
13 14In 2005, employment in the services industry represented the largest sector of employment in 15both counties combined followed closely by manufacturing and retail trade industries (Kansas 16Department of Labor 2006). The largest employer in Coffey County in 2006 was Wolf Creek 17Nuclear Operating Corporation with 900 employees (see Table 2-22). The majority of 18employment in Coffey County is located in the city of Burlington.
19 20 Table 2-22. Major Employers in Coffey County in 2006 21 22Firm Number of Employees Wolf Creek Nuclear Operating Corporation 900 Coffey Health System 250 Unified School District #244 166 Coffey County 160 Countertop Trends 70 Mid-American Machine 50 Hoover's Thriftway 40 Arnold's Greenhouse 35 Charloma, Inc. 35 Source: Southeast Kansas Inc., http://www.sekinc.org/counties/coffey_employers.htm, accessed May 7, 2007.
23Income information for Coffey and Lyon counties is presented in Table 2-23. There are slight 24differences in the income levels between the two counties. The median household and per 25capita income in Coffey and Lyon counties were both well below the Kansas average. In 1999, 26only 6.6 percent of the population in Coffey County was living below the official poverty level, 27while in Lyon County, 14.5 percent of the population was living below the poverty level (USCB 28 2007b).29 Plant and the Environment September 2007 2-97 Draft NUREG-1437, Supplement 32 Table 2-23.Income Information for the WCGS Region of Influence 1 2Coffey County Lyon County Kansas Median household income 1999 (dollars) 37,839 32,819 40,624 Per capita income 1999 (dollars) 18,337 15,724 20,506 Percent of persons below the poverty line (2000) 6.6 14.5 9.9 Sources: USCB 2007a and USCB 2007b 3 2.2.8.6.2 Unemployment 4 5In 2005, the annual unemployment average in the Coffey and Lyon counties were 5.6 and 4.5 6percent, respectively, which were slightly higher and lower than the annual unemployment 7average of 5.5 percent for Kansas (USCB 2007a and USCB 2007b).
8 9 2.2.8.6.3 Taxes 10 11WCNOC pays annual real estate taxes to Coffey County. From 2000 through 2006, WCNOC 12paid between $23.9 and $26.3 million annually in property taxes to Coffey County (see Table 2-1324). This represented between 79 and 85 percent of the county's total annual tax revenue.
14Each year, Coffey County retains a portion of this tax money for county operations and 15disburses the remainder to school districts, fire districts, and the county's municipalities to fund 16their respective operating budgets. The local public school system, USD #244, receives 38 to 1746 percent of the property tax payment (WCNOC 2006a).
18 19At present, the State of Kansas has taken no action on deregulation, which could, if enacted, 20affect tax payments to Coffey County. However, any changes to WCGS property tax rates due 21to deregulation would be independent of license renewal.
22 23The continued availability of WCGS and the associated tax base is an important feature in the 24ability of the Coffey County and county municipalities to continue to invest in infrastructure and 25to draw industry and new residents.
26 Plant and the Environment Draft NUREG-1437, Supplement 32 2-98 September 2007 Table 2-24. Coffey County Tax Revenues, WCGS Property Tax, and WCGS Property Tax as a 1Percentage of Tax Revenues, 2000 to 2006 2 3Entity Year Tax Revenues (in millions of dollars)Property Tax Paid by WCGS (in millions of dollars)WCGS Property Tax as Percentage of Tax Revenues Coffey County 2000 28.7 24.3 85 2001 29.6 23.9 81 2002 29.4 24.5 83 2003 30.6 24.6 81 2004 31.3 25.0 80 2005 31.6 25.1 79 2006 33.1 26.3 80 Sources: 2000 to 2004 data from WCNOC 2006a; 2005 and 2006 data from Raaf 2007 42.2.9 Historic and Archaeological Resources 5 6This section presents a brief summary of the region's cultural background and a description of 7known historic and archaeological resources at the WCGS site and its immediate vicinity. The 8information presented was collected from area repositories, the Kansas State Historical Society 9(KSHS), and the applicant's Environmental Report (WCNOC 2006a).
10 11 2.2.9.1 Cultural Background 12 13The first Native Americans to settle in the Central Plains arrived approximately 11,000 years 14before present. Archaeological evidence suggests that these early groups hunted large 15mammals using projectiles tipped with distinctively flaked stone points. Over the following 16several thousand years prehistoric peoples in this region adapted to environmental changes, 17subsisting on wild plant foods and smaller game. During the most recent portion of prehistory, 18beginning a few thousand years before the present, indigenous populations began to settle in 19semi-permanent villages based in part on agriculture and fishing and to use pottery for both food 20preparation and storage.
21 22During proto-historic times Osage Indians from Missouri had begun exploiting the resources of 23the lower stretches of the Neosho River in Kansas. Groups of Sac and Fox, Pottawatomie, and 24Kickapoo later moved into eastern Kansas. Historic accounts indicate that Sac and Fox bands 25ranged through Coffey County, just north of the WCGS area (KG&E and KCP&L 1974).
26 27The Spanish were the first Europeans to explore Kansas when, in the middle part of the 16 th 28century, explorer Francisco Vasquez de Coronado arrived seeking gold. In the late 18th 29century, France claimed most of Kansas and 12 other future states as part of the Louisiana 30Territory. Kansas was acquired from France in 1803, as part of the Louisiana Purchase.
31 Plant and the Environment September 2007 2-99 Draft NUREG-1437, Supplement 32 Historical records indicate that Meriwether Lewis and William Clark's Corps of Discovery made 1camp on the Kansas side of the Missouri River during their expedition to explore the new 2purchase in 1804 (WCNOC 2006a).
3 4The middle part of the 19 th century marked a surge in European settlement, following the 5passage of the Kansas-Nebraska Act in 1854 and the Homestead Law in 1862 (WCNOC 62006a). In the last quarter of the 19 th century "Turkey Red" wheat was introduced by Mennonite 7immigrants from Russia. The introduction of this new crop provided the basis for Kansas as a 8wheat-producing state (WCNOC 2006a).
9 10 2.2.9.2 Historic and Archaeological Resources at the WCGS Site 11 122.2.9.2.1 Previously Identified Resources 13 14The KSHS houses the State's archaeological site files and information on historic resources 15such as buildings and houses, including available information concerning the National or State 16Register eligibility status of these resources. The NRC cultural resource team visited the KSHS 17and reviewed site files on archaeological sites located within or nearby the WCGS property.
18 19Two surveys, conducted in 1973 and 1974, of Wolf Creek and the WCGS plant area resulted in 20the identification of 25 prehistoric sites within or adjacent to present day Coffey County Lake 21(KG&E and KCP&L 1974). The most significant of these sites, listed as the Anderson Site 22(14CF508), is described as being located "on a low terrace on the east bank of Wolf Creek."
23This site has since been inundated by the construction of Coffey County Lake. It is located 24approximately 150 meters west of the north end of the northern baffle dike. Initial recordation of 25the site noted a surface scatter of "stone chips, potsherds, chunks of heat altered limestone, 26and daub." Later excavations revealed more artifacts and five postmold features. Analysis of 27temporally diagnostic artifacts recovered from the 14CF508 indicates that the site was occupied 28during the Plains Woodland period of prehistory (about 500 to 1000 years BP).
29 30Of the 25 prehistoric sites recorded during the 1973 to 1974 surveys, 23 were inundated by the 31construction of Coffey County Lake. The two sites not inundated by the lake (14CF503 and 3214CF504) are located to the south of the earthen dam at the southern end of the lake, and were 33likely impacted during initial dam construction activity.
34 35A review of the KSHS files to identify above-ground cultural resources in Coffey County 36revealed a total of five resources listed on the National Register of Historic Places (NPS 2007).
37Within the town of Burlington there are three historic structures listed on the National Register.
38None of these sites are located within the boundaries of the WCGS site.
39 Plant and the Environment Draft NUREG-1437, Supplement 32 2-100 September 2007 2.2.9.2.2 Results of Walkover Survey 1 2The NRC staff performed an informal walkover survey of the WCGS property during the site 3audit (March 12-16, 2007), including the main generating station area, the environmental 4education area, and a portion of the transmission line ROW. During this walkover it was 5observed that the main generating station area has been extensively disturbed and graded, 6while much of the environmental education area and transmission line ROW appear to have 7been only minimally disturbed. All of the buildings and structures that comprise the station have 8been constructed since the mid 1970s.
9 102.2.9.2.3 Potential Archaeological Resources 11 12Due to disturbances associated with site preparation and construction, the main generating 13station area has little or no potential for archaeological resources. There is potential for 14archaeological resources to be present in the environmental education area, along the 15transmission line ROW, and along the shores of Coffey County Lake. These areas appear to 16have been only minimally disturbed and are comprised of landforms that may have been 17attractive during prehistory for varied resource exploitation.
18 192.2.10 Related Federal Project Activities and Consultations 20 21The NRC staff reviewed the possibility that activities of other Federal agencies might impact the 22renewal of the Operating License (OL) for WCGS. Any such activities could result in cumulative 23environmental impacts and the possible need for the Federal agency to become a cooperating 24agency for preparation of this draft SEIS.
25 26The NRC staff has reviewed local Federally owned facilities and Federally permitted industrial 27facilities in the local area near Burlington, Kansas, and has determined that there are no Federal 28project activities that would make it desirable for another Federal agency to become a 29cooperating agency for preparing this draft SEIS. The only known Federal project in the area is 30the operation of John Redmond Reservoir by the USACE.
31 32The USACE is currently involved in consideration of an action that could affect future operations 33at WCGS. In June 2002, USACE published a draft Supplement to the Final Environmental 34Impact Statement (EIS) for the reallocation of water supply storage within the reservoir 35(USACE 2002). The purpose of this action would be to raise the level of the conservation pool 36within the reservoir in order to ensure a continuing ability to meet contractual requirements to 37supply water to the State of Kansas under a water supply agreement reached in 1975 (USACE 382002). This agreement was reached to allow the State of Kansas to provide this water, under 39contract, to the Cottonwood and Neosho River Basins Water Assurance District Number 3, and 40 to WCGS. 41 Plant and the Environment September 2007 2-101 Draft NUREG-1437, Supplement 32 According to the USACE EIS, the water supply agreement was developed in 1975 to ensure a 1water supply of 34,900 ac-ft annually for the two users for the duration of the 50-year design life 2of the reservoir, which extended to 2014. However, by the late 1990s, USACE had determined 3that the rate of siltation in the conservation pool was higher than anticipated, and would result in 4limiting the ability of USACE to meet the contractual obligation to supply this amount of water.
5Based on this analysis, USACE evaluated alternatives to meet the contractual obligation, and 6their preferred alternative was to raise the level of the conservation pool from 1,039 to 1,041 ft 7above MSL (USACE 2002). Currently, this EIS remains in draft, and it is unknown whether 8USACE intends to implement the preferred alternative.
9 10 NRC is required under Section 102(c) of the National Environmental Policy Act of 1969, as 11amended to consult with and obtain the comments of any Federal agency that has jurisdiction 12by law or special expertise with respect to any environmental impact involved. NRC consulted 13with the EPA and the FWS. Consultation correspondence is included in Appendix E. The EPA 14submitted written comments during the scoping process; their comments are addressed in this 15 draft SEIS.
16 17 2.3 References 18 1910 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 20Protection Against Radiation."
21 2210 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 23Production and Utilization Facilities."
24 2540 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 26"Environmental Radiation Protection Standards for Nuclear Power Operations."
27 2840 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261, 29"Identification and Listing of Hazardous Waste."
30 3140 CFR Part 273. Code of Federal Regulations, Title 40, Protection of Environment, Part 273, 32"Standards for Universal Waste Management."
33 34 Canadian Wildlife Service and U.S. Fish & Wildlife Service (CWS and FWS). 2007.
35International Recovery Plan: Whooping Crane (Grus americana), Third Revision. Accessed at:
36http://www.fws.gov/endangered on June 2007.
37 38City of Burlington. 2007. Annual Water Quality Report - 2007. Burlington, Kansas.
39 Plant and the Environment Draft NUREG-1437, Supplement 32 2-102 September 2007 Coffey County Planning Board. 2000. "Zoning Regulations of Coffey County, Kansas". Official 1Copy as Incorporated by Resolution Number 386-A. Edition of June 21, 2000. Effective Date 2 July 7, 2000.
3 4Coffey County. 1999. "Coffey County Economic Development, Transportation/Location."
5Accessed at: http://www.coffeycountyks.org/ecodevo/trans.html on June 1, 2007.
6 7 Colvin, M. A. 1993.Ecology and Management of White Bass: a Literature Review. Missouri 8Department of Conservation, Dingell-Johnson project F-I-R-42, Study 1-31, Job 1, Final Report.
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36Wolf Creek Nuclear Operating Corporation (WCNOC). 1997. Fishery Monitoring Report for 37 Wolf Creek Lake. Burlington, Kansas.
38 39Wolf Creek Nuclear Operating Corporation (WCNOC). 2003c. 2002 Annual Radiological 40Environmental Operating Report. Burlington, Kansas.
41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-114 September 2007 1Wolf Creek Nuclear Operating Corporation (WCNOC). 2004a.
Wolf Creek Generating Station 2Annual Radioactive Effluent Release Report - 27. Burlington, Kansas.
3 4Wolf Creek Nuclear Operating Corporation (WCNOC). 2004b.
Wolf Creek Generating Station 5Firing Range Management Plan for Soil Lead Contamination.
February 2004. Document 6 Control Number WCEM-08-004.
7 8Wolf Creek Nuclear Operating Corporation (WCNOC). 2004c. "Wolf Creek Generation Station 9(WCGS) May 2004 National Pollutant Discharge Elimination System (NPDES) Discharge 10Monitoring Report, Permit I-NE07-PO02." Letter from K. J. Moles, Wolf Creek Nuclear 11Operating Corporation, Burlington, Kansas, to J. Martin, Kansas Department of Health and 12Environment, Topeka, Kansas. June 17, 2004.
13 14Wolf Creek Nuclear Operating Corporation (WCNOC). 2004d.
2003 Annual Radiological 15Environmental Operating Report. Burlington, Kansas.
16 17Wolf Creek Nuclear Operating Corporation (WCNOC). 2005a.
Wolf Creek Generating Station 18Annual Radioactive Effluent Release Report - 28. Burlington, Kansas.
19 20Wolf Creek Nuclear Operating Corporation (WCNOC). 2005b. "Wolf Creek Generation Station 21(WCGS) June 2005 National Pollutant Discharge Elimination System (NPDES) Discharge 22Monitoring Report, Permit I-NE07-PO02." Letter from K. J. Moles, Wolf Creek Nuclear 23Operating Corporation, Burlington, Kansas, to J. Martin, Kansas Department of Health and 24Environment, Topeka, Kansas. July 25, 2005.
25 26Wolf Creek Nuclear Operating Corporation (WCNOC). 2005c. "Wolf Creek Generation Station 27(WCGS) July 2005 National Pollutant Discharge Elimination System (NPDES) Discharge 28Monitoring Report, Permit I-NE07-PO02." Letter from K. J. Moles, Wolf Creek Nuclear 29Operating Corporation, Burlington, Kansas, to J. Martin, Kansas Department of Health and 30Environment, Topeka, Kansas. August 22, 2005.
31 32Wolf Creek Nuclear Operating Corporation (WCNOC). 2005d. Wolf Creek Generating Station, 33Annual Environmental Operating Report 2004. Burlington, Kansas.
34 Plant and the Environment September 2007 2-115 Draft NUREG-1437, Supplement 32 Wolf Creek Nuclear Operating Corporation (WCNOC). 2005e.
2004 Annual Radiological 1Environmental Operating Report. Burlington, Kansas.
2 3Wolf Creek Nuclear Operating Corporation (WCNOC). 2006a. Applicant's Environmental 4Report; Operating License Renewal Stage. Appendix E of License Renewal Application, Wolf 5Creek Generating Station Unit 1, Docket Number 50-482, Facility Operating License Number 6 NPF-42, (Revision 0).
7 8Wolf Creek Nuclear Operating Corporation (WCNOC). 2006b. Enclosure 3 to WM 06-0046 An 9Assessment of the Potential Impacts on Fish and Shellfish Resources from Impingement 10Related to the Operating License Renewal for Wolf Creek Generating Station, Unit No. 1.
11Contained in: Letter from Matthew W. Sunseri, Wolf Creek Nuclear Operating Corporation to 12U.S. Nuclear Regulatory Commission regarding Docket Number 50-482: Supplementary 13Environmental Information to Support the Application for Renewed Operating License for Wolf 14 Creek Generating Station. M 06-0046. November 17, 2006.
15 16Wolf Creek Nuclear Operating Corporation (WCNOC). 2006c. Wolf Creek Generating Station 17Annual Radioactive Effluent Release Report - 29. Burlington, Kansas.
18 19Wolf Creek Nuclear Operating Corporation (WCNOC). 2006d. Land Management at Wolf 20Creek Generating Station, 2005 Progress Report and 2006 Land Management Plan. March 21 2006.22 23Wolf Creek Nuclear Operating Corporation (WCNOC). 2006e.
Wolf Creek Generating Station, 24 2006 Land Use Census Report.
September 2006.
25 26Wolf Creek Nuclear Operating Corporation (WCNOC). 2006f
.Supplementary Environmental 27Information to Support the Application for Renewed Operating License for Wolf Creek 28 Generating Station
.Docket Number 50-482. Burlington, Kansas.
29 30Wolf Creek Nuclear Operating Corporation (WCNOC). 2006g.
2005 Annual Radiological 31Environmental Operating Report. Burlington, Kansas.
32 33Wolf Creek Nuclear Operating Corporation (WCNOC). 2006h. "Wolf Creek Generation Station 34(WCGS) June 2006 National Pollutant Discharge Elimination System (NPDES) Discharge 35Monitoring Report, Permit I-NE07-PO02." Letter from K. J. Moles, Wolf Creek Nuclear 36Operating Corporation, Burlington, Kansas, to M. Matheis, Kansas Department of Health and 37Environment, Topeka, Kansas. July 24, 2006.
38 39Wolf Creek Nuclear Operating Corporation (WCNOC). 2006i. Avian Protection Plan at Wolf 40Creek Generating Station. August. p. 30.
41 Plant and the Environment Draft NUREG-1437, Supplement 32 2-116 September 2007 Wolf Creek Nuclear Operating Corporation (WCNOC). 2007. "Docket 50-482: Response to 1NRC Request for Additional Information Related to Wolf Creek Generating Station License 2Renewal Application." Item Number 31. Cooling Water Intake Structures, Comprehensive 3 Demonstration Study, May 9, 2007.
4 5Wolf Creek Nuclear Operating Corporation (WCNOC). 2007a.
Wolf Creek Generating Station 6Annual Radioactive Effluent Release Report - 30. Burlington, Kansas.
7 8Wolf Creek Nuclear Operating Corporation (WCNOC). 2007b. "Docket Number 50-482:
9Response to NRC Request for Additional Information Related to Wolf Creek Generating Station 10License Renewal Application." Item Number 38. Letter from Terry J. Garrett, CNOC, to NRC 11Document Control Desk, Washington, DC, May 9, 2007.
12 13Wolf Creek Nuclear Operating Corporation (WCNOC). 2007c. Docket Number 50-482: Wolf 14Creek Nuclear Operating Corporation's Response to Request for Additional Information 15Regarding the Review of the License Renewal Application for Wolf Creek Generating Station.
16 ET 07-0001. January 11, 2007.
17 18Wolf Creek Nuclear Operating Corporation (WCNOC). 2007d. "Docket Number 50-482:
19Response to NRC Request for Additional Information Related to Wolf Creek Generating Station 20License Renewal Application." Item Number A75. Letter from Terry J. Garrett, CNOC, to NRC 21Document Control Desk, Washington, DC, May 9, 2007.
22 23Wolf Creek Nuclear Operating Corporation (WCNOC). 2007e. "Docket Number 50-482:
24Response to NRC Request for Additional Information Related to Wolf Creek Generating Station 25License Renewal Application." Item Number M19. Letter from Terry J. Garrett, CNOC, to NRC 26Document Control Desk, Washington, DC, May 9, 2007.
27 28Wolf Creek Nuclear Operating Corporation (WCNOC). 2007f. 2006 Annual Radiological 29Environmental Operating Report. Burlington, Kansas.
30 31Wolf Creek Nuclear Operating Corporation (WCNOC). 2007g. "Docket Number 50-482:
32Response to NRC Request for Additional Information Related to Wolf Creek Generating Station 33License Renewal Application." Item Number A17. Letter from Terry J. Garrett, CNOC, to NRC 34Document Control Desk, Washington, DC, May 9, 2007.
35 36Wolf Creek Nuclear Operating Corporation (WCNOC). 2007h. Number of Employees by 37County Residence. Wolf Creek Generating Station. Burlington, Kansas. March.
38 Plant and the Environment September 2007 2-117 Draft NUREG-1437, Supplement 32 Wolf Creek Nuclear Operating Corporation (WCNOC). 2007i. Docket Number 50-482: Wolf 1Creek Nuclear Operating Corporation's Response to Request for Additional Information 2Regarding the Review of the License Renewal Application for Wolf Creek Generating Station
.3 ET 07-0001. January 11, 2007.
4 5Wolf Creek Nuclear Operating Corporation (WCNOC). 2007j. "Docket Number 50-482:
6Response to NRC Request for Additional Information Related to Wolf Creek Generating Station 7License Renewal Application." Item Number 41. Information on plant noise, May 9, 2007 8
9World Book Encyclopedia, Kansas Climate, Chicago, IL, 2006.
10
September 2007 3-1 Draft NUREG-1437, Supplement 32 3.0 Environmental Impacts of Refurbishment 1 2 3 4Environmental issues associated with refurbishment activities are discussed in the Generic 5Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 6Volumes 1 and 2 (NRC 1996; 1999).(a) The GEIS includes a determination of whether the 7analysis of the environmental issues could be applied to all plants and whether additional 8mitigation measures would be warranted. Issues are then assigned a Category 1 or a 9Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 10the following criteria:
11 12 (1) The environmental impacts associated with the issue have been determined to apply 13either to all plants or, for some issues, to plants having a specific type of cooling system 14or other specified plant or site characteristics.
15 16 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 17the impacts (except for collective off-site radiological impacts from the fuel cycle and 18from high-level waste and spent fuel disposal).
19 20 (3) Mitigation of adverse impacts associated with the issue has been considered in the 21analysis, and it has been determined that additional plant-specific mitigation measures 22are likely not to be sufficiently beneficial to warrant implementation.
23 24For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 25required in this draft Supplemental Environmental Impact Statement unless new and significant 26information is identified.
27 28Category 2 issues are those that do not meet one or more of the criteria for Category 1; 29therefore, additional plant-specific review of these issues is required.
30 31License renewal actions may require refurbishment activities for the extended plant life. These 32actions may have an impact on the environment that requires evaluation, depending on the type 33of action and the plant-specific design. Environmental issues associated with refurbishment that 34were determined to be Category 1 issues are listed in Table 3-1.
35 36Environmental issues related to refurbishment considered in the GEIS for which these conclu-37sions could not be reached for all plants, or for specific classes of plants, are Category 2 issues.
38 These are listed in Table 3-2.
39 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.
Environmental Impacts of Refurbishment Draft NUREG-1437, Supplement 32 3-2 September 2007 Table 3-1. Category 1 Issues for Refurbishment Evaluation 1 2ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1GEIS Sections SURFACE WATER QUALITY ,HYDROLOGY , AND U SE (FOR ALL PLANTS
)Impacts of refurbishment on surface water quality3.4.1Impacts of refurbishment on surface water use3.4.1 AQUATIC ECOLOGY (FOR ALL PLANTS
)Refurbishment3.5 G ROUND-WATER USE AND QUALITYImpacts of refurbishment on ground-water use and quality3.4.2 LAND U SEOnsite land use3.2 HUMAN HEALTHRadiation exposures to the public during refurbishment3.8.1Occupational radiation exposures during refurbishment3.8.2 SOCIOECONOMICSPublic services: public safety, social services, and tourism and recreation3.7.4; 3.7.4.3; 3.7.4.4; 3.7.4.6Aesthetic impacts (refurbishment)3.7.8 3Category 1 and Category 2 issues related to refurbishment that are not applicable to Wolf Creek 4Generating Station (WCGS) because they are related to plant design features or site 5characteristics not found at WCGS are listed in Appendix F.
6 7The potential environmental effects of refurbishment actions would be identified, and the 8analysis would be summarized within this section, if such actions were planned. Wolf Creek 9Nuclear Operating Corporation (WCNOC) indicated that it has performed an evaluation of 10structures and components pursuant to Title 10 of the Code of Federal Regulations (CFR), Part 1154, Section 54.21 to identify activities that are necessary to continue operation of WCGS during 12the requested 20-year period of extended operation. These activities include replacement of 13certain components as well as new inspection activities, and are described in the Environmental 14Report (WCNOC 2006).
15 Environmental Impacts of Refurbishment September 2007 3-3 Draft NUREG-1437, Supplement 32 Table 3-2. Category 2 Issues for Refurbishment Evaluation 1 2ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections10 CFR 51.53 (c)(3)(ii) Subparagraph TERRESTRIAL R ESOURCESRefurbishment impacts3.6E THREATENED OR ENDANGERED S PECIES (FOR ALL PLANTS
)Threatened or endangered species3.9E A IR QUALITYAir quality during refurbishment (nonattainment and maintenance areas)3.3F SOCIOECONOMICSHousing impacts3.7.2IPublic services: public utilities3.7.4.5IPublic services, education (refurbishment)3.7.4.1IOffsite land use (refurbishment)3.7.5IPublic services, transportation3.7.4.2JHistoric and archaeological resources3.7.7K ENVIRONMENTAL J USTICEEnvironmental justice Notaddressed (a)Notaddressed (a)(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to 10 CFR Part 51 were prepared. If an applicant plans to undertake refurbishment activities for license renewal, environmental justice must be addressed in the applicant's environmental report and the Staff's environmental impact statement. The Commission issued a Final Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions in 2004 (NRC 2004).
3However, WCNOC stated that the replacement of these components and the additional 4inspection activities are within the bounds of normal plant component replacement and 5inspections; therefore, they are not expected to affect the environment outside the bounds of 6plant operations as evaluated in the final environmental statement (NRC 1982). In addition, 7WCNOC's evaluation of structures and components as required by 10 CFR 54.21 did not 8identify any major plant refurbishment activities or modifications necessary to support the 9continued operation of WCGS beyond the end of the existing operating licenses. Therefore, 10refurbishment is not considered in this draft Supplemental Environmental Impact Statement.
11 Environmental Impacts of Refurbishment Draft NUREG-1437, Supplement 32 3-4 September 2007 3.1 References 1 210 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 3Protection Regulations for Domestic Licensing and Related Regulatory Functions."
4 510 CFR Part 54. Code of Federal Regulations, Title 10, Energy,Part 54, "Requirements for 6Renewal of Operating Licenses for Nuclear Power Plants."
7 8 Nuclear Regulatory Commission (NRC). 1982.Final Environmental Statement Related to 9Operation of Wolf Creek Generating Station, Unit 1. NUREG-0878, Washington, DC.
10 11 Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for 12License Renewal of Nuclear Power Plants. NUREG-1437 Volumes 1 and 2, Washington, DC.
13 14 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 15License Renewal of Nuclear Plants Main Report
,"Section 6.3 - Transportation, Table 9.1, 16Summary of findings on NEPA issues for license renewal of nuclear power plants." NUREG-17 1437 Volume 1, Addendum 1, Washington, DC.
18 19 Nuclear Regulatory Commission (NRC). 2004. "Policy Statement on the Treatment of 20Environmental Justice Matters in NRC Regulatory and Licensing Actions."
Federal Register 21Volume 69, pp. 52040-52048. Washington, DC August 24, 2004.
22 23Wolf Creek Nuclear Operating Corporation (WCNOC). 2006. Applicant's Environmental Report 24- Operating License Renewal Stage, Wolf Creek Generating Station. Docket Number. 50-482.
25 Burlington, Kansas.
26 September 2007 4-1 Draft NUREG-1437, Supplement 32 4.0 Environmental Impacts of Operation 1 2 3Environmental issues associated with operation of a nuclear power plant during the renewal 4term are discussed in the Generic Environmental Impact Statement for License Renewal of 5 Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(a) The GEIS 6includes a determination of whether the analysis of the environmental issues could be applied to 7all plants and whether additional mitigation measures would be warranted. Issues are then 8assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues 9are those that meet all of the following criteria:
10 11(1) The environmental impacts associated with the issue have been determined to apply 12either to all plants or, for some issues, to plants having a specific type of cooling system 13or other specified plant or site characteristics.
14 15(2) A single significance level (i.e., SMALL,MODERATE, or LARGE) has been assigned to 16the impacts (except for collective off-site radiological impacts from the fuel cycle and 17from high-level waste and spent fuel disposal).
18 19(3) Mitigation of adverse impacts associated with the issue has been considered in the 20analysis, and it has been determined that additional plant-specific mitigation measures 21are likely not to be sufficiently beneficial to warrant implementation.
22 23For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 24required unless new and significant information is identified.
25 26Category 2 issues are those that do not meet one or more of the criteria for Category 1 and, 27therefore, additional plant-specific review of these issues is required.
28 29This chapter addresses the issues related to operation during the renewal term that are listed in 30Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B 31and are applicable to Wolf Creek Generating Station (WCGS). Section 4.1 addresses issues 32applicable to the WCGS cooling system. Section 4.2 addresses issues related to transmission 33lines and on-site land use. Section 4.3 addresses the radiological impacts of normal operation, 34and Section 4.4 addresses issues related to the socioeconomic impacts of normal operation 35during the renewal term. Section 4.5 addresses issues related to groundwater use and quality, 36while Section 4.6 discusses the impacts of renewal-term operations on threatened and 37endangered species. Section 4.7 addresses potential new information that was identified during 38the scoping period and Section 4.8 discusses cumulative impacts. The results of the evaluation 39of environmental issues related to operation during the renewal term are summarized in 40 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" includ e the GEIS and its Addendum 1.
Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-2 September 2007 Section 4.9. Finally, Section 4.10 lists thereferences for Chapter 4. Category 1 and Category 2 1issues that are not applicable to WCGS because they are related to plant design features or site 2characteristics not found at WCGS are listed in Appendix F.
3 44.1 Cooling System 5 6Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, that are applicable to 7WCGS cooling system operation, during the renewal term, are listed in Table 4-1. Wolf Creek 8Nuclear Operating Corporation (WCNOC) stated in its Environmental Report (ER; WCNOC 92006a) that it is not aware of any new and significant information associated with the renewal of 10the WCGS operating license (OL). The U.S. Nuclear Regulatory Commission (NRC) staff also 11has not identified any new and significant information during its independent review of the 12WCNOC ER, the Staff's site audit, the scoping process, or evaluation of other available 13information. For all of the Category 1 issues, the Staff concluded in the GEIS that the impacts 14would be SMALL, and additional plant-specific mitigation measures are not likely to be 15sufficiently beneficial to be warranted.
16 17 Table 4-1. Category 1 Issues Applicable to the Operation of the WCGS 18Cooling System During the Renewal Term 19 20ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1GEIS Sections SURFACE WATER QUALITY ,HYDROLOGY , AND U SE (FOR ALL PLANTS
)Altered current patterns at intake and discharge structures4.2.1.2.1; 4.3.2.2; 4.4.2Altered thermal stratification of lakes4.2.1.2.2, 4.4.2.2Scouring caused by discharged cooling water4.2.1.2.3; 4.4.2.2Eutrophication4.2.1.2.3, 4.4.2.2Discharge of chlorine or other biocides4.2.1.2.4; 4.4.2.2Discharge of sanitary wastes and minor chemical spills4.2.1.2.4. 4.4.2.2Discharge of other metals in wastewater4.2.1.2.4; 4.3.2.2; 4.4.2.2 21 22 Environmental Impacts of Operation September 2007 4-3 Draft NUREG-1437, Supplement 32 1 Table 4-1. (contd)
AQUATIC ECOLOGY (FOR ALL PLANTS
)Accumulation of contaminants in sediments or biota4.2.1.2.4; 4.3.3; 4.4.2.2; 4.4.3Entrainment of phytoplankton and zooplankton4.2.2.1.1; 4.3.3; 4.4.3Cold shock4.2.2.1.5; 4.3.3; 4.4.3Distribution of aquatic organisms4.2.2.1.6; 4.4.3Premature emergence of aquatic insects 4.2.2.1.7; 4.4.3 Gas supersaturation (gas bubble disease)4.2.2.1.8; 4.4.3Low dissolved oxygen in the discharge4.2.2.1.9; 4.3.3; 4.4.3Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses 4.2.2.1.10; 4.4.3Stimulation of nuisance organisms4.2.2.1.11; 4.4.3 TERRESTRIAL R ESOURCESCooling pond impacts on terrestrial resources 4.4.4 Human HealthMicrobiological organisms (occupational health) 4.3.6 Noise 4.3.7 2A brief description of the Staff's review and the GEIS conclusions, as codified in Table B-1, for 3each of these Category 1 issues follows:
4 5 Altered current patterns at intake and discharge structures. Based on information in the 6GEIS, the Commission found that:
7 8Altered current patterns have not been found to be a problem at operating nuclear power 9plants and are not expected to be a problem during the license renewal term.
10 11The Staff has not identified any new and significant information during its independent 12review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 13information. Therefore, the Staff concludes that there would be no impacts of altered 14current patterns at intake and discharge structures during the renewal term beyond those 15discussed in the GEIS.
16 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-4 September 2007 Altered thermal stratification of lakes. Based on information in the GEIS, the 1Commission found that:
2 3Generally, lake stratification has not been found to be a problem at operating nuclear 4power plants and is not expected to be a problem during the license renewal term.
5 6The Staff has not identified any new and significant information during its independent 7review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 8information. Therefore, the Staff concludes that there would be no impacts of altered 9thermal stratification of lakes during the renewal term beyond those discussed in the GEIS.
10 11 Scouring caused by discharged cooling water. Based on information in the GEIS, the 12Commission found that:
13 14Scouring has not been found to be a problem at most operating nuclear power plants 15and has caused only localized effects at a few plants. It is not expected to be a problem 16during the license renewal term.
17 18The Staff has not identified any new and significant information during its independent 19review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 20information. Therefore, the Staff concludes that there would be no impacts of scouring 21caused by discharged cooling water during the renewal term beyond those discussed in the 22 GEIS.23 24 Eutrophication. Based on information in the GEIS, the Commission found that:
25 26Eutrophication has not been found to be a problem at operating nuclear power plants 27and is not expected to be a problem during the license renewal term.
28 29The Staff has not identified any new and significant information during its independent 30review of the WCGS ER, the site audit, the scoping process, review of monitoring programs, 31or evaluation of other available information. Therefore, the Staff concludes that there would 32be no impacts of eutrophication during the renewal term beyond those discussed in the 33 GEIS.34 35 Discharge of chlorine or other biocides. Based on information in the GEIS, the 36Commission found that:
37 38Effects are not a concern among regulatory and resource agencies and are not expected 39to be a problem during the license renewal term.
40 Environmental Impacts of Operation September 2007 4-5 Draft NUREG-1437, Supplement 32 The Staff has not identified any new and significant information during its independent 1review of the WCGS ER, the site audit, the scoping process, and evaluation of other 2available information including the National Pollutant Discharge Elimination System 3(NPDES) permit for WCGS, or discussion with the U.S. Environmental Protection Agency 4(EPA) and Kansas Department of Health and the Environment (KDHE) NPDES compliance 5offices. Therefore, the Staff has determined that there would be no significant impacts of 6discharge of chlorine or other biocides during the renewal term beyond those discussed in 7 the GEIS.
8 9 Discharge of sanitary wastes and minor chemical spills. Based on information in the 10 GEIS, the Commission found that:
11 12Effects are readily controlled through the NPDES permit and periodic modifications, if 13needed, and are not expected to be a problem during the license renewal term.
14 15The Staff has not identified any new and significant information during its independent 16review of the WCGS ER, the site audit, the scoping process, and evaluation of other 17available information including the NPDES permit for WCGS, or discussion with the EPA 18and KDHE NPDES compliance offices. Therefore, the Staff has determined that there 19 would be no significant impacts of discharge of sanitary wastes and minor chemical spills 20during the renewal term beyond those discussed in the GEIS.
21 22 Discharge of other metals in wastewater. Based on information in the GEIS, the 23Commission found that:
24 25These discharges have not been found to be a problem at operating nuclear power 26plants with cooling-tower-based heat dissipation systems and have been satisfactorily 27mitigated at other plants. They are not expected to be a problem during the license 28 renewal term.
29 30The Staff has not identified any new and significant information during its independent 31review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 32information including the NPDES permit for WCGS. Therefore, the Staff concludes that 33there would be no impacts of discharges of other metals in wastewater during the renewal 34term beyond those discussed in the GEIS.
35 36 Accumulation of contaminants in sediments or biota. Based on information in the GEIS, 37the Commission found that:
38 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-6 September 2007 Accumulation of contaminants has been a concern at a few nuclear power plants but 1has been satisfactorily mitigated by replacing copper alloy condenser tubes with 2those of another metal. It is not expected to be a problem during the license renewal 3 term.4 5As discussed in Section 2.2.3.1.4, monitoring data from both WCNOC and KDHE have 6documented the bioaccumulation of tritium in fish within Coffey County Lake (WCNOC 72006b, KDHE 2006a). Both the WCNOC annual report (WCNOC 2006b) and KDHE annual 8report (KDHE 2006a) provide an evaluation of the risk posed to humans from exposure to 9tritium concentrations in the surface water and fish in Coffey County Lake. Both reports 10note that Coffey County Lake is not used as a drinking water source, and the lake is not 11approved for any recreational activity other than fishing. The KDHE report provides a dose 12assessment for a standard man consuming 21 kilograms per year (kg/yr) of fish from Coffey 13County Lake, and calculates that the man would receive a committed effective dose 14equivalent of 0.017 millirems (mrem; KDHE 2006a). WCNOC performs a similar calculation, 15resulting in a committed effective dose equivalent of 0.013 mrem. These calculated doses 16are much less than the 100 mrem regulatory limit for a member of the public (KDHE 2006a).
17 18The Staff has not identified any new and significant information during its independent 19review of the WCGS ER, the site audit, the scoping process, or evaluation of available 20information. Therefore, the Staff concludes that there would be no impacts of accumulation 21of contaminants in sediments or biota during the renewal term beyond those discussed in 22 the GEIS.
23 24 Entrainment of phytoplankton and zooplankton. Based on information in the GEIS, the 25Commission found that:
26 27Entrainment of phytoplankton and zooplankton has not been found to be a problem at 28operating nuclear power plants and is not expected to be a problem during the license 29 renewal term.
30 31The Staff has not identified any new and significant information during its independent 32review of the WCGS ER, the site audit, the scoping process, review of monitoring programs, 33or evaluation of other available information. Therefore, the Staff concludes that there would 34be no impacts of entrainment of phytoplankton and zooplankton during the renewal term 35beyond those discussed in the GEIS.
36 37 Cold shock. Based on information in the GEIS, the Commission found that:
38 39Cold shock has been satisfactorily mitigated at operating nuclear plants with once-40through cooling systems, has not endangered fish populations or been found to be a 41 Environmental Impacts of Operation September 2007 4-7 Draft NUREG-1437, Supplement 32 problem at operating nuclear power plants with cooling towers or cooling ponds, and is 1not expected to be a problem during the license renewal term.
2 3The Staff has not identified any new and significant information during its independent 4review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 5information. Therefore, the Staff concludes that there would be no impacts of cold shock 6during the renewal term beyond those discussed in the GEIS.
7 8 Distribution of aquatic organisms. Based on information in the GEIS, the Commission 9 found that:
10 11Thermal discharge may have localized effects but is not expected to affect the larger 12geographical distribution of aquatic organisms.
13 14The Staff has not identified any new and significant information during its independent 15review of the WCGS ER, the site audit, the scoping process, review of monitoring programs, 16or evaluation of other available information. Therefore, the Staff concludes that there would 17be no impacts on distribution of aquatic organisms during the renewal term beyond those 18discussed in the GEIS.
19 20 Premature emergence of aquatic insects. Based on information in the GEIS, the 21Commission found that:
22 23Premature emergence has been found to be a localized effect at some operating nuclear 24power plants but has not been a problem and is not expected to be a problem during the 25license renewal term.
26 27The Staff has not identified any new and significant information during its independent 28review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 29information. Therefore, the Staff concludes that there would be no impacts of premature 30emergence of aquatic insects during the renewal term beyond those discussed in the GEIS.
31 32 Gas supersaturation (gas bubble disease). Based on information in the GEIS, the 33Commission found that:
34 35Gas supersaturation was a concern at a small number of operating nuclear power plants 36with once-through cooling systems but has been satisfactorily mitigated. It has not been 37found to be a problem at operating nuclear power plants with cooling towers or cooling 38ponds and is not expected to be a problem during the license renewal term.
39 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-8 September 2007 The Staff has not identified any new and significant information during its independent 1review of the WCGS ER, the site audit, the scoping process, review of monitoring programs, 2or evaluation of other available information. Therefore, the Staff concludes that there would 3be no impacts of gas supersaturation during the renewal term beyond those discussed in 4 the GEIS.5 6 Low dissolved oxygen in the discharge. Based on information in the GEIS, the 7Commission found that:
8 9Low dissolved oxygen has been a concern at one nuclear power plant with a once-10through cooling system but has been effectively mitigated. It has not been found to be a 11problem at operating nuclear power plants with cooling towers or cooling ponds and is 12not expected to be a problem during the license renewal term.
13 14The Staff has not identified any new and significant information during its independent 15review of the WCGS ER, the site audit, the scoping process, review of monitoring programs, 16or evaluation of other available information. Therefore, the Staff concludes that there would 17be no impacts of low dissolved oxygen during the renewal term beyond those discussed in 18 the GEIS.
19 20 Losses from predation, parasitism, and disease among organisms exposed to 21sublethal stresses. Based on information in the GEIS, the Commission found that:
22 23These types of losses have not been found to be a problem at operating nuclear power 24plants and are not expected to be a problem during the license renewal term.
25 26The Staff has not identified any new and significant information during its independent 27review of the WCGS ER, the Staff's site visit, the scoping process, or evaluation of other 28available information. Therefore, the Staff concludes that there would be no impacts of 29losses from predation, parasitism, and disease among organisms exposed to sub-lethal 30stresses during the renewal term beyond those discussed in the GEIS.
31 32 Stimulation of nuisance organisms. Based on information in the GEIS, the Commission 33 found that:
34 35Stimulation of nuisance organisms has been satisfactorily mitigated at the single nuclear 36power plant with a once-through cooling system where previously it was a problem. It 37has not been found to be a problem at operating nuclear power plants with cooling 38towers or cooling ponds and is not expected to be a problem during the license renewal 39 term.40 Environmental Impacts of Operation September 2007 4-9 Draft NUREG-1437, Supplement 32 The Staff has not identified any new and significant information during its independent 1review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 2information. Therefore, the Staff concludes that there would be no impacts of stimulation of 3nuisance organisms during the renewal term beyond those discussed in the GEIS.
4 5 Cooling pond impacts on terrestrial resources. Based on information in the GEIS, the 6Commission found that:
7 8These effects have not been found to be a problem at operating nuclear power plants 9and are not expected to be a problem during the license renewal term.
10 11The Staff has not identified any new and significant information during its independent 12review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 13information. Therefore, the Staff concludes that there would be no impacts of cooling ponds 14on terrestrial resources during the renewal term beyond those discussed in the GEIS.
15 16 Microbiological organisms (occupational health). Based on information in the GEIS, the 17Commission found that:
18 19Occupational health impacts are expected to be controlled by continued application of 20accepted industrial hygiene practices to minimize worker exposures.
21 22The Staff has not identified any new and significant information during its independent 23review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 24information. Therefore, the Staff concludes that there would be no impacts of 25microbiological organisms on occupational health during the renewal term beyond those 26discussed in the GEIS.
27 28 Noise. Based on information in the GEIS, the Commission found that:
29 30Noise has not been found to be a problem at operating plants and is not expected to be 31 a problem at any plant during the license renewal term.
32 33The Staff has not identified any new and significant information during its independent 34review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 35information. Therefore, the Staff concludes that there would be no impacts of noise during 36the license renewal term beyond those discussed in the GEIS.
37 38The Category 2 issues related to cooling system operation during the renewal term that are 39applicable to WCGS are discussed in the sections that follow, and are listed in Table 4-2.
40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-10 September 2007 Table 4-2. Category 2 Issues Applicable to the Operation of the 1WCGS Cooling System During the Renewal Term 2 3ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections10 CFR 51.53(c)(3)(ii) SubparagraphDraft SEIS SectionSurface-Water Quality, Hydrology, and Use (FOR ALL PLANTS
)Water use conflicts (plants with cooling towers and cooling ponds using makeup water from a small river with low flow) 4.3.2.1;4.4.2.1A4.1.1 AQUATIC ECOLOGY (FOR PLANTS WITH COOLING POND HEAT
-DISSIPATION SYSTEMS
)Entrainment of fish and shellfish in early life stages 4.2.2.1.2; 4.4.3B4.1.2Impingement of fish and shellfish 4.2.2.1.3; 4.4.3B4.1.3 Heat shock 4.2.2.1.4; 4.4.3B4.1.5Human HealthMicrobiological organisms (public health) (plants using a lake, canal, or cooling pond or that discharge to a small river) 4.3.6 G 4.1.6 44.1.1 Water Use Conflicts 5 6For plants with cooling pond systems that are supplied with make-up water from a small river 7with low flow, the potential impact on instream and riparian communities is considered a 8Category 2 issue, thus requiring a site-specific assessment for license renewal review. Near 9WCGS, the Neosho River at Burlington has an average annual flow of approximately 1,603 10cubic ft per second (cfs; Putnam and Schneider 2005). This volume meets the NRC definition 11of a small river of 100,000 cfs (3.15 X 10 12 cubic feet per year listed in 10 CFR Part 1251.53(c)(3)(ii)(A)), resulting in water use conflicts being a potentially applicable issue for 13relicensing of WCGS.
14 15In order to evaluate potential impacts related to water withdrawal from Wolf Creek and the 16Neosho River, and the potential for impacts to instream and riparian communities associated 17with the Neosho River, the Staff independently reviewed the WCGS ER, visited the site, 18consulted with Federal and State resource agencies, and reviewed the applicant's existing 19NPDES permit and other existing literature.
20 Environmental Impacts of Operation September 2007 4-11 Draft NUREG-1437, Supplement 32 The GEIS considered surface water use conflicts to be a Category 2 issue for two separate 1 reasons: 2 31) Consumptive water use can adversely affect riparian vegetation and instream aquatic 4communities in the stream. Reducing the amount of water available to either the riparian 5zones or instream communities could result in impacts to threatened and endangered 6species, wildlife, and recreational uses of the water body. In addition, riparian vegetation 7performs several important ecological functions, included stabilizing channels and 8floodplains, influencing water temperature and quality, and providing habitat for aquatic 9and terrestrial wildlife (NRC 1996). The GEIS specifically mentioned WCGS as an 10example of a facility that had already experienced water-use conflicts associated with 11 the withdrawal of make-up water during drought periods (NRC 1996).
12 132) Continuing operation of these facilities depends on the availability of water within the 14river from which they are withdrawing water. For facilities that are located on small 15bodies of water, the volume of water available is expected to be susceptible to droughts 16and to competing water uses within the basin. In cases of extreme drought, these 17facilities may be required to curtail operations if the volume of water available is not 18 sufficient (NRC 1996).
19 20An additional potential effect of the withdrawal of water from a small river is that the withdrawal 21may have an impact on groundwater levels and, therefore, result in groundwater use conflicts 22(NRC 1996). This is considered to be a separate Category 2 issue, and is evaluated in Section 234.5.1 of this draft Supplemental Environmental Impact Statement (SEIS). In addition, the facility 24purchases water from local sources to use as potable water. Potential impacts associated with 25the use of this purchased water during the license renewal period are discussed in Section 26 4.4.2.27 28The water stored within Coffey County Lake is used as cooling water, and also acts as the 29supply for the Service Water and Essential Service Water Systems for the facility. The three 30separate physical sources of make-up water to Coffey County Lake include:
31 32 All natural flows within the Wolf Creek drainage basin upstream of the Coffey County Lake 33dam. Administratively, these flows are obtained by WCGS through water appropriation file 34 number 20,275 (State of Kansas 1977a in WCNOC 2006c). The reported average monthly 35stream flow in Wolf Creek prior to construction of the WCGS facility was approximately 8,100 36gallons per minute (gpm), or 18 cfs (NRC 1982 in WCNOC 2006c).
37 38 A portion of the natural flows within the Neosho River basin. These natural flows are defined 39as the water within the John Redmond Reservoir above the elevation of 1,039 feet (ft) above 40mean sea level (MSL). These flows are obtained by WCGS through two separate water 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-12 September 2007 appropriations: water appropriation file number 14,626 (55 cfs, up to a maximum of 25,000 1acre (ac)-ft per yr, and water appropriation file number 19,882 (170 cfs, up to a maximum of 257,300 ac-ft per yr) (State of Kansas 1977b, State of Kansas 1977c in WCNOC 2006c).
3 4 The conservation pool within the John Redmond Reservoir, which is defined as the water 5contained in the reservoir below the elevation of 1,039 ft above MSL. This water is obtained 6through purchase contract number 76-02 with the Kansas Water Resources Board (State of 7Kansas 1976 in WCNOC 2006c).
8 9To evaluate whether the re-licensing of WCGS would result in an impact with respect to water 10use conflicts, the potential impact of water withdrawals from each of these three sources was 11evaluated separately. For each source, the potential impact was evaluated with respect to the 12two reasons that water use conflicts were made a Category 2 issue - the potential for impacts to 13instream and riparian communities and the potential for shut down of the facility due to water 14 shortage.15 164.1.1.1 Impacts to Instream and Riparian Communities 17 184.1.1.1.1 Instream and Riparian Impacts in Wolf Creek 19 20Wolf Creek is an intermittent stream subject to drying during periods of drought. It was 21impounded by the construction of the Coffey County Lake dam approximately 5.5 miles 22upstream of the confluence where this tributary empties into the Neosho River. Because of the 23capture of water in the Coffey County Lake and the resulting evaporation and seepage losses 24from the lake, it is likely the flow in Wolf Creek below the dam has been reduced by WCGS 25operations. However, Wolf Creek is ungauged, and current flow measurements for the creek 26 are unavailable.
27 28During the most severe drought of record for the Wolf Creek basin, which lasted from 1951 to 291957, the estimated discharge from Wolf Creek was zero for much of the period (NRC 1975).
30During future drought conditions, water would not be released from Coffey County Lake, and 31this intermittent stream may dry up as it has during droughts prior to the construction and 32operation of WCGS (NRC 1982). Prior to construction of the dam, the estimated average 33 annual flow in Wolf Creek was 18 cfs at the Neosho River (NRC 1982). Near the Wolf Creek 34confluence, the estimated average annual flow in the Neosho River at Burlington during water 35years 1963 to 2004 was 1603 cfs (Putnam and Schneider 2005). Based on this river flow and 36the estimated annual average Wolf Creek flow prior to construction, the creek would have 37contributed approximately one percent of the average flow in this reach of the river. Thus, the 38marginal reductions in Wolf Creek flow due to WCGS are expected to have a negligible effect 39on flow in the Neosho River. Additionally, because Wolf Creek was historically an intermittent 40 Environmental Impacts of Operation September 2007 4-13 Draft NUREG-1437, Supplement 32 stream, WCGS operations are not expected to affect instream and riparian resources in Wolf 1 Creek downstream of the dam.
2 34.1.1.1.2 Instream and Riparian Impacts in the Neosho River 4
5The surface water resources within and along the Neosho River that may be affected by water 6use conflicts include instream and riparian communities. These instream and riparian resources 7are described in detail in Section 2 of this draft SEIS. The instream organisms include rare 8species, and the Neosho River below John Redmond Dam has been designated by the Kansas 9Department of Wildlife and Parks (KDWP) as critical habitat for the Neosho madtom (noturus 10 placidus) and five mussels, the Neosho mucket (Lampsilis rafinesqueana
), Ouachita kidneyshell 11 (Ptychobranchus occidentalis
), rabbitsfoot (Quadrula cylindrica
), western fanshell (Cyprogenia 12 aberti), and flutedshell (Lasmigona costata). All of these species are State-listed as threatened 13or endangered, and the Neosho madtom and Neosho mucket have Federal status as 14threatened and candidate species, respectively. The Neosho River also is a drinking water 15source for several towns downstream of John Redmond Reservoir, including Burlington, 16 Neosho Falls, and Iola.
17 18To support these resources, the State of Kansas has established Minimum Desirable 19Streamflow (MDS) levels in the Neosho River "for instream uses relative to fish, wildlife, water 20quality, general aesthetics and downstream domestic and senior water rights" (KWO 2001).
21The MDS established for the Neosho River at Iola, Kansas under the Kansas Water 22Appropriation Act (KWAA) is 40 cfs from July to March. The MDS increases to 60 cfs in April 23and 200 cfs in May and June if the reservoir is in flood pool in order to maintain flows that 24support fish spawning in the river; otherwise, the MDS in April through June is 40 cfs (KWAA 25 2004).26 27 The estimated average annual flow in the Neosho River at Iola, approximately 55 miles 28downstream of John Redmond Reservoir, was 1,865 cfs for water years 1899 to 2005, and at 29Burlington, approximately 5 river miles downstream of John Redmond Reservoir and upstream 30of the Wolf Creek confluence, was 1,603 cfs for water years 1962 to 2005 (Putnam and 31Schneider 2005). Based on these long-term averages, the annual average flow near Burlington 32 is approximately 86 percent of the flow downstream at Iola. Consequently, when the MDS is 40 33cfs at Iola, the streamflow near Burlington may be estimated to be approximately 34 cfs. Based 34on habitat characteristics (current velocity and depth) reported in the literature for two sensitive 35indicator species, the Neosho madtom and the Neosho mucket mussel, the applicant calculated 36the approximate flows in the Neosho River that would correspond to these conditions. The 37estimated preferred flows were 15 to 55 cfs for the Neosho madtom and 35 cfs for the Neosho 38mucket. Comparison of these preferred flows for habitat maintenance to flow under the worst-39case MDS of 40 cfs measured at Iola indicated that this range of desirable flows generally would 40be maintained (WCNOC 2007a). Therefore, the MDS is expected to protect populations of the 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-14 September 2007 Neosho madtom and Neosho mucket in the Neosho River from John Redmond Dam 1downstream to Iola. Flows sufficient to protect these two rare species also are expected to 2protect other species of fish and invertebrates in the river.
3 4The withdrawal of water from the natural flows within the Neosho River is regulated by the 5conditions of the two appropriation mechanisms used by WCGS to acquire the water. These 6conditions require that withdrawals of natural flows can only be made when the flow volume 7remaining within the Neosho River downstream of the Makeup Water Screen House (MUSH) 8intake structure is 250 cfs or greater (WCNOC 2006c). However, the appropriations mechanism 9allows WCNOC to request a variance of the 250 cfs limitation from the Chief Engineer of the 10Division of Water Resources (DWR). The appropriation mechanisms are not subject to the 11MDS restriction of 40 to 200 cfs for the Neosho River.
12 13The resources that could be affected by the purchase of water from the conservation pool are 14the same as those that could be affected by the WCGS appropriations from the natural flows of 15the Neosho River. The purchase of the conservation pool water would only occur when the 16water elevation within John Redmond Reservoir is below 1,039 ft above MSL, and under these 17conditions, the flow rate within the Neosho River would already be below the 250 cfs required to 18acquire water through the appropriations (WCNOC 2006c). Therefore, the Neosho River would 19already be in a low flow or drought condition (WCNOC 2006c).
20 21Prior to the beginning of facility operations, the NRC conducted an analysis of the impact of 22water withdrawal from the Neosho River during severe and prolonged drought conditions (NRC 231975). This analysis evaluated the expected water withdrawal rates from WCGS during what 24was considered to be a 1 in 50 year drought. The precipitation and water volume data to 25support the study were taken from actual measurements on the Neosho River during the period 26from January 1951 to December 1959, which corresponded with a 1 in 50 year drought. The 27results of this analysis were that withdrawal of stored contract water by WCGS at 41 cfs would 28 cause reduced flows within the river, would extend the duration and severity of low flow 29conditions, and could cause stress to aquatic communities and fish populations (NRC 1982).
30 31Similar to the Neosho River appropriations, the withdrawal of water from the conservation pool 32through the purchase contracts is regulated by the conditions of the purchase contract and also 33is restricted by the physical limitations of the MUSH withdrawal system (WCNOC 2006c).
34These restrictions result in a maximum withdrawal rate of 70 cfs for stored water from the 35conservation pool (WCNOC 2006c). This volume of water exceeds the 41 cfs estimate 36established by NRC as the volume of withdrawal that could cause reduced flows within the river.
37 38Although MDS levels have been established to protect aquatic resources in the Neosho River, 39the appropriations and water purchase contract mechanisms under which WCGS obtains make-40up water are not subject to these restrictions. The MDS restrictions apply only to junior water 41 Environmental Impacts of Operation September 2007 4-15 Draft NUREG-1437, Supplement 32 rights obtained after April 12, 1984, and Kansas Statutes Annotated (KSA) 82a-703b(b) states 1that "all vested rights, water appropriation rights and applications for permits to appropriate 2 water having a priority date on or before April 12, 1984, shall not be subject to any minimum 3desirable streamflow requirements." As the WCGS appropriations were established prior to 4April 12, 1984, they are not subject to the restrictions. The water purchase contract is also not 5subject to MDS restrictions. A comparison of water withdrawal dates with Neosho River 6streamflows indicates that withdrawals have occurred in the past on days when the Neosho 7River flow rate was below the 40 cfs MDS.
8 9Reducing flow below desirable levels can have a variety of adverse effects on instream aquatic 10and riparian communities. Lower water levels in streams can cause water to drain from riparian 11marshes and vegetated areas and damage or destroy riparian plant communities that provide 12habitat, refugia, and nursery areas for fish and invertebrates. Habitat can also be lost from the 13stream due to decreased volume and area of aquatic habitat. With lowered water levels, fish 14can lose refuges; nesting, spawning, and nursery areas; and cover. With less habitat, fish and 15invertebrates would become more crowded and be subject to increased frequency of inter- and 16intra-specific interactions, such as predation. The decreased habitat can increase the 17susceptibility of fish not only to predatory fish, but also to piscivorous birds and mammals such 18 as raccoons (Procyon lotor). Not only the quantity but also the quality of habitat can be 19affected. Lowered flow rates can alter sediment processes and characteristics, such as 20siltation, suspension, transportation, and sorting that in turn can affect success of invertebrate 21communities and fish reproductive processes. Lower stream flow and shallower water can 22increase stream water temperatures, which can degrade fish and invertebrate habitat.
23Decreased flow and turbulence and increased water temperature can reduce dissolved oxygen 24levels in some reaches and decrease the quality of fish habitat. These examples illustrate the 25complex ways in which reducing flow below desirable levels can adversely affect instream and 26riparian habitat quality and quantity and the populations of fish and invertebrates that inhabit 27 them.28 294.1.1.2 Availability of Water During License Renewal Term 30 314.1.1.2.1 Availability of Water from Wolf Creek 32 33The limiting factor in the ability of the facility to withdraw water using their Wolf Creek 34appropriations is the volume of water existing in the Wolf Creek drainage above Coffey County 35Lake. WCGS has the right and the physical capability to withdraw 100 percent of the water 36within Wolf Creek, so there are no physical or administrative limitations. However, because 37Wolf Creek is an intermittent drainage basin, the contribution of the Wolf Creek flow to the total 38volume of water necessary to operate WCGS is small. The estimated annual flow volume within 39Wolf Creek is reported to be 18 cfs (NRC 1982), and during drought periods, this volume is 40likely to be reduced to 0 cfs. The volume of water available to WCGS through the water 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-16 September 2007 appropriations from the natural flows within the Neosho River is 225 cfs, so the average flow in 1Wolf Creek is less than 10 percent of the volume of water available to the facility from the 2Neosho River appropriations. Therefore, the availability of water within the Wolf Creek basin is 3not likely to have a substantial impact on the overall availability of water for facility operations.
4 54.1.1.2.2 Availability of Water from Neosho River 6 7The ability of WCGS to access water from the Neosho River may be limited by several factors, 8including the presence of water, competing uses, administrative limitations, and physical 9limitations. During a severe drought, it is likely that the volume of water available through the 10Neosho River and Wolf Creek appropriations would be very low or zero. Therefore, the ultimate 11limitation on the availability of water to maintain facility operations lies in the availability of water 12within the conservation pool of John Redmond Reservoir, accessed through the WCGS 13purchase contract.
14 15Historically, the purchase of water from the conservation pool has been the primary source of 16water to WCGS. A review of the Annual Environmental Operating Reports for 1985 to 2005 17indicates that the volume of water obtained through the purchase contract is highly variable, 18ranging from 0.464 to 6.810 billion gallons per yr (WCNOC 2007b). The purchase contract 19limits the total amount of water that can be withdrawn on an annual basis to 9.672 billion 20gallons, while the WCGS standard operating procedure (SOP) AP 26A-006 Section 6.11.3 21places an annual limit of 4.83 billion gallons of water (WCNOC 2007c). From 2002 to 2006, the 22actual volume of water withdrawal from both appropriations and the purchase contract has 23ranged from 3.7 to 4.92 billion gallons per yr (WCNOC 2003a, WCNOC 2004a, WCNOC 2005a, 24WCNOC 2006b). This ranges from 38 to 51 percent of the volume allowed under the purchase 25contract. Therefore, WCGS has never approached their full allotment.
26 27In the most severe drought conditions, stipulations within the water purchase contract could be 28used to further limit the amount available to be withdrawn by WCGS (WCNOC 2006a). The 29contract contains the following clauses that reserve the right of the State of Kansas to limit water 30purchases to protect downstream users and instream and riparian communities:
31 32 If the total amount of water contracted for withdrawal from the John Redmond Reservoir in 33the next 12-month period is greater than the supply available from that reservoir which is 34deemed to be 9.672 billion gallons per yr due to a prolonged drought, the Board will 35apportion the available waters among the purchasers having contracts therefore as may best 36provide for the health, safety, and general welfare of the people of this state as determined 37by the Board. (State of Kansas 1976 in WCNOC 2006c).
38 39 If, because of an emergency, the Board deems it necessary for the health, safety, or general 40welfare of the people of Kansas to reduce or terminate the withdrawal of water from John 41 Environmental Impacts of Operation September 2007 4-17 Draft NUREG-1437, Supplement 32 Redmond Reservoir, the Board will apportion any available water among persons having 1contracts as may best provide for the health, safety, or general welfare of the people of 2Kansas . . . . (State of Kansas 1976 in WCNOC 2006c).
3 4 Whenever the elevation of water in the reservoir is below 1,039 ft above mean sea level, the 5amount of water taken at the point of withdrawal from the reservoir will not exceed a running 6average rate of 26,499 million gallons per day (mgd; State of Kansas 1976 in WCNOC 7 2006c).8 9These provisions indicate that WCGS's contract for water purchase from the conservation pool 10is not a right, and can be curtailed by the state, if necessary, to prevent impacts to other users 11and resources. This could occur if water levels in John Redmond Reservoir were to drop below 12the bottom level of the conservation pool at 1,020 ft above MSL. If water withdrawals were 13severely limited or eliminated, it would cause a subsequent reduction of the water level in Coffey 14County Lake through evaporation and seepage. If the water level in Coffey County Lake falls 15below 1,080 ft above MSL, the facility would implement plant procedure OFN SG-003: "Natural 16Events" (WCNOC 2003a in WCNOC 2006a). If the lake level were to fall below 1,075 ft above 17MSL, facility operations would be shut down (WCNOC 2006a).
18 19While these actions to curtail water supply to the facility have never occurred, incidents where 20other water rights are curtailed to maintain the MDS flow rate in the Neosho River are becoming 21increasingly common (KWO 2004). The Kansas Water Plan, Neosho Basin Section, specifically 22addresses "Protecting and Enhancing Instream Flow" as a Basin Priority Issue for the Neosho 23River (KWO 2004). According to this section, droughts in 2000, 2002, and 2003 had raised 24concern about streamflow in several basins in Kansas, and administration of junior water rights 25to meet the MDS on the Neosho River had become more frequent and longer in duration. Most 26recently, water rights that had been obtained after April 12, 1984, were curtailed for the period 27from November 8, 2006 to February 21, 2007 (WCNOC 2007b). The Neosho River is now 28closed to new appropriations during the irrigation season (May to September), and there 29continues to be new water right permit applications, mostly for recreational uses (KWO 2004).
30 31Another possible limitation on the access to water through the purchase contract during the 32WCGS re-license term (2025 to 2045) is that the available volume of water in John Redmond 33Reservoir is decreasing due to sedimentation (USACE 2002). The designed lifespan of John 34Redmond Reservoir is 50 years, beginning at the opening of the reservoir in 1964, and the 35water supply contract is based on the amount of storage space that was projected to be 36available at the end of the design life in 2014 (USACE 2002). However, the reservoir is silting 37up faster than was projected. The Design Sedimentation Rate in the conservation pool of the 38reservoir was 404 ac-ft per yr, while the reported actual rate from 1964 to 2007 is 874 ac-ft per 39yr (KWO 2007). The higher rate of sedimentation is causing a reduction in the volume of water 40available within the conservation pool, and it is now projected that this reduction could affect the 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-18 September 2007 ability of the U.S. Army Corps of Engineers (USACE) to meet their contractual obligation to 1provide 9.672 billion gallons per yr to the Kansas Water Office (KWO; and thus to WCGS) 2through 2014 (USACE 2002). The analysis concluded that, without action, there would be a 25 3percent reduction in water available for cooling purposes at WCGS, and this could reduce 4WCNOC's ability to operate the facility during years when the full contracted water capacity was 5 required (USACE 2002).
6 7This faster-than-expected decrease in the volume of the conservation pool has led the USACE 8to develop a draft Environmental Impact Statement (EIS) and plan for water reallocation to 9ensure that the water supply obligation can be met through 2014 (USACE 2002). The 10USACE's preferred alternative in the draft EIS is to reallocate the water storage capacity in the 11reservoir by raising the level of the conservation pool by 2 ft, from 1,039 ft to 1,041 ft above 12MSL (USACE 2002). This action was proposed to ensure the availability of water to meet the 13contractual obligations through 2014. However, this action would reduce the amount of storage 14space within the reservoir available for flood control, and could result in increasing the 15frequency or severity of floods. Also, the reallocation of the water storage in the reservoir 16considered in the draft EIS would only ensure availability of water through the end of the design 17life of the reservoir, which is 2014 (USACE 2002).
18 19The gradual reduction of the available water volume due to sedimentation in the conservation 20pool in John Redmond Reservoir suggests that water use conflicts would continue to become 21more likely through the re-licensing period beginning in 2025. Although WCGS has never used 22its full allocation, the proposed reallocation of the storage space by USACE is designed only to 23ensure adequate water supply through 2014 (USACE 2002). Therefore, it is likely that other 24actions would be required to ensure an adequate water supply through the re-licensing period 25from 2025 to 2045. The scope of these actions has not yet been decided. The USACE, Kansas 26Water Office (KWO), and WCNOC have all indicated that they are aware of the long-term issue, 27and that preliminary discussions have occurred to begin planning for the future water supply.(b)28However, there are currently no definitive plans or proposals in place to supply water during the 29 re-licensing period.
30 (b)Personal Communications and Meeting Minutes as follows: Personal communication between Robert Dover, Hydrologist for Earth Tech and Steve Nolan, USACE discussing the draft EIS. June 12, 2007. (Accession No. ML072420200). Personal communication between Robert Dover and Cheryl Buttenhoff, KWO, discussing withdrawal from the Neosho River. June 27, 2007. (Accession No. ML072420200).
Meeting minutes from a conference call on June 21, 2007 discussing water use of the John Redmond Reservoir. Participants included NRC, Earth Tech, and WCNOC. (Accession No. ML071840181).
Environmental Impacts of Operation September 2007 4-19 Draft NUREG-1437, Supplement 32 4.1.1.3 Summary of Impacts Related to Water Use Conflicts 1 2The aquatic resources within the Wolf Creek drainage basin have been increased by facility 3operations due to the construction of Coffey County Lake. Prior to facility construction, there 4was no perennial surface water within this basin (WCNOC 2006a). However, the analysis of the 5water use by the facility for cooling and service water purposes indicates that, although physical 6and administrative controls on water withdrawal rates exist, water withdrawals can still occur, 7and have occurred, during times when the natural flow rate in the Neosho River is already below 8the 40 cfs MDS established to be protective of instream and riparian communities.
9 10There may also be water use conflicts associated with long-term availability of the current water 11supply (John Redmond Reservoir) during the re-licensing period. The proposed action 12described in the WCGS Environmental Report (ER; WCNOC 2006a) assumes that John 13Redmond Reservoir would continue to be the primary source of makeup water, but does not 14address the likelihood that the availability of this source is being reduced through sedimentation.
15The documentation of the sedimentation issue in the USACE draft EIS (USACE 2002) and the 16Kansas Water Office Fact Sheet for John Redmond Reservoir (KWO 2007) strongly suggest 17that future actions will be required to ensure the continuity of the water supply. If no actions are 18taken, the volume of water available within the conservation pool would continue to decrease, 19and the supply of water to WCGS would begin to compete with the volumes of water available 20to maintain adequate streamflow and provide flow to the Cottonwood and Neosho River Basins 21Water Assurance District Number 3. If this situation coincides with a drought condition, 22continued water withdrawal by WCGS could severely deplete habitat and affect biota within and 23along the Neosho River. Such conditions could result in derating the plant temporarily during 24drought periods. Actions that may be taken to increase the water availability during the 25relicense period may include additional reallocations of the conservation and flood pools within 26the reservoir, dredging of sediment from the reservoir, or accessing alternative water supplies 27(groundwater or surface water based) from the local area. Once a proposal is developed and 28evaluated, it is likely that the impacts and specific mitigation measures would be evaluated in 29future National Environmental Policy Act (NEPA) environmental documentation developed by 30 NRC, USACE, or the State of Kansas.
31 32Because these future actions have not yet been proposed, it is currently not possible to 33determine the impacts that would be associated with them. Therefore, due to the uncertainty 34associated with water availability to the WCGS, the Staff has determined that impacts 35associated with future water use conflicts may range from SMALL to MODERATE.
36 37The NRC staff has identified potential mitigation measures, which may help reduce adverse 38impacts related to water use conflicts during the license-renewal term for continued operation of 39WCGS. Such mitigation measures include managing water withdrawals in a manner that 40continues to maintain the MDS levels within the Neosho River. Other mitigation measures may 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-20 September 2007 be appropriate, depending on the future actions taken to address the reduction in water 1availability within John Redmond Reservoir. The staff has concluded that implementation of 2such measures may be beneficial enough to be warranted.
3 44.1.2 Entrainment of Fish and Shellfish in Early Life Stages 5 6For nuclear power plants such as WCGS with cooling pond heat dissipation systems, 7entrainment of fish and shellfish in early life stages into cooling water systems associated with 8the plant is considered a Category 2 issue requiring a site-specific assessment for the license 9renewal review. The Staff reviewed the WCGS ER; visited the site; consulted with Federal and 10State resource agencies; and reviewed the applicant's existing NPDES permit and 11correspondence between WCNOC and KDHE, environmental studies, and information related 12to operational entrainment studies conducted at WCGS.
13 14Section 316(b) of the Clean Water Act (CWA 1977), the common name for the Federal Water 15Pollution Control Act, requires that the location, design, construction, and capacity of cooling 16intake structures reflect the best technology available for minimizing adverse environmental 17impacts (33 USC 1326). Entrainment of fish and shellfish into the cooling system is a potential 18adverse environmental impact that could be minimized by use of the best technology available.
19 20WCGS has not been required by KDHE or EPA to perform entrainment monitoring. The State 21of Kansas issued the first NPDES permit for WCGS in 1977 and the permit subsequently has 22been renewed seven times. The State has never required WCNOC to conduct a 316(b) study 23for WCGS, and it has not made an explicit 316(b) determination for the station. The lack of an 24explicit determination is not unusual in Kansas and WCNOC has concluded that issuance of the 25WCGS NPDES permit by the State constitutes an implicit determination that the WCGS cooling 26water intake structure reflects the best technology available for minimizing adverse 27environmental impacts such as the entrainment of fish and shellfish in early life stages (WCNOC 282006d). However, because there is not a formal 316(b) determination, the NRC staff has 29conducted a full analysis of impacts due to entrainment and impingement in this draft SEIS.
30 31Entrainment of fish and other organisms can occur at two locations associated with WCGS: the 32circulating water intake structure (CWIS) on Coffey County Lake and the MUSH on the Neosho 33River. The organisms subject to entrainment are those small enough to pass through the 3/8-34inch (in.) openings of the traveling screens within the intakes. Of these, the organisms 35principally of concern are the eggs and larvae of fish and invertebrates.
36 374.1.2.1 Coffey County Lake Cooling Water Entrainment 38 39Entrainment monitoring at the Coffey County Lake cooling water intake was not required for 40initial licensing of WCGS. The NRC relied on the State of Kansas for determination of the need 41 Environmental Impacts of Operation September 2007 4-21 Draft NUREG-1437, Supplement 32 for monitoring in regard to aquatic issues (NRC 1984). The State of Kansas has not required 1such monitoring. Thus, no entrainment monitoring program has been initiated 2(WCNOC 2006d).
3 4Limited data on larval fish in Coffey County Lake have been collected by WCNOC. Samples 5were collected to provide a rough estimate of the amount of larval entrainment and the effects of 6entrainment on the biota of Coffey County Lake were evaluated by the NRC (1975, 1982). The 7evaluations assumed that entrainment would result in 100 percent mortality. Thermal shock in 8the condensers was expected to be the main cause of entrainment mortality, though stresses 9associated with mechanical damage, chemical additions, and pressure changes were also 10considered likely to contribute to mortality. There were no shellfish species (e.g. mollusks and 11crustaceans) in Coffey County Lake considered likely to be entrained at the cooling water 12 intake. Most shellfish likely to be found in Coffey County Lake (for example, crayfish) tend to be 13benthic and are not particularly susceptible to entrainment. Therefore, the focus of the 14evaluation was fish, primarily in the larval stage (WCNOC 2006d).
15 16To determine numbers of larval fish present in the water at the intake, vertical tows with a 17plankton net were completed from the lake bottom to the surface. These samples were 18collected monthly from March through August 2005 to determine approximate peak occurrence 19of larvae. Two to three replicate samples were collected at 8-hour (hr) intervals over a 24-hr 20period to detect differences between night and day. The plankton net had an opening 30 21centimeters (cm) in diameter and a mesh size of 0.5 millimeter (mm). The results indicated a 22possible peak in larval numbers during late May to June, similar to results from studies in the 23 Neosho River (EAI 1982, Wedd 1985). Larval fish densities (larvae per cubic meter) estimated 24 from these samples were 1.31 for gizzard shad (Dorosoma cepedianum), 0.47 for white crappie 25 (Pomoxis annularis
), and 0.36 for freshwater drum (Aplodinotus grunniens
). In comparison, 26annual larval densities (larvae per cubic meter) in the Neosho River during 1981 were 52,950 27for gizzard shad, 600 for white crappie, and 1,320 for freshwater drum (WCNOC 2006d).
28 29Although sample sizes were small, the results indicated that larval fish densities were much 30lower upstream of the cooling water intake in Coffey County Lake than in the Neosho River.
31This suggests that the area near the cooling water intake is unlikely to be an important 32spawning or nursery area in Coffey County Lake and that WCGS probably does not remove 33appreciable numbers of larval fish from the fishery. It is likely that other factors, such as 34predation, were limiting gizzard shad densities in Coffey County Lake (WCNOC 2006d).
35 364.1.2.2 Neosho River Makeup Water Entrainment 37 38Makeup water to maintain Coffey County Lake is pumped from the Neosho River. Water is 39withdrawn from the Neosho River at the makeup water intake facility, the MUSH, located 40immediately downstream of John Redmond Dam. Because the withdrawals are not for the 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-22 September 2007 purposes of cooling, according to the State of Kansas, Section 316(b) of the CWA does not 1apply to the Neosho River MUSH (Staab 2007) and the Neosho River intake is not subject to 2EPA or Kansas Phase II 316(b) cooling water intake regulations (WCNOC 2006d). Discussion 3of entrainment impacts with the State of Kansas also occurred during the initial certification and 4discharge permitting process (KG&E 1975).
5 6In order to evaluate potential entrainment effects, extensive larval fish monitoring was 7conducted in the Neosho River from 1975 to 1982, before and during initial operation of the 8MUSH (NRC 1975 and 1982, WCNOC 2006a). No records of invertebrate monitoring are 9available. Monitoring of larval fish in the Neosho River prior to and during initial MUSH 10operation was extensive (Nalco 1976, 1977, and 1978; Hazelton 1979 and 1980; EAI 1981 and 111982; and Wedd 1985). The gizzard shad was the dominant species in most samples, though 12the freshwater drum and various members of the sucker family (Catostomidae) and the minnow 13family (Cyprinidae) also were common. In general, larval fish appeared in the Neosho River 14each year beginning in April and continuing until July, with peak levels typically occurring during 15June. Therefore, WCNOC came to the conclusion that makeup water withdrawals during other 16times of the year would be unlikely to entrain appreciable numbers of fish larvae (WCNOC 17 2006d).18 19The majority of the larvae identified in these studies are likely to have originated as drift from 20John Redmond Reservoir and not from reproduction within the Neosho River. Even if these 21species reproduced in the riverine habitat below the dam, there is a very limited area for nesting 22habitat in the river upstream of the MUSH and below the dam from which larvae or eggs could 23drift into the MUSH. In addition, the eggs of most native riverine fish are demersal and remain 24on or within the substrate, while the larvae may tend to drift downstream and have minimal 25ability to move upstream against the current. Thus, the potential for eggs or larvae of 26reproducing populations of native fish species within the Neosho River to be present in the 27water column immediately below John Redmond Dam and subject to entrainment is negligible.
28Similarly, the potential for Neosho River invertebrates to be entrained is negligible as most 29invertebrates present in the Neosho River are demersal and thus only susceptible to 30 entrainment during downstream drift and emergence.
31 32Fishery monitoring in the river subsequent to the beginning of WCGS operations revealed no 33reductions in populations or other changes that could be attributed to makeup pumping 34(EAI 1982). The normally higher precipitation and river flows in spring usually have reduced the 35need for makeup diversion and the potential for entrainment during the months of peak larval 36occurrences (WCNOC 2006d), and this would be expected to continue during the renewal 37period, at least in years with near normal precipitation.
38 39Unlike cooling water intakes, the WCGS makeup intake does not subject entrained organisms to 40thermal stresses. As a result, many of the fish would be expected to pass through the makeup 41 Environmental Impacts of Operation September 2007 4-23 Draft NUREG-1437, Supplement 32 pumps and piping and survive in Coffey County Lake. This is considered the mechanism by 1which gizzard shad, white bass (Morone chrysops), white crappie, and all rough fish species 2living in Coffey County Lake became established. These species were not initially stocked in 3Coffey County Lake by WCGS (WCNOC 2006d). Although fish transferred to Coffey County 4Lake by this mechanism are lost from the aquatic community of the Neosho River, they 5contribute to the fish populations of Coffey County Lake and may replace some of the limited 6number of larvae lost to entrainment within the Coffey County Lake intake.
7 8 4.1.2.3 Summary of Entrainment Impacts 9 10The Staff has reviewed the available information on the potential impacts of the cooling water 11intake resulting from the entrainment of fish and shellfish in early life stages and concludes that 12the impacts would be SMALL and that, therefore, no additional mitigation is warranted. The 13Staff considered mitigation measures to minimize impacts associated with entrainment. These 14measures include fine mesh screens, circulating water flow reduction, and cooling towers. The 15Staff concluded that implementation of such measures would not be beneficial enough to be 16 warranted.
17 184.1.3 Impingement of Fish and Other Aquatic Organisms 19 20For plants with cooling pond cooling systems, such as WCGS, impingement of fish and shellfish 21on traveling debris screens associated with nuclear power plant cooling water intakes is 22considered a Category 2 issue, thus requiring a site-specific assessment for license renewal 23review. To evaluate this, the Staff reviewed the WCGS ER; visited the site; consulted with 24Federal and State resource agencies; and reviewed the applicant's existing NPDES permit and 25correspondence between WCGS and KDHE, environmental studies, and information related to 26operational impingement studies conducted at WCGS. Impingement of fish and other 27organisms can occur at two locations associated with WCGS: the CWIS on Coffey County Lake 28 and the MUSH on the Neosho River.
29 30 4.1.3.1 Impingement at Coffey County Lake Cooling Water Intake 31 324.1.3.1.1 Impingement Monitoring 33 34Impingement surveys were conducted monthly at WCGS over the December 2004 through 35March 2006 period. A fine-mesh (0.25-in. bar mesh) collection basket was placed in a catch 36basin to collect all fish washed from the CWIS traveling screens over a given 24-hr period. Fish 37were removed from the basket every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and identified, measured, and examined in order 38to ascertain their condition. Each fish was classified as "live," "recently dead," or "dead" based 39on its physical condition. Fish categorized as "recently dead" were assumed to have been alive 40when impinged and to have died in the collection basket as a result of exposure and oxygen 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-24 September 2007 deprivation (WCNOC 2006e). All fish categorized as "dead" based on examination were 1considered to have been dead before they were impinged on the traveling screens. These fish 2were assumed by the applicant to represent natural mortality in Coffey County Lake. However, 3 the NRC staff does not agree with this assumption because the fish may have died as a result 4of being impinged or due to natural mortality.
5 6Because the traveling screen wash passes though a trash grating (with 1 in. by 3.75-in. [2.54 7cm by 9.53 cm ] openings) at the point at which it leaves the Circulating Water Screenhouse 8(CWSH) and flows into Coffey County Lake, the following assumptions were made by WCNOC 9in estimating monthly and annual rates of impingement mortality by extrapolating from the 10basket surveys (WCNOC 2006a):
11 12 All fish greater than 100 mm total length (TL), no matter their condition in the collection 13basket, would die under normal circumstances because they would not likely pass 14through the openings in the trash grating.
15 All fish in the collection basket less than or equal to 100 mm TL categorized as "live" or 16"recently-dead" would, under normal circumstances, return to Coffey County Lake and 17survive. However, survival studies have not been performed by WCGS to verify this 18assumption and the NRC staff does not agree with this assumption.
19 20The NRC staff also evaluated the impingement data collected from December 2004 through 21March 2006 and estimated the monthly and annual rates of impingement mortality based on 22 more conservative assumptions:
23 24 Recently dead fish less than or equal to 100 mm TL were assumed to have died as a 25result of impingement.
26 Dead fish may have died of natural causes, but they also may have died from 27impingement; therefore, in calculating monthly impingement mortality, it was assumed 28that all dead fish died from impingement.
29 As a result, all fish and shellfish were assumed to have died from impingement except 30live fish and shellfish less than or equal to 100 mm TL.
31 32Table 4-3presents the assumptions utilized by WCNOC and NRC staff in order to extrapolate 33monthly and annual impingement totals based on fish length and condition.
34 Environmental Impacts of Operation September 2007 4-25 Draft NUREG-1437, Supplement 32 Table 4-3. Assumptions Used in Estimating Impingement Totals 1 2Fish LengthConditionWCNOC Assumption NRC Assumption > 100 mm TL Dead Natural mortality Natural or Impingement mortality Recently dead Impingement mortality Impingement mortality Live Impingement mortality Impingement mortality
</= 100 mm TL Dead Natural mortality Natural or Impingement mortality Recently dead Would have survived Impingement mortality Live Would have survived Impingement mortality Adapted from: WCNOC 2006e 3Fish size and condition were used to determine if fish would have returned to the reservoir and 4survived had the collection basket not been in place. After these adjustments, data from 24-hr 5basket surveys served as the basis for estimates of monthly and annual impingement mortality 6rates, and their effect on the Coffey County Lake environment. To extrapolate monthly and 7annual impingement rates, the number of fish collected over a given 24-hr period was multiplied 8by the number of days in the month in which the data were collected. The monthly totals were 9then summed to calculate annual totals. Because no data were available from April 2005, when 10the plant was down for re-fueling, the impingement rates for March and May 2005 were 11evaluated for use as surrogates. The May data were ultimately used because they reflected a 12much higher rate of impingement and, thus, were more conservative. Similarly, March 2006 13data were used as surrogates for February 2006 when data were unable to be collected. For 14annual impingement rates, only 2005 data were used to capture all four seasons and 15corresponding lake conditions (WCNOC 2006a).
16 17 4.1.3.1.2 Assessment of Impingement Impacts 18 19Totals of 420 fish and 104 invertebrates (crayfish and Asiatic clam [Corbicula fluminea
]) were 20collected in impingement samples at WCNOC during the December 2004 to March 2006 time 21period (Table 4-4). Five fish species represented 93 percent of all impinged fish: freshwater 22drum (33 percent of fish collected), white crappie (23 percent), gizzard shad (21 percent), 23 bluegill (Lepomis macrochirus; 11 percent), and channel catfish (Ictalurus punctatus; 6 percent).
24Smaller numbers of white bass, buffalo (Ictiobus spp.), walleye (Sander vitreus
), smallmouth 25 bass (Micropterus dolomieu), and flathead catfish (Pylodictis olivaris) were also collected, but 26 Table 4-4. Total Number of Fish Collected in Impingement Samples from the CWIS on Coffey County Lake (December 2004 - March 2006) 1 2 Species (1)Date GS RCS SBF CC FC WB BG SMB WC WAE FWD AC CR sp. Total Temp o FDec-04 30 0 3 7 0 8 12 0 27 0 98 2 1 188 38.5 Jan-05 20 1 0 2 0 0 0 0 0 0 0 0 2 25 37.5 Feb-05 0 0 0 1 0 0 0 0 0 0 1 0 1 3 45.2 Mar-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 47.5 Apr-05 0 0 0 0 0 0 0 0 1 0 0 0 0 1 64.9 May-05 0 0 0 0 0 0 1 0 1 0 0 33 1 36 70.2 Jun-05 22 0 0 0 0 0 5 0 0 0 0 20 1 48 81.8 Jul-05 3 0 0 0 0 0 1 0 1 0 2 6 2 15 85.8 Aug-05 2 0 0 0 0 3 0 1 10 0 7 1 2 26 80.7 Sep-05 0 0 0 0 0 0 1 0 1 0 3 15 1 21 79.9 Oct-05 0 0 0 0 0 1 0 0 0 1 1 4 0 7 67.6 Nov-05 1 0 0 1 0 2 26 0 33 1 0 2 0 66 57.8 Dec-05 10 0 3 5 1 2 2 0 19 0 19 0 4 65 40.5 Jan-06 0 0 0 3 0 0 0 0 1 0 1 3 2 10 45.1 Feb-06 0 0 0 0 0 0 0 0 0 0 0 0 0 0 42.0 Mar-06 0 0 0 5 0 1 0 0 2 0 4 1 0 13 46.4 2005(Totals) 58 1 3 9 1 8 36 1 66 2 33 81 14 313 ALL 88 1 6 24 1 17 48 1 95 2 136 87 17 524 (1) Fish species abbreviations: Gizzard shad GS Smallmouth bass SMB River carpsucker RCS White crappie WC Smallmouth buffalo SBF Walleye WAE Channel catfish CC Freshwater drum FWD Flathead catfish FC Asiatic clam AC White bass WB Crayfish spp. CR sp. Bluegill BG Adapted from: WCNOC 2006a 3 Dr a f t N U RE G-14 3 7,Supp l e m e n t32 4-2 6 Septe m be r 2 00 7 Environmental Im pacts of O p eration Environmental Impacts of Operation September 2007 4-27 Draft NUREG-1437, Supplement 32 none of these species comprised more than 4 percent of the total. Invertebrates collected over 1the 16-month period were 87 Asiatic clams and 17 crayfish (WCNOC 2006e).
2 3Approximately 52 percent of all fish and invertebrates impinged were found dead in the 4collection basket. Gizzard shad showed the highest mortality rate at 63 percent 5(WCNOC 2006a). Gizzard shad are known to be fragile and subject to winter kills (Haines 62000) as well as summer kills (Mettee et al. 1996). Freshwater drum also showed a fairly high 7rate of mortality, 58 percent. Mortality rates for bluegill, channel catfish, and white crappie were 848 percent, 46 percent, and 31 percent, respectively.
9 10To estimate mortality due to impingement, WCNOC and NRC adjusted the data in accordance 11with the assumptions in Table 4-3 by removing the fish unlikely to die or to have died from 12impingement. This resulted in monthly impingement mortality rates ranging from 0 to 1,612 13under WCNOC assumptions (Table 4-5) and from 28 to 5,706 under NRC assumptions (Table 144-6). Under WCNOC assumptions, an annual total of 957 fish (no shellfish) was estimated to 15have died as a result of being impinged (Table 4-5). However, under NRC assumptions, annual 16totals of 6,690 fish and 2,545 shellfish were estimated to have died (Table 4-6). This 17corresponds to annual impingement mortality rates of 31 percent for finfish and 0 percent for 18shellfish using WCNOC assumptions (WCNOC 2006e) and rates of 100 percent for finfish and 1943 percent for shellfish using NRC assumptions. The WCNOC and NRC assumptions taken 20together put lower and upper bounds on impingement mortality and, therefore, provide a 21 measure of uncertainty of the impingement estimates.
22 23The highest impingement rates were observed in late spring to early summer (June) and fall to 24early winter (November and December). Water temperatures in the 30s and low 40s (o F) were 25generally associated with higher rates of impingement and impingement mortality for all fish 26species, but trends were less than clear-cut. The lowest temperature observed over the 16-27 month period (37.5 oF in January 2005) was associated with a fairly low impingement rate 28(WCNOC 2006e).
29 30WCNOC (2006e) stated that there appeared to be no correlation (based on visual evidence 31only) between cooling water withdrawal rates and impingement mortality, although no data were 32provided to confirm this. The authors stated that the highest impingement rates were often 33associated with the operation of two circulating water pumps and the lowest impingement rates 34were often associated with the operation of three circulating water pumps. The authors also 35stated that environmental factors influence impingement as much or more than operational 36factors. These environmental factors include meteorology (frontal movement, specifically air 37temperature, wind speed, wind direction), water quality (water temperature, dissolved oxygen 38levels at depth), and biology (distribution and abundance of species that are vulnerable to 39impingement, such as gizzard shad; overall health of the fish community; size and age 40composition, as smaller fish are relatively more vulnerable than larger fish, which are stronger.
41 Table 4-5. Estimated Monthly Impingement Mortality for the CWIS on Coffey County Lake - Based on WCNOC Assumptions (1)1(December 2004 - March 2006) 2 3 Species (2, 3)Date GS RCS SBF CC FC WB BG SMB WC WAE FWD AC CR sp. Total Dec-04 155 0 93 0 0 186 0 0 62 0 1116 0 0 1612 Jan-05 341 31 0 0 0 0 0 0 0 0 0 0 0 372 Feb-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Mar-05 0 0 0 0 0 0 0 0 0 0 31 0 0 31 Apr-05 (4) 0 0 0 0 0 0 0 0 31 0 0 0 0 31 May-05 0 0 0 0 0 0 0 0 31 0 0 0 0 31 Jun-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Jul-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Aug-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Sep-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Oct-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Nov-05 0 0 0 0 0 60 0 0 30 30 0 0 0 120 Dec-05 0 0 31 0 0 62 31 0 93 0 155 0 0 372 Jan-06 0 0 0 0 0 0 0 0 31 0 0 0 0 31 Feb-06 (5) 0 0 0 31 0 0 0 0 31 0 31 0 0 93 Mar-06 0 0 0 31 0 0 0 0 31 0 31 0 0 93 2005(Totals) 341 31 31 0 0 122 31 3 185 30 186 0 0 957 ALL 496 31 124 62 0 308 31 0 340 30 1364 0 0 2786 (1) Mortality was adjusted for fish considered alive and likely retu rned to the lake unharmed in accordance with the WCNOC assumptions in Table 4-3. (2) Fish species abbreviations: Gizzard shad GS White bass WB Freshwater drum FWD River carpsucker RCS Bluegill BG Asiatic clam AC Smallmouth buffalo SBF Smallmouth bass SMB Crayfish spp. CR sp. Channel catfish CC White crappie WC Flathead catfish FC Walleye WAE(3) All live and recently dead fish and shellfish in impingement samples that were 100 mm total length were considered likely to have returned to the lake alive. Recently dead fish > 100 mm total length were assumed to have died from impingement and all dead fish were assumed to have died from natural causes.
(4) Data unable to be collected due to a facility shutdown. Surrogate data from May 2005 were used.(5) Data unable to be collected. Surrogate data from March 2006 were used.
Adapted from: WCNOC 2006a CWIS = cooling water intake structureEnvironmental Impacts of Operation Dr a f t N U RE G-14 3 7,Supp l e m e n t32 4-2 8 Septe m be r 2 00 7 Table 4-6. Estimated Monthly Impingement Mortality for the CWIS on Coffey County Lake - Based on NRC Assumptions (1)1(December 2004 - March 2006) 2 3 Species (2, 3)Date GS RCS SBF CC FC WB BG SMB WC WAE FWD AC CR sp. Total Dec-04 930 0 93 186 0 248 372 0 837 0 3,038 2 0 5,706 Jan-05 620 31 0 62 0 0 0 0 0 0 0 0 31 744 Feb-05 0 0 0 0 0 0 0 0 0 0 28 0 0 28 Mar-05 0 0 0 0 0 0 0 0 0 0 31 0 0 31 Apr-05 (4) 0 0 0 0 0 0 31 0 31 0 0 713 0 775 May-05 0 0 0 0 0 0 31 0 31 0 0 713 0 775 Jun-05 660 0 0 0 0 0 150 0 0 0 0 600 30 1,440 Jul-05 93 0 0 0 0 0 31 0 31 0 62 93 31 341 Aug-05 62 0 0 0 0 93 0 31 310 0 217 0 31 744 Sep-05 0 0 0 0 0 0 30 0 30 0 90 150 0 300 Oct-05 0 0 0 0 0 31 0 0 0 31 31 124 0 217 Nov-05 30 0 0 30 0 60 780 0 990 30 0 60 0 1,980 Dec-05 310 0 93 155 31 62 62 0 589 0 589 0 62 1,953 Jan-06 0 0 0 93 0 0 0 0 31 0 31 31 31 217 Feb-06 (5) 0 0 0 93 0 31 0 0 62 0 124 31 0 341 Mar-06 0 0 0 93 0 31 0 0 62 0 124 31 0 341 2005(Totals) 1,775 31 93 247 31 246 1,115 31 2,012 61 1,048 2,453 185 9,328 ALL 2,705 31 186 712 31 556 1,487 31 3,004 61 4,365 2,548 216 15,933 (1) Mortality was adjusted for fish considered alive and likely returne d to the lake unharmed in accordance with the NRC assumptions in Table 4-3. (2) Fish species abbreviations: Gizzard shad GS White bass WB Freshwater drum FWD River carpsucker RCS Bluegill BG Asiatic clamACSmallmouth buffalo SBF Smallmouth bass SMB Crayfish spp. CR sp. Channel catfish CC White crappie WC Flathead catfish FC Walleye WAE (3) All live fish and shellfish in impingement samples that were 100 mm total length were considered likely to have returned to the lake alive. All other fish and shellfish in the samples (dead, recently dead, or alive and > 100 mm total length) were assumed to have died as a result of impingement. (4) Data unable to be collected due to a facility shutdown. Surrogate data from May 2005 were used. (5) Data unable to be collected. Surrogate data from March 2006 were used.
Adapted from: WCNOC 2006a CWIS = cooling water intake structure Environmental Impacts of Operation Septe m be r 2 007 4-2 9 Dr a f t N U RE G-14 3 7,Supp l e m e n t3 2 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-30 September 2007 swimmers). While these factors are known to have a major impact on impingement, no data 1were available to corroborate this for Coffey County Lake and WCGS.
2 3The fishery in Coffey County Lake reflects Coffey County Lake management efforts to 4biologically control impingement rates by promoting predator species. This effort was 5undertaken to prevent the economic and operational difficulties that could be caused by 6excessive impingement, particularly of gizzard shad. Predator species that are considered 7important at WCGS to control impingement include species that are also important for 8recreational fishing purposes. These species, which include channel catfish, white bass, wiper 9 hybrids (Morone saxatilis x M. chrysops
), smallmouth bass, largemouth bass (Micropterus 10salomides), white crappie, and walleye, are discussed below.
11 12Channel catfish 13 14During the 16-month monitoring period, channel catfish collected in the impingement samples 15totaled 24 (Table 4-4). Based on the WCNOC and NRC assumptions presented above, it was 16estimated that a total of 62 to 712 channel catfish would have been impinged on the CWIS 17screens during the period (Tables 4-5 and 4-6). WCNOC concluded that these fish would have 18all been returned to the lake alive and, thus, there was no impingement mortality related to the 19operation of the screens (WCNOC 2006e).
20 21 White bass 22 23During the 16-month monitoring period, white bass collected in the impingement samples 24totaled 17 (Table 4-4). Based on the WCNOC and NRC assumptions presented above, it was 25estimated that 308 to 556 white bass would have been impinged on the CWIS screens (Tables 26 4-5 and 4-6).
27 28Based on annual fish monitoring data for Coffey County Lake (expressed as the catch-per-unit-29effort [CPUE]), the white bass population in Coffey County Lake has remained relatively 30consistent (Table 2-9). Survival rates for Coffey County Lake white bass were unavailable, but 31survival in regional reservoirs ranged from 21 to 52 percent and averaged 35 percent (Colvin 321993). Growth rates in Coffey County Lake indicate that it would take approximately 3 years for 33white bass to reach 12 in. (305 mm) TL, which is the current minimum length for recreational 34harvest (WCNOC 2006e). Using an average annual survival of 35 percent, the 122 white bass 35removed from the Coffey County Lake population by impingement would correspond to 5.2 fish 36by the time they are available for recreational harvest (WCNOC 2006a). This would equate to 370.3 to 1.4 percent of the annual recreational harvest from 1999 through 2005 (WCNOC 2006e).
38 Environmental Impacts of Operation September 2007 4-31 Draft NUREG-1437, Supplement 32 Wiper hybrids, Smallmouth bass, and Largemouth bass 1 2There were no wiper hybrids or largemouth bass collected in the impingement samples, and 3only one smallmouth bass was observed (Table 4-4). The one smallmouth that was collected 4was dead (WCNOC 2006e).
5 6Population trends for these species have been variable throughout the life of Coffey County 7Lake. Both the largemouth bass and the wiper had a higher CPUE during the initial years of 8reservoir operation, whereas the smallmouth bass CPUE has varied consistently throughout the 922-year sampling program (Table 2-9). However, due to the lack of impingement for these 10species, it is unlikely that WCGS has any impact on these species.
11 12 White crappie 13 14During the 16-month monitoring period, white crappie collected in the impingement samples 15totaled 95 (Table 4-4). Based on the WCNOC and NRC assumptions presented above, it was 16estimated that 340 to 3,004 white crappie would have been impinged on the CWIS screens 17during the period (Tables 4-5 and 4-6).
18 19White crappie is an important species for WCGS because gizzard shad is one of its major 20forage items. Most of the crappies impinged during this study were slightly longer than the 100 21mm TL used for data adjustment and were young-of-year (YOY) fish (WCNOC 2006e).
22 23Annual survival rates for Coffey County Lake have not been calculated; however, annual 24survival rates ranging from 23 to 46 percent have been reported in the region (Mosher 2000, 25Muoneke et al. 1992). WCNOC states that white crappie survival is likely to be toward the 26higher range due to relatively larger, longer-lived crappie present in Coffey County Lake 27(WCNOC 2006e).
28 29Average growth rates for Coffey County Lake crappies indicate that they typically reach the 30recreational length limit of 14 in. (356 mm) TL at 4 years of age. Applying the higher 46 percent 31survival rate to the adjusted impinged fish yields reductions to 185 after year one, to 85 after 32year two, to 39 after year three, and to 18 after year four. Accordingly, impingement would 33cause 18 crappies to be unavailable for recreational harvest (WCNOC 2006e).
34 35 Walleye 36 37During the 16-month monitoring period, walleye collected in the impingement samples totaled 2 38(Table 4-4). Based on the WCNOC and NRC assumptions presented above, it was estimated 39that a total of 30 to 61 walleye would have been impinged on the CWIS screens during the 40period (Tables 4-5 and 4-6).
41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-32 September 2007 Catch curve regressions for walleye in Coffey County Lake for 2003 and 2004 indicate an 1average total survival rate of 29 percent (WCNOC 2006e). At the current slot limit (18 to 26 in.
2protected) and at growth rates present in 2003 and 2004, the 30 walleye at 388 mm TL (length 3of impinged specimen) would remain available for recreational harvest for approximately 2 4years. Applying the 29 percent survival estimate, reductions to the extrapolated 30 impinged 5walleye would be 21.3 fish the first year, and an additional 6.2 fish the second year. This means 6that of the 30 impinged walleye, if similar impingement, survival, and growth continued annually, 7estimated annual loss to the recreational fishery would be 11.2 walleye (8.7 fish remaining after 8the first year, plus 2.5 remaining after the second year) (WCNOC 2006e).
9 10Gizzard shad 11 12One of WCNOC's primary goals in managing the fishery in Coffey County Lake is to eliminate 13excessive gizzard shad wintertime impingement events (WCNOC 2006e). Shad are also an 14important species that provide forage to upper trophic level species. Reductions caused by 15natural predation or other influences, such as winter die-offs or WCGS impingement, cannot be 16greater than the population can recover from. Extremely low shad densities could cause 17subsequent reduction in important predator species (Haines 2000).
18 19During the 16-month monitoring period, gizzard shad collected in the impingement samples 20totaled 88 (Table 4-4). Based on the WCNOC and NRC assumptions presented above, it was 21estimated that 496 to 2,705 gizzard shad would have been impinged on the CWIS screens 22during the period (Tables 4-5 and 4-6). Using 2005 data as representative of annual mortality, 23the adjusted impingement mortality for the gizzard shad ranged from 341 (WCNOC 2006e) to 241,775 (NRC assumptions).
25 26An estimate of the total gizzard shad estimate from Coffey County Lake was derived based on 27mid-summer seine hauls from 1983 through 1997 (Haines 2000). Average density estimates in 28Coffey County Lake of similar sized shad over the 1983 through 1997 period were 3 million 29(Haines 2000). Mortality attributable to impingement represents 0.01 percent of this average 30YOY population estimate (WCNOC 2006e).
31 32 Other species 33 34Several other species have been observed in the impingement sampling at WCGS. These 35 include: 36 37 River carpsucker (Carpiodes carpio
)38 Smallmouth buffalo (Ictiobus bubalus
)39 Flathead catfish 40 Environmental Impacts of Operation September 2007 4-33 Draft NUREG-1437, Supplement 32 Bluegill 1 Freshwater drum 2 Crayfish species 3 Asiatic clam 4 5Other than the freshwater drum, these species were all observed in low numbers in the 6impingement samples (Table 4-4). None of these species are considered to be recreationally 7important or critical to the management of impingement by WCGS (WCNOC 2006e).
8 9 4.1.3.2 Impingement at Neosho River Makeup Water Intake 10 11 4.1.3.2.1 Impingement Monitoring 12 13An additional intake at WCGS is on the Neosho River. Water is withdrawn periodically from the 14Neosho in order to ensure adequate pool levels in Coffey County Lake. Water from the Neosho 15is withdrawn by the MUSH prior to being piped to Coffey County Lake. The MUSH is situated 16on the east side of the Neosho River downstream of John Redmond Dam. Because the 17withdrawals at the MUSH are a water transfer and are not for the purpose of power plant 18cooling, the State of Kansas has determined that this intake structure is exempt from the CWA 19 316(b) requirements (Staab 2007).
20 21As a condition of the Wolf Creek Construction Permit Number CPPR-147, the NRC required 22Kansas Gas and Electric Company (KG&E) to monitor the impingement of fish during the lake-23filling phase of construction. The NRC requirement was outlined in Section 6.1.3.2 of the Wolf 24Creek Generating Station, Unit No. 1 Final Environmental Statement, NUREG-75/096. The 1-25year impingement study on the MUSH was performed between November 1980 and October 26 1981 (KG&E 1981).
27 28Two 12-hr screen counts were conducted twice weekly between April and July and twice a 29month from August to March. The first screen count started at 0800 hrs and ended at 2000 hrs, 30while the second count started at 2000 hrs and ended at 0800 hrs. Traveling screens were 31washed starting about 30 minutes before the beginning and end of a sample period, with all 32debris and fish washed from the screen into an aluminum basket or nylon bag net. The mesh 33size of both the basket and the bag was 0.375 in. (KG&E 1981).
34 35 4.1.3.2.2 Assessment of Impingement Impacts 36 37At the MUSH, impingement was dominated by the major clupeid species present, gizzard shad 38(Table 4-7). Gizzard shad, along with white bass and freshwater drum, comprised more than 3999.9 percent of total impingement. Peak impingement for all three of these taxa occurred during 40 Table 4-7. Total Number of Fish Collected in Impingement Samples for the MUSH on the Neosho River (November 1980 - October 1981)
Species Date (1)GS CC GF RS GHS NO sp. GOS PIsp. RCS SBF CCF BCF FCF WB BG OSF LSF GSF LEsp. WC WAE FWD Monthly Total Temp°F Nov-80 117,302 0 0 0 0 0 0 0 24 12 314 0 0 60 0 0 0 0 0 24 0 2,440 120,176 40.46 Dec-80597,151 0 0 0 0 9 0 0 0 9 124 0 0 625 9 0 0 0 12 59 0 2,751 600,749 39.74 Jan-8124,514,431 0 0 0 0 0 0 0 48 0 168 0 0 1,951 0 0 0 17 0 164 0 6,990 24,523,769 39.02 Feb-8179,732,164 0 0 0 0 0 0 0 0 2,050 2,050 0 0 241,357 0 0 0 0 0 5,869 0 155,745 80,139,235 33.08 Mar-81 2,954 0 0 0 18 55 36 18 0 18 2,092 0 0 238 0 36 0 0 0 365 0 66,602 72,432 54.5 Apr-81 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 0 N/A May-81 19 0 2 0 0 0 2 2 0 6 196 2 6 0 3 61 0 6 0 2 0 265 572 67.64 Jun-81174 4 4 7 4 7 0 7 0 0 68 0 0 53 11 46 25 11 0 92 0 453 966 75.02 Jul-81273 10 3 0 3 10 0 0 27 3 37 0 13 262 13 63 60 43 0 130 3 485 1,438 80.6 Aug-81 145 0 0 0 0 21 0 0 0 0 124 0 21 21 0 0 0 0 0 166 0 104 602 74.48 Sep-81134 0 0 0 0 0 0 0 0 0 104 0 0 134 0 0 0 0 0 401 0 728 1,501 75.92 Oct-81520 46 0 0 0 0 0 0 0 0 153 0 60 46 0 0 0 0 0 45 0 2,793 3,663 60.26 (1) Fish species abbreviations: Gizzard shad GS Blue catfish BCF Common carp CC Flathead catfish FCF Goldfish GF White bass WB Red shiner RS Bluegill BG Ghost shiner GHS Orangespotted sunfish OSF Notropis sp. NO spp. Longear sunfish LSF Golden shiner GOS Green sunfish GSF Pimephales sp. PI spp. Lepomis sp. LE spp. River carpsucker RCS White crappie WC Smallmouth buffalo SBF Walleye WAE Channel catfish CCF Freshwater drum FWD No sampling completed N/A Adapted from: Koester 1982 Environmental Im p acts of O p eration Dr a f t N U RE G-14 3 7,Supp l e m e n t32 4-34 Septe m be r 2 00 7 Environmental Impacts of Operation September 2007 4-35 Draft NUREG-1437, Supplement 32 January and February and was predominately YOY fish (Koester 1982). Gizzard shad were by 1far the most dominant component of impinged fish, composing over 99 percent of the calculated 2total (KG&E 1981). Koester (1982) hypothesized that during peak impingement, shad were 3being discharged from John Redmond Reservoir in a stressed condition and were unable to 4avoid the low intake velocities present at the MUSH. No threatened, endangered, or rare 5species were impinged at the MUSH during this study (KG&E 1981).
6 7During the monitoring period, low rainfall resulted in low discharge rates from John Redmond 8Reservoir, which consistently isolated the MUSH intake channel from the Neosho River 9throughout late 1980 and early 1981. Additionally, filling of Coffey County Lake occurred during 10this time period; therefore, pumps were constantly running during this study (KG&E 1981). The 11MUSH has been used for transfer of water to Coffey County Lake every year since the plant 12went on line. Records were not available to the NRC staff to determine how often the MUSH is 13used, but the 2006 Annual Environmental Operating Report stated that makeup activities 14occurred from September 1 through December 20, 2006 and that a total of 3.665 billion gallons 15(38 percent of the contracted allotment) was transferred (Moles 2007). From 1985 until 2005, 16an average of 3.16 billion gallons of water per yr was transferred to Coffey County Lake 17(WCNOC 2007b).
18 19The MUSH is only operated to maintain water levels in Coffey County Lake. Therefore, under 20normal rainfall levels or greater, the MUSH would be utilized only sparingly and impingement of 21organisms from the Neosho river will be minimized. The impingement of larger fish should be 22minimal because the operational intake velocities of approximately 0.5 ft per second (fps) are 23low in comparison to the stream flows in habitats where most species of fish native to this 24watershed occur (WCNOC 2006e). In the MUSH vicinity, Neosho River flows can typically range 25from 0.8 to 4.9 fps (Wedd 1985). Based on this, the applicant concluded that impingement of 26adult fish would rarely occur and then only when the fish are in a physiologically weakened 27condition or dead and, thus, unable to avoid even the low current velocities near the MUSH 28intake (WCNOC 2006e). WCNOC has procedural guidelines to avoid pumping during the cold 29winter months (WCNOC 2006e). This may also help to minimize impingement rates.
30 31During times of water use conflicts when the MUSH is withdrawing water from the Neosho river 32and water levels are low, impingement impacts to fish populations may increase. The reduced 33volume and area of habitat in the Neosho River would cause the density of fish susceptible to 34impingement to be higher and could result in increased impingement rates. Reduced area and 35volume of habitat could cause fish to seek new habitat and refuges, and reduced flow would 36make their upstream migration to the MUSH area from downstream easier. Together these 37changes could increase impingement impact.
38 39Survival studies of impinged organisms on the MUSH screens have not been conducted.
40However, it is likely that, for the organisms impinged at the MUSH, survival is likely to be low 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-36 September 2007 due to the lack of a fish-return system (fish are currently washed off the screens, directed to a 1sluiceway, and then dropped at least 10 ft to the river).
2 3 4.1.3.3 Summary of Impingement Impacts 4 5The data used by NRC staff to evaluate the potential impacts of renewal of the operating license 6at WCGS represents only a small percentage of the operating period. Most of the data were 7collected over 20 years ago and may not represent current biological conditions. As a result, 8any determination of impact has a much higher level of uncertainty than would likely exist at a 9plant with a consistent long-term impingement monitoring program. Because EPA and KDHE 10consider Coffey County Lake to be a cooling impoundment the regulatory agencies have not 11required WCGS to consistently monitor impingement.
12 13The State of Kansas issued the first NPDES permit for WCGS in 1977 and has issued seven 14renewals since that time. The state has never required WCNOC to conduct a 316(b) study for 15WCGS but has made no explicit 316(b) determination for the station. The lack of an explicit 16determination is not unusual in Kansas, though, and WCNOC concludes that State issuance of 17the WCGS NPDES permit constitutes an implicit determination that the WCGS cooling water 18intake structure reflects the best technology available for minimizing adverse environmental 19impact such as entrainment of fish and shellfish (WCNOC 2006a).
20 21Similar to the CWIS, the MUSH also has a very small and old data set from which to evaluate 22the potential effects of the proposed action. KDHE and EPA both consider the pumping of 23water to Coffey County Lake from the Neosho River to be a water withdrawal and a transfer of 24water from one basin to another. Water transfers are not covered by NPDES permitting; thus, 25there are no 316(b) requirements to fulfill for the MUSH.
26 27However, NRC staff evaluated impingement studies conducted at WCGS over the December 282004 to March 2006 period. These studies suggest that impingement rates were very low in 29absolute numbers of fish and impingement mortality was relatively low. Available data also 30suggest that impingement has had little or no effect on fish populations in Coffey County Lake.
31 32 NRC staff also evaluated impingement due to makeup water diversion during the worst-case 33conditions, which was initial Coffey County Lake filling. Since that time, makeup pumping 34during WCGS operation has been less frequent and has diverted less volume (WCNOC 2006e).
35WCNOC has administrative guidelines in place to avoid makeup pumping when low flow 36conditions may be expected. However, during times of water use conflicts when the MUSH is 37withdrawing water from the Neosho River and water levels are low, impingement impacts to fish 38populations may increase. The reduced volume and area of habitat in the Neosho River would 39cause the density of fish susceptible to impingement to be higher and could result in increased 40 Environmental Impacts of Operation September 2007 4-37 Draft NUREG-1437, Supplement 32 impingement rates. Reduced area and volume of habitat could cause fish to seek new habitat 1and refuges, and reduced flow would make their upstream migration to the MUSH area from 2downstream easier. Together these changes could increase impingement impact.
3 4Therefore, based on a review of the available information relative to potential impacts of the 5cooling water intake system and the makeup water intake system on the impingement of fish 6and other aquatic organisms, the Staff concludes that impacts on aquatic organisms in both 7Coffee County Lake and the Neosho River during the renewal term would be SMALL, if no 8water use conflicts exist. However, if SMALL to MODERATE impacts occur due to water use 9conflicts (see Section 4.1.1), as fish would have less available habitat to use as a refuge and 10would likely be exposed to greater pumping frequency and volume removals from the Neosho 11River. Therefore, impingement impacts in the Neosho River could also be SMALL to 12MODERATE.
13 14The NRC staff has identified potential mitigation measures that might reduce adverse impacts 15due to impingement during the license-renewal term for continued operation of WCGS. The 16mitigation measures include a fish-return system, behavioral barriers, and barrier nets.
17However, the Staff concluded that implementing such measures would not be cost beneficial 18enough to be warranted.
19 204.1.4 Heat Shock 21 22For plants with cooling ponds or reservoirs, the effects of heat shock are listed as a Category 2 23issue and require plant-specific evaluation before license renewal. The NRC identified impacts 24on fish and shellfish resources resulting from heat shock as a Category 2 issue because of 25continuing concerns about thermal discharge effects and the possible need to modify thermal 26discharges in the future in response to changing environmental conditions (NRC 1996). To 27perform this evaluation, the Staff reviewed the WCGS ER; visited the site; consulted with 28Federal and State resource agencies; and reviewed the applicant's existing NPDES permit and 29correspondence between WCGS and KDHE, environmental studies, and information related to 30operational thermal studies conducted at WCGS.
31 32Information considered in the evaluation includes: (1) the type of cooling system and (2) 33evidence of a CWA Section 316(a) variance or equivalent State documentation. WCGS has a 34once-through heat dissipation system that is classified by NRC as a cooling pond system 35because it withdraws from and discharges to a cooling pond (Coffey County Lake). For the 36purposes of facility classification, a cooling pond was defined as "a man-made impoundment 37that does not impede the flow of a navigable system and that is used primarily to remove waste 38 heat from condenser water prior to recalculating the water back to the main condenser" (NRC 391996). Section 316(a) of the CWA establishes a process by which a discharger can 40demonstrate that the established thermal discharge limitations are more stringent than 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-38 September 2007 necessary to protect balanced, indigenous populations of fish and wildlife and obtain facility-1specific thermal discharge limits (33 USC 1326).
2 3WCGS received Permit No. I-NE07-P002 to discharge under the NPDES, which was approved 4by the Administrator of the EPA pursuant to Section 402(b) of the Federal Water Pollution 5Control Act Amendments of 1972 [PL 92-500, 33 USC 1342 (b)]. Based on the criteria set forth 6in Section 306 of PL 92-500, EPA regulations at 40 CFR 423, and information submitted by 7KG&E, the KDHE determined that the WCGS was exempt from Federal thermal standards and 8that thermal discharge studies pursuant to Section 316(a) of PL 92-500 were not required 9(Koester 1974, Gray 1974, Koester 1975). However, the WCGS was determined by the State of 10Kansas, Department of Health and Environment, to be subject to the Water Quality Criteria for 11Interstate and Intrastate Waters of Kansas (Carlson 1975). The current WCGS NPDES Permit 12(No. I-NE07-PO02) does not contain thermal effluent limitations.
13 144.1.4.1 Cooling Water Discharge to Coffey County Lake 15 16The WCGS cooling system and discharge are described in Section 2.1.3. Condenser cooling 17water is withdrawn from Coffey County Lake through the circulating water intake structure. After 18passing through the condenser, the heated water is returned to Coffey County Lake through the 19circulating water discharge structure located at the northeast corner of the facility. This 20structure has a discharge well that overflows into a 40-ft wide apron and then onto the surface 21of Coffey County Lake. The heated effluent is discharged from the circulating water discharge 22structure into an approximately 290-ac cove in Coffey County Lake. A baffle dike (Baffle Dike 23B) directs the effluent along a northwesterly path as it leaves the discharge cove to allow greater 24heat dissipation before warm water mixes with water in the main body of the lake (Figures 2-3 25and 2-4; WCNOC 2006f).
26 27Field temperature measurements in the immediate discharge area during late September and 28October 1985 were 4 to 7 degrees (°) F lower than the condenser outlet temperature, indicating 29rapid cooling as the discharge jet enters the lake. Vertical temperature distributions measured 30in the discharge cove in October 1985 exhibited substantial vertical and horizontal 31heterogeneity. The apparent rapid mixing of the discharge and the surface plume reduces the 32volume of water with maximum discharge temperatures. This mixing and the resulting 33temperature heterogeneity reduce the amount of warm water available to fish and provide a 34thermal refuge for fish that may be attracted to the discharge cove for reasons other than the 35warmer water, such as to forage or seek flowing water (EA 1985). Horizontal temperature 36profiles showed that the thermal plume remained perched on the surface throughout most of the 37discharge area. With WCGS at or near full power, the plume depth typically extended to a 38depth of 10 to 12 ft. Water temperatures below that depth often were similar to the cooler 39 Environmental Impacts of Operation September 2007 4-39 Draft NUREG-1437, Supplement 32 WCGS intake area. In effect, this artificial stratification provides a thermal refuge and a zone of 1passage for fish within the thermally influenced discharge area of Coffey County Lake 2(WCNOC 2006f).
3 4Additional data collected in 1985 and 1986 indicated that the behavior of the thermal discharge 5within the discharge cove was strongly affected by factors such as the temperature difference 6between the discharged water and ambient lake water, the number of pumps operating, wind, 7and morphology of the cove. Wind plays a large role in discharge cove temperature distribution.
8A strong south wind greatly lengthens the path of discharged water, which expands the heated 9area. Conversely, strong north, east, or northeast winds force the discharge current tightly 10against Baffle Dike B and quickly out of the cove (WCNOC 2006f). The most important 11morphological features of the discharge cove were found to be the two arms on the north side of 12the cove and the deepwater area at its center, all of which are thermally isolated from water 13movements during normal operations. In the absence of a strong south wind, the two arms 14extending to the north of the cove are thermally isolated and near ambient temperature. The 15 deep portion of the cove remains near ambient temperatures, with only the overlying water 16layers being affected by the warm water discharge during extended periods of normal plant 17operations (WCNOC 2006f).
18 19Based on data prior to and including 1992, temperature stratification patterns in Coffey County 20Lake appear to be independent of the WCGS discharge in parts of the lake away from the 21thermal plume. Stratification that would have been detrimental to the lake's fishery or 22productivity was not observed (WCNOC 1993). Any thermal plume impacts in Coffey County 23Lake are limited and localized due to the relatively small 290-ac area that the discharge cove 24occupies within the 5,090-ac Coffey County Lake (less than 6 percent of Coffey County Lake).
25Data on the vertical and horizontal distribution of temperatures within the cove also suggest the 26area of maximum thermal effects from the plant is even smaller than the area of the cove and 27varies with meteorological conditions (WCNOC 2006f).
28 29Potential thermal impacts on the Coffey County Lake fishery were intensively studied by 30WCNOC during the initial operational period. Fish thermal distribution and preference were 31determined by electrofishing in the discharge area and correlating fish numbers with water 32temperatures (WCNOC 1987a). As the ambient lake temperatures cooled to below 50°F, 33certain fish species were found to move into the thermal plume, which was about 80°F. This 34occurred typically during October through March. When ambient temperatures rose above 3550°F, fish were found to leave the plume area according to their species-specific, preferred 36temperature ranges (WCNOC 2006f).
37 38Fish mortality resulting from heat shock has not been observed in Coffey County Lake. There 39are no fish wintering areas or migration routes affected by the thermal plume, and fish avoid the 40plume when temperatures exceed their thermal tolerance limits. Substrate types in the 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-40 September 2007 discharge cove, such as silt, clay, and gravel, are common in areas not affected by the thermal 1plume and would not be unavailable to fish as a result of the plume. During colder periods, 2many fish were found to be attracted to the warmer temperatures of the plume. Thus, the 3thermal plume affects less than 6 percent of the area of Coffey County Lake and has not been 4observed to result in acute impacts to fish, such as death or disability (WCNOC 2006f)
.5 64.1.4.2 Coffey County Lake Discharge to Wolf Creek and the Neosho River 7 8The KDHE determined in 1976 that "the Water Quality Criteria of the State of Kansas will be 9enforced in the Neosho River, below the confluence of the Wolf Creek, except for an 10appropriate mixing zone. The State Water Quality Criteria will not apply to Wolf Creek, which is 11unclassified under the State Water Quality Criteria. In general, the effluent limitations to be 12stipulated in the NPDES permit will apply at the point the cooling lake discharges into Wolf 13Creek" (Carlson 1976). WCGS discharges from Coffey County Lake into the Neosho River are 14regulated by NPDES permit limitations. Because discharges from Coffey County Lake are 15sporadic, water is sampled on the first day of each discharge and weekly thereafter. In 1985, 16the first year of WCGS operation, effluent parameters measured included temperature, pH, flow 17rate, and concentrations of total dissolved solids (TDS), sulfate, and chloride(WCNOC 2006f)
.18 19Wolf Creek inputs to the Neosho River were regulated to maintain a zone of passage for aquatic 20organisms at the confluence. Consequently, the flows allowable from Wolf Creek have ranged 21from zero to unrestricted, depending on the differences in temperature and water quality 22between Wolf Creek and the Neosho River, with a maximum temperature of 90°F allowable in 23the Neosho River downstream of the mixing zone. In 1985, no NPDES violations at the Coffey 24County Lake discharge were recorded. In September 1994, a new NPDES permit set discharge 25limits from Coffey County Lake for sulfates, chlorides, and pH, but it included no flow restrictions 26based on water quality in the Neosho River.No NPDES permit violations have been observed 27at the Coffey County Lake discharge to Wolf Creek and at no time did water quality criteria 28restrict cooling lake discharge to the Neosho River (WCNOC 2006f)
.29 30A monitoring program was begun in the Neosho River in 1973 to satisfy licensing requirements 31and assess facility impacts. The monitoring was to continue through at least two years of plant 32operation, which was satisfied in 1987. No adverse impacts greater than those predicted and 33evaluated in licensing documents were identified. Subsequent to 1987, the scope and 34frequency of Neosho River monitoring has been gradually reduced. After analyses of 1995 35data, it was determined that further water quality monitoring was not necessary and it was 36discontinued. Overall, the monitoring studies in the Neosho River indicated that there had been 37no apparent deleterious effects on phytoplankton, macroinvertebrates, or fish populations in the 38river as a result of temperature or other water quality impacts from WCGS (WCNOC 2006f)
.39 Environmental Impacts of Operation September 2007 4-41 Draft NUREG-1437, Supplement 32 4.1.4.3 Summary of Heat Shock Impacts 1 2The Staff has reviewed the available information on heat shock, including the conditions of the 3NPDES permit, the operating history of WCGS, the Staff's site visit, and other public sources.
4The staff evaluated the potential impacts to aquatic resources due to heat shock during 5continued operation during the renewal period. The Staff concluded that the potential impacts 6to aquatic resources due to heat shock during the renewal term would be SMALL.
7During the course of the draft SEIS preparation, the Staff considered mitigation measures, such 8as cooling towers, for the continued operation of WCGS during the license renewal term. Based 9on the NRC staff assessment, no new mitigation measures are beneficially warranted for 10impacts related to heat shock.
11 124.1.5 Microbiological Organisms (Public Health) 13 14For power plants that use a cooling pond, lake, or canal or that discharge to a small river, the 15effects of microbiological organisms on human health are listed as a Category 2 issue and 16require plant-specific evaluation for license renewal review. This issue is applicable to WCGS 17because the facility uses a cooling pond as defined in the GEIS (NRC 1996). Also, the cooling 18pond (Coffey County Lake) discharges to Wolf Creek, which is an ungauged intermittent stream 19that empties into the Neosho River about 5.5 miles downstream. The Neosho River at 20Burlington, just upstream of its confluence with Wolf Creek, has an average annual flow of 21approximately 5.06 x 10 10 cubic ft/yr (Putnam and Schneider 2005), which meets the NRC 22definition of a small river (less than 3.15 x 10 12 cubic ft/yr) in 10 CFR 51.53 (c)(3)(ii)(G). This 23issue is also relevant to WCGS because Coffey County Lake is used by the public for fishing. It 24is not used for swimming.
25 26The Category 2 designation is based on the potential for public health impacts associated with 27 thermal enhancement of Naegleria fowleri, a pathogenic amoeba, and other enteric pathogens 28that could not be determined generically. The NRC noted that impacts of nuclear plant thermal 29discharges are considered to be of small significance if they do not enhance the presence of 30 microorganisms that are detrimental to water quality and pubic health (NRC 1996).
31 32Microbiological organisms that grow at temperatures above 45°C to 50°C (113°F to 122°F) are 33termed thermophilic, or heat-loving, organisms (Brock 1974). WCGS monitors water 34temperature in Coffey County Lake at the cooling water intake structure and in the discharge 35cove created by the baffle dike. During the summer months, water temperatures in the 36discharge cove, including areas adjacent to the discharge structure, can range from 90°F to 37110°F. Water temperature at the intake structure is in the range of 77°F to 81°F, which is likely 38similar to the temperatures found throughout the lake (WCNOC 2006a). During warmer 39months, water temperatures in the cooling pond could support survival of thermophilic 40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-42 September 2007 microorganisms; however, temperatures are generally below the range most conducive to their 1growth and reproduction.
2 3In 1987, WCNOC collected water and sediment samples from the cooling pond and 4commissioned an outside consultant to analyze the samples for the presence of Naegleria 5 fowleri. The analysis did not identify any of the pathogenic species of Naegleria; however, it did 6find an abundance of the nonpathogenic species in the discharge cove. No Naegleria were 7detected in water or sediment from the intake structure. High levels of other thermophilic 8amoebae can sometimes interfere with detecting the pathogen (WCNOC 1987b). Fishermen 9are not allowed in the discharge cove near the discharge structure and, therefore, are not 10exposed to the warmest water (WCNOC 2006a).
11 12WCNOC requested that KDHE provide information on any studies that may have been 13conducted on thermophilic microorganisms in the WCGS region and any concerns the agency 14might have relative to these organisms in Coffey County Lake. KDHE responded that there 15have not been any reports of illness from thermophilic pathogens associated with Coffey County 16 Lake and, since swimming is not allowed, that there is no likely threat from pathogens to the 17public's use of the lake. 18 19Based on its independent review of the above information, the Staff concludes that the potential 20impacts to public health from microbiological organisms, resulting from operation of the WCGS 21cooling water discharge system to the aquatic environment on or in the vicinity of the site, are 22SMALL and additional mitigation is not warranted.
23 244.2 Transmission Lines 25 26The three transmission lines built to connect WCGS with the transmission system that existed 27before the construction of WCGS are described in Section 2.1 and shown on Figure 2-5. The 28Wolf Creek - Rose Hill line and connecting sections of the Wolf Creek - Benton and Wolf Creek 29- La Cygne lines total approximately 106 miles of 345-kilovolt (kV) transmission line within 150-30ft-wide right-of-ways (ROWs). The transmission line ROWs include a total area of 31approximately 1,922 ac. These transmission lines are owned and maintained by Westar 32 Energy, Inc (Westar).
33 34Westar follows a standard vegetation management program on these and their other 35transmission line ROWs. The program is designed to allow operation of the lines at their full 36rated capacity without outages caused by an energized line contacting vegetation. Ongoing 37surveillance and maintenance of these transmission lines and ROWs ensure continued 38conformance to transmission line design standards. The transmission line ROW maintenance 39practices include both mechanical cutting and chemical/herbicide methods. Transmission line 40 Environmental Impacts of Operation September 2007 4-43 Draft NUREG-1437, Supplement 32 ROWs are first cleared of vegetation through mechanical mowing and pruning. One to two 1years after mechanical clearing, ROWs are treated with herbicides (Westar Undated).
2Herbicide management is essential because repeated mechanical cutting causes vegetation to 3grow back thicker and fuller requiring more frequent mechanical management that exposes 4workers and the environment to risks from petroleum products that fuel the cutting and mowing 5equipment (Edison Electric Institute 2007). Herbicides used by electric companies to manage 6the growth of undesirable vegetation in the transmission line ROWs are generally lower in 7toxicity to humans and animals than petroleum products released by mechanical cutting 8equipment (Edison Electric Institute 2007).
9 10Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to 11transmission lines from WCGS are listed in Table 4-8. The NRC staff has not identified any new 12and significant information during its independent review of the WCGS ER, the site audit, the 13scoping process, or evaluation of other available information that would indicate any new and 14significant information associated with the renewal of the WCGS OL. Therefore, the Staff 15concludes that there would be no impacts related to these issues beyond those discussed in the 16GEIS. For all of those issues, the Staff concluded in the GEIS that the impacts would be 17SMALL, and additional facility-specific mitigation measures are not likely to be sufficiently 18beneficial to be warranted.
19 20 Table 4-8. Category 1 Issues Applicable to the WCGS Transmission Lines 21During the Renewal Term 22 23ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1GEIS Sections TERRESTRIAL R ESOURCES Power line ROW management (cutting and herbicide application)4.5.6.1Bird collisions with power lines4.5.6.2Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, wildlife, livestock) 4.5.6.3Floodplains and wetland on power line ROW4.5.7 A IR QUALITYAir quality effects of transmission lines4.5.2 LAND U SEOn-site land use4.5.3Power line ROW4.5.3 24A brief description of the Staff's review and GEIS conclusions, as codified in Table B-1, for each 25of these issues follows:
26 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-44 September 2007 Power line ROW management (cutting and herbicide application). Based on information 1in the GEIS, the Commission found that:
2 3The impacts of ROW maintenance on wildlife are expected to be of small significance at 4all sites.
5 6The Staff has not identified any new and significant information during its independent 7review of the WCGS ER (WCNOC 2006a), the site audit, the scoping process, consultation 8with the U.S. Fish and Wildlife Service (FWS), or evaluation of other information. Therefore, 9the Staff concludes that there would be no impacts of power line ROW maintenance on 10wildlife during the renewal term beyond those discussed in the GEIS.
11 12 Bird collisions with power lines. Based on information in the GEIS, the Commission 13found that:
14 15Impacts are expected to be of small significance at all sites.
16 17The Staff has not identified any new and significant information during its independent 18review of the WCGS ER (WCNOC 2006a), the site audit, the scoping process, consultation 19with the FWS, or evaluation of other information. Therefore, the Staff concludes that there 20would be no impacts of bird collisions with power lines during the renewal term beyond 21 those discussed in the GEIS.
22 23 Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, 24 honeybees, wildlife, livestock). Based on information in the GEIS, the Commission 25 found that:
26 27No significant impacts of electromagnetic fields on terrestrial flora and fauna have been 28identified. Such effects are not expected to be a problem during the license renewal 29 term.30 31The Staff has not identified any new and significant information during its independent 32review of the WCGS ER (WCNOC 2006a), the site audit, the scoping process, or evaluation 33of other information. Therefore, the Staff concludes that there would be no impacts of 34electromagnetic fields on flora and fauna during the renewal term beyond those discussed in 35 the GEIS.
36 37 Floodplains and wetlands on power line right of way. Based on information in the GEIS, the 38Commission found that:
39 Environmental Impacts of Operation September 2007 4-45 Draft NUREG-1437, Supplement 32 Periodic vegetation control is necessary in forested wetlands underneath power lines 1and can be achieved with minimal damage to the wetland. No significant impact is 2expected at any nuclear power plant during the license renewal term.
3 4The Staff has not identified any new and significant information during its independent 5review of the WCGS ER (WCNOC 2006a), the site audit, the scoping process, consultation 6with the FWS and KDWP, or evaluation of other information. Therefore, the Staff concludes 7that there would be no impacts of power line ROW maintenance on floodplains and 8wetlands during the renewal term beyond those discussed in the GEIS.
9 10 Air quality effects of transmission lines. Based on the information in the GEIS, the 11Commission found that:
12 13Production of ozone and oxides of nitrogen is insignificant and does not contribute 14measurably to ambient levels of these gases.
15 16The Staff has not identified any new and significant information during its independent 17review of the WCGS ER (WCNOC 2006a), the site audit, the scoping process, or evaluation 18of other information. Therefore, the Staff concludes that there would be no air quality 19impacts of transmission lines during the renewal term beyond those discussed in the GEIS.
20 21 On-site land use. Based on the information in the GEIS, the Commission found that:
22 23Projected on-site land use changes required during the renewal period would be a small 24fraction of any nuclear power plant site and would involve land that is controlled by the 25 applicant.
26 27The Staff has not identified any new and significant information during its independent 28review of the WCGS ER (WCNOC 2006a), the site audit, the scoping process, or evaluation 29of other information. Therefore, the Staff concludes that there would be no on-site land use 30impacts during the renewal term beyond those discussed in the GEIS.
31 32 Power line right of way. Based on information in the GEIS, the Commission found that:
33 34Ongoing use of power line ROWs would continue with no change in restrictions. The 35effects of these restrictions are of small significance.
36 37The Staff has not identified any new and significant information during its independent 38review of the WCGS ER (WCNOC 2006a), the site audit, the scoping process, or evaluation 39of other information. Therefore, the Staff concludes that there would be no impacts of power 40line ROWs on land use during the renewal term beyond those discussed in the GEIS.
41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-46 September 2007 Two Category 2 issues exist for the transmission lines. The issue of chronic effects was not 1categorized the GEIS, but is being treated as a Category 2 issue in this draft SEIS. The 2Category 2 issues are listed in Table 4-9 and are discussed in Sections 4.2.1 and 4.2.2.
3 4 Table 4-9.
Category 2 and Uncategorized Issues Applicable to the WCGS 5Transmission Lines During the Renewal Term 6 7ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section HUMAN HEALTHElectromagnetic fields, acute effects (electric shock)4.5.4.1H4.2.1Electromagnetic fields, chronic effects4.5.4.2NA4.2.2 84.2.1 Electromagnetic Fields-Acute Effects 9 10Based on the GEIS, the Commission found that electric shock resulting from direct access to 11energized conductors or from induced charges in metallic structures has not been found to be a 12problem at most operating plants and generally is not expected to be a problem during the 13license renewal term. However, site-specific review is required to determine the significance of 14the electric shock potential along the portions of the transmission lines that are within the scope 15 of this SEIS.
16 17In the GEIS (NRC 1996), the Staff found that without a review of the conformance of each 18nuclear plant transmission line with National Electrical Safety Code (NESC; NESC 1997) 19criteria, it was not possible to determine the significance of the electric shock potential.
20Evaluation of individual plant transmission lines is necessary because the issue of electric shock 21safety was not addressed in the licensing process for some plants. For other plants, land use in 22the vicinity of transmission lines may have changed, or power distribution companies may have 23chosen to upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must 24provide an assessment of the potential shock hazard if the transmission lines that were 25constructed for the specific purpose of connecting the plant to the transmission system do not 26meet the recommendations of the NESC for preventing electric shock from induced currents.
27 28An analysis of the WCGS transmission lines' conformance with the NESC standard was 29conducted using computer modeled data of induced current under the transmission lines.
30Objects located near the transmission lines can become electrically charged due to their 31immersion in the lines' electromagnetic field. This electrical charge results in a current that 32flows through the object to the ground. This current is called "induced" because there is no 33 Environmental Impacts of Operation September 2007 4-47 Draft NUREG-1437, Supplement 32 direct connection between the line and the object. The induced current can also flow to the 1ground through the body of a person who touches the electrically charged object. An object that 2is insulated from the ground can actually store an electrical charge, becoming what is called 3"capacitively charged." A person standing on the ground and touching a vehicle or a fence 4receives an electrical shock due to the sudden discharge of the capacitive charge through the 5person's body to the ground. After the initial discharge, a steady-state current can develop, with 6the magnitude of the current depending upon several factors. These factors include the 7strength of the electric field (dependent on the voltage of the transmission line and its height and 8geometry), the size of the object on the ground, and the extent to which the object is grounded 9(WCNOC 2006a).
10 11Electric lines having voltages exceeding 98-kV alternating current to ground must comply with 12the NESC provision to have a clearance that limits the induced current due to electrostatic 13effects to 5 millamperes (mA) if the largest truck, vehicle, or equipment were short-circuited to 14ground. The three lines constructed to distribute power from WCGS were analyzed by 15evaluating the lines' configuration to determine where the potential for current-induced shock is 16the greatest. The electric field strength was calculated for each transmission line, then the 17induced currents were calculated (WCNOC 2006a). The analysis determined that the Wolf 18Creek - Rose Hill line had the capacity to induce 4.3 mA and the LaCygne-Benton lines had the 19capacity to induce 1.5 mA for a vehicle the size of a tractor trailer parked beneath the lines.
20Therefore, the lines conform to the NESC guidelines by not producing induced currents over 5 21mA and preventing electric shock. Details of the analysis can be found in the "Calculation 22Package for Wolf Creek Transmission Lines Induced Current Analysis" (TTNUS 2005 in 23WCNOC 2006a). Westar also regularly conducts surveillance and maintenance activities to 24ensure that the ground clearances for the transmission lines do not change, which could 25increase the potential risks of electric shock.
26 27The Staff has reviewed the available information, including the applicant's evaluation and 28computational results, the site visit, the scoping process, and other public sources of 29information. Based on this information, the Staff evaluated the potential impacts of electric 30shock resulting from operation of WCGS and its associated transmission lines. It is the Staff's 31conclusion that the potential impacts of electric shock during the renewal term would be SMALL 32and no additional mitigation is warranted.
33 344.2.2 Electromagnetic Fields-Chronic Effects 35 36In the GEIS, the chronic effects of 60 hertz electromagnetic fields from power lines were not 37designated as Category 1 or 2, and a designation will not be made until a scientific consensus is 38reached on the health implications of these fields. The potential for chronic effects from these 39fields continues to be studied and is not known at this time. The National Institute of 40Environmental Health Sciences (NIEHS) directs related research through the U.S. Department 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-48 September 2007 of Energy (DOE). The 1999 report of the NIEHS and DOE Working Group (Portier and Wolfe 11999) contains the following conclusion:
2 3The NIEHS concludes that extremely low frequency-electromagnetic field exposure (ELF-4EMF) cannot be recognized as entirely safe because of weak scientific evidence that 5exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to warrant 6aggressive regulatory concern. However, because virtually everyone in the United States 7uses electricity and therefore is routinely exposed to ELF-EMF, passive regulatory action is 8warranted, such as a continued emphasis on educating both the public and the regulated 9community on means aimed at reducing exposures. The NIEHS does not believe that other 10cancers or non-cancer health outcomes provide sufficient evidence of a risk to currently 11 warrant concern.
12 13This statement is not sufficient to cause the Staff to change its position with respect to the 14chronic effects of electromagnetic fields. The Staff considers the GEIS finding of "not 15applicable" still appropriate and continues to follow developments on this issue.
16 174.3 Radiological Impacts of Normal Operations 18 19Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to 20WCGS in regard to radiological impacts are listed in Table 4-10. WCNOC stated in its ER that it 21is not aware of any new and significant information associated with the renewal of the WCGS 22OL. The NRC staff has not identified any new and significant information during its independent 23review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 24 information. Therefore, the NRC staff concludes that there would be no impacts related to these 25issues beyond those discussed in the GEIS.For these issues, the NRC staff concluded in the 26GEIS that the impacts are SMALL and additional plant-specific mitigation measures are not 27likely to be sufficiently beneficial to be warranted.
28 29 Table 4-10. Category 1 Issues Applicable to Radiological Impacts of Normal Operations During the 30Renewal Term 31 32ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1GEIS Sections HUMAN HEALTHRadiation exposures to public (license renewal term)4.6.2Occupational radiation exposures (license renewal term)4.6.3 33A brief description of the Staff's review and the GEIS conclusions, as codified in Table B-1, for 34 each of these issues follows:
35 Environmental Impacts of Operation September 2007 4-49 Draft NUREG-1437, Supplement 32 Radiation exposures to public (license renewal term). Based on information in the GEIS, 1the Commission found that:
2 3Radiation doses to the public will continue at current levels associated with 4 normal operations.
5 6The NRC staff has not identified any new and significant information during its independent 7review of the WCNOC ER, the site audit, the scoping process, or evaluation of other available 8information. Therefore, the NRC staff concludes that there would be no impacts of radiation 9exposures to the public during the renewal term beyond those discussed in the GEIS.
10 11Occupational radiation exposures (license renewal term). Based on information in the 12 GEIS, the Commission found that:
13Projected maximum occupational doses during the license renewal term are 14within the range of doses experienced during normal operations and normal 15maintenance outages, and would be well below regulatory limits.
16 17The NRC staff has not identified any new and significant information during its independent 18review of the WCGS ER, the site audit, the scoping process, or evaluation of other available 19 information. Therefore, the NRC staff concludes that there would be no impacts of occupational 20radiation exposures during the renewal term beyond those discussed in the GEIS.
21 22There are no Category 2 issues related to radiological impacts of routine operations.
23 244.4 Socioeconomic Impacts of Plant Operations During the 25 License Renewal Term 26 27Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, which are applicable 28to socioeconomic impacts during the renewal term are listed in Table 4-11. As stated in the 29GEIS, the impacts associated with these Category 1 issues were determined to be SMALL, and 30plant-specific mitigation measures would not be sufficiently beneficial to be warranted.
31The NRC staff reviewed and evaluated the WCGS ER, scoping comments, other available 32information, and visited the WCGS site in search of new and significant information that would 33change the conclusions presented in the GEIS. No new and significant information was 34identified during this review. Therefore, it is expected that there would be no impacts related to 35these Category 1 issues during the renewal term beyond those discussed in the GEIS.
36 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-50 September 2007 Table 4-11. Category 1 Issues Applicable to Socioeconomics During the Renewal Term 1 2ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section SOCIOECONOMICSPublic services: public safety, social services, and tourism and recreation 4.7.3; 4.7.3.3; 4.7.3.4; 4.7.3.6 Public services: education (license renewal term) 4.7.3.1 Aesthetic impacts (license renewal term) 4.7.6 Aesthetic impacts of transmission lines (license renewal term) 4.5.8 3The results of the review and brief statement of GEIS conclusions, as codified in Table B-1 of 410 CFR Part 51, Subpart A, Appendix B, for each of the socioeconomic Category 1 issues are 5 provided below.
6 7 Public services: public safety, social services, and tourism and recreation.
Based on 8information in the GEIS, the Commission found that:
9 10Impacts to public safety, social services, and tourism and recreation are 11expected to be of small significance at all sites.
12 13No new and significant information was identified during the review. Therefore, it is 14expected that there would be no impacts on publicsafety, social services, and tourism and 15recreation during the renewal term beyond those discussed in the GEIS.
16 17 Public services: education (license renewal term).
Based on information in the GEIS, the 18Commission found that:
19 20Only impacts of small significance are expected.
21 22No new and significant information was identified during the review. Therefore, it is 23expected that there would be no impacts on education during the renewal term beyond 24 those discussed in the GEIS.
25 26 Aesthetic impacts (license renewal term).
Based on information in the GEIS, the 27Commission found that:
28 29No significant impacts are expected during the license renewal term.
30 Environmental Impacts of Operation September 2007 4-51 Draft NUREG-1437, Supplement 32 No new and significant information was identified during the review. Therefore, it is 1expected that there would be no aesthetic impacts during the renewal term beyond those 2discussed in the GEIS.
3 4 Aesthetic impacts of transmission lines (license renewal term). Based on information in the 5 GEIS, the Commission found that:
6 7No significant impacts are expected during the license renewal term.
8 9No new and significant information was identified during the review. Therefore, it is 10expected that there would be no aesthetic impacts of transmission lines during the renewal 11term beyond those discussed in the GEIS.
12 13Table 4-12 lists the Category 2 socioeconomic issues, which require plant-specific analysis, 14and an additional issue, environmental justice, which was not addressed in the GEIS.
15 16Table 4-12. Category 2 Issues Applicable to Socioeconomics 17and Environmental Justice During the Renewal Term 18 19ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section SOCIOECONOMICSHousing impacts 4.7.1 I 4.4.1 Public services: public utilities 4.7.3.5 I 4.4.2 Off-site land use (license renewal term) 4.7.4 I 4.4.3 Public services: transportation 4.7.3.2 J 4.4.4 Historic and archaeological resources 4.7.7 K 4.4.5
Environmental justice Not addressed (a)Not addressed (a)4.4.6(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to 10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in plant-specific reviews.
204.4.1 Housing Impacts 21 22Appendix C of the GEIS presents a population characterization method based on two factors, 23sparseness and proximity (GEIS, Section C.1.4). Sparseness measures population density 24within 20 miles of the site, and proximity measures population density and city size within 50 25 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-52 September 2007 miles. Each factor has categories of density and size (GEIS, Table C.1). A matrix is used to 1rank the population category as low, medium, or high (GEIS, Figure C.1).
2 3According to the 2000 Census, approximately 13,095 people lived within 20 miles of WCGS, 4which equates to a population density of 10 persons per square mile (sq mi) (WCNOC 2006a).
5This density translates to the least sparse Category 1 (less than 40 persons per sq mi and no 6community with 25,000 or more persons within 20 miles). Approximately 176,301 people live 7within 50 miles of WCGS (WCNOC 2006a). This equates to a population density of 23 persons 8per sq mi. Applying the GEIS proximity measures, WCGS is classified as proximity Category 1 9(no city with 100,000 or more persons and less than 50 persons per sq mi within 50 miles).
10Therefore, according to the sparseness and proximity matrix presented in the GEIS, the WCGS 11ranks of sparseness Category 1 and proximity Category 1 result in the conclusion that WCGS is 12located in a low population area.
13 14Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 15are expected to be of small significance in medium or high-density population areas where 16growth-control measures are not in effect. Since WCGS is located in a low population area and 17Coffey and Lyon Counties are not subject to growth-control measures that would limit housing 18development, any WCGS employment-related impact on housing availability would likely be 19small. Since WCNOC has indicated that there would be no major plant refurbishment and no 20non-outage employees would be added to support WCGS operations during the license renewal 21term, employment levels at WCGS would remain relatively constant with no additional demand 22for housing during the license renewal term. In addition, the number of available housing units 23has kept pace with or exceeded the low growth in the area population. Based on this 24information, there would be no impacts on housing during the license renewal term, and no 25mitigation measures would be required.
26 274.4.2 Public Services: Public Utility Impacts 28 29Impacts on public utility services are considered SMALL if there is little or no change in the 30ability of the system to respond to demand and thus there is no need to add capital facilities.
31Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak 32demand. Impacts are considered LARGE if services (e.g., water, sewer) are substantially 33degraded and additional capacity is needed to meet ongoing demand. The GEIS indicated that, 34in the absence of new and significant information to the contrary, the only impacts on public 35utilities that could be significant are impacts on public water supplies.
36 37Analysis of impacts on the public water systems considered both facility demand and facility-38related population growth. As previously discussed in Section 2.2.2, WCGS purchases water 39from Rural Water District 3, which purchases water from the City of Burlington and Public 40 Environmental Impacts of Operation September 2007 4-53 Draft NUREG-1437, Supplement 32 Wholesale District 12. WCGS uses less than one percent of the total combined capacity of the 1City of Burlington and Public Wholesale District 12. Water usage by WCGS has not stressed 2system capacities and is not currently an issue. WCNOC also has no plans to increase WCGS 3staffing due to refurbishment or new construction activities, and has identified no operational 4changes during the license renewal term that would increase facility water use.
5 6WCGS operations during the license renewal term would not increase facility-related population 7demand for public water services. Given that WCNOC has indicated that there would be no 8major plant refurbishment, overall employment levels at WCGS would remain relatively constant 9during this period with no additional demand for public services. In addition, public water 10systems in the region would be adequate to provide the capacity required to meet the demand 11of residential and industrial customers in the area. Based on a review of available public water 12supply use and capacity information in the region, there would be no impact to public water and 13sewer services during the license renewal term, and no mitigation measures would be required.
14 154.4.3Off-site Land Use During Operations 16 17Off-site land use during the license renewal term is a Category 2 issue. Table B-1 of 10 CFR 51 18Subpart A, Appendix B notes that "significant changes in land use may be associated with 19population and tax revenue changes resulting from license renewal." 20 21Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant 22operation during the license renewal term as follows:
23 24SMALL - Little new development and minimal changes to an area's land-use pattern.
25 26MODERATE - Considerable new development and some changes to the land-use pattern.
27 28LARGE - Large-scale new development and major changes in the land-use pattern.
29 30Tax revenue can affect land use because it enables local jurisdictions to provide the public 31services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 32the GEIS states that the assessment of tax-driven land-use impacts during the license renewal 33term should consider (1) the size of the plant's payments relative to the community's total 34revenues, (2) the nature of the community's existing land-use pattern, and (3) the extent to 35which the community already has public services in place to support and guide development. If 36the plant's tax payments are projected to be small relative to the community's total revenue, tax-37driven land-use changes during the plant's license renewal term would be SMALL, especially 38where the community has pre-established patterns of development and has provided adequate 39public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax 40payments by the plant owner are less than 10 percent of the taxing jurisdiction's revenue, the 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-54 September 2007 significance level would be SMALL. If the plant's tax payments are projected to be medium to 1large relative to the community's total revenue, new tax-driven land-use changes would be 2MODERATE. If the plant's tax payments are projected to be a dominant source of the 3community's total revenue, new tax-driven land-use changes would be LARGE. This would be 4especially true where the community has no pre-established pattern of development or has not 5provided adequate public services to support and guide development.
6 7Population-Related Impacts 8
9Since WCNOC has no plans to add non-outage employees during the license renewal period; 10there would be no noticeable change in land use conditions in the vicinity of the WCGS site.
11Therefore, there would be no land use impacts during the license renewal term and no 12mitigation measures would be required.
13 14Tax-Revenue-Related Impacts 15 16As previously discussed in Section 2.2.8.6, WCNOC pays annual real estate taxes to Coffey 17County. From 2000 through 2006, WCNOC paid between $23.9 and $26.3 million annually in 18property taxes to Coffey County. This represented between 79 an 85 percent of the county's 19total annual tax revenue. Each year, Coffey County retains a portion of this tax money for 20county operations and disburses the remainder to school districts, fire districts, and the county's 21municipalities to fund their respective operating budgets. The local public school system, 22Unified School District Number 244, receives 38 to 46 percent of the property tax payment.
23 24At present, the State of Kansas has taken no action on deregulation, which could, if enacted, 25affect tax payments to Coffey County. However, any changes to WCGS property tax rates due 26to deregulation would be independent of license renewal. Discontinuing the current level of tax 27revenues would have a significant negative economic impact on the county.
28 29WCNOC has indicated that there would be no major plant refurbishment or license renewal-30related construction activities necessary to support the continued operation of WCGS during the 31license renewal period. Accordingly, there would be no increase in the assessed value of 32WCGS and annual property taxes to Coffey County would remain relatively constant throughout 33the license renewal period. Based on this information, there would be no tax revenue-related 34land-use impacts during the license-renewal term and no mitigation measures would be 35 required.36 Environmental Impacts of Operation September 2007 4-55 Draft NUREG-1437, Supplement 32 4.4.4Public Services: Transportation Impacts During Operations 1 2Table B-1, 10 CFR Part 51 states: "Transportation impacts (level of service) of highway traffic 3generated... during the term of the renewed license are generally expected to be of small 4significance. However, the increase in traffic associated with additional workers and the local 5road and traffic control conditions may lead to impacts of moderate or large significance at some 6sites." All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway 7traffic generated by the proposed project on the level of service of local highways during the 8term of the renewed license.
9 10Given that WCNOC has no plans to add non-outage employees during the license renewal 11period, there would be no noticeable change in traffic volume and levels of service on roadways 12in the vicinity of the WCGS site. Therefore, there would be no transportation impacts during the 13license renewal term and no mitigation measures would be required.
14 154.4.5 Historic and Archaeological Resources 16 17The National Historic Preservation Act (NHPA) requires that Federal agencies take in to account 18the effects of their undertakings on historic properties. The historic preservation review process 19mandated by Section 106 of the NHPA is outlined in regulations issued by the Advisory Council 20on Historic Preservation at 36 CFR Part 800. Renewal of an operating license is an undertaking 21that could potentially affect historic properties. Therefore, according to the NHPA, the NRC is to 22make a reasonable effort to identify historic properties in areas of potential effects. If no historic 23 properties are present or affected, the NRC is required to notify the State Historic Preservation 24 Officer before proceeding. If it is determined that historic properties are present the NRC is 25required to assess and resolve possible adverse effects of the undertaking.
26 274.4.5.1 Site Specific Cultural Resources Information 28 29A review of the Kansas State Historical (KSHS) files shows that there are no National Register 30eligible or listed archaeological or above ground historic resources identified on the WCGS 31property. As noted in Section 2.2.9.2 two surveys of Wolf Creek and the WCGS plant area 32conducted in 1973 and 1974 resulted in the identification of 25 prehistoric archaeological sites, 33all of which were eventually determined to be ineligible for listing on the National Register 34(NRC 1982). This testing also concluded that there is no evidence of prehistoric occupation in 35the area around the station (NRC 1982).
36 37There is potential for archaeological resources to be present on other portions of the WCGS site 38that have not been surveyed (i.e., the environmental education area, along the transmission line 39ROW, and along the shores of Coffey County Lake). As noted in Section 2.2.9.2, while five 40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-56 September 2007 National Register listed resources have been identified in Coffey County, none are located 1within the boundaries of the WCGS.
2 3 4.4.5.2 Conclusions 4 5No new facilities, service roads, or transmission lines are proposed for the WCGS as a part of 6this operating license renewal, nor are refurbishment activities proposed. Therefore, the 7potential impacts to National Register eligible historic or archaeological resources would be 8SMALL during the license renewal term and no mitigation measures would be required.
9 104.4.6 Environmental Justice 11 12Executive Order (EO) 12898 (59 FR 7629) directs Federal agencies to identify and address, as 13appropriate, potential disproportionately high and adverse human health and environmental 14impacts on minority and low-income populations. Although the Executive Order is not 15mandatory for independent agencies such as the NRC, the NRC has voluntarily committed to 16undertake environmental justice reviews. In 2004, the Commission issued a Policy Statement 17on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions 18(69 FR 52040) which states "The Commission is committed to the general goals set forth in EO.
1912898, and strives to meet those goals as part of its NEPA review process."
20 21The Council of Environmental Quality (CEQ) provides the following information in Environmental 22Justice: Guidance Under the National Environmental Policy Act (CEQ 1997a):
23 24Disproportionately High and Adverse Human Health Effects
.Adverse health effects are 25measured in risks and rates that could result in latent cancer fatalities, as well as other 26fatal or nonfatal adverse impacts on human health. Adverse health effects may include 27bodily impairment, infirmity, illness, or death. Disproportionately high and adverse 28human health effects occur when the risk or rate of exposure to an environmental hazard 29 for a minority or low-income population is significant (as defined by the National 30Environmental Policy Act [NEPA]) and appreciably exceeds the risk or exposure rate for 31the general population or for another appropriate comparison group (CEQ 1997a).
32 33 Disproportionately High and Adverse Environmental Effects.
A disproportionately high 34environmental impact that is significant (as defined by NEPA) refers to an impact or risk 35of an impact on the natural or physical environment in a low-income or minority 36community that appreciably exceeds the environmental impact on the larger community.
37Such effects may include ecological, cultural, human health, economic, or social 38impacts. An adverse environmental impact is an impact that is determined to be both 39harmful and significant (as defined by NEPA). In assessing cultural and aesthetic 40 Environmental Impacts of Operation September 2007 4-57 Draft NUREG-1437, Supplement 32 environmental impacts, impacts that uniquely affect geographically dislocated or 1dispersed minority or low-income populations or American Indian tribes are considered 2(CEQ 1997a).
3 4The environmental justice analysis assesses the potential for disproportionately high and 5 adverse human health or environmental effects on minority and low-income populations that 6could result from the operation of WCGS during the renewal term. In assessing the impacts, the 7following CEQ (1997a) definitions of minority individuals and populations and low-income 8population were used:
9 10 Minority individuals.Individuals who identify themselves as members of the following 11population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or 12African American, Native Hawaiian or Other Pacific Islander, or two or more races, 13meaning individuals who identified themselves on a Census form as being a member of 14two or more races, for example, Hispanic and Asian.
15 16Minority populations.
Minority populations are identified when (1) the minority population 17of an affected area exceeds 50 percent or (2) the minority population percentage of the 18affected area is meaningfully greater than the minority population percentage in the 19general population or other appropriate unit of geographic analysis.
20 21 Low-income population.Low-income populations in an affected area are identified with 22the annual statistical poverty thresholds from the Census Bureau's Current Population 23 Reports, Series P-60, on Income and Poverty.
24 25 4.4.6.1 Minority Population in 2000 26 27Those census block groups (196) wholly or partly within the 50-mile (mi) radius of WCGS were 28reported in the 2000 census as having a minority population of 17,024 or 8.3 percent of the total 29population in these block groups. The largest minority group was that of Hispanic or Latino 30ethnicity (9,081 or 4.4 percent), and the largest single racial group was Black or African 31American (2,500 or 1.2 percent). However, "Other" minority racial groups and "Two or More" 32races together accounted for 8,155 or 4 percent (2.2 percent as "Other" racial groups and 1.8 33percent "Two or More" racial groups). In Coffey County, 3.7 percent of the population are 34reported as minority, with Hispanic or Latino the largest minority group (1.5 percent) followed by 35individuals identifying themselves as belonging to two or more races (1.4 percent).
36 37Census block groups with minority populations exceeding the 8.3 percent were considered 38minority block groups. Based on 2000 census data, Figure 4-1shows 52 minority block groups 39within a 50-mi radius of WCGS that exceed this threshold.
40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-58 September 2007 Figure 4-1.Minority block groups in 2000 within a 50-mi radius of WCGS Environmental Impacts of Operation September 2007 4-59 Draft NUREG-1437, Supplement 32 4.4.6.2 Low-Income Populations 2000 1 2According to 2000 census data, 20,150 individuals (10.0 percent) residing within a 50-mi radius 3of WCGS were identified as living below the Federal poverty threshold. (The 1999 Federal 4poverty threshold was $17,029 for a family of four.) The USCB reported median household 5income for Kansas in 1999 was $40,624, while 9.9 percent of the state population was 6determined to live below the 1999 Federal poverty threshold.
7 8Coffey County had a lower median household income ($37,839) and a lower percentage (6.6 9percent) of individuals living below the poverty level than the state. Woodson County had the 10lowest median household incomes ($25,335) while Douglas County had the highest percentage 11(15.9 percent) of individuals below the poverty within the 50-mi radius of WCGS
.12 13Census block groups were considered low-income block groups if the percentage of the 14population living below the Federal poverty threshold exceeded 10.0 percent. Based on 2000 15Census data, there were 90 block groups that exceeded this threshold. Figure 4-2shows low-16income block groups within a 50-mi radius of WCGS.
17 184.4.6.3 Analysis of Impacts 19 20Consistent with the impact analysis for the public and occupational health and safety, the 21affected populations are defined as minority and low-income populations who reside within a 2250-mi radius of WCGS. Based on the analysis of impacts for all resource areas presented in 23this DSEIS, there would be no high and adverse impacts from the operation of WCGS during 24the license renewal period.
25 26 NRC also analyzed the risk of radiological exposure through the consumption patterns of 27special pathway receptors, including subsistence consumption of fish, native vegetation, surface 28waters, sediments, and local produce; absorption of contaminants in sediments through the 29skin; and inhalation of plant materials. The special pathway receptors analysis is important to 30the environmental justice analysis because consumption patterns may reflect the traditional or 31cultural practices of minority and low-income populations in the area.
32 33 4.4.6.4 Subsistence Consumption of Fish and Wildlife 34 35Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 36appropriate, to collect and analyze information on the consumption patterns of populations who 37rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 38consumption patterns to the public. In this draft SEIS, NRC considered whether there were any 39means for minority or low-income populations to be disproportionately affected by examining 40impacts to American Indian, Hispanic, and other traditional lifestyle special pathway receptors.
41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-60 September 2007 2 4 6 8 10 12 14 16 18 Figure 4-2.Low-income block groups with a 50-mi radius of WCGS 19 Environmental Impacts of Operation September 2007 4-61 Draft NUREG-1437, Supplement 32 Special pathways that took into account the levels of contaminants in native vegetation, crops, 1soils and sediments, surface water, fish, and game animals on or near the WCGS site were 2considered.
3 4WCNOC has a comprehensive Radiological Environmental Monitoring Program (REMP) at WCGS 5to assess the impact of site operations on the environment. Samples are collected from the aquatic 6and terrestrial pathways applicable to the site. The aquatic pathways include fish, surface waters 7and sediment. The terrestrial pathways include airborne particulates and radioiodine, milk, food 8 products and direct radiation. During 2005, analyses were performed on collected samples of 9environmental media as part of the required REMP and showed no significant or measurable 10radiological impact from WCGS operations. Cesium-137 activity was detected in the samples 11obtained from the control location at John Redmond Reservoir and was attributed to fallout from 12past weapons testing. Activity due to plant operation was not evident in any shoreline sediment 13samples taken during 2005 and no unusual trends were noted. Tritium, att ributable to WCGS 14operation, was detected in all surface water samples collected from Coffey County Lake during 152005. Tritium was the only isotope detected in surface water samples. All fish samples taken from 16Coffey County Lake had tritium activity detected (7,700 picoCurie per kilogram [pCi/kg] annual 17mean) and were attributable to plant operation. An adult consuming 21 kg of fish, at the maximum 18measured tritium concentration for 2005 (9,480 pCi/kg), would receive a committed effective dose 19 equivalent of 0.013 millirem (mrem), which is well below NRC dose limits. No other radionuclides 20were detected in fish during the year (WCNOC 2006g).
21 22The results of the 2005 REMP demonstrate that the routine operation at the WCGS site had no 23significant or measurable radiological impact on the environment. No elevated radiation levels 24were detected in the offsite environment as a result of plant operations and the storage of 25radioactive waste. The results of the REMP continue to demonstrate that the operation of the 26plant has not resulted in a significant measurable dose to a member of the general population or 27adversely impacted the environment as a result of radiological effluents (WCNOC 2006g).
28REMP continues to demonstrate that the dose to a member of the public from the operation of 29WCGS remains significantly below the federally required dose limits specified in 10 CFR Part 20, 3040 CFR Part 190, and 10 CFR Part 72.
31 32KDHE also conducts its own Environmental Radiation Surveillance (ERS) program of WCGS, 33which parallels (and partially overlaps) the WCNOC REMP. The purpose of the ERS program, 34instituted in 1985, is to detect, identify, and measure radioactive material released to the 35environment from the operation of WCGS (KDHE 2006b).
36 37Similar to REMP, air, surface and ground water, milk, sediment and soil, fish, game animals, 38domestic meat, and terrestrial and aquatic vegetation samples are collected by KDHE from the 39environs surrounding WCGS. Analyses are performed by the Kansas Health and Environment 40Laboratories Radiochemistry Laboratory at Forbes Field on all collected samples. Game animal 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-62 September 2007 sampling is usually limited to the collection of edible meat portions from deer killed on the road.
1Sample portions of deer killed on the road are usually collected as available by WCNOC and 2split with KDHE for laboratory analysis (KDHE 2006b).
3 4Based on recent monitoring results, concentrations of contaminants in native vegetation, crops, 5soils and sediments, surface water, fish, and game animals in areas surrounding WCGS have 6been quite low (at or near the threshold of detection) and seldom above background levels 7(WCNOC 2006g and KDHE 2006b). Consequently, no disproportionately high and adverse 8human health impacts would be expected in special pathway receptor populations in the region 9as a result of subsistence consumption of fish and wildlife and no mitigation would be required.
10 114.5 Groundwater Use and Quality 12 13Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 14WCGS groundwater use and quality are listed in Table 4-13. WCNOC stated in its ER that it is 15not aware of any new and significant information associated with the renewal of the WCGS OL 16(WCNOC 2006a). The Staff has not identified any new and significant information during its 17independent review of the WCGS ER, the Staff's site visit, the scoping process, or evaluation of 18other available information. Therefore, the Staff concludes that there are no impacts related to 19these issues beyond those discussed in the GEIS. For these issues, the GEIS concluded that 20the impacts are SMALL, and additional plant specific mitigation measures are not likely to be 21sufficiently beneficial to be warranted.
22 23 Table 4-13. Category 1 Issues Applicable to Groundwater Use and Quality During the Renewal Term 24 25ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections GROUNDWATER USE AND QUALITYGroundwater use conflicts (potable and service water; plants that use <100 gpm)4.8.1.1, 4.8.1.2 26A brief description of the Staff's review and the GEIS conclusions, as codified in Table B-1, 27 10 CFR 51, follows.
28 29Groundwater use conflicts (potable and service water; plants that use <100 gpm). Based 30on information in the GEIS, the Commission found that:
31 32Plants using less than 100 gpm are not expected to cause any groundwater use conflicts.
33 Environmental Impacts of Operation September 2007 4-63 Draft NUREG-1437, Supplement 32 As discussed in Section 2.2.2, WCGS does not use groundwater wells as a water source.
1 2The Staff has not identified any new and significant information during its independent review of 3the WCGS ER, the site audit, the scoping process, or evaluation of other available information.
4Therefore, the Staff concludes that there are no groundwater use conflicts during the renewal 5term beyond those discussed in the GEIS.
6 7The Category 2 issues related to groundwater use and quality during the renewal term that are 8applicable to WCGS are discussed in the sections that follow, and are listed in Table 4-14.
9 10 Table 4-14. Category 2 Issues Applicable to WCGS Groundwater Use and Quality 11During the Renewal Term 12 13ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections10 CFR 51.53(c)(3)(ii) SubparagraphDraft SEIS Section GROUNDWATER USE AND QUALITYGroundwater use conflicts (plants with cooling towers withdrawing makeup water from a small river)4.8.1.3A4.5.1Groundwater quality degradation (cooling ponds at inland sites)4.8.3D4.5.2 144.5.1 Groundwater Use Conflicts 15 16For plants with cooling pond systems that are supplied with make-up water from a small river 17with low flow, potential groundwater use conflicts are considered a Category 2 issue, thus 18requiring a site-specific assessment for license renewal review. Near WCGS, the Neosho River 19at Burlington has an average annual flow of approximately 1,603 cfs (Putnam and Schneider 202005, in WCNOC 2006a). This volume meets the NRC definition of a small river of 100,000 cfs 21(3.15 X 10 12 cubic ft per year listed in 10 CFR Part 51.53(c)(3)(ii)(A)), resulting in water use 22conflicts being a potentially applicable issue for relicensing of WCGS. The Staff independently 23reviewed the WCGS ER, visited the site, consulted with Federal and State resource agencies, 24and reviewed the applicant's existing NPDES permit and existing literature related to water 25withdrawal from Wolf Creek and the Neosho River, and the potential for this withdrawal to 26impact the availability of groundwater within the alluvial aquifer system associated with these 27 streams. 28 29The GEIS considered groundwater water use conflicts to be a Category 2 issue because of the 30potential for withdrawal of water in a small river during low flow conditions to reduce the amount 31of recharge to the alluvial aquifers associated with that river. At WCGS, the groundwater 32 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-64 September 2007 resources that are present, and for which the potential impact has been evaluated, include the 1groundwater in the alluvial aquifer associated with the Wolf Creek drainage, the aquifer located 2between Wolf Creek and the Neosho River, and the alluvial aquifer associated with the Neosho 3 River.4 5 4.5.1.1 Aquifers Associated with Wolf Creek, and between Wolf Creek and Neosho 6 River 7 8The volume of water withdrawn from the Wolf Creek drainage system through appropriations is 9discussed in Section 4.1.1. Although WCGS is permitted to access the water associated with 10Wolf Creek to use for cooling, the facility also stores that water, as well as the make-up water 11from the Neosho River, in an unlined, man-made reservoir (Coffey County Lake) within the Wolf 12Creek drainage basin. Because Coffey County Lake is unlined, and is used to store water from 13both within and outside of the Wolf Creek basin, the net effect is actually to increase the 14elevation of the groundwater within the Wolf Creek basin. Prior to facility construction, an 15analysis by NRC predicted that groundwater elevations associated with Coffey County Lake 16would rise 45.8 ft within 100 ft of the lake 50 years after filling (NRC 1975). Groundwater 17elevations 2 miles from the lake were predicted to rise less than 0.4 ft (NRC 1975). Because of 18this rise in groundwater levels, groundwater availability within the Wolf Creek basin, and in at 19least a portion of the area between Wolf Creek and the Neosho River, has likely increased due 20to facility construction and operation. This increased availability of groundwater within the Wolf 21Creek basin will continue during the re-licensing period.
22 234.5.1.2 Aquifers Associated with Neosho River 24 25The volume of water withdrawn from the Neosho River through appropriations and contract 26purchases is discussed in Section 4.1.1. During normal flow conditions, water would be 27withdrawn from the Neosho River through the two water appropriations (number 14,626 and 28number 19,882). The amount of water permitted to be withdrawn through these two 29mechanisms totals 225 cfs. However, based on the operational limitations of the pumping 30system, the maximum rate at which water can be withdrawn from the river during normal flow 31conditions is approximately 120 cfs (WCNOC 2006c). Both of the appropriations have an 32administrative limitation that only allows withdrawals that would maintain a flow of 250 cfs in the 33river. Therefore, even a maximum withdrawal rate of 120 cfs would remove less than one-half 34of the available water in the river. Under normal flow conditions, the annual average flow rate is 35approximately 1,603 cfs (Putnam and Schneider 2005, in WCNOC 2006a), and withdrawals 36under the appropriations would remove less than 7.5 percent of the flow. Therefore, under 37normal flow conditions, withdrawal under the appropriations is unlikely to have an impact on 38groundwater levels in the alluvial aquifer.
39 Environmental Impacts of Operation September 2007 4-65 Draft NUREG-1437, Supplement 32 The proportion of the overall flow removed for facility operations during low flow periods is 1 expected to be much higher. As discussed in Section 4.1.1.3, NRC has concluded that 2withdrawal of water at rates of 41 cfs or more through the purchase contract mechanism, which 3would occur during periods of drought, could extend the duration and severity of low flow 4conditions in the river (NRC 1982). During these periods, the amount of water available to 5recharge the alluvial aquifers is expected to be substantially reduced already, due to the natural 6drought conditions, and this effect could be exacerbated by further water withdrawals by WCGS 7under the purchase contract. In such a situation, it is likely that the impact on the alluvial 8aquifers would be considered as part of the overall consideration of the "health, safety, or 9general welfare of the people of Kansas" referenced in the purchase contract. If this evaluation 10resulted in a determination that continuing withdrawals would have an adverse impact on the 11aquifers, then the state could terminate water sales to the facility.
12 13 4.5.1.3 Groundwater Users Potentially Impacted 14 15 Although the withdrawal of water could potentially reduce the amount of water available in the 16alluvial aquifers associated with the Neosho River, those aquifers do not act as a substantial 17source of water supply within the area. According to the Kansas Water Plan (KWO 2004), 18approximately 80 percent of the water use within the Neosho River basin is from surface water 19sources. Uses of groundwater within the local area primarily include domestic and livestock 20supply (WCNOC 2006a). No local municipalities obtain water from groundwater sources. The 21only known use of groundwater for industrial sources is from a single well owned by the 22Atchison Topeka and Santa Fe Railway located 15 miles west-northwest of WCGS (WCNOC 232006a). A review of the Kansas Geological Survey well location database identified a total of 92 24wells located within 2 miles of the facility, and/or located between Coffey County Lake and the 25Neosho River (KGS 2007). However, it appears that only one of these wells is located 26downgradient of the facility, is listed as used for domestic purposes, and may potentially be still 27 active.28 29 4.5.1.4 Summary of Impacts Related to Groundwater Use Conflicts 30 31The Staff has reviewed the potential effect of water withdrawals on the availability of 32groundwater in the local area near the facility. Because Coffey County Lake provides recharge 33to the groundwater, the availability of groundwater within the immediate local area of the facility 34has likely increased due to facility operation. For the Neosho River during periods of normal 35flow rates, the volume of water withdrawn from the Neosho River is likely to be low compared to 36the volume of water available for recharge, so impacts to groundwater availability are unlikely.
37During periods of drought, availability of groundwater resources would be impacted by the 38natural drought conditions, and continuing withdrawals of water using the purchase contracts 39could potentially extend the duration and severity of this impact. However, this impact would be 40considered by the state in determining whether to continue water sales to WCGS under the 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-66 September 2007 purchase contract during these periods. In general, groundwater use within the local area is 1limited to scattered domestic and livestock supply wells, and there are no municipalities or 2significant industrial users in the area that could be impacted by WCGS operations.
3 4Based on a review of the available information relative to potential impacts of the use of cooling 5and service water on the availability of groundwater in the local area, the staff concludes that 6the potential impacts from renewal of the operating license would be SMALL. The NRC staff 7has not identified any potential mitigation measures that may help reduce adverse impacts 8related to groundwater use conflicts during the license-renewal term for continued operation of 9 WCGS.10 114.5.2 Groundwater Quality Degradation 12 13For plants with cooling pond systems, potential degradation of groundwater quality is 14considered a Category 2 issue, thus requiring a site-specific assessment for license renewal 15review. The Staff independently reviewed the WCGS ER, visited the site, consulted with 16Federal and State resource agencies, and reviewed information from WCGS and KDHE 17monitoring programs to evaluate the potential for groundwater quality impacts.
18 19In the GEIS, WCGS is specifically mentioned as one of nine facilities that operate man-made 20cooling ponds. The GEIS considered groundwater quality degradation from cooling ponds at 21these nine facilities to be a Category 2 issue because of the potential for degradation of surface 22water quality within the cooling ponds, and the likelihood that the ponds act as a source of 23recharge to the groundwater (NRC 1996). In the GEIS, the potential contaminants discussed 24included TDS, metals, and chlorinated organic compounds. Concentrations of TDS and metals 25are expected to potentially increase in the surface water in the ponds due to evaporation, while 26chlorinated organic compounds may be present due to the use of chlorine to prevent biofouling 27(NRC 1996). The GEIS analysis did not address radionuclides within the surface water, but the 28transport mechanism considered within the GEIS (groundwater recharge) would be applicable 29to these as well, if they were present in elevated concentrations in the cooling ponds. The GEIS 30analysis concluded that some contaminants could reach offsite areas, but that because offsite 31groundwater monitoring was not a standard practice, no actual data existed indicating that 32offsite impacts had occurred at any of the nine facilities with cooling ponds (NRC 1996).
33 34At WCGS, Coffey County Lake is a cooling pond that may have elevated contaminant 35concentrations, and from which these contaminants may migrate to local groundwater by 36infiltration. The following subsections present and evaluate the known information regarding the 37water quality in Coffey County Lake, the potential for that water to infiltrate to groundwater, and 38the potential for that groundwater to migrate and cause impacts to off-site resources.
39 Environmental Impacts of Operation September 2007 4-67 Draft NUREG-1437, Supplement 32 4.5.2.1 Water Quality in Coffey County Lake 1 2The existing surface water quality studies associated with WCGS are discussed in Sections 32.2.2 and 2.2.3. Surface water quality in Coffey County Lake and Wolf Creek is evaluated and 4regulated with respect to a variety of parameters (Total Suspended Solids, Total Residual 5Oxidant, oil and grease, pH, chloride, nitrate, sulfate, and ammonia) through the facility's 6NPDES permit. A review of the monitoring results associated with this permit shows that there 7is no substantial impact to water quality in Coffey County Lake or Wolf Creek, with respect to 8the parameters that are regulated by the permit.Therefore, there is no potential for 9groundwater quality degradation with respect to these parameters.
10 11 Radiological parameters within the surface water are not regulated by the NPDES permit.
12Surface water sampling is conducted as part of the annual radiological monitoring programs 13performed by both WCGS and KDHE, and includes periodic sampling and radiological analysis 14of surface water within Coffey County Lake and the Neosho River. As discussed in Section 152.2.3., these studies have documented a steady increase in the concentration of tritium within 16the surface water in Coffey County Lake, with detections attributable to facility operations and 17identified shortly after operations began (WCNOC 2006b, KDHE 2006a). The pre-operational 18estimate for the ultimate tritium concentration in the water in Coffey County Lake was 23,000 19pCi/liter (NRC 1982). This value exceeds the Kansas Department of Health and Environment 20criteria for domestic drinking water of 20,000 picoCuries per liter (pCi/L) tritium (KDHE 2004).
21Although the water in Coffey County Lake is not used as a drinking water source, infiltration and 22offsite migration of water containing 23,000 pCi/L tritium could potentially result in human 23 exposure to degraded groundwater.
24 25 4.5.2.2 Potential for Infiltration to Groundwater 26 27As discussed in Section 4.5.1.1, water within Coffey County Lake is expected to provide 28recharge to the groundwater, with a pre-construction estimate that groundwater elevations 29associated with Coffey County Lake would rise 45.8 ft within 100 ft of the lake 50 years after 30filling (NRC 1975). Groundwater elevations 2 miles from the lake were predicted to rise less 31than 0.4 ft (NRC 1975).
32 33Although sampling of groundwater production wells is performed as part of the annual programs 34by WCNOC and KDHE (WCNOC 2006b, KDHE 2006a), these monitoring programs do not 35include evaluation of groundwater elevations. According to WCGS personnel, no effort has 36been made to measure groundwater elevations or evaluate the pre-construction estimates 37regarding infiltration rates.(c) In addition, the sampling programs have typically consisted of the 38sampling of 3 downgradient wells, all more than 2 miles from the site, and all of unknown depth 39 (c) Minutes from a meeting held on March 13, 2007 discussing tritium in surface and groundwater. Participants included: NRC, Earth Tech, WCNOC and others. (Accession No. ML072250572).
Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-68 September 2007 and construction. All wells sampled are pre-existing production wells associated with houses 1and farms, and none were installed for the specific purpose of evaluating migration of water 2from Coffey County Lake. Therefore, these monitoring programs are limited in their ability to 3evaluate actual infiltration and migration of tritium from Coffey County Lake.
4 5Based on the design and characteristics of Coffey County Lake, it is probable that water 6containing elevated concentrations of tritium has been released to groundwater beneath the 7lake. Prior to facility construction and operation, an NRC analysis concluded that the 8groundwater recharge would result in a groundwater mound beneath Coffey County Lake (NRC 91975). In addition, boreholes and wells that were installed as part of the pre-construction 10investigation of the lake area may act as a conduit allowing more rapid seepage than originally 11predicted (WCNOC 1980). According to the 1980 Environmental Report for the Operating 12License, at least 4 wells within the area inundated by the lake were not plugged prior to flooding.
13Although no direct data exists to show the extent of infiltration, the fact that the lake is unlined 14and unplugged monitoring wells were inundated make it likely that infiltration has occurred, and 15 that a mound currently exists.
16 17 4.5.2.3 Potential for Groundwater Impacts 18 19The direction and rate of migration of this water would be influenced by the local topography 20and the regional groundwater flow pattern, both suggesting a direction of flow to the west and 21southwest, towards the Neosho River. The normal operating elevation of the water in Coffey 22County Lake is approximately 1,087 ft above MSL (WCNOC 2006c), while the elevation of the 23Neosho River directly west of the facility is approximately 983.5 ft above MSL (USGS 1979).
24Therefore, there is a hydraulic head of more than 100 ft over a distance of approximately 1.2 25miles between Coffey County Lake and the Neosho River, in the direction of regional 26 groundwater flow.
27 28The rate of flow of groundwater was estimated by NRC prior to facility operation, based on 29hydrogeologic data collected during siting studies for the facility. The two rock units exposed in 30the bottom of the Coffey County Lake are the Plattsmouth Limestone Member, and the Jackson 31Park Shale Member (NRC 1975). The calculated time for the cooling lake water to move a 32distance of 1 mile through these rock units was estimated to be 6,000 years for the Plattsmouth 33Limestone Member and 1,020 years for the Jackson Park Shale Member (NRC 1975).
34 35A review of the Kansas Geological Survey well location database identified a total of 92 wells 36located within 2 miles of the facility, and/or located between Coffey County Lake and the 37Neosho River (KGS 2007). Only one of these wells is a domestic well that may currently be 38operational, so there is currently a limited number of groundwater users situated in locations 39that could potentially be affected. Three existing wells in this area are subject to periodic 40 Environmental Impacts of Operation September 2007 4-69 Draft NUREG-1437, Supplement 32 sampling and tritium analysis under the REMP program, and none of these wells has been 1found to be impacted. If additional groundwater users install wells in this area in the future, the 2facility would be required to evaluate the potential for impact and possible inclusion of these 3wells in the REMP sampling program. Therefore, the potential for offsite impacts due to 4groundwater degradation is low.
5 6 4.5.2.4 Summary of Impacts Related to Groundwater Quality Degradation 7
8The Staff has reviewed the potential impacts due to groundwater degradation associated with 9facility operation. Water quality within Coffey County Lake is known to include rising 10concentrations of tritium, and due to the unlined nature of the lake, this water is available to 11infiltrate to groundwater. In addition, the existing groundwater monitoring programs operated by 12WCNOC and KDHE are not specifically designed to identify and evaluate migration of impacted 13water from Coffey County Lake. However, groundwater use within the local area is limited, and 14there are no municipalities or significant industrial users in the area that could be impacted by 15 WCGS operations.
16 17Based on a review of the available information relative to potential impacts from groundwater 18quality degradation, the staff concludes that the potential impacts from renewal of the operating 19license would be SMALL.
20 21The NRC staff has identified potential mitigation measures, which may help reduce adverse 22impacts related to groundwater quality degradation during the license-renewal term for 23continued operation of WCGS. Such mitigation measures include implementation of a 24groundwater investigation program designed to confirm the pre-construction predictions 25regarding the rate of infiltration and groundwater flow. Due to the uncertainties regarding these 26issues, the staff has concluded that implementation of such measures may be beneficial enough 27 to be warranted.
28 294.6 Threatened or Endangered Species 30 31Potential impacts to threatened or endangered species are listed as a Category 2 issue in 3210 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-15.
33 34 Table 4-15. Category 2 Issues Applicable to Threatened or Endangered Species 35During the Renewal Term 36 37ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section10 CFR 51.53(c)(3)(ii) Subparagraph Draft SEIS Section THREATENED OR ENDANGERED S PECIES (FOR ALL PLANTS
)Threatened or Endangered Species 4.1E4.6 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-70 September 2007 This issue requires consultation with appropriate agencies to determine whether threatened or 1endangered species are present and whether they would be adversely affected by continued 2operation of the nuclear facility during the license renewal term. The presence of threatened or 3endangered species in the vicinity of the WCGS site is discussed in Sections 2.2.5.4 and 42.2.6.4. On December 7, 2006, the Staff contacted the FWS to request information on 5threatened and endangered species and the impacts of license renewal (NRC 2006). In 6response, on January 29, 2007, the FWS provided additional information regarding Federally 7listed species that have been observed or may occur in the vicinity of WCGS and its associated 8transmission line ROWs as well as the concerns that the FWS has regarding those species 9(FWS 2007a). The FWS stated in this letter that formal consultation is not required unless the 10proposed action may adversely affect the listed species. Although the NRC staff does not 11believe that license renewal would adversely affect the Federally listed species, the Staff has 12prepared a biological assessment (BA) that documents its review. The BA is provided in 13Appendix E of this draft SEIS.
14 154.6.1 Aquatic Species 16 17Of the rare aquatic species recorded as occurring in Coffey, Greenwood, or Butler Counties, 18Section 2.2.5.4 identified one Federally listed species (the Neosho madtom) as having been 19confirmed in the vicinity of WCGS or along the associated transmission line ROW. The Neosho 20madtom occurs in the Neosho River both upstream and downstream of its confluence with Wolf 21Creek. Other than the madtom, no aquatic species that is Federally listed as threatened or 22endangered is known to occur or to have designated critical habitats in the vicinity of the WCGS 23site or along the associated transmission line ROW.
24 25The populations of the Neosho madtom that potentially are affected by WCGS are those 26inhabiting the Neosho River from the John Redmond Dam downstream, extending past the Wolf 27Creek confluence. Factors associated with WCGS operations that potentially could affect this 28species in this reach of the river include: (1) reduction in Neosho River flow due to makeup 29water withdrawals, (2) increase in Neosho madtom mortality due to entrainment and/or 30impingement via the MUSH, and (3) toxic effects from chemical constituents in surface water of 31Coffey County Lake and the Neosho River. Each of these factors is addressed below.
32 33(1) As explained in detail in Section 4.1.1, the State of Kansas has established MDS levels 34 in the Neosho River that are protective of rare aquatic species. The worst-case MDS 35established for the Neosho River at Iola is 40 cfs from July to March. The MDS 36increases to 60 cfs in April and 200 cfs in May and June if the reservoir is in flood pool, 37in order to maintain flows supportive of fish spawning in the river; otherwise, the MDS in 38April through June is 40 cfs (KWAA 2004). Calculation by the applicant of preferred flow 39conditions for the Neosho madtom indicated that its needs would be met under the 40 Environmental Impacts of Operation September 2007 4-71 Draft NUREG-1437, Supplement 32 worst-case MDS of 40 cfs measured at Iola (WCNOC 2007a). Therefore, the MDS is 1expected to be protective of populations of this species in the Neosho River below John 2Redmond Dam during relatively brief periods of drought. However, it should be noted 3that severe, extended droughts prior to construction of WCGS, such as in the 1950s, 4have reduced Neosho River flows to well below 40 cfs for extended periods. Should 5such a drought occur during the renewal period, this species would be affected as they 6have been historically, because the MDS could not be met during a prolonged drought 7(FWS 1991). Because WCGS is permitted to continue water withdrawals during these 8periods, the withdrawals could contribute to the duration and severity of drought 9conditions. Water withdrawals from the Neosho River during low flow events or drought 10conditions could adversely affect the habitat of the Neosho madtom.
11 12(2) The MUSH intake in the Neosho River generally is operated only as necessary to 13provide makeup water to maintain the pool at Coffey County Lake. Therefore, under 14conditions of normal or higher rainfall, the MUSH would be utilized only sparingly, and 15entrainment and impingement of organisms from the Neosho River would be minimized.
16Entrainment is discussed in detail in Section 4.1.2. A 1981 study of larval fish drift in the 17Neosho River included sample locations upstream of John Redmond Reservoir, in the 18tailwaters of John Redmond Dam, and at Burlington. The only Noturus species collected 19and identified were two individuals at the upstream location, and these were not believed 20to be the Neosho madtom (Wedd 1985). No data are available regarding the species of 21fish eggs and larvae that have been entrained by the intake since 1982. However, 22available lines of evidence indicate that entrainment of the Neosho madtom is very 23 unlikely.24 25 The impingement of healthy juvenile and adult fish at the MUSH is expected to be 26minimal because the operational intake velocity of up to approximately 0.5 fps is low in 27comparison to the stream flows in habitats where the Neosho madtom and other native 28fish occur (WCNOC 2006e). In the MUSH vicinity, Neosho River flows typically range 29from 0.8 to 4.9 fps (Wedd 1985). Thus, impingement of adult fish is expected to occur 30rarely and then only when the fish are in a weakened condition or dead and unable to 31avoid even the low current velocity near the MUSH intake (WCNOC 2006e). In addition, 32the Neosho madtom was not among the species impinged in a 1 year impingement 33study at the MUSH conducted between November 1980 and October 1981 (Koester 341982). These lines of evidence indicate that the potential for Neosho madtom larvae, 35juveniles, or adults to be present at the intake and subject to entrainment or 36impingement is very low.
37 38(3) Contaminant concentrations in the aquatic environment at WCGS are monitored on an 39ongoing basis by WCNOC and KDHE. These agencies operate sampling programs to 40evaluate any potential effects of facility operations on surface water, sediment, and 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-72 September 2007 aquatic life. Samples collected to monitor for potential releases of radionuclides to 1surface water include surface water samples, drinking water samples, shoreline 2sediment samples, bottom sediment samples, aquatic vegetation samples, and fish 3 tissue samples. A summary of surface water and sediment quality, including a 4description of contaminants detected in surface water and sediment, is presented in 5Section 2.2.3, Water Quality. The results of analyses of plant and fish tissue and results 6from toxicity tests on water samples collected at WCGS are summarized in Section 72.2.5.2. These studies have not found toxic effects levels of any of the constituents 8evaluated in Coffey County Lake. Given that discharges from Coffey County Lake to 9Wolf Creek are limited and infrequent, the potential for chemicals that have entered 10surface water from WCGS operations to reach the Neosho River and result in 11concentrations that would be toxic to fish, mussels, or other aquatic organisms is 12negligible.
13 14The potential for concentrations of metals to accumulate in cooling ponds as a result of 15corrosion within the cooling system is an issue that was evaluated in the GEIS and 16determined to be a Category 1 issue. However, to address possible concerns related to 17this issue and its potential to affect the Neosho madtom, Neosho mucket, and other 18wildlife, the concentrations of relevant metals were examined by the applicant. The 19average concentrations of chromium, copper, iron, mercury, and nickel in Coffey County 20Lake in 2005 and 2006 were compared to the concentrations of these metals in the 21Neosho River at Leroy, approximately 10 miles downstream of the Coffey County Lake 22dam (WCNOC 2007a). Only copper, iron, and nickel were detected, and the 23concentrations of each of these metals was higher in the Neosho River at Leroy than in 24Coffey County Lake. The concentrations of these three metals in both the river and 25Coffey County Lake were well below their respective National Recommended Water 26Quality Criteria for the protection of freshwater aquatic life under continuous (chronic) 27exposure conditions (EPA 2006). Therefore, the potential for risk to aquatic organisms 28or their predators from metals in Coffey County Lake or the Neosho River is expected to 29 be minimal.
30 31Given that compliance with existing water use agreements is expected and that no change in 32operations, expansion of existing facilities, or disturbance of additional land is anticipated, these 33rare aquatic species are unlikely to be adversely affected during the renewal period.
34 354.6.2 Terrestrial Species 36 37Four species that are Federally listed as threatened or endangered have been recorded as 38occurring currently or historically in Coffey, Butler, or Greenwood Counties: the piping plover 39 (Charadrius melodus), whooping crane (Grus americana), least tern (Sterna antillarum
), and 40 Environmental Impacts of Operation September 2007 4-73 Draft NUREG-1437, Supplement 32 Mead's milkweed (Asclepias meadii
). Consequently, these species may have a potential to 1occur in the vicinity of the WCGS site or along the associated transmission line ROWs if suitable 2habitat is present. Because there is no planned expansion of existing facilities, change in ROW 3maintenance procedures, or disturbance of additional land anticipated during the renewal 4period, these species, if present, are unlikely to be adversely affected by future operations.
5 6As discussed in Section 2.2.6.4.5, Mead's milkweed potentially may occur in tall grass prairie 7communities in Coffey County, and such communities are present on WCGS property and 8within transmission line ROWs. However, surveys to determine its presence have not been 9performed. If present, it would not be expected to be adversely affected by continuation of 10current land management activities during the renewal period.
11 12Of the rare terrestrial species recorded as occurring in Coffey, Greenwood, or Butler Counties, 13Section 2.2.6.4 identified one Federally listed species (the least tern) as having been confirmed 14in the vicinity of WCGS or along the associated transmission line ROW. Least terns were 15recorded at Coffey County Lake in the 1980s, but nesting has not been observed there. With 16the exception of this species, no other terrestrial species that is Federally listed as threatened or 17endangered has been recorded as occurring in the vicinity of the WCGS site or along the 18associated transmission line ROWs.
19 20Three of the Federally listed species are birds (piping plover, whooping crane, and least tern), 21which potentially could be injured or killed as a result of collisions with transmission lines and 22towers. As discussed in Section 4.2, the issue of bird collisions with power lines was evaluated 23in the GEIS and determined to be a Category 1 issue because the impacts are expected to be 24of small significance at all sites. However, this issue was raised by the FWS as a possible 25concern in its consultation letter regarding the proposed action (FWS 2007). The issue is 26evaluated herein with regard to the rare bird species, as their populations potentially are the 27most susceptible. An Avian Protection Plan (WCNOC 2006h) has been completed for WCGS 28that assesses the facility's potential impacts on birds, particularly the bald eagle (Haliaeetus 29leucocephalus), which has recently been delisted from the endangered species list. This plan 30identifies improvements to minimize impacts, and presents contingency plans to address 31possible future needs for additional activities. The plan includes as an attachment a review of 32bird collision data for transmission facilities at WCGS that was completed as part of a survey 33program recommended by the NRC in 1982 to determine if mitigation was warranted.
34 35The bird collision survey included searches for dead birds along transmission lines crossing 36Coffey County Lake and the area of the Lime Sludge Pond. The Coffey County Lake search 37areas were Firing Range Cove, which is east of the facility and traversed by two 345-kV lines 38and one 69-kV line, and Cemetary Cove, which is north of the facility and traversed by one 345-39kV line. These were considered the areas where collisions by waterfowl and other water birds 40were most likely to occur. The survey focused on waterfowl and bald eagle collisions, but all 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-74 September 2007 bird species were included. The dead bird surveys began in February 1983 and continued 1through February 1988. The timing of the surveys included the winter-spring migration seasons 2during each year, with surveys occurring mainly in January, February, April, November, and 3December. Prior to dead bird searches in each area, live birds present in the area were 4identified and counted from November 1985 through February 1988 (WCNOC 2006h). In 5addition, more detailed live-bird surveys of waterfowl, other water birds, and bald eagles using 6habitats throughout Coffey County Lake were performed during the migratory season from 7October 1987 through March 1988 (WCNOC 1988).
8 9Comparison of the dead and live bird data revealed no relationship between collision frequency 10and bird usage of Coffey County Lake or Lime Sludge Pond. Total transmission line collisions 11were estimated by adjusting the total number of dead birds found to account for search bias, 12scavenger removal bias, and crippling bias. The estimated percentage of the total number of 13birds counted using Coffey County Lake each year that died in collisions ranged from 0.2 to 0.5 14percent, values which were comparable to those reported in other avian collision assessments.
15No substantial increases or decreases were noted between pre-operational and operational 16seasons. Based on these small percentage losses due to collisions relative to other mortality 17rates for waterfowl and water birds, it was concluded that the effects from collisions with WCGS 18transmission lines were insignificant to populations of unlisted waterfowl and other birds. No 19bald eagles or other listed threatened or endangered species were found during the dead bird 20searches (WCNOC 1988). Based on these surveys, it can be concluded that collisions with 21transmission lines at WCGS do not pose a substantial risk to listed threatened or endangered 22avian species that might be attracted to the water or shoreline of Coffey County Lake or the 23Lime Sludge Pond (such as the piping plover, least tern, and whooping crane), or more common 24 birds.25 26Elsewhere along the transmission line ROW, there are no other habitats where these three 27Federally listed bird species would be likely to be attracted and become susceptible to a 28substantial risk of collision mortalities, with the possible exception of the whooping crane. As 29discussed in Section 2.2.6.4, the only self-sustaining wild population of the whooping crane 30migrates through central Kansas in the spring (March - April) and fall (October - November) 31(KDWP 2004). Two areas in central Kansas, Cheyenne Bottoms State Waterfowl Management 32Area in Barton County and Quivira National Wildlife Refuge in Stafford, Reno, and Rice 33Counties, have been Federally designated as critical habitat for migrating whooping cranes 34(FWS 2007b). These two critical habitats are on the approximate center line of a 200-mi-wide 35migration corridor that crosses central Kansas in a north-south orientation. The corridor 36encompasses approximately 94 percent of all sightings through 1999 (CWS and FWS 2007).
37The two critical habitats are located more than 160 miles west of WCGS and 80 miles northwest 38of the western terminus of the WCGS - Rose Hill transmission line ROW. WCGS is 39approximately 60 miles east of the migration corridor; however, the terminal end of the 40 Environmental Impacts of Operation September 2007 4-75 Draft NUREG-1437, Supplement 32 transmission line ROW extends approximately 30 miles inside the corridor to the Rose Hill 1Substation. The FWS Region 6 website indicates no current records of the whooping crane in 2Coffey, Butler, or Greenwood Counties (FWS 2007c), but KDWP designates Coffey and 3Greenwood Counties as being within the known historic range of the whooping crane (KDWP 4 2004).Collisions withpower lines are a major cause of whooping crane mortality during 5migration, and 60 to 80 percent of losses occur during migration (CWS and FWS 2007).
6However, no dead or living whooping cranes have been found in the bird surveys at WCGS, and 7none have been reported along the terminal segment of the WCGS - Rose Hill transmission line 8that is within the migration corridor in Butler County. Therefore, it appears that this transmission 9line is unlikely to pose a substantial risk to individual whooping cranes or the population.
10 11 4.6.3 Conclusions 12 13The Staff reviewed information from the site audit, WCNOC's ER, other reports, and information 14from the FWS and KDWP. The Staff concludes that the impacts on Federally listed threatened 15or endangered species of an additional 20 years of operation and maintenance of WCGS and 16associated transmission lines and ROW would be SMALL if no water use conflicts exist.
17However, if SMALL to MODERATE impacts occur due to water use conflicts (see Section 184.1.1), impacts to the Neosho madtom could be SMALL to MODERATE. During low-flow events 19or drought conditions, there could be a reduction in the habitat available in the river to the 20Neosho madtom. Although formal consultation is not required by the FWS, a BA (Appendix E) 21was developed to document the evaluation of the potential impacts of continued operation of 22WCGS on Federally listed species that, according to the FWS, may occur in the project area.
23 244.7 Evaluation of New and Potentially Significant 25 Information on Impacts of Operations During the 26 Renewal Term 27 28The Staff has not identified new and significant information on environmental issues listed in 10 29CFR Part 51, Subpart A, Appendix B, Table B-1, related to operation during the renewal term.
30The Staff also determined that information provided during the public comment period did not 31identify any new issue that requires site-specific assessment. The Staff reviewed the discussion 32of environmental impacts associated with operation during the renewal term in the GEIS and 33has conducted its own independent review, including public scoping meetings, to identify issues 34with new and significant information. Processes for identification and evaluation of new 35information are described in Section 1.2.2.
36 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-76 September 2007 4.8 Cumulative Impacts 1 2The Staff considered the potential for cumulative impacts of operations of WCGS during the 3renewal term. For the purposes of this analysis, past actions are those related to the resources 4at and since the time of the plant licensing and construction, present actions are those related to 5the resources at the time of current operation of the power plant,and future actions are 6considered to be those that are reasonably foreseeable through the end of plant operation.
7Therefore, the analysis considers potential impacts through the end of the current license term 8as well as the 20-year renewal license term. The geographical area over which past, present, 9and future actions would occur is dependent on the resource evaluated and is described below 10 for each resource.
11 12The impacts of the proposed action, as described in previous sections of Chapter 4, are 13combined with other past, present, and reasonably foreseeable future actions at WCGS 14regardless of what agency (Federal or non-Federal) or person undertakes such other actions.
15These combined impacts are defined as "cumulative" in 40 CFR 1508.7 and include individually 16minor but collectively significant actions taking place over a period of time (CEQ 1997b). It is 17possible that an impact that may be SMALL by itself could result in a MODERATE or LARGE 18impact when considered in combination with the impacts of other actions on the affected 19resource. Likewise, if a resource is regionally declining or imperiled, even a SMALL individual 20impact could be important if it contributes to or accelerates the overall resource decline.
21 224.8.1 Cumulative Impacts on Aquatic Resources 23 24As discussed in Section 4.1, the Staff found no new and significant information that would 25indicate that the conclusions regarding any of the aquatic resources potentially affected by 26WCGS are inconsistent with the conclusions in the GEIS (NRC 1996). The Staff has 27determined that the effects of the proposed action would have a SMALL to MODERATE impact 28on aquatic resources associated with the Neosho River due to water use conflicts. The Staff 29has determined that individually the effects of the proposed action would have a SMALL impact 30due to impingement, entrainment, and heat shock, with one exception, impingement in the 31Neosho River could be SMALL to MODERATE if water use impacts are SMALL to MODERATE.
32 33There are a variety of natural and anthropogenic factors that may influence aquatic biota in the 34area potentially affected by WCGS, including fishing mortality, entrainment and impingement 35from the CWIS and MUSH, heat shock from the cooling water discharge, contaminants, 36environmental changes associated with changes in regional water use, and habitat modification 37and loss. In addition, changes to water and sediment quality from runoff, urbanization, and 38industrial activities may act as stressors on the biological environment. To evaluate the impacts 39of these other stressors on aquatic resources and, in turn, to be able to elucidate the cumulative 40 Environmental Impacts of Operation September 2007 4-77 Draft NUREG-1437, Supplement 32 impacts of the continued operation of WCGS, the Staff consulted with State and Federal 1resource agencies, reviewed the applicant's ER and other environmental reports, conducted an 2independent search for other potential stressors in the project area, and considered public 3 comments.
4 5Coffey County Lake was originally designed and developed to be a cooling impoundment for 6WCGS. This is still the primary function of this lake; however, in recent years recreational 7fishing has also been allowed on the lake. Direct or indirect impacts associated with usage of 8the lake for recreational fishing may include harvesting of predator fish that are necessary for 9control of gizzard shad, release of pollutants from boats (gasoline, waste), or the introduction of 10invasive species such as the zebra mussel (Dreissena polymorpha
). However, WCGS in 11conjunction with the Coffey County sheriff maintains strict access to the lake via a permit 12system. A creel survey is in place to determine the types and sizes of fish harvested from the 13lake. In addition, all boats are inspected for the presence of invasive species prior to launching 14in the lake. Thus, it is unlikely that recreational fishing would have an adverse impact on the 15lake. Fishing is allowed on the Neosho River in the vicinity of the MUSH; however, the river in 16this area downstream of the dam is shallow and only a very short distance from the dam.
17Therefore, the likelihood of significant fishing pressure in this area is minimal.
18 19There is no residential, commercial, or industrial development on the lake with the exception of 20the WCGS and a small boat ramp and associated docking structures on the west side of the 21lake. Consequently, due to the limited development on the lake and the WCGS implementation 22of riparian buffers on the lake to address potential impacts associated with agricultural activities, 23non-point source runoff in the form of contaminants or soil erosion is minimal.
24 25The combined effects of entrainment and impingement may have an impact on the fisheries in 26Coffey County Lake. This effect is difficult to assess as only a limited set of impingement data 27has been collected, and almost no data are available on entrainment by the CWIS. However 28WCGS has had an annual fishery monitoring program in place since the facility first went on 29line, and this program, while not providing direct evidence, has indicated that the CWIS is not 30having a detectable impact on aquatic resources in the lake. The combined effects of 31entrainment and impingement may also have an impact on the aquatic biota in the Neosho 32River. However, this impact is likely to be small as the MUSH is only operated sporadically 33throughout the year and is located immediately downstream of the John Redmond Dam.
34 35The thermal discharge from the CWIS is likely having an effect on the aquatic resources in the 36lake; however, this effect is likely to be localized in the area near the discharge. This impact 37may be beneficial for some aquatic organisms in that the warmer temperatures may encourage 38a longer growing season. However, aquatic organisms in the discharge area of the lake may be 39negatively affected should the heated discharge be disrupted during the winter months, as this 40likely would result in cold shock. The extent of losses attributable to this localized phenomenon 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-78 September 2007 is expected to be minimal in relation to the numbers and biomass of aquatic organisms in Coffey 1 County Lake.
2 3Changes in regional water usage, either man-made (through increased water withdrawals or 4changes in allocations) or natural (drought), may also have a detrimental effect on aquatic 5organisms. As discussed in Section 4.1.1, it has been documented that water withdrawal may 6occur during periods when the flow rate in the Neosho River is below the MDS established to be 7protective of aquatic resources. If withdrawals are made during the re-licensing period at times 8of drought when the river flow is below the 40 cfs level, then the duration and severity of impacts 9to aquatic resources may be increased.
10 11As described above, the NRC staff considered the many potential factors that may affect the 12aquatic resources, associated with Coffey County Lake during the license renewal term. These 13factors are not expected to have a significant impact on these resources; thus, the cumulative 14impacts on aquatic resources in Coffey County Lake would be expected to be SMALL. Due to 15the potential impacts associated with water use conflicts in the Neosho River, the cumulative 16impacts of the proposed action on aquatic resources, including threatened and endangered 17species, in the Neosho River are expected to be SMALL to MODERATE during the license 18 renewal term.
19 204.8.2 Cumulative Impacts on Terrestrial Resources 21 22This section analyzes past, present, and future actions that could result in adverse cumulative 23impacts to terrestrial resources including threatened and endangered species, such as wildlife 24populations, the size and distribution of habitat areas, and aquatic resources such as streams, 25wetlands, and floodplains. For purposes of this cumulative effects analysis, the geographic area 26considered in the evaluation includes the WCGS site and its associated transmission line 27 ROWs.28 29 The transmission line ROWs do not cross any State or Federal parks, wildlife refuges, or wildlife 30management areas. Riparian and wetland communities are a small component of the natural 31communities present within the transmission line ROWs. Major rivers and associated 32watersheds traversed by the Wolf Creek - Rose Hill transmission line include the Neosho River, 33primarily in Coffey County, the Verdigris and Fall Rivers, primarily in Greenwood County, and 34the Walnut River, primarily in Butler County. The portion of the La Cygne - Benton transmission 35line rerouted around Coffey County Lake in conjunction with the construction of WCGS is 36approximately 7.7-mi long and mainly on WCGSproperty. Westar, the owner of the 37transmission lines, follows ROW management procedures that were designed to be protective 38of sensitive ecological resources, including wildlife habitat, wetlands, and floodplains. The 39 Environmental Impacts of Operation September 2007 4-79 Draft NUREG-1437, Supplement 32 maintenance procedures minimize disturbance of wildlife and wetlands and prevent potential 1off-site effects, such as erosion, on surrounding areas with other land uses.
2 3Maintenance and operation of the transmission system are not expected to destabilize or 4noticeably alter the existing terrestrial or freshwater aquatic environment. Likewise, operation of 5WCGS is not likely to have a detectable effect on terrestrial species located in the vicinity of the 6WCGS site or the transmission line ROW. No other Federal or non-Federal activities have been 7identified that would have an adverse effect on terrestrial species in the area. The Staff 8concludes that the incremental contribution to cumulative impacts on terrestrial resources 9including threatened and endangered species resulting from continued operation of WCGS and 10its associated transmission line ROW would be SMALL.
11 12The Staff has not identified any mitigation measures that would be appropriate for reducing the 13impacts on threatened and endangered species.
14 154.8.3 Cumulative Human Health Impacts 16 17The continued operation of WCGS is not likely to result in significant cumulative impacts due to 18microbiological organisms because, no pathogenic species of amoeba Naegleria has been 19found in the water or sediment from the intake structures, swimming is not allowed, and KDHE 20has indicated that there have not been any reports of illness from thermophillic pathogens 21associated with Coffey County Lake. On the basis of these considerations, NRC staff has 22determined that the cumulative impacts to public health from microbiological organisms, 23resulting from operation of the WCGS cooling water discharge system to the aquatic 24environment or in the vicinity of the site, will be SMALL and no additional mitigation is 25 warranted.
26 27The NRC staff has determined that the electric-field-induced currents from the WCGS 28transmission lines are well below the NESC recommendations for preventing electric shock from 29induced currents. Therefore, the WCGS transmission lines do not significantly affect the overall 30potential for electric shock from induced currents within the analysis area. With respect to 31chronic effects of electromagnetic fields, although the NRC staff considers the GEIS finding of 32"not-applicable" to be appropriate in regard to WCGS, the WCGS transmission lines do not 33significantly contribute to the regional exposure of ELF-EMF. Therefore, the NRC staff has 34determined that the cumulative impacts of the continued operation of the WCGS transmission 35lines will be SMALL and no additional mitigation is warranted.
36 37The radiological dose limits for protection of the public and workers have been developed by the 38 EPA and NRC to address the cumulative impact of acute and long-term exposure to radiation 39and radioactive material. These dose limits are codified in 40 CFR Part 190 and 10 CFR Part 4020. For the purpose of this analysis, the area within a 50-mi radius of the WCGS site was 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-80 September 2007 included. The REMP conducted by WCNOC in the vicinity of the Wolf Creek site measures 1radiation and radioactive materials from all sources, including Wolf Creek; therefore, the 2monitoring program measures cumulative radiological impacts. There are no other nuclear 3power plants within a 50-mi radius of Wolf Creek.
4 5Monitoring results for the 5 year period from 2002 to 2006 were reviewed as part of the 6cumulative impacts assessment (WCNOC 2003b, WCNOC 2004b, WCNOC 2005b, WCNOC 72006i, WCNOC 2007d). Additionally, in Sections 2.2.7 and 4.3, the Staff concluded that 8impacts of radiation exposure to the public and workers (occupational) from operation of Wolf 9Creek during the renewal term are SMALL. The NRC and the State of Kansas would regulate 10any future actions in the vicinity of the Wolf Creek site that could contribute to cumulative 11radiological impacts.
12 13Therefore, the Staff concludes that cumulative radiological impacts of continued operations of 14WCGS are SMALL and that no further mitigation measures are warranted.
15 164.8.4 Cumulative Socioeconomic Impacts 17 18As discussed in Section 4.4 of this draft SEIS, the continued operation of WCGS during the 19license renewal term would have no impact on socioeconomic conditions in the region beyond 20those already being experienced. Since WCNOC has indicated that there would be no major 21plant refurbishment, overall expenditures and employment levels at WCGS would remain 22relatively constant with no additional demand for housing, public utilities, and public services. In 23addition, since employment levels and the value of WCGS would not change, there would be no 24population and tax revenue-related land use impacts. There would also be no 25disproportionately high or adverse health or environmental impacts on minority and low-income 26populations in the region. Based on this and other information presented in this draft SEIS, 27there would be no cumulative socioeconomic impacts from WCGS operations during the license 28renewal term and no mitigation would be required.
29 304.8.5 Cumulative Impacts on Groundwater Use and Quality 31 32WCGS does not use groundwater in their operations and is not proposing to change this during 33the re-licensing period, so the facility has no direct impact on the availability of local 34groundwater. In addition, groundwater use within the local area is limited to scattered domestic 35and livestock supply wells, and there are no municipalities or significant industrial users in the 36area that could be impacted by WCGS operations. Potable water for local residents and towns 37is obtained from surface water sources, and WCNOC does not plan an increase in employment 38in the local area, so continued operations will not increase the demand for groundwater.
39 Environmental Impacts of Operation September 2007 4-81 Draft NUREG-1437, Supplement 32 The development and operation of a cooling pond (Coffey County Lake) does have the potential 1to impact local groundwater quality through seepage. If contaminant concentrations were to 2build up in the surface water in the lake, downward infiltration and migration of this water could 3have the potential to transport this contamination through a wide area and to groundwater 4users. The primary flow direction would be to the west toward the Neosho River, and discharge 5of groundwater into the river could potentially impact aquatic resources in the river.
6 7An additional potential source of groundwater contamination in this area is the Coffey County 8Landfill, which is located close to the western edge of Coffey County Lake. This landfill opened 9in 2001, and is therefore subject to current liner construction and groundwater monitoring 10 requirements.
11 12No site-specific monitoring data have been collected to evaluate the extent of surface water 13infiltration from Coffey County Lake to the groundwater. In addition, analytical data for the 14surface water within the lake is limited to radiological parameters and to general chemistry 15parameters associated with the facility NPDES permit. The radiological analyses indicate that 16tritium concentrations have increased in the lake since operations began and may be 17approaching the pre-construction estimate of 23,000 pCi/L(NRC 1982). Early analyses of 18metals in Coffey County Lake found that copper concentrations increased during the first 2 19years of operation, but no monitoring data for metals was collected after that time (EA 1988).
20 21These data suggest that water quality within the lake is not completely known, but degradation 22of water quality due to tritium has been documented. In addition, the actual infiltration rate to 23groundwater is not known. However, pre-construction models based on hydrogeological data 24collected before the filling of Coffey County Lake predicted that the rate of groundwater 25migration would be very slow, and that off-site groundwater users would not be impacted. Also, 26a recent review of groundwater well data indicates that there is only one groundwater well near 27the facility that may still be used for domestic supply purposes. This well is located between 28Coffey County Lake and the Neosho River.
29 30On the basis of this analysis, the Staff concludes that the cumulative impact to groundwater 31resources during the license renewal period would be SMALL and no additional mitigation 32 measures would be warranted.
33 344.8.6 Conclusions Regarding Cumulative Water Use Impacts 35 36As discussed in Section 4.1.1, there are uncertainties regarding the availability of water during 37the relicensing period. Through the period of operations from 1982 to present, there have been 38no conflicts because there have been no significant droughts such as the 50-year drought that 39occurred in the 1950s, and the availability of water within the conservation pool of John 40Redmond Reservoir still has the necessary capacity to provide supply to all users. However, 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-82 September 2007 during the relicensing period, the likelihood of a 50-year drought occurring increases, and 1currently undefined actions will be necessary to extend the operational life of John Redmond 2Reservoir or otherwise develop alternate water sources.
3 4Other factors affecting cumulative water use impacts include the volume of demand from other 5water uses in the basin, and the availability of water storage within the basin. These additional 6uses include water supply provided to residents within the Neosho River Basin, and the MDS 7established within the Neosho River. Demand from these uses is likely to increase in the future.
8The availability of water storage within the basin is known to be currently decreasing due to 9siltation in the conservation pool of John Redmond Reservoir as well as other reservoirs within 10the basin, although this decrease may be reversed by future re-allocation or dredging actions.
11Because the water use impacts from the relicensing action are deemed to range from SMALL to 12MODERATE, future water demands are likely to increase, and future water storage capacity is 13decreasing, the Staff concludes that cumulative impacts on water use are SMALL to 14MODERATE, and future mitigation will likely be warranted.
15 164.8.7 Conclusions Regarding Cumulative Impacts 17 18The NRC staff considered the potential impacts resulting from the operation of WCGS and 19maintenance of the transmission line ROW since WCGS was constructed and went on line 20through the end of the license renewal term and resulting from other past, present, and future 21actions in the vicinity of WCGS. The Staff's determination is that the cumulative impacts 22resulting from the incremental contribution of WCGS operation and maintenance of transmission 23line ROW would be SMALL for all resources with the exception of aquatic resources, which 24would experience SMALL to MODERATE cumulative impacts due to the potential for surface 25water use conflicts.
26 274.9 Summary of Impacts of Operations During the Renewal 28 Term 29 30Neither WCNOC nor the NRC staff is aware of information that is both new and significant 31related to any of the applicable Category 1 issues associated with the WCGS operation during 32the renewal term. Consequently, the Staff concludes that the environmental impacts associated 33with these issues are bounded by the impacts described in the GEIS. For each of these issues, 34the GEIS concluded that the impacts would be SMALL and thatadditional plant-specific 35mitigation measures are not likely to be sufficiently beneficial to warrant implementation.
36 37Plant-specific environmental evaluations were conducted for 15 Category 2 issues applicable to 38WCGS operation during the renewal term and for environmental justice and chronic effects of 39 Environmental Impacts of Operation September 2007 4-83 Draft NUREG-1437, Supplement 32 electromagnetic fields. For 12 issues and environmental justice, the Staff concluded that the 1potential environmental impact of renewal term operations of WCGS would be of SMALL 2significance in the context of the standards set forth in the GEIS and that additional mitigation 3would not be warranted. For water use impacts, the Staff concluded that there was not enough 4information to determine what actions will be taken in the future to ensure the availability of a 5water source during the re-license term. The available information documents that the current 6water source (John Redmond Reservoir) is reaching the end of its design life, and additional 7actions by USACE, WCGS, or some other entity will be required to either extend the life of the 8reservoir or provide a different source of water. These actions may or may not have impacts, 9and there may or may not be mitigation measures required for those impacts. Therefore, the 10Staff concludes that water use impacts would be SMALL to MODERATE.
11 12The Staff concluded that impacts to aquatic organisms in both Coffey County Lake and the 13Neosho River during the renewal term would be SMALL, if no water use impacts exist.
14However, if SMALL to MODERATE impacts occur due to water use conflicts, impingement 15impacts in the Neosho River could be SMALL to MODERATE. Similarly if SMALL to 16MODERATE impacts occur due to water use conflicts, impacts to a Federally-threatened 17species, the Neosho madtom, in the Neosho River could be SMALL to MODERATE.
18 19Research is continuing in the area of chronic effects of electromagnetic fields, and a scientific 20consensus has not been reached. Therefore, the Staff did not conduct an evaluation of this 21 issue.22 23Cumulative impacts of past, present, and reasonably foreseeable future actions were 24considered, regardless of what agency (Federal or non-Federal) or person undertakes such 25other actions. The Staff concluded that cumulative impacts of WCGS license renewal would be 26SMALL for all potentially affected resources, with the exception of the water use conflicts, for 27which impacts would be SMALL to MODERATE.
28 29 4.10 References 30 3110 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 32Protection Against Radiation."
33 3410 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 35Protection Regulations for Domestic Licensing and Related Regulatory Functions."
36 3710 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, "Licensing 38Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 39Waste, and Reactor Related Greater than Class C Waste."
40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-84 September 2007 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property
, 1Part 800, "Protection of Historic and Cultural Properties."
2 340 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 4"Environmental Radiation Protection Standards for Nuclear Power Operations."
5 640 CFR Part 423. Code of Federal Regulations, Title 40, Protection of Environment, Part 423, 7"Steam Electric Power Generating Point Source Category."
8 940 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment , Part 10 1508, "Terminology and Index."
11 12 Brock, T. D. 1974.Biology of Microorganisms. Prentice-Hall, Inc., Englewood Cliffs, New 13 Jersey. 14 15 Canadian Wildlife Service and U.S. Fish & Wildlife Service (CWS and FWS). 2007.
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17http://www.fws.gov/endangered. June 2007.
18 19Carlson, D. R. 1975. Sanitary Engineer, Water Pollution and Control, State of Kansas 20Department of Health and Environment, Topeka, Kansas. Letter dated April 10 to G. Koester, 21Kansas Gas and Electric Company, Wichita, Kansas.
22 23Carlson, D. R. 1976. Sanitary Engineer, Water Pollution Control, State of Kansas Department 24of Health and Environment, Topeka, Kansas. Letter dated February 3 to M. Miller, 25Environmental Coordinator, Kansas Gas and Electric Company, Wichita, Kansas.
26 27Clean Water Act of 1977 (CWA). 33 USC 1326 et seq. (common name of the Federal Water 28Pollution Control Act of 1977).
29 30 Colvin, M. A. 1993.Ecology and Management of White Bass: A Literature Review. Missouri 31Department of Conservation, Dingell-Johnson Project F-1-R-42, Study I-31, Job 1, Final Report.
32 33Council on Environmental Quality. (CEQ). 1997a. Environmental Justice: Guidance Under the 34National Environmental Policy Act. Executive Office of the President, Washington, DC.
35 36Council on Environmental Quality. (CEQ). 1997b. Considering Cumulative Impacts Under the 37National Environmental Policy Act. Executive Office of the President, Washington, DC.
38 Environmental Impacts of Operation September 2007 4-85 Draft NUREG-1437, Supplement 32 EA Engineering, Science, and Technology, Inc. (EA). 1985. Assessment of Cold Shock 1Potential for Six Target Species from the Wolf Creek Cooling Lake.
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3 4EA Engineering, Science, and Technology, Inc. (EA). 1988.
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15 16Edison Electric Institute. 2007. "Electric Companies and Vegetation Management." Accessed 17at: http://www.eei.org/industry_issues/environment/landvegetation_management/index.htm on 18June 20, 2007.
19 20Environmental Protection Agency (EPA). 2006. "National Recommended Water Quality 21Criteria." Office of Water.
22 23Executive Order 12898. "Federal Actions to Address Environmental Justice in Minority 24Populations and Low-Income Populations." Federal Register, Volume 59, Number 32, 25Washington DC, February 16, 1994.
26 27 Fish and Wildlife Service (FWS). 1991.Neosho Madtom Recovery Plan. FWS Region 6, 28Denver, CO. p. 42.
29 30Fish and Wildlife Service (FWS). 2007a. Letter from Michael J. LeValley, Field Supervisor, 31Kansas Ecological Services Field Office, FWS, Manhattan, Kansas, to Chief, Rules and 32Directives Branch, NRC, Washington, DC. Response to December 7, 2006 letter from NRC 33requesting information on federally listed, proposed, and candidate species and critical habitat 34that may be in the vicinity of WCGS and its transmission line ROW. January 29, 2007.
35 36 Fish & Wildlife Service (FWS). 2007b. Species Information, Threatened and Endangered 37Species System (TESS), Species Profiles. Accessed at:
38http://ecos.fws.gov/tess_public/StartTESS.do. June 2007.
39 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-86 September 2007 Fish & Wildlife Service (FWS). 2007c. Mountain-Prairie Region, Endangered Species Program.
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2 3Gray, M. W. 1974. Director, Division of Environment, State of Kansas Department of Health 4and Environment, Topeka, Kansas. Letter dated December 13 to G. Koester, Kansas Gas and 5Electric Company, Wichita, Kansas.
6 7Haines, D. E. 2000. "Biological Control of Gizzard Shad Impingement at a Nuclear Power 8 Plant."Environmental Science & Policy , 3: S275-S281.
9 10Hazelton Environmental Sciences. 1979. Final Report of Construction Environmental 11Monitoring Program Wolf Creek Generating Station, March 1978 - February 1979, Project No.
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17 18Kansas Department of Health and Environment (KDHE). 2004. Kansas Surface Water Quality 19Standards: Numeric Criteria. May 18, 2004.
20 21Kansas Department of Health and Environment (KDHE). 2006a.
Report of Radiological 22Environmental Monitoring of the Environs Surrounding Wolf Creek Generating Station, July 232005 to June 2006. Topeka, Kansas.
24 25Kansas Department of Health and Environment (KDHE). 2006b.
Report of Radiological 26Environmental Monitoring and the Environs Surrounding Wolf Creek Generating Station, July 272004 - June 2005. Division of Environment, Bureau of Air and Radiation, Radiation and 28Asbestos Control section. Topeka, Kansas.
29 30Kansas Department of Wildlife and Parks (KDWP). 2004. Threatened and Endangered 31Species, Species Information. Accessed at:
32 http://www.kdwp.state.ks.us/news/otherservices/threatenedandendangered_species/threatened 33and endangered species/speciesinformation. June 2007.
34 35Kansas Gas & Electric Company (KG&E). 1975. "Information on Facility Exemption from 36Discharge of Heat." Letter from G. Koester, Kansas Gas and Electric, Wichita, Kansas to M.
37Gray, Kansas Department of Health and Environment, Topeka, Kansas. April 4, 1975.
38 Environmental Impacts of Operation September 2007 4-87 Draft NUREG-1437, Supplement 32 Kansas Gas & Electric Company (KG&E). 1981.
Wolf Creek Generating Station, Makeup 1Screenhouse Impingement Monitoring Report, November 1980 - October 1981
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.4Accessed at: http://abyss.kgs.ku.edu/pls/abyss on June 8, 2007.
5 6Kansas Water Appropriation Act (KWAA). 2004. Statutes K.S.A. 82A-701 through 82A-737, and 7 K.S.A.42-313, 42-314 as Amended 2004. Accessed at:
8http://www.accesskansas.org/kda/dwr/laws-rules/kwaa.pdf on March 1, 2007.
9 10Kansas Water Office (KWO). 2001. "Minimum Desirable Steamflows". Accessed at:
11http://www.kwo.org/reports%20&%20publications/fact%20sheets/no_12_minimum_desirable_st 12reamflow.pdf on March 1, 2007.
13 14Kansas Water Office (KWO). 2004. "Kansas Water Plan, Neosho Basin Section". Accessed at:
15 http://www.kwo.org/kansas%20water%20plan/neo_basin/111804.pdf on January 3, 2007.
16 17Kansas Water Office (KWO). 2007.
John Redmond Lake Reservoir Fact Sheet. Accessed at:
18 http://www.kwo.org/reservoirinformation/reservoirfactsheets/john_redmond_lake.pdf on June 12, 19 2007).20 21Koester, G. L. 1974. Kansas Gas and Electric, Letter of November 14 to M. Gray, State 22of Kansas Department of Health and Environment, Topeka, Kansas.
23 24Koester, G. L. 1975. Kansas Gas and Electric, Letter of April 4 to M. Gray, Director, Division of 25Environment, State of Kansas Department of Health and Environment, Topeka, Kansas.
26 27Koester, G. L. 1982. Letter from G.L. Koester, Kansas Gas and Electric Company to U.S. NRC 28transmitting the Makeup Screenhouse Impingement Monitoring Report, November 1980 -
29 October 1981. March 19.
30 31Mettee M. F., P. E. O'Neil, and J. M. Pierson. 1996. Fishes of Alabama and the Mobile Basin
.32Oxmoor House. Birmingham, Alabama.
33 34 Moles, K. J. 2007.Wolf Creek 2006 Annual Environmental Operating Report. Wolf Creek 35Nuclear Operating Corporation. April 17, 2007. RA 07-0044.
36 37 Mosher,T. D. 2000.Assessment of a 254-mm Minimum Length Limit for Crappie in Three 38 Northeastern Kansas Reservoirs. Final Report. Kansas Department of Wildlife and Parks.
39Federal Aid Project No. FW-9-12 and F-30-R-1.
40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-88 September 2007 Muoneke, M. I., C. C. Henry, and O. E. Maughan. 1992. "Population Structure and Food Habits 1 of White Crappie Pomoxis annularis Rafinesque in a Turbid Oklahoma Reservoir."
Journal of 2 Fish Biology. Volume 1, p. 647. October.
3 4Nalco Environmental Sciences. 1976. Final Report of Preconstruction Environmental 5Monitoring Program WCGS, March 1975 - February 1976. Kansas Gas and Electric Company.
6Wichita, Kansas. May.
7 8Nalco Environmental Sciences. 1977. Final Report of Preconstruction Environmental 9Monitoring Program WCGS, March 1976 - February 1977. Kansas Gas and Electric Company.
10Wichita, Kansas. May.
11 12Nalco Environmental Sciences. 1978. Final Report of Preconstruction Environmental 13Monitoring Program WCGS, March 1977 - February 1978. Kansas Gas and Electric Company.
14Wichita, Kansas. May.
15 16National Electrical Safety Code (NESC). 1997. Institute of Electrical and Electric Engineers, 17 New York.
18 19 Nuclear Regulatory Commission (NRC). 1975.Final Environmental Statement related to 20Construction of Wolf Creek Generating Station, Unit 1. NUREG-175/096, Washington, DC.
21 22 Nuclear Regulatory Commission (NRC). 1982.Final Environmental Statement Related 23to the Operation of Wolf Creek Generating Station, Unit No. 1. NUREG-0878, Washington, DC.
24 25 Nuclear Regulatory Commission (NRC). 1984. Wolf Creek Generating Station, Unit No. 1 26Environmental Protection Plan, Appendix B to Facility Operating License No NPF-42.
27 28 Nuclear Regulatory Commission (NRC). 1996.Generic Environmental Impact Statement for 29License Renewal of Nuclear Power Plants. NUREG-1437 Volumes 1 and 2, Washington, DC.
30 31 Nuclear Regulatory Commission (NRC). 1996.Generic Environmental Impact Statement for 32License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, DC.
33 34 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 35License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1, 36Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report."
37NUREG-1437, Volume 1, Addendum 1, Washington, DC.
38 Environmental Impacts of Operation September 2007 4-89 Draft NUREG-1437, Supplement 32 Nuclear Regulatory Commission (NRC). 2006. Letter to Mike LeValley, Project Leader, U.S.
1Fish and Wildlife Service, Manhattan, Kansas: Request for list of protected species within the 2area under evaluation for the Wolf Creek Generating Station License Renewal Application 3review. December 7.
4 5 Nuclear Regulatory Commission (NRC). 2007. Letter from NRC to Wolf Creek Nuclear 6Operating Corporation Regarding Summary of Environmental Site Audit Related to the Review 7of the License Renewal Application for Wolf Creek Generating Station, Unit 1. April 27.
8 9Putnam, J. E., and D. R. Schneider. 2005. Water Resources Data - Kansas, Water Year 2004
.10Water-Data Report KS-04-1. U.S. Geological Survey, Lawrence, Kansas.
11 12Portier, C. J., and M. S. Wolfe, eds. 1999. Assessment of Health Effects from Exposure to 13Power-Line Frequency Electric and Magnetic Field. Working Group Report, National Institute of 14Environmental Health Sciences of the National Institutes of Health. p. 508.
15 16Staab, E. C. 2007. Letter from Eric C. Staab, Industrial Programs Section, Bureau of Water, 17Kansas Department of Health and Environmental, Topeka, KS, to Kevin J. Molec, WCNOC, 18Burlington, KS, regarding WCGS 316(b) Water Transfer Information, NPDES Permit No. I-19NE07-P002. January 23.
20 21State of Kansas Department of Agriculture, Division of Water Resources. 1977a. "Approval of 22Application and Permit to proceed, Appropriation of Water for Beneficial Use File Number 23 20,275." August, 1977.
24 25State of Kansas Department of Agriculture, Division of Water Resources. 1977b. "Approval of 26Application and Permit to proceed, Appropriation of Water for Beneficial Use File Number 27 14,626." August, 1977.
28 29State of Kansas Department of Agriculture, Division of Water Resources. 1977c. "Approval of 30Application and Permit to proceed, Appropriation of Water for Beneficial Use File Number 31 19,882." August, 1977.
32 33State of Kansas Water Resources Board. 1976. "Water Purchase Contract Number 76-2."
34 35TetraTech NUS (TTNUS). 2005. "Calculation Package for Wolf Creek Transmission Lines 36Induced Current Analysis." Aiken, South Carolina. May.
37 38 U.S. Army Corp of Engineers (USACE). 2002.Draft Supplement to the Final Environmental 39Impact Statement Prepared for the
- Reallocation of Water Supply Storage Project: John 40Redmond Lake, Kansas.
41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-90 September 2007 U.S. Census Bureau (USCB). 2000. Census of Population and Housing 2000, Summary File 3, 1Tables P6 and P7. Accessed at: http://factfinder.census.gov in July 2007.
2 3U.S. Geological Survey (USGS). 1979. Burlington Quadrangle, 7.5 Minute Series Topographic 4 Map , Photorevised 1979.
5 6Wedd, G. R. 1985. "Observations on Neosho River Larval Fish in Coffey County, Kansas."
7The Emporia State Research Studies, Volume XXXIV, Number 1. pp. 5-56.
8 9Westar Energy, Inc. (Westar). Undated. Docket Number WCNOC-082. "Transmission Line 10Vegetation Management Program".
11 12 Wolf Creek Generating Station (WCGS). 1980.Wolf Creek Generating Station Unit No. 1, 13Environmental Report, Operating License Stage - Volume 1. Burlington, Kansas.
14 15Wolf Creek Nuclear Operating Corporation (WCNOC). 1987a. Evaluation of the Environmental 16Effects of Higher-than-Postulated Condenser Delta T's, LI 87-0092, Interoffice correspondence 17from Brad Loveless to TE: 42072, February 12.
18 19Wolf Creek Nuclear Operating Corporation (WCNOC). 1987b. "Naegleria fowleri Test Results", 20LI 87-0627, interoffice correspondence from Greg Wedd to Distribution, October 16, 1987, with 21attached letter and data table from R. L.Tyndall, Microbial Monitoring, Clinton, Tennessee, to 22Brad Loveless, Wolf Creek Nuclear Operating Corporation, Burlington, Kansas, September 20, 23 1987.24 25Wolf Creek Nuclear Operating Corporation (WCNOC). 1988.
Wolf Creek Generating Station 261987-1988 Operational Wildlife Monitoring Report.
Engineering and Technical Services, 27Environmental Management Group. November.
28 29Wolf Creek Nuclear Operating Corporation (WCNOC). 1993. Wolf Creek Generating Station 30Aquatic Monitoring, 1992 Reports and 1993 Plans. Internal document. March 1993.
31 32Wolf Creek Nuclear Operating Corporation (WCNOC). 2003a.
Wolf Creek Generating Station 33Annual Environmental Operating Report 2002. Burlington, Kansas.
34 35Wolf Creek Nuclear Operating Corporation (WCNOC). 2003b.
2002 Annual Radiological 36Environmental Operating. Burlington, Kansas.
37 38Wolf Creek Nuclear Operating Corporation (WCNOC). 2004a.
Wolf Creek Generating Station 39Annual Environmental Operating Report 2003. Burlington, Kansas.
40 Environmental Impacts of Operation September 2007 4-91 Draft NUREG-1437, Supplement 32 Wolf Creek Nuclear Operating Corporation (WCNOC). 2004b.
2003 Annual Radiological 1Environmental Operating. Burlington, Kansas.
2 3Wolf Creek Nuclear Operating Corporation (WCNOC). 2005a. Wolf Creek Generating Station, 4Annual Environmental Operating Report 2004. Burlington, Kansas.
5 6Wolf Creek Nuclear Operating Corporation (WCNOC). 2005b.
2004 Annual Radiological 7Environmental Operating. Burlington, Kansas.
8 9Wolf Creek Nuclear Operating Corporation (WCNOC). 2006a. Applicant's Environmental 10Report; Operating License Renewal Stage. Appendix E of License Renewal Application, Wolf 11Creek Generating Station Unit 1, Docket Number. 50-482, Facility Operating License No. NPF-12 42, (Revision 0).
13 14Wolf Creek Nuclear Operating Corporation (WCNOC). 2006b.
Wolf Creek Generating Station 15Annual Environmental Operating Report 2005.
Burlington, Kansas.
16 17Wolf Creek Nuclear Operating Corporation (WCNOC). 2006c. Enclosure 1 to WM 06-0046 An 18Assessment of the Potential Impacts on the Flow of the Neosho River Related to the Operating 19License Renewal for Wolf Creek Generating Station. Contained in: Letter from Matthew W.
20Sunseri, Wolf Creek Nuclear Operating Corporation to U.S. Nuclear Regulatory Commission 21regarding Docket Number 50-482: Supplementary Environmental Information to Support the 22Application for Renewed Operating License for Wolf Creek Generating Station. WM 06-0046.
23November 17, 2006.
24 25Wolf Creek Nuclear Operating Corporation (WCNOC). 2006d. Enclosure 2 to WM 06-0046, An 26Assessment of the Impact on Fish and Shellfish Resources from Entrainment Related to the 27Operating License Renewal for Wolf Creek Generating Station, Unit No. 1. Contained in: Letter 28from Matthew W. Sunseri, Wolf Creek Nuclear Operating Corporation to U.S. Nuclear 29 Regulatory Commission regarding Docket 50-482: Supplementary Environmental Information to 30Support the Application for Renewed Operating License for Wolf Creek Generating Station.
31WM 06-0046. November 17, 2006.
32 33Wolf Creek Nuclear Operating Corporation (WCNOC). 2006e. Enclosure 3 to WM 06-0046, An 34Assessment of the Potential Impacts on Fish and Shellfish Resources from Impingement 35Related to the Operating License Renewal for Wolf Creek Generating Station, Unit No. 1
.36Contained in: Letter from Matthew W. Sunseri, Wolf Creek Nuclear Operating Corporation to 37U.S. Nuclear Regulatory Commission regarding Docket Number 50-482: Supplementary 38Environmental Information to Support the Application for Renewed Operating License for Wolf 39Creek Generating Station. WM 06-0046. November 17, 2006.
40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 32 4-92 September 2007 Wolf Creek Nuclear Operating Corporation (WCNOC). 2006f. Enclosure 4 to WM 06-0046, An 1Assessment of the Impact on Fish and Shellfish Resources from Heat Shock Related to the 2Operating License Renewal for Wolf Creek Generating Station, Unit Number 1. Contained in:
3Letter from Matthew W. Sunseri, Wolf Creek Nuclear Operating Corporation to U.S. Nuclear 4Regulatory Commission regarding Docket Number 50-482: Supplementary Environmental 5Information to Support the Application for Renewed Operating License for Wolf Creek 6Generating Station. WM 06-0046. November 17, 2006.
7 8Wolf Creek Nuclear Operating Corporation (WCNOC). 2006g. Wolf Creek Generating Station 92005 Annual Radiological Environmental Operating Report. Burlington, Kansas.
10 11Wolf Creek Nuclear Operating Corporation (WCNOC). 2006h. Avian Protection Plan at Wolf 12Creek Generating Station. August. p. 30.
13 14Wolf Creek Nuclear Operating Corporation (WCNOC). 2006i. 2005 Annual Radiological 15Environmental Operating. Burlington, Kansas.
16Wolf Creek Nuclear Operating Corporation (WCNOC). 2007a. Biological Assessment of 17Potential Impact to the Neosho Madtom and Neosho Mucket Due to License Renewal of Wolf 18Creek Generating Station. Burlington, Kansas. March.
19 20Wolf Creek Nuclear Operating Corporation (WCNOC). 2007b. "Docket Number 50-482:
21Response to NRC Request for Additional Information Related to Wolf Creek Generating Station 22License Renewal Application." Item Number M56. Letter from Terry J. Garrett, Wolf Creek 23Nuclear Operating Corporation, to NRC Document Control Desk, Washington, DC, May 9, 2007.
24 25Wolf Creek Nuclear Operating Corporation (WCNOC). 2007c. "Docket Number 50-482:
26Response to NRC Request for Additional Information Related to Wolf Creek Generating Station 27License Renewal Application." Item Number R57. Letter from Terry J. Garrett, Wolf Creek 28Nuclear Operating Corporation, to NRC Document Control Desk, Washington, DC, May 9, 2007.
29 30Wolf Creek Nuclear Operating Corporation (WCNOC). 2007d.
2006 Annual Radiological 31Environmental Operating. Burlington, Kansas.
32 September 2007 5-1 Draft NUREG-1437, Supplement 32 5.0 Environmental Impacts of Postulated Accidents 1 2 3Environmental issues associated with postulated accidents are discussed in the Generic 4Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 5Volumes 1 and 2 (NRC 1996, 1999).(a) The GEIS includes a determination of whether the 6analysis of the environmental issue could be applied to all plants and whether additional 7mitigation measures would be warranted. Issues are then assigned a Category 1 or a 8Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 9the following criteria:
10 11(1) The environmental impacts associated with the issue have been determined to apply 12either to all plants or, for some issues, to plants having a specific type of cooling system 13or other specified plant or site characteristics.
14 15(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 16the impacts (except for collective off-site radiological impacts from the fuel cycle and 17from high-level waste and spent fuel disposal).
18 19(3) Mitigation of adverse impacts associated with the issue has been considered in the 20analysis, and it has been determined that additional plant-specific mitigation measures 21are likely not to be sufficiently beneficial to warrant implementation.
22 23For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 24required unless new and significant information is identified.
25 26Category 2 issues are those that do not meet one or more of the criteria for Category 1:
27therefore, additional plant-specific review of these issues is required.
28 29This chapter describes the environmental impacts from postulated accidents that might occur 30during the license renewal term.
31 325.1 Postulated Plant Accidents 33 34Two classes of accidents are evaluated in the GEIS. These are design-basis accidents and 35severe accidents, as discussed below.
36 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the A GEIS@ include the GEIS and Addendum 1.
Environmental Impacts of Postulated Accidents Draft NUREG-1437, Supplement 32 5-2 September 2007 5.1.1 Design-Basis Accidents 1 2In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 3power facility, an applicant for an initial operating license (OL) must submit a Safety Analysis 4Report (SAR) as part of its application. The SAR presents the design criteria and design 5information for the proposed reactor and comprehensive data on the proposed site. The SAR 6also discusses various hypothetical accident situations and the safety features that are provided 7to prevent and mitigate accidents. The NRC staff reviews the application to determine whether 8the plant design meets the Commission
=s regulations and requirements and includes, in part, 9the nuclear plant design and its anticipated response to an accident.
10 11Design-basis accidents (DBAs) are those accidents that both the licensee and the NRC staff 12evaluate to ensure that the plant can withstand normal and abnormal transients, and a broad 13spectrum of postulated accidents, without undue hazard to the health and safety of the public.
14A number of these postulated accidents are not expected to occur during the life of the plant, 15but are evaluated to establish the design basis for the preventive and mitigative safety systems 16of the facility. The acceptance criteria for DBAs are described in Title 10 of the Code of Federal 17Regulations Part 50 and Part 100 (10 CFR Part 50 and 10 CFR Part 100).
18 19The environmental impacts of DBAs are evaluated during the initial licensing process, and the 20ability of the plant to withstand these accidents is demonstrated to be acceptable before 21issuance of the OL. The results of these evaluations are found in license documentation such 22 as the applicant
=s Final Safety Analysis Report (FSAR), the NRC staff
=s Safety Evaluation 23Report (SER), the Final Environmental Statement (FES), and Section 5.1 of this Supplemental 24Environmental Impact Statement (SEIS). A licensee is required to maintain the acceptable 25design and performance criteria throughout the life of the plant, including any extended-life 26operation. The consequences for these events are evaluated for the hypothetical maximally 27exposed individual; as such, changes in the plant environment will not affect these evaluations.
28Because of the requirements that continuous acceptability of the consequences and aging 29management programs be in effect for license renewal, the environmental impacts as calculated 30for DBAs should not differ significantly from initial licensing assessments over the life of the 31plant, including the license renewal period. Accordingly, the design of the plant relative to DBAs 32during the extended period is considered to remain acceptable, and the environmental impacts 33of those accidents were not examined further in the GEIS.
34 35The Commission has determined that the environmental impacts of DBAs are of SMALL 36significance for all plants because the plants were designed to successfully withstand these 37accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 38Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The early resolution of 39the DBAs makes them a part of the current licensing basis of the plant; the current licensing 40basis of the plant is to be maintained by the licensee under its current license and, therefore, 41 Environmental Impacts of Postulated Accidents September 2007 5-3 Draft NUREG-1437, Supplement 32 under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This 1issue, applicable to Wolf Creek Generating Station (WCGS), is listed in Table 5-1.
2 3 Table 5-1. Category 1 Issues Applicable to Postulated Accidents During the Renewal Term 4 5 ISSUE B10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections POSTULATED A CCIDENTSDesign-basis accidents 5.3.2; 5.5.1 6Based on information in the GEIS, the Commission found that:
7 8The NRC staff has concluded that the environmental impacts of design-basis 9accidents are of small significance for all plants.
10 11Wolf Creek Nuclear Operating Corporation (WCNOC) stated in its Environmental Report (ER) 12(WCNOC 2006a) that it is not aware of any new and significant information associated with the 13renewal of the WCGS OL. The NRC staff has not identified any new and significant information 14during its independent review of the WCGS ER, the site visit, the scoping process, evaluation of 15other available information. Therefore, the NRC staff concludes that there are no impacts 16related to DBAs beyond those discussed in the GEIS.
17 185.1.2 Severe Accidents 19 20Severe nuclear accidents are those that are more severe than DBAs because they could result 21in substantial damage to the reactor core, regardless of off-site consequences. In the GEIS, the 22NRC staff assessed the impacts of severe accidents using the results of existing analyses and 23site-specific information to conservatively predict the environmental impacts of severe accidents 24for each plant during the renewal period.
25 26Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes, 27fires, and sabotage, traditionally have not been discussed in quantitative terms in FESs and 28were not specifically considered for the WCGS site in the GEIS. However, in the GEIS, the 29NRC staff did evaluate existing impact assessments performed by the NRC and by the industry 30at 44 nuclear plants in the United States and concluded that the risk from beyond-design-basis 31earthquakes at existing nuclear power plants is SMALL. The GEIS for license renewal 32performed a discretionary analysis of terrorist acts in connection with license renewal, and 33concluded that the core damage and radiological release from such acts would be no worse 34than the damage and release expected from internally initiated events. In the GEIS, the 35Commission concludes that the risk from sabotage and beyond-design-basis earthquakes at 36existing nuclear power plants is small and, additionally, that the risks from other external events 37 Environmental Impacts of Postulated Accidents Draft NUREG-1437, Supplement 32 5-4 September 2007 are adequately addressed by a generic consideration of internally initiated severe accidents 1(GEIS, Vol. 1, p. 5-18).
2 3Based on information in the GEIS, the Commission found that:
4 5The probability weighted consequences of atmospheric releases, fallout onto 6open bodies of water, releases to groundwater, and societal and economic 7impacts from severe accidents are small for all plants. However, alternatives to 8mitigate severe accidents must be considered for all plants that have not 9considered such alternatives.
10 11Therefore, the Commission has designated mitigation of severe accidents as a Category 2 issue 12in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue, applicable to WCGS, is listed 13in Table 5-2.
14 15 Table 5-2. Category 2 Issues Applicable to Postulated Accidents During the Renewal Term 16 17 ISSUE B10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section POSTULATED A CCIDENTSSevere 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 L 5.2 18The NRC staff has not identified any new and significant information with regard to the 19consequences from severe accidents during its independent review of the WCGS ER 20(WCNOC 2006a), the site visit, the scoping process, or evaluation of other available information.
21Therefore, the NRC staff concludes that there are no impacts of severe accidents beyond those 22discussed in the GEIS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the NRC staff 23has reviewed severe accident mitigation alternatives (SAMAs) for WCGS. The results of its 24review are discussed in Section 5.2.
25 265.2 Severe Accident Mitigation Alternatives 27 28Section 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to 29mitigate severe accidents if the Staff has not previously evaluated SAMAs for the applicant's 30plant in an environmental impact statement (EIS) or related supplement or in an environmental 31assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware, 32procedures, and training) with the potential for improving severe accident safety performance 33are identified and evaluated. SAMAs have not been previously considered for Wolf Creek 34 Environmental Impacts of Postulated Accidents September 2007 5-5 Draft NUREG-1437, Supplement 32 Generating Station (WCGS); therefore, the remainder of Chapter 5 addresses those 1alternatives.
2 3 5.2.1 Introduction 4 5This section summarizes the SAMA evaluation conducted by Wolf Creek Nuclear Operating 6Corporation (WCNOC) and the NRC staff's review of this evaluation. The NRC staff performed 7its review with contract assistance from Information Systems Laboratories, Inc. The NRC staff's 8review is available in full in Appendix G; the SAMA evaluation is available in full in WCNOC's 9 ER.10 11The SAMA evaluation for WCGS was conducted with a four-step approach. In the first step 12WCNOC quantified the level of risk associated with potential reactor accidents using the plant-13specific probabilistic safety assessment (PSA) and other risk models.
14 15In the second step WCNOC examined the major risk contributors and identified possible ways 16(SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 17systems, procedures, and training. WCNOC initially identified 19 potential SAMAs for WCGS.
18WCNOC screened out 4 SAMAs from further consideration because they were determined to 19provide no measurable benefit or to have estimated costs that would exceed the dollar value 20associated with completely eliminating all severe accident risk at WCGS. The remaining 15 21SAMAs were subjected to further evaluation.
22 23In the third step WCNOC estimated the benefits and the costs associated with each of the 24remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 25estimates were developed in terms of dollars in accordance with NRC guidance for performing 26regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs was also 27 estimated.
28 29Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were 30 compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the 31SAMA were greater than the cost (a positive cost-benefit). WCNOC found three SAMAs to be 32potentially cost-beneficial in the baseline analysis, and four additional SAMAs to be potentially 33cost-beneficial when analysis uncertainties are considered (WCNOC 2006b).
34 35The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging 36during the period of extended operation; therefore, they need not be implemented as part of 37license renewal pursuant to 10 CFR Part 54. WCNOC's SAMA analyses and the NRC's review 38 are discussed in more detail below.
39 Environmental Impacts of Postulated Accidents Draft NUREG-1437, Supplement 32 5-6 September 2007 5.2.2 Estimate of Risk 1 2WCNOC submitted an assessment of SAMAs for WCGS as part of the ER (WCNOC 2006b).
3This assessment was based on the most recent WCGS PSA available at that time, a plant-4specific offsite consequence analysis performed using the MELCOR Accident Consequence 5Code System 2 (MACCS2) computer program, and insights from the WCGS Individual Plant 6Examination (IPE) (WCNOC 1992) and Individual Plant Examination of External Events (IPEEE; 7WCNOC 1995).
8 9The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is 10approximately 3.0 x 10
-5 per year. This CDF is based on the risk assessment for internally-11initiated events. WCNOC did not include the contribution to risk from external events within the 12WCGS risk estimates; however, it did account for the potential risk reduction benefits associated 13with external events by increasing the estimated benefits for internal events by a factor of two.
14The breakdown of CDF by initiating event is provided in Table 5-3.
15 16 Table 5-3. WCGS Core Damage Frequency 17 18 Initiating Event CDF(Per Year)
%Contribution to CDFLoss of Offsite Power 1.7 x 10
-5 57 Small LOCA 7.0 x 10
-6 23 Interfacing System LOCA 1.9 x 10
-6 6 Very Small LOCA 1.3 x 10
-6 4 Steam Generator Tube Rupture 8.7 x 10
-7 3 Transients With Power Conversion Systems Available 3.9 x 10-7 1 Reactor Vessel Failure 3.0 x 10
-7 1 Steamline Break 2.4 x 10
-7 1 Transients Without Power Conversion Systems Available 1.8 x 10-7 1 Loss of Vital DC Bus NK04 1.5 x 10
-7 1 Medium LOCA 1.4 x 10
-7 <1 Loss of Vital DC Bus NK01 1.2 x 10
-7 <1 Loss of All Service Water 8.6 x 10
-8 <1 Environmental Impacts of Postulated Accidents September 2007 5-7 Draft NUREG-1437, Supplement 32 Table 5-3. (contd) 1 2 Initiating Event CDF(Per Year)
%Contribution to CDFLoss of Component Cooling Water 5.8 x 10
-8 <1 Feedwater Line Break 3.3 x 10
-8 <1 Large LOCA 2.8 x 10
-8 <1 Total CDF (internal events) 3.0 x 10
-5 100 3As shown in Table 5-3, events initiated by loss of offsite power and small break loss of coolant 4accident (LOCA) are the dominant contributors to CDF. Although not separately reported, 5station blackout (SBO) sequences contribute 1.7 x 10
-5 per year (about 55 percent of the total 6internal events CDF), while anticipated transient without scram (ATWS) sequences are not 7present in the dominant sequences.
8 9WCNOC estimated the dose to the population within 80 km (50 mi) of the WCGS site to be 10approximately 0.0286 person-Sv (2.86 person-rem) per year. The breakdown of the total 11population dose by containment release mode is summarized in Table 5-4. Interfacing system 12LOCA (ISLOCA) and containment failures within the early time frame (less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 13following accident initiation) dominate the population dose risk at WCGS.
14 15 Table 5-4. Breakdown of Population Dose by Containment Release Mode 16 17Containment Release Mode Population Dose (Person-Rem 1 Per Year)
%ContributionEarly Containment Failure0.145Late Containment Failure0.041Containment Bypass - Steam Generator Tube Ruptures (SGTR)0.041Containment Bypass - ISLOCA2.5589Containment Bypass - Isolation FailureNegligible<1Intact Containment0.093 Total2.86100 1One person-Rem = 0.01 person-Sv 18 19The NRC staff has reviewed WCNOC's data and evaluation methods and concludes that the 20quality of the risk analyses is adequate to support an assessment of the risk reduction potential 21for candidate SAMAs. Accordingly, the Staff based its assessment of offsite risk on the CDFs 22and offsite doses reported by WCNOC.
23 Environmental Impacts of Postulated Accidents Draft NUREG-1437, Supplement 32 5-8 September 2007 5.2.3 Potential Plant Improvements 1 2Once the dominant contributors to plant risk were identified, WCNOC searched for ways to 3reduce that risk. In identifying and evaluating potential SAMAs, WCNOC considered insights 4from the plant-specific PSA, and SAMA analyses performed for other operating plants that have 5submitted license renewal applications. WCNOC identified 19 potential risk-reducing 6improvements (SAMAs) to plant components, systems, procedures and training.
7 8WCNOC removed 4 SAMAs from further consideration because they were determined to 9provide no measurable benefit or to have estimated costs that would exceed the dollar value 10associated with completely eliminating all severe accident risk at WCGS. A detailed cost-11benefit analysis was performed for each of the 15 remaining SAMAs.
12 13The Staff concludes that WCNOC used a systematic and comprehensive process for identifying 14potential plant improvements for WCGS, and that the set of potential plant improvements 15identified by WCNOC is reasonably comprehensive and, therefore, acceptable.
16 175.2.4 Evaluation of Risk Reduction and Costs of Improvements 18 19WCNOC evaluated the risk-reduction potential of the remaining 15 SAMAs. The SAMA 20evaluations were performed using realistic assumptions with some conservatism.
21 22WCNOC estimated the costs of implementing the 15 candidate SAMAs through the application 23of engineering judgement, and use of other licensees' estimates for similar improvements. The 24cost estimates conservatively did not include the cost of replacement power during extended 25outages required to implement the modifications, nor did they include contingency costs 26associated with unforeseen implementation obstacles.
27 28The Staff reviewed WCNOC's bases for calculating the risk reduction for the various plant 29improvements and concludes that the rationale and assumptions for estimating risk reduction 30are reasonable and somewhat conservative (i.e., the estimated risk reduction is similar to or 31somewhat higher than what would actually be realized). Accordingly, the Staff based its 32estimates of averted risk for the various SAMAs on WCNOC's risk reduction estimates.
33The Staff reviewed the bases for the applicant's cost estimates. For certain improvements, the 34Staff also compared the cost estimates to estimates developed elsewhere for similar 35improvements, including estimates developed as part of other licensees' analyses of SAMAs for 36operating reactors and advanced light-water reactors. The Staff found the cost estimates to be 37consistent with estimates provided in support of other plants' analyses.
38 39The Staff concludes that the risk reduction and the cost estimates provided by WCNOC are 40sufficient and appropriate for use in the SAMA evaluation.
41 Environmental Impacts of Postulated Accidents September 2007 5-9 Draft NUREG-1437, Supplement 32 5.2.5 Cost-Benefit Comparison 1 2The cost-benefit analysis performed by WCNOC was based primarily on NUREG/BR-0184 3 (NRC 1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently 4been revised to reflect the agency's revised policy on discount rates. Revision 4 of NUREG/BR-50058 states that two sets of estimates should be developed - one at three percent and one at 6seven percent (NRC 2004). WCNOC provided both sets of estimates (WCNOC 2006b).
7 8WCNOC identified three potentially cost-beneficial SAMAs in the baseline analysis contained in 9the ER (using a three percent discount rate). The potentially cost-beneficial SAMAs are:
10 11 SAMA 2 - Modify controls and operating procedures to permit the diesel generators at 12the Sharpe Station to be more rapidly aligned to the WCGS emergency buses in SBO 13 events.14 15 SAMA 4, Case 2 - Proceduralize operator actions to perform local isolations of any 16valves that fail to close remotely in an interfacing system LOCA.
17 18 SAMA 5 - Modify procedures to open emergency diesel generator room doors to provide 19alternate room cooling given failure of the heating ventilation and air-conditioning 20(HVAC) supply fan.
21 22WCNOC performed additional analyses to evaluate the impact of parameter choices and 23uncertainties on the results of the SAMA assessment (WCNOC 2006b). If the benefits are 24increased by a factor of 1.9 to account for uncertainties, four additional SAMA candidates were 25determined to be potentially cost-beneficial:
26 27 SAMA 1 - Install a permanent, dedicated generator for the normal charging pump (NCP) 28in order to provide reactor coolant pump seal cooling in SBO events.
29 30 SAMA 3 - Provide the capability to cross-tie between 4kV AC buses in the event of a 31loss of power to one bus.
32 33 SAMA 13 - Install an alternative fuel oil tank with gravity feed capability to address fuel 34oil transfer failure events.
35 36 SAMA 14 - Install a permanent, dedicated generator for the NCP (similar to SAMA 1), 37and a motor-driven auxiliary feedwater (AFW) pump and battery charger to address SBO 38events in which the turbine-driven AFW pump is unavailable.
39 Environmental Impacts of Postulated Accidents Draft NUREG-1437, Supplement 32 5-10 September 2007 The Staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 1above, the costs of the SAMAs evaluated would be higher than the associated benefits.
2 3 5.2.6 Conclusions 4 5The Staff reviewed WCNOC's analysis and concluded that the methods used and the 6implementation of those methods were sound. The treatment of SAMA benefits and costs 7support the general conclusion that the SAMA evaluations performed by WCNOC are 8reasonable and sufficient for the license renewal submittal. Although the treatment of SAMAs 9for external events was somewhat limited by the unavailability of an external event PSA, the 10likelihood of there being cost-beneficial enhancements in this area was minimized by 11improvements that have been realized as a result of the IPEEE process, and increasing the 12estimated SAMA benefits for internal events by a factor of two to account for potential benefits 13 in external events.
14 15Based on its review of the SAMA analysis, the Staff concurs with WCNOC's identification of 16areas in which risk can be further reduced in a cost-beneficial manner through the 17implementation of all or a subset of potentially cost-beneficial SAMAs. Given the potential for 18cost-beneficial risk reduction, the Staff considers that further evaluation of these SAMAs by 19WCNOC is warranted. However, none of the potentially cost-beneficial SAMAs relate to 20adequately managing the effects of aging during the period of extended operation. Therefore, 21they need not be implemented as part of the license renewal pursuant to 10 CFR Part 54.
22 23 5.3 References 24 2510 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 26Production and Utilization Facilities."
27 2810 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 29Protection Regulations for Domestic Licensing and Related Regulatory Functions."
30 3110 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 32Renewal of Operating Licenses for Nuclear Power Plants."
33 3410 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, "Physical Protection of 35Plants and Materials."
36 3710 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site 38 Criteria."
39 Environmental Impacts of Postulated Accidents September 2007 5-11 Draft NUREG-1437, Supplement 32 Nuclear Regulatory Commission (NRC). 1996.Generic Environmental Impact Statement for 1License Renewal of Nuclear Power Plants. NUREG-1437 Volumes 1 and 2, Washington, DC.
2 3 Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 4 Handbook. NUREG/BR-0184, Washington, DC.
5 6 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 7License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1, 8Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report."
9NUREG-1437, Volume 1, Addendum 1, Washington, DC.
10 11 Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.
12Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, DC.
13 14Wolf Creek Nuclear Operating Corporation (WCNOC). 1992. Letter from Bart D. Withers, 15WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket 16Number 50-482: Wolf Creek Generating Station Individual Plant Examination. September 28, 17 1992.18 19Wolf Creek Nuclear Operating Corporation (WCNOC). 1995. Letter from Robert C. Hagan, 20WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket 21Number 50-482: Final Response to Generic Letter 88-20. Supplement 4 (IPEEE Submittal).
22June 27, 1995.
23 24Wolf Creek Nuclear Operating Corporation (WCNOC). 2006a. Applicant's Environmental 25Report; Operating License Renewal Stage. Appendix E of License Renewal Application, Wolf 26Creek Generating Station Unit 1, Docket Number 50-482, Facility Operating License Number 27 NPF-42, (Revision 0).
28 29Wolf Creek Nuclear Operating Corporation (WCNOC). 2006b. Letter from Terry J. Garrett, 30WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket 31Number 50-482: Application for Renewed Operating License, September 27, 2006.
32
September 2007 6-1 Draft NUREG-1437, Supplement 296.0 Environmental Impacts of the Uranium Fuel 1 Cycle and Solid Waste Management 2 3 4Environmental issues associated with the uranium fuel cycle and solid waste management are 5discussed in the Generic Environmental Impact Statement for License Renewal of Nuclear 6 Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999.)(a) The GEIS includes a 7determination of whether the analysis of the environmental issue could be applied to all plants 8and whether additional mitigation measures would be warranted. Issues are then assigned a 9Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues are those 10that meet all of the following criteria:
11 12(1) The environmental impacts associated with the issue have been determined to apply 13either to all plants or, for some issues, to plants having a specific type of cooling system 14or other specified plant or site characteristics.
15 16(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 17the impacts (except for collective off-site radiological impacts from the fuel cycle and 18from high-level waste [HLW] and spent fuel disposal).
19 20(3) Mitigation of adverse impacts associated with the issue has been considered in the 21analysis, and it has been determined that additional plant-specific mitigation measures 22are likely not to be sufficiently beneficial to warrant implementation.
23 24For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 25required unless new and significant information is identified.
26 27Category 2 issues are those that do not meet one or more of the criteria for Category 1; 28therefore, additional plant-specific review of these issues is required.
29 30This chapter addresses the issues that are related to the uranium fuel cycle and solid waste 31management during the license renewal term that are listed in Table B-1 of Title 10 of the Code 32of Federal Regulations (CFR) Part 51, Subpart A, Appendix B, and are applicable to Wolf Creek 33Generating Station (WCGS). The generic potential impacts of the radiological and 34nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear 35fuel and wastes are described in detail in the GEIS based, in part, on the generic impacts 36provided in 10 CFR 51.51(b), Table S-3, "Table of Uranium Fuel Cycle Environmental Data,"
37and in 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and Waste 38to and from One Light-Water-Cooled Nuclear Power Reactor." The U.S. Nuclear Regulatory 39 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.
Fuel Cycle Draft NUREG-1437, Supplement 29 6-2 September 2007 Commission (NRC) staff also addresses the impacts from radon-222 and technetium-99 in the 1 GEIS.2 36.1 The Uranium Fuel Cycle 4 5Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to 6WCGS from the uranium fuel cycle and solid waste management are listed in Table 6-1.
7 8 Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste 9Management During the Renewal Term 10 11ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1GEIS Section URANIUM FUEL CYCLE AND WASTE MANAGEMENTOff-site radiological impacts (individual effects from other than the disposal of spent fuel and high level waste) 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4Off-site radiological impacts (collective effects)6.2.2.1; 6.2.3; 6.2.4Off-site radiological impacts (spent fuel and high level waste disposal)6.2.2.1; 6.2.2.2; 6.2.3; 6.2.4Nonradiological impacts of the uranium fuel cycle6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4Low-level waste storage and disposal6.2.2.2; 6.4.2; 6.4.3 Mixed waste storage and disposal6.4.5On-site spent fuel6.4.6Nonradiological waste6.5 Transportation6.3, Addendum 1 12Wolf Creek Nuclear Operating Corporation (WCNOC) stated in its Environmental Report (ER) 13(WCNOC 2006) that it is not aware of any new and significant information associated with the 14renewal of the WCGS operating license. The Staff has not identified any new and significant 15information during its independent review of the WCGS ER (WCNOC 2006), the site audit, the 16scoping process, or evaluation of other available information. Therefore, the Staff concludes 17that there are no impacts related to these issues beyond those discussed in the GEIS. For 18these issues, the Staff concluded in the GEIS that the impacts are SMALL except for the 19collective off-site radiological impacts from the fuel cycle and from HLW and spent fuel disposal, 20as discussed below, and that additional plant-specific mitigation measures are not likely to be 21sufficiently beneficial to be warranted.
22 Fuel Cycle September 2007 6-3 Draft NUREG-1437, Supplement 32A brief description of the Staff review and the GEIS conclusions, as codified in Table B-1, 10 1CFR Part 51, for each of these issues follows:
2 3 Off-site radiological impacts (individual effects from other than the disposal of spent fuel 4 and high level waste). Based on information in the GEIS, the Commission found that:
5 6Off-site impacts of the uranium fuel cycle have been considered by the Commission in 7Table S-3 of this part (10 CFR 51.51[b]). Based on information in the GEIS, impacts on 8individuals from radioactive gaseous and liquid releases including radon-222 and 9 technetium-99 are small.
10 11The Staff has not identified any new and significant information during its independent 12review of the WCNOC ER (WCNOC 2006), the site audit, the scoping process, or evaluation 13of other available information. Therefore, the Staff concludes that there are no off-site 14radiological impacts (individual effects) of the uranium fuel cycle during the renewal term 15beyond those discussed in the GEIS.
16 17 Off-site radiological impacts (collective effects). Based on information in the GEIS, the 18Commission found that:
19 20The 100 year environmental dose commitment to the U.S. population from the 21fuel cycle, high level waste and spent fuel disposal excepted, is calculated to be 22about 14,800 person rem, or 12 cancer fatalities, for each additional 20-year 23power reactor operating term. Much of this, especially the contribution of radon 24releases from mines and tailing piles, consists of tiny doses summed over large 25populations. This same dose calculation can theoretically be extended to include 26many tiny doses over additional thousands of years as well as doses outside the 27U.S. The result of such a calculation would be thousands of cancer fatalities 28from the fuel cycle, but this result assumes that even tiny doses have some 29statistical adverse health effect which will not ever be mitigated (for example no 30cancer cure in the next one thousand years), and that these doses projected over 31thousands of years are meaningful. However, these assumptions are 32questionable. In particular, science cannot rule out the possibility that there will 33be no cancer fatalities from these tiny doses. For perspective, the doses are 34very small fractions of regulatory limits and even smaller fractions of natural 35background exposure to the same populations.
36 37Nevertheless, despite all of the uncertainty, some judgement as to the regulatory 38 NEPA (National Environmental Policy Act of 1969, as amended) implications of 39these matters should be made and it makes no sense to repeat the same 40judgement in every case. Even taking the uncertainties into account, the 41Commission concludes that these impacts are acceptable in that these impacts 42 Fuel Cycle Draft NUREG-1437, Supplement 29 6-4 September 2007 would not be sufficiently large to require the NEPA conclusion, for any plant, that 1the option of extended operation under 10 CFR Part 54 should be eliminated.
2Accordingly, while the Commission has not assigned a single level of significance 3for the collective effects of the fuel cycle, this issue is considered Category 1.
4 5The Staff has not identified any new and significant information during its independent 6review of the WCNOC ER (WCNOC 2006), the Staff's site visit, the scoping process, or its 7evaluation of other available information. Therefore, the Staff concludes that there are no 8off-site radiological impacts (collective effects) from the uranium fuel cycle during the 9renewal term beyond those discussed in the GEIS.
10 11 Off-site radiological impacts (spent fuel and high level waste disposal). Based on 12information in the GEIS, the Commission found that:
13 14For the high level waste and spent fuel disposal component of the fuel cycle, there are 15no current regulatory limits for off-site releases of radionuclides for the current candidate 16repository site. However, if we assume that limits are developed along the lines of the 171995 National Academy of Sciences (NAS) report, "Technical Bases for Yucca Mountain 18Standards" (NAS 1995), and that in accordance with the Commission's Waste 19Confidence Decision, 10 CFR 51.23, a repository can and likely will be developed at 20some site which will comply with such limits, peak doses to virtually all individuals will be 21100 millirem per year or less. However, while the Commission has reasonable 22confidence that these assumptions will prove correct, there is considerable uncertainty 23since the limits are yet to be developed, no repository application has been completed or 24reviewed, and uncertainty is inherent in the models used to evaluate possible pathways 25to the human environment. The NAS report indicated that 100 millirem per year should 26be considered as a starting point for limits for individual doses, but notes that some 27measure of consensus exists among national and international bodies that the limits 28should be a fraction of the 100 millirem per year. The lifetime individual risk from 100 29millirem annual dose limit is about 3 x 10
-3.30 31Estimating cumulative doses to populations over thousands of years is more problem-32atic. The likelihood and consequences of events that could seriously compromise the 33integrity of a deep geologic repository were evaluated by the Department of Energy in 34the "Final Environmental Impact Statement: Management of Commercially Generated 35Radioactive Waste," October 1980 (DOE 1980). The evaluation estimated the 70-year 36whole-body dose commitment to the maximum individual and to the regional population 37resulting from several modes of breaching a reference repository in the year of closure, 38after 1,000 years, after 100,000 years, and after 100,000,000 years. Subsequently, the 39NRC and other federal agencies have expended considerable effort to develop models 40for the design and for the licensing of a high level waste repository, especially for the 41 Fuel Cycle September 2007 6-5 Draft NUREG-1437, Supplement 32candidate repository at Yucca Mountain. More meaningful estimates of doses to 1population may be possible in the future as more is understood about the performance 2of the proposed Yucca Mountain repository. Such estimates would involve very great 3uncertainty, especially with respect to cumulative population doses over thousands of 4years. The standard proposed by the NAS is a limit on maximum individual dose. The 5relationship of potential new regulatory requirements, based on the NAS report, and 6cumulative population impacts has not been determined, although the report articulates 7the view that protection of individuals will adequately protect the population for a 8repository at Yucca Mountain. However, U.S. Environmental Protection Agency's 9 (EPA's) generic repository standards in 40 CFR part 191 generally provide an indication 10of the order of magnitude of cumulative risk to population that could result from the 11licensing of a Yucca Mountain repository, assuming the ultimate standards will be within 12the range of standards now under consideration. The standards in 40 CFR part 191 13protect the population by imposing "containment requirements" that limit the cumulative 14amount of radioactive material released over 10,000 years. Reporting performance 15 standards that will be required by EPA are expected to result in releases and associated 16health consequences in the range between 10 and 100 premature cancer deaths with an 17upper limit of 1,000 premature cancer deaths world-wide for a 100,000 metric tonne 18(MTHM) repository.
19 20Nevertheless, despite all of the uncertainty, some judgement as to the regulatory NEPA 21implications of these matters should be made and it makes no sense to repeat the same 22judgement in every case. Even taking the uncertainties into account, the Commission 23concludes that these impacts are acceptable in that these impacts would not be 24sufficiently large to require the NEPA conclusion, for any plant, that the option of 25extended operation under 10 CFR part 54 should be eliminated. Accordingly, while the 26Commission has not assigned a single level of significance for the impacts of spent fuel 27 and high level waste disposal, this issue is considered Category 1.
28 29On February 15, 2002, based on a recommendation by the Secretary of the Department 30of Energy, the President recommended the Yucca Mountain site for the development of 31a repository for the geologic disposal of spent nuclear fuel and HLW. The U.S.
32Congress approved this recommendation on July 9, 2002, in Joint Resolution 87, which 33designated Yucca Mountain as the repository for spent nuclear waste. On July 23, 342002, the President signed Joint Resolution 87 into law; Public Law 107-200, 116 Stat.
35735 (2002) designates Yucca Mountain as the repository for spent nuclear waste. This 36development does not represent new and significant information with respect to the off-37site radiological impacts from license renewal related to disposal of spent nuclear fuel 38 and HLW. 39 40The EPA developed Yucca Mountain-specific repository standards, which were 41subsequently adopted by the NRC in 10 CFR Part 63. In an opinion, issued July 9, 42 Fuel Cycle Draft NUREG-1437, Supplement 29 6-6 September 2007 2004, the U.S. Court of Appeals for the District of Columbia Circuit (the Court) vacated 1EPA's radiation protection standards for the candidate repository, which required 2compliance with certain dose limits over a 10,000 year period. The Court's decision also 3vacated the compliance period in NRC's licensing criteria for the candidate repository in 410 CFR Part 63.
5 6Therefore, for the HLW and spent fuel disposal component of the fuel cycle, there is 7some uncertainty with respect to regulatory limits for off-site releases of radioactive 8nuclides for the current candidate repository site. However, prior to promulgation of the 9affected provisions of the Commission's regulations, it was assumed that limits would be 10developed in line with the 1995 NAS report, Technical Bases for Yucca Mountain 11 Standards (NAS 1995), and that in accordance with the Commission's Waste 12Confidence Decision, 10 CFR 51.23, a repository that would comply with such limits 13could and likely would be developed at some site. Peak doses to virtually all individuals 14would be 100 mrem per year or less.
15 16Despite the current uncertainty with respect to these rules, some judgment as to the 171969 NEPA implications of off-site radiological impacts of spent fuel and HLW disposal 18should be made. The Staff concludes that these impacts are acceptable in that the 19impacts would not be sufficiently large to require the NEPA conclusion that the option of 20extended operation under 10 CFR Part 54 should be eliminated.
21 22The Staff has not identified any new and significant information during its independent 23review of the WCNOC ER (WCNOC 2006), the site audit, the scoping process, or evaluation 24of other available information. Therefore, the Staff concludes that there are no off-site 25radiological impacts related to spent fuel and HLW disposal during the renewal term beyond 26 those discussed in the GEIS.
27 28 Nonradiological impacts of the uranium fuel cycle. Based on information in the GEIS, the 29Commission found that:
30 31The nonradiological impacts of the uranium fuel cycle resulting from the renewal of an 32operating license for any plant are found to be small.
33 34The Staff has not identified any new and significant information during its independent 35review of the WCNOC ER (WCNOC 2006), the Staff's site visit, the scoping process, or its 36evaluation of other available information. Therefore, the Staff concludes that there are no 37nonradiological impacts of the uranium fuel cycle during the renewal term beyond those 38discussed in the GEIS.
39 Fuel Cycle September 2007 6-7 Draft NUREG-1437, Supplement 32 Low-level waste storage and disposal. Based on information in the GEIS, the Commission 1 found that:
2 3The comprehensive regulatory controls that are in place and the low public doses being 4achieved at reactors ensure that the radiological impacts to the environment will remain 5small during the term of a renewed license. The maximum additional on-site land that 6may be required for low-level waste storage during the term of a renewed license and 7associated impacts will be small. Nonradiological impacts on air and water will be 8negligible. The radiological and nonradiological environmental impacts of long-term 9disposal of low-level waste from any individual plant at licensed sites are small. In 10addition, the Commission concludes that there is reasonable assurance that sufficient 11low-level waste disposal capacity will be made available when needed for facilities to be 12decommissioned consistent with NRC decommissioning requirements.
13 14The Staff has not identified any new and significant information during its independent 15review of the WCNOC ER (WCNOC 2006), the site audit, the scoping process, or evaluation 16of other available information. Therefore, the Staff concludes that there are no impacts of 17low-level waste storage and disposal associated with the renewal term beyond those 18discussed in the GEIS.
19 20 Mixed waste storage and disposal. Based on information in the GEIS, the Commission 21 found that:
22 23The comprehensive regulatory controls and the facilities and procedures that are in 24place ensure proper handling and storage, as well as negligible doses and exposure to 25toxic materials for the public and the environment at all plants. License renewal will not 26increase the small, continuing risk to human health and the environment posed by mixed 27waste at all plants. The radiological and nonradiological environmental impacts of long-28term disposal of mixed waste from any individual plant at licensed sites are small. In 29addition, the Commission concludes that there is reasonable assurance that sufficient 30mixed waste disposal capacity will be made available when needed for facilities to be 31decommissioned consistent with NRC decommissioning requirements.
32 33The Staff has not identified any new and significant information during its independent 34review of the WCNOC ER (WCNOC 2006), the site audit, the scoping process, or evaluation 35of other available information. Therefore, the Staff concludes that there are no impacts of 36mixed waste storage and disposal associated with the renewal term beyond those 37discussed in the GEIS.
38 Fuel Cycle Draft NUREG-1437, Supplement 29 6-8 September 2007 On-site spent fuel. Based on information in the GEIS, the Commission found that:
1 2The expected increase in the volume of spent fuel from an additional 20 years of 3operation can be safely accommodated on site with small environmental effects through 4dry or pool storage at all plants if a permanent repository or monitored retrievable 5storage is not available.
6 7The Staff has not identified any new and significant information during its independent 8review of the WCNOC ER (WCNOC 2006), the site audit, the scoping process, or evaluation 9of other available information. Therefore, the Staff concludes that there are no impacts of 10on-site spent fuel associated with license renewal beyond those discussed in the GEIS.
11 12 Nonradiological waste. Based on information in the GEIS, the Commission found that:
13 14No changes to generating systems are anticipated for license renewal. Facilities and 15procedures are in place to ensure continued proper handling and disposal at all plants.
16 17The Staff has not identified any new and significant information during its independent 18review of the WCNOC ER (WCNOC 2006), the site, the scoping process, or evaluation of 19other available information. Therefore, the Staff concludes that there are no nonradiological 20waste impacts during the renewal term beyond those discussed in the GEIS.
21 22 Transportation. Based on information contained in the GEIS, the Commission found that:
23 24The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with 25average burnup for the peak rod to current levels approved by NRC up to 62,000 26MWd/MTU (megawatt-days per metric ton of uranium) and the cumulative impacts of 27transporting high-level waste to a single repository, such as Yucca Mountain, Nevada 28are found to be consistent with the impact values contained in 10 CFR 51.52(c), 29Summary Table S Environmental Impact of Transportation of Fuel and Waste to and 30from One Light-Water-Cooled Nuclear Power Reactor. If fuel enrichment or burnup 31conditions are not met, the applicant must submit an assessment of the implications for 32the environmental impact values reported in § 51.52.
33 34WCGS meets the fuel-enrichment and burnup conditions set forth in Addendum 1 to the 35GEIS. The Staff has not identified any new and significant information during its 36independent review of the WCNOC ER (WCNOC 2006), the site audit, the scoping process, 37or evaluation of other available information. Therefore, the Staff concludes that there are no 38 Fuel Cycle September 2007 6-9 Draft NUREG-1437, Supplement 32impacts of transportation associated with license renewal beyond those discussed in the 1 GEIS.2 3There are no Category 2 issues for the uranium fuel cycle and solid waste management.
4 5 6.2 References 6 710 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 8Protection Regulations for Domestic Licensing and Related Regulatory Functions."
9 1010 CFR Part 54. Code of Federal Regulations, Title 10, Energy,Part 54, "Requirements for 11Renewal of Operating Licenses for Nuclear Power Plants."
12 1310 CFR Part 63. Code of Federal Regulations, Title 10, Energy,Part 63, "Disposal of High-14Level Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada."
15 1640 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 17"Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 18Fuel, High-Level and Transuranic Radioactive Waste."
19 20Department of Energy (DOE). 1980. Final Environmental Impact Statement: Management of 21Commercially Generated Radioactive Waste. DOE/EIS-0046F, Washington, DC.
22 23Joint Resolution 87, 2002. Public Law 107-200, 116 Stat 735.
24 25National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards
.26Washington, DC.
27 28National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et. seq.
29 30 Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for 31License Renewal of Nuclear Power Plants. NUREG-1437 Volumes 1 and 2, Washington, DC.
32 33 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 34License Renewal of Nuclear Plants Main Report
,"Section 6.3 - Transportation, Table 9.1, 35Summary of findings on NEPA issues for license renewal of nuclear power plants." 36NUREG-1437 Volume 1, Addendum 1, Washington, DC.
37 38Wolf Creek Nuclear Operating Corporation (WCNOC). 2006. Applicant's Environmental Report 39- Operating License Renewal Stage, Wolf Creek Generating Station. Docket Number 50-482.
40 Burlington, Kansas.
41
September 2007 7-1 Draft NUREG-1437, Supplement 32 7.0 Environmental Impacts of Decommissioning 1 2 3Environmental impacts from the activities associated with the decommissioning of any reactor 4before or at the end of an initial or renewed license are evaluated in the Generic Environmental 5Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 6Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC 2002). The 7Staff's evaluation of the environmental impacts of decommissioning presented in NUREG-0586, 8Supplement 1 identifies a range of impacts for each environmental issue.
9 10The incremental environmental impacts associated with decommissioning activities resulting 11from continued plant operation during the renewal term are discussed in the Generic 12Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 13Volumes 1 and 2 (NRC 1996; 1999).(a) The GEIS includes a determination of whether the 14analysis of the environmental issue could be applied to all plants and whether additional 15mitigation measures would be warranted. Issues were then assigned a Category 1 or a 16Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 17the following criteria:
18 19(1) The environmental impacts associated with the issue have been determined to apply 20either to all plants or, for some issues, to plants having a specific type of cooling system 21or other specified plant or site characteristics.
22 23(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 24the impacts (except for collective offsite radiological impacts from the fuel cycle and from 25high level waste and spent fuel disposal).
26 27(3) Mitigation of adverse impacts associated with the issue has been considered in the 28analysis, and it has been determined that additional plant-specific mitigation measures 29are likely not to be sufficiently beneficial to warrant implementation.
30 31For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 32required unless new and significant information is identified.
33 34Category 2 issues are those that do not meet one or more of the criteria for Category 1; 35therefore, additional plant-specific review of these issues is required. There are no Category 2 36issues related to decommissioning.
37 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" includ e the GEIS and its Addendum 1.
Environmental Impacts of Decommissioning Draft NUREG-1437, Supplement 32 7-2 September 2007 7.1 Decommissioning 1 2Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, 3Subpart A, Appendix B that are applicable to Wolf Creek Generating Station (WCGS) 4decommissioning following the renewal term are listed in Table 7-1. Wolf Creek Nuclear 5Operating Corporation (WCNOC) stated in its Environmental Report (ER) (WCNOC 2006) that it 6is aware of no new and significant information regarding the environmental impacts of WCGS 7license renewal. The Staff has not identified any new and significant information during its 8independent review of the WCGS ER (WCNOC 2006), the site visit, the scoping process, or its 9evaluation of other available information. Therefore, the Staff concludes that there are no 10impacts related to these issues beyond those discussed in the GEIS. For all of these issues, 11the Staff concluded in the GEIS that the impacts are SMALL, and additional plant-specific 12mitigation measures are not likely to be sufficiently beneficial to be warranted.
13 14 Table 7-1. Category 1 Issues Applicable to the Decommissioning of WCGS 15Following the Renewal Term 16 17ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1GEIS Section D ECOMMISSIONINGRadiation doses7.3.1Waste management7.3.2 Air quality 7.3.3Water quality 7.3.4Ecological resources7.3.5Socioeconomic impacts7.3.7 18A brief description of the Staff's review and the GEIS conclusions, as codified in Table B-1, 10 19CFR Part 51, for each of the issues follows:
20 21 Radiation doses. Based on information in the GEIS, the Commission found that:
22 23Doses to the public will be well below applicable regulatory standards regardless 24of which decommissioning method is used. Occupational doses would increase 25no more than 1 man-rem caused by buildup of long-lived radionuclides during the 26license renewal term.
27 28The Staff has not identified any new and significant information during its independent 29review of the WCGS ER (WCNOC 2006), the site visit, the scoping process, or its evaluation 30of other available information. Therefore, the Staff concludes that there are no radiation 31 Environmental Impacts of Decommissioning September 2007 7-3 Draft NUREG-1437, Supplement 32 dose impacts associated with decommissioning following the license renewal term beyond 1 those discussed in the GEIS.
2 3 Waste management. Based on information in the GEIS, the Commission found that:
4 5Decommissioning at the end of a 20-year license renewal period would generate no 6more solid wastes than at the end of the current license term. No increase in the 7quantities of Class C or greater than Class C wastes would be expected.
8 9The Staff has not identified any new and significant information during its independent 10review of the WCGS ER (WCNOC 2006), the site visit, the scoping process, or its evaluation 11of other available information. Therefore, the Staff concludes that there are no impacts from 12solid waste associated with decommissioning following the license renewal term beyond 13 those discussed in the GEIS.
14 15 Air quality. Based on information in the GEIS, the Commission found that:
16 17Air quality impacts of decommissioning are expected to be negligible either at the 18end of the current operating term or at the end of the license renewal term.
19 20The Staff has not identified any new and significant information during its independent 21review of the WCGS ER (WCNOC 2006), the site visit, the scoping process, or its evaluation 22of other available information. Therefore, the Staff concludes that there are no impacts on 23air quality associated with decommissioning following the license renewal term beyond 24 those discussed in the GEIS.
25 26 Water quality. Based on information in the GEIS, the Commission found that:
27 28The potential for significant water quality impacts from erosion or spills is no 29greater whether decommissioning occurs after a 20-year license renewal period 30or after the original 40-year operation period, and measures are readily available 31 to avoid such impacts.
32 33The Staff has not identified any new and significant information during its independent 34review of the WCGS ER (WCNOC 2006), the site visit, the scoping process, or its evaluation 35of other available information. Therefore, the Staff concludes that there are no impacts on 36water quality associated with decommissioning following the license renewal term beyond 37 those discussed in the GEIS.
38 Environmental Impacts of Decommissioning Draft NUREG-1437, Supplement 32 7-4 September 2007 Ecological resources. Based on information in the GEIS, the Commission found that:
1 2Decommissioning after either the initial operating period or after a 20-year 3license renewal period is not expected to have any direct ecological impacts.
4 5The Staff has not identified any new and significant information during its independent 6review of the WCGS ER (WCNOC 2006), the site visit, the scoping process, or its evaluation 7of other available information. Therefore, the Staff concludes that there are no impacts on 8ecological resources associated with decommissioning following the license renewal term 9beyond those discussed in the GEIS.
10 11 Socioeconomic Impacts. Based on information in the GEIS, the Commission found that:
12 13Decommissioning would have some short-term socioeconomic impacts. The 14impacts would not be increased by delaying decommissioning until the end of a 1520-year relicense period, but they might be decreased by population and 16 economic growth.
17 18The Staff has not identified any new and significant information during its independent 19review of the WCGS ER (WCNOC 2006), the site visit, the scoping process, or its evaluation 20of other available information. Therefore, the Staff concludes that there are no 21socioeconomic impacts associated with decommissioning following the license renewal term 22beyond those discussed in the GEIS.
23 24 7.2 References 25 2610 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 27Protection Regulations for Domestic Licensing and Related Regulatory Functions."
28 29 Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for 30License Renewal of Nuclear Power Plants. NUREG-1437 Volumes 1 and 2, Washington, DC.
31 32 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 33License Renewal of Nuclear Plants Main Report
,"Section 6.3 - Transportation, Table 9.1, 34Summary of findings on NEPA issues for license renewal of nuclear power plants."
35NUREG-1437 Volume 1, Addendum 1, Washington, DC.
36 37 Nuclear Regulatory Commission (NRC). 2002.Generic Environmental Impact Statement on 38Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 39 Nuclear Power Reactors. NUREG-0586 Volumes 1 and 2, Supplement 1, Washington, DC.
40 Environmental Impacts of Decommissioning September 2007 7-5 Draft NUREG-1437, Supplement 32 Wolf Creek Nuclear Operating Corporation (WCNOC). 2006. Applicant's Environmental Report 1- Operating License Renewal Stage, Wolf Creek Generating Station. Docket Number 50-482.
2 Burlington, Kansas.
3
September 2007 8-1 Draft NUREG-1437, Supplement 32 8.0 Environmental Impacts of Alternatives 1 to License Renewal 2 3 4This chapter examines the potential environmental impacts associated with denying the renewal 5of an operating license (OL) (i.e., the no-action alternative); the potential environmental impacts 6from electric generating sources other than Wolf Creek Generating Station (WCGS); the 7possibility of purchasing electric power from other sources to replace power generated by 8WCGS and the associated environmental impacts; the potential environmental impacts from a 9combination of generating and conservation measures; and other generation alternatives that 10were deemed unsuitable for replacement of power generated by WCGS. The environmental 11impacts are evaluated using the U.S. Nuclear Regulatory Commission's (NRC's) three-level 12standard of significance - SMALL, MODERATE, or LARGE - developed using the Council on 13Environmental Quality guidelines and set forth in the footnotes to Table B-1 of Title 10 of the 14 Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B:
15 16SMALL - Environmental effects are not detectable or are so minor that they will neither 17destabilize nor noticeably alter any important attribute of the resource.
18 19MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize 20important attributes of the resource.
21 22LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 23important attributes of the resource.
24 258.1 No-action Alternative 26 27The NRC's regulations implementing the National Environmental Policy Act of 1969, as 28amended (NEPA), specify that the no-action alternative be discussed in an NRC environmental 29impact statement (EIS) (see 10 CFR Part 51, Subpart A, Appendix A[4]). For license renewal, 30the no-action alternative refers to a scenario in which the NRC would not renew the OL for 31WCGS and Wolf Creek Nuclear Operating Corporation (WCNOC) would then cease plant 32operations by the end of the current license and initiate decommissioning of the plant.
33 34WCNOC will be required to shut down WCGS and comply with NRC decommissioning 35requirements in 10 CFR Part 50.82 whether or not the OL is renewed. If the WCGS OL is 36renewed, shutdown of the facility and decommissioning activities will not be avoided, but will be 37postponed for up to an additional 20 years.
38 39The environmental impacts associated with decommissioning, following a license renewal 40period of up to 20 years or following the no-action alternative, would be bounded by the 41 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-2 September 2007 discussion of impacts in Chapter 7 of the GEIS, Chapter 7 of this draft supplemental EIS (SEIS), 1 and the Final Generic Environmental Impact Statement on Decommissioning of Nuclear 2Facilities, NUREG 0586, Supplement 1 (NRC 2002). The impacts of decommissioning after 60 3years of operation are not expected to be significantly different from those occurring after 40 4 years of operation.
5 6Impacts from the decision to permanently cease operations are not considered in NUREG-0586, 7 Supplement 1.(a) Therefore, immediate impacts that occur between plant shutdown and the 8beginning of decommissioning are considered here. These impacts will occur when the unit 9shuts down regardless of whether the license is renewed or not (see Table 8-1 presented at the 10end of Section 8.1). Plant shutdown will result in a net reduction in power production capacity.
11The power not generated by WCGS during the license renewal term would likely be replaced by 12(1) power supplied by other producers using generating technologies that may differ from that 13employed at WCGS, (2) demand-side management (DSM) and energy conservation, or (3) 14some combination of these options. The environmental impacts of these options are discussed 15in Section 8.2. While these options are alternatives to license renewal, they also constitute 16potential consequences of the no-action alternative.
17 188.1.1 Land Use 19 20In Chapter 4 of this draft SEIS, the Staff concluded that the impacts of continued plant operation 21on land use would be SMALL. On-site land use will not be affected immediately by the 22cessation of operations. Plant structures and other facilities are likely to remain in place until 23decommissioning. In the near term, the transmission lines associated with WCGS will likely be 24retained until final disposition of the dormant facility and site are ascertained. In the long term, it 25is possible that the transmission lines that extend from the on-site switchyard to major 26transmission corridors will be removed, at which point right-of-way (ROW) maintenance will 27cease and the ROW will revert to the conditions found in adjacent areas. Also, as a result of 28plant shutdown, there would be a reduction in uranium mining activity positively impacting 29approximately 1,165 acres (ac). Therefore, the Staff concludes that the impacts on land use 30 from plant shutdown would be SMALL.
31 32 8.1.2 Ecology 33 34In Chapter 4 of this draft SEIS, the Staff concluded that ecological impacts of continued plant 35operation were generally SMALL, except during times of water use conflicts. During low-flow 36and drought event, impacts may become SMALL to MODERATE for impingement of aquatic 37 (a) Appendix J of NUREG-0586 Supplement 1 discusses the socioeconomic impacts of plant closure, but the results of the analysis in Appendix J are not incorporated in the analysis presented in the main body of the NUREG.
Environmental Impacts of License Renewal September 2007 8-3 Draft NUREG-1437, Supplement 32 organisms, and for one aquatic threatened and endangered species when WCGS uses water 1from the Neosho River below John Redmond Reservoir to increase water levels in Coffey 2County Lake. Cessation of operations will eliminate cooling water intake flow and the facility's 3thermal plume. Therefore; the environmental impacts to aquatic species, including threatened 4and endangered species, associated with cessation of operations are generally positive.
5 6The impacts of plant closure on the terrestrial ecosystem range between negative and positive 7depending on final disposition of the WCGS site. Currently, there is an active management 8program on the property that preserves habitat and controls invasive species. Cessation of that 9program with plant closure would have a negative impact. The Staff concludes that overall 10ecological impacts from shutdown of the plant would be SMALL.
11 128.1.3 Water Use and Quality - Surface Water 13 14In Chapter 4 of this draft SEIS the Staff concluded that impacts of continued plant operation on 15surface water use and quality were SMALL to MODERATE due to potential water use conflicts 16associated with the availability of water from the current water supply (John Redmond 17Reservoir) during the re-licensing period. When the plant stops operating there will be an 18immediate reduction in the consumptive use of water because of the elimination of the cooling 19water intake, which would reduce water use conflicts by reducing the need for water from John 20Redmond Reservoir. In addition, the shutdown of WCGS would result in a decrease in the 21amount of heat discharged to Coffey County Lake and the tritium concentrations in Coffey 22County Lake would stop increasing and gradually decay. Therefore, the Staff concludes that 23the impacts on surface water use and quality from plant shutdown would be SMALL.
24 258.1.4 Water Use and Quality - Groundwater 26 27In Chapter 4 of this draft SEIS, the Staff determined that the facility will not have an impact on 28off-site groundwater users because any potential effects from Coffey County Lake water 29migrating into aquifers would be mitigated by slow aquifer flow rates. In addition, the plant uses 30no groundwater. Consequently, the Staff concludes that groundwater quality impacts from 31 shutdown of the plant would be SMALL.
32 338.1.5 Air Quality 34 35In Chapter 4 of this draft SEIS, the Staff found the impacts of continued plant operation on air 36quality to be SMALL. When the plant stops operating, there will be a reduction in emissions 37from activities related to plant operation such as use of diesel generators and workers traveling 38to the WCGS site. The Staff concludes that the impact on air quality from shutdown of the plant 39 would be SMALL.
40 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-4 September 2007 8.1.6 Waste 1 2The impacts of waste generated by continued plant operation are discussed in Chapter 6 of this 3draft SEIS. The impacts of low-level and mixed waste from plant operation are characterized as 4SMALL. When WCGS stops operating, the plant will stop generating high-level waste and 5generation of low-level and mixed waste associated with plant operation will decline. Therefore, 6the Staff concludes that impacts of waste generated after shutdown of the plant would be 7 SMALL.8 98.1.7 Human Health 10 11In Chapter 4 of this draft SEIS, the Staff concluded that the impacts of continued plant operation 12on human health are SMALL. After cessation of operations, the amount of radioactive material 13released to the environment in gaseous and liquid forms, which are within regulatory limits, will 14be reduced. Therefore, the Staff concludes that the impact of shutdown of the plant on human 15health would also be SMALL. In addition, the variety of potential accidents at the plant will be 16reduced to a limited set associated with shutdown events and fuel handling. In Chapter 5 of this 17draft SEIS, the Staff concluded that impacts of accidents during operation are SMALL.
18Therefore, the Staff concludes that the impacts of potential accidents following shutdown of the 19plant would be SMALL.
20 21 8.1.8 Socioeconomics 22 23In Chapter 4 of this draft SEIS, the NRC staff concluded that the socioeconomic impacts of 24continued plant operation would be SMALL. Should the plant shut down, there would be 25immediate socioeconomic impacts due to the loss of jobs (approximately 1,525 permanent and 26long-term contract employees) and there may also be an immediate reduction in property tax 27revenues for Coffey County. These impacts may, however, be partially offset as a result of 28projected regional economic growth. The NRC staff concludes that the socioeconomic impacts 29of plant shutdown would be LARGE. See Appendix J to NUREG-0586, Supplement 1 (NRC 302002), for additional discussion of the potential impacts of plant shutdown.
31 328.1.9 Socioeconomics (Transportation) 33 34In Chapter 4 of this draft SEIS, the Staff concluded that the impacts of continued plant operation 35on transportation would be SMALL. Cessation of operations will be accompanied by reduced 36traffic in the vicinity of the plant. Most of the reduction will be associated with a reduction in 37plant workforce, but there will also be a reduction in shipment of maintenance materials to and 38from the plant. Therefore, the Staff concludes that the impacts of plant closure on transportation 39 would be SMALL.
40 Environmental Impacts of License Renewal September 2007 8-5 Draft NUREG-1437, Supplement 32 8.1.10 Aesthetics 1 2In Chapter 4 of this draft SEIS, the Staff concluded that the aesthetic impacts of continued plant 3operation would be SMALL. Plant structures and other facilities are likely to remain in place 4until decommissioning. Upon decommissioning the number of on-site structures would be 5reduced. Since no net changes would occur after shut down and before decommissioning, the 6Staff concludes that the aesthetic impacts of plant closure would be SMALL.
7 88.1.11 Historic and Archaeological Resources 9 10In Chapter 4 of this draft SEIS, the Staff concluded that the impacts of continued plant operation 11on historic and archaeological resources would be SMALL. On-site land use will not be affected 12immediately by the cessation of operations. Plant structures and other facilities are likely to 13remain in place until decommissioning. The transmission lines associated with the project may 14ultimately be removed once the facility stops operating and, should this occur, maintenance of 15the transmission line ROWs will cease. Therefore, the Staff concludes that the impacts on 16historic and archaeological resources from plant shutdown would be SMALL.
17 188.1.12 Environmental Justice 19 20In Chapter 4 of this draft SEIS, the Staff concluded that the environmental justice impacts of 21continued operation of the plant would be SMALL because continued operation of the plant 22 would not have a disproportionately high and adverse impact on minority and low-income 23populations. Although the Staff concluded that the socioeconomic impacts of plant shutdown 24would be LARGE, the impacts of plant shutdown are likely to be felt across the entire 25community and are not expected to be significantly disproportionate to minority and low-income 26populations. The Staff concludes that the environmental justice impacts of plant shutdown 27would be SMALL. See Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional 28discussion of these impacts.
29 30 Table 8-1. Summary of Environmental Impacts of the No-action Alternative 31 32Impact Category ImpactComment Land Use SMALLImpacts are expected to be SMALL because plant shutdown is expected to result in few changes to off-site and on-site land use, and transition to alternate uses is expected over an extended timeframe. EcologySMALLSMALL to MODERATE negative impacts to aquatic ecology of Coffey County Lake will cease, while positive terrestrial impacts of conservation management in transmission corridors will also terminate. The overall impact is SMALL.
Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-6 September 2007 Table 8-1.
(contd) 1 2 Impact Category ImpactComment Water Use and Quality- Groundwater SMALLImpacts are expected to be SMALL as slow aquifer flow rates reduce possible effects from surface water intrusion. Air Quality SMALLImpacts are expected to be SMALL because emissions related to plant operation and worker transportation will
decrease. Waste SMALLImpacts are expected to be SMALL because generation of high-level waste will stop, and generation of low-level and mixed waste will decrease. Human Health SMALLImpacts are expected to be SMALL because radiological doses to workers and members of the public, which are within regulatory limits, will be reduced. Socioeconomics LARGEImpacts are expected to be LARGE because of a decrease in employment and tax revenues. Socioeconomics (Transportation)
SMALLImpacts are expected to be SMALL because the decrease in employment would reduce traffic.
Aesthetics SMALLImpacts are expected to be SMALL because plant structures will remain after plant shutdown. Historic and Archaeological Resources SMALLImpacts are expected to be SMALL because shutdown of the plant will not change land use. Environmental Justice SMALLImpacts are expected to be SMALL because there are no significant disproportionate impacts to minority or low income populations.
38.2 Alternative Energy Sources 4 5This section discusses the environmental impacts associated with developing alternative 6sources of electric power to replace power generated by WCGS. The order of alternative 7energy sources presented in this section does not imply which alternative would be most likely 8to occur or which is expected to have the least environmental impacts.
9 10The following central generating station alternatives are considered in detail:
11 12 Coal-fired generation at either Wolf Creek or an alternate site (Section 8.2.1) 13 14 Natural gas-fired generation at either Wolf Creek or an alternate site 15(Section 8.2.2) 16 17 Nuclear generation at either Wolf Creek or an alternate site (Section 8.2.3) 18 Environmental Impacts of License Renewal September 2007 8-7 Draft NUREG-1437, Supplement 32 The alternative of purchasing power to replace WCGS is discussed in Section 8.2.4. Other 1power generation alternatives and conservation alternatives are discussed in Section 8.2.5. In 2section 8.2.6, the environmental impacts of a combination of generation and conservation 3alternatives are discussed.
4 5Each year the Energy Information Administration (EIA), a component of the U.S. Department of 6Energy (DOE), issues an Annual Energy Outlook. In its Annual Energy Outlook 2007 with 7Projections to 2030, EIA projects that natural gas-fired plants will account for approximately 36 8percent of new electric generating capacity between the years 2006 and 2030 (DOE/EIA 2007).
9This technology is designed primarily to supply peak and intermediate electric generating 10capacity, but combined-cycle gas-fired systems can also be used to meet baseload(b) require-11ments. EIA projects that coal-fired plants will account for approximately 54 percent of new 12capacity additions during this period. Coal-fired plants are generally used to meet baseload 13requirements. EIA projects that renewable energy sources - primarily wind, biomass 14gasification, and municipal solid waste units - will account for six percent of capacity additions.
15EIA's bases projections of capacity additions on the assumption that providers of new 16generating capacity will seek to minimize cost while meeting applicable environmental 17requirements. According to EIA, advanced coal-fired and advanced combined-cycle generating 18facilities will be approximately competitive with each other in 2015, on a total evaluated cost of 19production basis, while advanced coal-burning facilities will likely gain a competitive edge by 202030 (DOE/EIA 2007). EIA indicates that oil-fired plants will account for little or none of the new 21generating capacity additions in the United States during the 2004 to 2030 time frame because 22of high fuel costs (DOE/EIA 2007).
23 24EIA also projects that about 12.5 gigawatts of new nuclear power generating capacity will be 25constructed prior to 2030. Of this capacity growth, 9 gigawatts are related to the availability of 26production tax credits under the Energy Policy Act of 2005 (EPACT2005; DOE/EIA 2007).
27Several site licensing applications are currently under review by the NRC and nuclear operating 28companies have announced their intention to submit reactor license applications beginning in 29late 2007. In response to industry interest in constructing new reactors, NRC has established a 30reactor licensing program organization to manage reactor and site licensing applications 31 (NRC 2001). As a result of EIA's projections, EPACT2005's incentives, and NRC's 32organizational capacity, a new nuclear plant alternative for replacing power generated by 33WCGS is considered in this draft SEIS and resulting impacts are presented in Section 8.2.3.
34 35Since WCGS has a net electric output of 1,165 megawatts electric (MW[e]), the Staff evaluated 36the impacts of coal, natural gas, and new nuclear alternatives having comparable capabilities.
37WCGS is situated on a 9,818 ac site of which approximately 4,700 ac are upland areas 38 (b)A baseload plant normally operates to supply all or part of the minimum continuous load of a system and consequently produces electricity at an essentially constant rate. Nuclear power plants are commonly used for baseload generation; and generally run near full load.
Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-8 September 2007 potentially available for development. Consequently, NRC staff expects that any of the three 1technologies being evaluated could be developed at either Wolf Creek or at a hypothetical, 2unspecified alternate site. Thus, impacts of the alternative technologies are presented below for 3both siting options.
4 5While the alternate site considered here need not be situated in Kansas, the availability of 6 transmission-line capacity to deliver output from a relatively remote location to current WCGS 7customers could constrain siting choices. For instance, a recent DOE analysis (DOE 2006) 8concludes that transmission-line constraints currently exist in the Southwest Power Pool 9Region, which encompasses essentially all of the State of Kansas. In particular, the DOE 10analysis notes that a congestion pattern exists in electricity flows from Nebraska and West 11Kansas into Central Kansas. It is possible that these transmission congestion patterns would 12influence selection of an alternate site.
13 148.2.1 Coal-Fired Generation 15 16The assumptions and numerical values used in Section 8.2.1 are based on the Staff's 17independent assessment and on information provided by WCNOC in the WCGS Environmental 18Report (ER) (WCNOC 2006). Where information from the WCGS ER was used, it was 19independently reviewed by the Staff and compared to environmental impact information in the 20GEIS. Impacts of a coal-fired alternative evaluated by the Staff assume that the new plant 21would have a gross electrical capacity of 1,234 MW(e). This differs somewhat from the 22approach taken in the ER since the Staff assumed that the coal-fired alternative would have the 23same net electrical output as WCGS, rather than a smaller output based on commercially-24available gas-fired unit sizes. As in the ER, staff estimated that on-site power demand would be 25approximately six percent of net output. While the WCGS OL renewal period is only 20 years, 26the Staff considers the impact of operating a coal-fired alternative for a full 40 years, since 40 27years is the expected operating life of a new coal-fired plant.
28 29Based on Table 8-1 of the GEIS, a pulverized coal-fired facility requires approximately 1.7 ac of 30land per MW(e). Based on this relationship, a 2,098 ac site would be needed to replace WCGS 31with an equivalent capacity coal-fired facility. As the existing site includes approximately 4,700 32ac of upland area, the Staff concludes there is sufficient land area at WCGS to support 33operations of the alternative. Thus, the coal-fired alternative is analyzed below for both an 34alternate site and for the WCGS site. It should be noted that several of the newer coal 35utilization technologies (e.g., coal-fired integrated gasification combined cycle systems) could be 36accommodated on smaller sites than would the conventional pulverized coal concept evaluated 37 here.38 39Based on information supplied by WCNOC, the coal-fired plant would consume approximately 405.4 million tons/year (yr) of pulverized bituminous coal with an ash content of approximately 41 Environmental Impacts of License Renewal September 2007 8-9 Draft NUREG-1437, Supplement 32 5.53 percent (WCNOC 2006). WCNOC, in the ER, assumes a heat rate(c) of 10,200 British 1thermal units per kilowatt-hour (BTU/kWh) and a capacity factor (d)of 0.85. After combustion, 299.9 percent of the ash would be collected and either disposed on-site or, as suggested by 3WCNOC, sold for beneficial reuse. In addition, approximately 112,000 tons of sludge from 4sulfur dioxide (SO
- 2) scrubbers would also be disposed on-site. These scrubbers would 5consume 38,000 tons of lime annually.
6 7Coal and lime would be delivered to the generating station by rail. A rail spur would be 8constructed to bring coal onto the WCGS site from a nearby rail line. Output of the new coal-9fired facility would be transmitted from the WCGS site via the existing transmission lines.
10Development of a coal-fired facility at an alternate site would necessitate construction of a new 11transmission line to connect that plant to the regional transmission grid.
12 13For purposes of this section, the Staff assumes that a coal-fired plant located at an alternate site 14would use a closed-cycle cooling system while a coal-fired plant at the WCGS site would utilize 15Coffey County Lake for condenser cooling purposes.
16 17The overall impacts of the coal-fired generating facility are discussed in the following sections 18and summarized in Table 8-2, at the end of this section (Section 8.2.1.1). The implications of 19constructing a new coal-fired plant at an alternate site will depend on the actual location and 20characteristics of that site; staff will generally evaluate impacts below.
21 22 8.2.1.1 Land Use 23 24According to the GEIS, constructing a 1,234 MW(e) coal-fired generating facility would entail 25disruption of approximately 2,100 ac for coal storage, rail yards and waste disposal facilities.
26However, since a coal-fired facility at the WCGS site would use some of the existing plant 27features such as the switch yard, transmission lines, and administrative complex, it is likely that 28less than the projected 2,100 ac of land would be needed. As a result of the substantial site 29area that would be dedicated to and disrupted by coal-fired operations, the Staff views this 30alternative as having potentially MODERATE to LARGE land-use impacts.
31 32Construction of a 1,234 gross MW(e) pulverized coal-fired alternative at an alternate site could 33also impact up to 2,100 ac of land (NRC 1996). Additional land would be needed to bring a rail 34spur onto the alternate site and, as well as, for a transmission line or lines to deliver the plant's 35 (c)Heat rate is a measure of generating station thermal efficiency. In English units, It is generally expressed in British thermal units (BTUs) per net kilowatt-hour (kWh). It is computed by dividing the total BTU content of the fuel burned for electric generation by the resulting kWh generation.
(d)The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy that could have been generated at continuous full-power operation during the same period.
Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-10 September 2007 output to the nearest transmission inter-tie. Depending on the length of transmission line and 1rail line routing, this alternative would result in MODERATE to LARGE land-use impacts on and 2in the vicinity of the alternate site.
3 4Additionally, for the coal-fired alternative, land use changes would occur at an undetermined 5coal mining area where approximately 41 square miles (sq mi) (26,240 ac) would be affected for 6mining coal and disposing of mining wastes to support a 1234 MW(e) coal-fired power plant (the 7GEIS estimates that approximately 34 sq mi (21,760 ac) would be disturbed for a 1,000 MW(e) 8coal-fired plant [NRC 1996]).
9 10 8.2.1.2 Ecology 11 12NRC staff assumes that a coal-fired plant on the WCGS site would use Coffey County Lake for 13condenser cooling purposes. In Chapter 4 of this draft SEIS, the Staff concluded that ecological 14impacts of continued operation of WCGS were SMALL, except during times of water use 15conflicts. Since a coal-fired generating station of comparable output to WCGS would utilize 16approximately the same volume of cooling water as the current WCGS plant, it is expected that 17impacts from long term operation of an open cooling cycle coal-fired plant at WCGS will be 18approximately equal to those resulting from the current operation of WCGS. However, 19terrestrial impacts of coal-fired operations at WCGS would be significant due to the disruption of 20somewhat less than 2,100 ac at the WCGS site which would result in habitat loss and 21fragmentation. Overall the Staff considers the ecological impacts of coal-fired operations at the 22WCGS to be MODERATE to LARGE.
23 24Siting a coal-fired plant at an alternate site would introduce construction and operating impacts.
25Ecological resources would be altered due to the need to convert roughly 2,100 ac of land to 26industrial use (generating facilities, coal storage, ash and scrubber sludge disposal). Even if 27some of the site had been previously disturbed, it is expected that impacts of developing a 282,100 ac area would include wildlife habitat loss, reduced productivity, habitat fragmentation, 29and reduction in on-site biological diversity.
30 31Use of a nearby surface water resource to provide cooling tower makeup would have some 32impact on local aquatic resources. Construction and maintenance of a transmission line and rail 33spur would incrementally add to the terrestrial ecological impacts. Overall, the Staff concludes 34that ecological impacts at an alternate site would be MODERATE to LARGE.
35 36 8.2.1.3 Water Use and Quality 37 388.2.1.3.1 Surface Water 39 40For coal-fired operations at the WCGS, water withdrawn from Coffey County Lake for condenser 41cooling purposes would represent the principal use of surface water. In Chapter 4 the Staff 42 Environmental Impacts of License Renewal September 2007 8-11 Draft NUREG-1437, Supplement 32 concluded that impacts of such withdrawals for cooling the existing plant would be SMALL to 1MODERATE. Impacts of water withdrawals to support coal-fired operations would be 2approximately the same as for the existing nuclear facility. The coal-fired alternative would still 3result in water use conflicts associated with water availability from the John Redmond 4Reservoir. However, with the shutdown of the current WCGS, tritium concentrations in Coffey 5County Lake would stop increasing and gradually decay. Discharges to surface water during 6coal-fired operations could result from coal pile runoff, runoff from coal ash and scrubber 7byproduct disposal areas, and from in-plant processes. Both the use of surface waters and 8discharge to surface waters would be regulated by the State of Kansas. Overall the Staff 9concludes that the potential impacts to surface water resources and water quality would be 10SMALL to MODERATE.
11 12For coal-fired operations at an alternate site, impacts to surface waters would result from 13withdrawal of water for various operating needs of the facility. These operating needs would 14include cooling tower makeup and possibly auxiliary cooling for equipment and potable water 15requirements. Discharges to surface water could result from cooling tower blowdown, coal pile 16runoff, and runoff from coal ash and scrubber byproduct disposal areas. Both the use of surface 17waters and discharges to surface waters would be regulated by the state within which the coal-18 fired facility is located.
19 20NRC staff expects that any new coal-fired facility would comply with requirements of the 21discharge permits issued for its operation. Thus discharges from the plant would be legally 22obligated to conform to applicable water quality standards. Overall, the Staff concludes that the 23potential impacts to surface water resources and water quality would be SMALL to MODERATE 24for a replacement coal-fired facility located at an alternate site.
25 26 8.2.1.3.2 Groundwater 27 28Potential impacts to groundwater quality at either WCGS or an alternate site, under a coal 29burning scenario, may occur as a result of seepage to groundwater from coal storage areas and 30on-site ash and scrubber sludge disposal areas. In all cases, it is expected that a coal-fired 31facility would comply with a groundwater use and discharge permit issued by the State having 32jurisdiction over the plant. Therefore, the Staff concludes that the potential impacts to 33groundwater resources would be SMALL to MODERATE.
34 35 8.2.1.4 Air Quality 36 37The air quality impacts of a pulverized coal-fired facility vary considerably from those of a 38comparable nuclear plant, due to emissions of sulfur oxides (SO x), nitrogen oxides (NO x), 39particulates, carbon monoxide (CO), hazardous air pollutants (e.g., mercury) and naturally 40occurring radioactive materials.
41 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-12 September 2007 WCGS is located in Coffey County, Kansas which is in the Southeast Kansas Intrastate Air 1Quality Control Region. Coffey County has been designated an attainment area (i.e., meets the 2National Ambient Air Quality Standards promulgated by the U.S. Environmental Protection 3Agency [EPA] and found in 40 CFR Part 50) for all criteria pollutants. The EPA has various 4regulatory requirements for visibility protection in 40 CFR Part 51, Subpart P, including a 5specific requirement for review of any major stationary source in an area designated as 6attainment or unclassified under the Clean Air Act (CAA). These requirements would apply to 7both a new coal-burning plant at the WCGS site and also at an alternate site depending on the 8attainment status of the region within which the alternate site is situated.
9 10A new coal-fired generating plant located in Kansas would need a Prevention of Significant 11Deterioration permit issued under Title 1, Part C, of the CAA. The project would also need an 12operating permit under Title V of the CAA. The plant would be required to comply with the New 13Source Performance Standards for such plants as set forth in 40 CFR Part 60 Subpart Da.
14Those standards establish limits for particulate matter and opacity (40 CFR 60.42a), SO 2 (40 15 CFR 60.43a), and NO X (40 CFR 60.44a).
16 17Section 169A of the CAA (42 USC 7401) establishes a national goal of preventing future and 18remedying existing impairment of visibility in mandatory Class I Federal areas when impairment 19results from man-made air pollution. EPA issued a regional haze rule on July 1, 1999 (64 FR 2035714) (EPA 1999). The rule specifies that for each mandatory Class I Federal area located 21within a state, the State must establish goals that provide for reasonable progress towards 22achieving natural visibility conditions. The reasonable progress goals must provide for an 23improvement in visibility for the most impaired days over the period of the implementation plan 24and ensure no degradation in visibility for the least impaired days over the same period 25(40 CFR 51.308[d][1]). If a coal-fired plant were located close to a mandatory Class I area 26(there are none in Kansas but Class I areas are found in adjoining states), additional air 27pollution control requirements could be imposed.
28 29Air quality impacts for various pollutants are as follows:
30 31 Sulfur oxides emissions. WCNOC indicates in its ER that a coal-fired plant would use a 32hydrated lime-wet scrubbing system for flue gas desulfurization (WCNOC 2006). A new coal-33fired power plant would be subject to the requirements in Title IV of the CAA. Title IV was 34enacted to reduce emissions of SO x and NO x, the two principal precursors of acid rain, by 35restricting emissions of these pollutants from power plants. Title IV caps aggregate annual 36 power plant SO x emissions and imposes controls on SO x emissions through a system of 37marketable allowances. EPA issues one allowance for each ton of SO x that a unit is allowed to 38 emit.39 40New units do not receive allowances, but are required to have allowances to cover their SO x 41emissions. Owners of new units must, therefore, acquire allowances from owners of other 42 Environmental Impacts of License Renewal September 2007 8-13 Draft NUREG-1437, Supplement 32 power plants or reduce SO x emissions at other power plants they own. Allowances can be 1banked for use in future years. Thus, a new coal-fired power plant would not add to net regional 2 SO x emissions, although it might contribute to the local SO x burden. 3 4Regardless, SO x emissions would be greater for the coal alternative than the OL renewal 5alternative. The Staff estimates that the coal-fired alternative would emit approximately 2,060 6 tons/yr of SO x.7 8Nitrogen oxides emissions. Title IV of the CAA directed EPA to establish technology-based 9emission limitations for NO x emissions (see Section 407), rather than a market-based allowance 10 system as used for SO x emissions. A new coal-fired power plant would be subject to the new 11source performance standards for such plants at 40 CFR 60.44a(d)(1). That regulation, issued 12September 16, 1998 (63 FR 49453 [EPA 1998]), limits the discharge of any gases that contain 13nitrogen oxides (expressed as nitrogen dioxide [NO 2]) to 200 nanograms per joule of gross 14energy output (1.6 pound/megawatt-hour [MWh]), based on a 30-day rolling average.
15 16The Staff estimates that using the technology referenced in the WCNOC ER (low NO x burners, 17overfire air and selective catalytic reduction [SCR]) the total annual NO x emissions for a new 18coal-fired power plant would be approximately 1,355 tons, less than the amount allowed by Title 19 IV of the CAA. However, even with these control technologies, NO x emissions would be greater 20than for the OL renewal alternative since a nuclear power plant releases essentially no NO x 21during normal operations.
22 23Particulate emissions. The Staff estimates that the total annual stack emissions would include 24150 tons of filterable total suspended particulates and 55 tons of particulate matter having an 25aerodynamic diameter less than or equal to 10 microns (PM
- 10) (40 CFR 50.6). As indicated in 26the WCGS ER, fabric filters or electrostatic precipitators would be used for particulate control.
27In addition to flue emissions, coal-handling equipment would introduce fugitive particulate 28emissions from coal piles, reclamation equipment, conveyors, and other sources. Particulate 29emissions would be greater under the coal alternative than the OL renewal alternative.
30 31Fugitive dust would also be generated during the construction of a coal-fired plant and 32construction vehicles and motorized equipment would further contribute to construction phase 33air emissions. These emissions would be short-lived and intermittent and construction crews 34would likely mitigate some impacts through dust control measures.
35 36Carbon monoxide emissions. The Staff estimates that the total CO emissions from coal 37combustion would be approximately 1,355 tons/yr. The level of CO emissions from a coal-fired 38plant would be substantially greater than those resulting from the OL renewal alternative.
39 40Hazardous air pollutants including mercury. In December 2000, the EPA issued regulatory 41findings on emissions of hazardous air pollutants from electric utility steam-generating units 42 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-14 September 2007 (EPA 2000a). EPA determined that coal- and oil-fired electric utility steam-generating units are 1significant emitters of hazardous air pollutants. Coal-fired power plants were found by EPA to 2emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, 3lead, manganese, and mercury (EPA 2000a). EPA concluded that mercury is the hazardous air 4pollutant of greatest concern. EPA found that (1) there is a link between coal consumption and 5mercury emissions; (2) electric utility steam-generating units are the largest domestic source of 6mercury emissions; and (3) certain segments of the U.S. population (e.g., the developing fetus 7and subsistence fish-eating populations) are believed to be at potential risk of adverse health 8effects due to mercury exposures resulting from consumption of contaminated fish (EPA 92000a). Accordingly, on March 15, 2005, EPA issued the Clean Air Mercury Rule to 10permanently cap and reduce mercury emissions from coal-fired power plants (EPA 2007).
11 12Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring 13elements. According to Alex Gabbard of Oak Ridge National Laboratory, uranium 14concentrations are generally in the range of 1 to 10 parts per million (ppm) and thorium 15concentrations are generally about 2.5 time this level (Gabbard 1993). The U.S. Geological 16Survey (USGS) indicates that Western and Illinois Basin coals contain uranium and thorium at 17roughly equal concentrations, mostly between 1 and 4 ppm, but also indicates that some coals 18may contain concentrations as high as 20 ppm of both elements (USGS 1997). Gabbard 19indicates that a 1000 MW(e) coal-fired plant could release roughly 4.7 MT (5.2 tons) of uranium 20 and 11.6 MT (12.8 tons) of thorium to the atmosphere (Gabbard 1993). Both USGS and 21Gabbard indicate that almost all of the uranium, thorium, and most decay projects remain in 22solid coal wastes, especially in the fine glass spheres that constitute much of the coal's fly ash.
23Modern emissions controls, such as those included for this coal-fires alternative, allow for 24recovery of greater than 99% of these solid wastes (EPA 1998), thus retaining most of the coal's 25radioactive elements in solid form rather than releasing it to the atmosphere. Even after 26concentration in coal waste, the level of radioactive elements remains relatively low - typically 2710 to 100 ppm - and consistent with levels found in naturally occurring granitic rocks, shales, 28and phosphate rocks (USGS 1997). The levels of uranium and thorium contained in coal 29wastes and discharged to the environmental exceed the levels of uranium and thorium released 30to the environment by WCGS.
31 32 Carbon dioxide. A coal-fired plant would also have unregulated carbon dioxide (CO
- 2) emissions 33that could contribute to global warming. The level of emissions from a coal-fired plant would be 34 greater than the OL renewal alternative.
35 36 Summary. The GEIS analysis did not quantify emissions from coal-fired power plants, but 37implied that air impacts would be substantial. The GEIS also mentioned global warming from 38unregulated carbon dioxide emissions and acid rain from SO x and NO x emissions as potential 39impacts (NRC 1996). Adverse human health effects such as cancer and emphysema have 40been associated with the products of coal combustion. The appropriate characterization of air 41 Environmental Impacts of License Renewal September 2007 8-15 Draft NUREG-1437, Supplement 32 impacts from coal-fired generation would be MODERATE. The impacts would be clearly 1noticeable, but would not destabilize air quality.
2 3 8.2.1.5 Waste 4 5Coal combustion generates waste in the form of ash and scrubber sludge. A 1,234 gross 6MW(e) coal-fired plant would generate approximately 416,000 tons of such waste annually for 740 years. If the waste were entirely disposed on-site, approximately 231 ac of land area would 8be required over the 40-yr plant life. The NRC staff notes that the applicant indicated that 50 9percent of the ash generated by coal burning could be sold thereby reducing the on-site 10disposal burden. Impacts of on-site waste disposal to groundwater and surface water could 11extend beyond the operating life of the plant if leachate and runoff from the waste storage area 12occurs. Disposal of the waste could noticeably affect land use and groundwater quality, but with 13appropriate management and monitoring, it would not destabilize any resources. After closure 14of the waste site and revegetation, the land could be available for other uses.
15 16In May 2000, the EPA issued a A Notice of Regulatory Determination on Wastes From the 17 Combustion of Fossil Fuels (65 FR 32214 [EPA 2000b]). EPA concluded that some form of 18national regulation is warranted to address coal combustion waste products because: (a) the 19composition of these wastes could present danger to human health and the environment under 20certain conditions; (b) EPA has identified 11 documented cases of proven damages to human 21health and the environment by improper management of these wastes in landfills and surface 22impoundments; (c) disposal practices are such that, in 1995, these wastes were being managed 23in 40 percent to 70 percent of landfills and surface impoundments without reasonable controls in 24place, particularly in the area of groundwater monitoring; and (d) EPA identified gaps in state 25oversight of coal combustion wastes. Accordingly, EPA announced its intention to issue 26regulations for disposal of coal combustion waste under subtitle D of the Resource 27Conservation and Recovery Act (RCRA). In addition to the waste streams generated during 28plant operations, considerable debris would be generated during construction of a coal-fired 29facility. The volume of construction debris would likely be greater at an alternate site than 30WCGS since the land at WCGS has already been disturbed and many of the necessary 31structures are already in place. Crews would likely dispose of land-clearing debris onsite.
32 33For all of the preceding reasons, the Staff considers the impacts of managing waste generated 34by a coal facility (construction and operating phases) to be MODERATE - the impacts would be 35 clearly noticeable, but would not destabilize any important resource.
36 378.2.1.6 Human Health 38 39Coal-fired power generation introduces risks to workers from fuel and limestone mining, from 40fuel and lime/limestone transportation, and from disposal of coal combustion waste. In addition, 41there are public health risks from inhalation of stack emissions that can be widespread and 42 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-16 September 2007 difficult to quantify. The coal alternative also introduces the risk of coal-pile fires and attendant 1 inhalation risks.
2 3In the GEIS, the Staff stated that there could be human health impacts (cancer and emphy-4sema) from inhalation of toxins and particulates, but it did not identify the significance of these 5impacts (NRC 1996). In addition, the discharges of uranium and thorium from coal-fired plants 6can potentially produce radiological doses in excess of those arising from nuclear power plant 7operations (Gabbard 1993).
8 9Regulatory agencies, including EPA and state agencies, set air emission standards and 10requirements based on human health impacts. These agencies also impose site-specific 11emission limits as needed to protect human health. As discussed previously, EPA has recently 12concluded that certain segments of the U.S. population (e.g., the developing fetus and 13subsistence fish-eating populations) are believed to be at potential risk of adverse health effects 14due to mercury exposures from sources such as coal-fired power plants. However, in the 15absence of more quantitative data, human health impacts from radiological doses and inhaling 16toxins and particulates generated by burning coal are characterized as SMALL.
17 18 8.2.1.7 Socioeconomics 19 20Construction of a coal-fired facility at either the WCGS site or an alternate site would take 21approximately four years. The work force would be expected to vary between 1,000 and 2,000 22 workers during the 4-year construction period (NRC 1996). During construction, the 23surrounding communities would experience demands on housing and public services that could 24have MODERATE impacts unless some of the work force is composed of local residents. After 25construction, the host community would be impacted by the loss of the construction jobs and, in 26the case of WCGS, a loss of 1,525 permanent and long term contract employees. However, 27this loss would be partially offset by the approximately 250 permanent jobs associated with the 28new generating station. Socioeconomic impacts would be greater at rural sites such as the 29WCGS site where infrastructure and labor are not readily available to support construction 30activities. Also, property tax revenue would dramatically increase for communities near the 31alternate site and would diminish for communities near WCGS. The Staff considers the most 32appropriate characterization of non-transportation socioeconomic impacts of developing a new 33coal-fired generating facility to be MODERATE to LARGE, with the WCGS site experiencing the 34larger impact due to the overall loss of permanent and long-term contract employees.
35 36During the 4-year construction period of the coal-fired unit, up to 2,000 construction workers 37would be working at the site. The addition of these workers would increase traffic on highways 38and local roads that lead to the construction site. The impact of this additional traffic could have 39a MODERATE impact on nearby roadways, particularly if the alternate site is in a rural area.
40Impacts associated with plant operating personnel commuting to work are considered SMALL.
41 Environmental Impacts of License Renewal September 2007 8-17 Draft NUREG-1437, Supplement 32 For rail transportation of coal and lime to the alternate site, impacts are likely to range from 1MODERATE to LARGE. On average, approximately two, 70-car trains per day would deliver 2coal to the new generating station and two, 10-car trains per week would deliver lime to the 3facility. Overall, transportation impacts associated with coal and lime delivery would be 4MODERATE to LARGE.
5 6 8.2.1.8 Aesthetics 7 8The boiler house and associated air pollution control equipment at a new coal-fired facility could 9be up to 200 feet (ft) in height and a typical exhaust stack would be somewhere in the range of 10400 to 600 ft high. Construction of a coal-fired facility at the WCGS site would necessitate 11running a rail spur onto the site so that coal and lime could be shipped to the plant and coal 12wastes transported off-site. However, aesthetic impacts of new transmission lines would be 13avoided at WCGS as would the visual intrusion associated with closed-cycle cooling. At both 14sites, the power plant would be noticeable at night due to its 24-hour operating schedule and the 15need for on-site safety lighting. Aesthetic impacts of a coal-fired facility on the WCGS site are 16 expected to be MODERATE.
17 18At an alternate site, cooling towers would be installed with the likely technologies being either 19mechanical draft (approximately 75 ft tall) or natural draft type (approximately 400 ft tall). The 20cooling towers and associated plume would be visible from a considerable distance.
21Beyond near-site aesthetic impacts, development of a new coal-fired facility at an alternate site 22would entail construction of a new transmission line and a new rail spur to bring coal and lime to 23the plant. The rail spur and transmission line could extend many miles distance off-site to tie-in 24points with existing rail and transmission systems. The visual intrusion of these two linear 25elements, particularly the transmission line, could be significant. Consequently, the overall 26aesthetic impacts of a new coal-fired facility at an alternate site are expected to be MODERATE 27 to LARGE.
28 29Coal-fired generation would introduce mechanical sources of noise that would be audible off-30site. Sources contributing to total noise produced by plant operations are classified as 31continuous or intermittent. Continuous sources include the mechanical equipment associated 32with normal plant operations. Intermittent sources include the coal handling equipment, solid-33waste disposal systems, outside loudspeakers, and commuting activities of plant employees.
34Noise impacts associated with rail delivery of coal and lime to the generating station site would 35be most significant for residents living along the new rail spur leading to the plant. Although 36passing trains significantly raise noise levels near rail corridors, the short duration of the noise 37tends to mitigate impacts. Thus, the impact of elevated noise levels on residents in the vicinity 38of the generating facility and the rail line is considered MODERATE at either the WCGS site or 39the alternate site.
40 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-18 September 2007 8.2.1.9 Historic and Archaeological Resources 1 2Before construction at either the WCGS site or an alternate site, studies would likely be needed 3to identify, evaluate, and address mitigation of the potential impacts of new plant construction on 4cultural resources. The studies would likely be needed for all areas of potential disturbance at 5the proposed plant site and along associated corridors where new construction would occur 6(e.g., roads, transmission corridors, rail lines, or other right-of-ways (ROWs). Since the WCGS 7land is already disturbed and a support infrastructure already exists, the potential impacts of 8new plant construction on cultural resources at the WCGS site would be expected to be less 9than at an alternate site. However, historic and archaeological resource impacts can generally 10be effectively managed and therefore, are considered SMALL for both the WCGS site and an 11alternate site.
12 13 8.2.1.10 Environmental Justice 14 15Although the Staff concluded that the socioeconomic impacts of construction of a coal-fire 16generating plant at either the WCGS site or an alternate site would be MODERATE to LARGE, 17no environmental pathways or locations have been identified that would result in 18disproportionately high and adverse environmental impacts on minority and low-income 19populations if a replacement coal-fired plant were built at the WCGS site. Thus, impacts of the 20coal-fired alternative at the WCGS site would be SMALL. Impacts of constructing a coal-fired 21facility at an alternate site would depend upon the site chosen and the nearby population 22distribution. Therefore, it is expected that impacts at an alternate site could be SMALL to 23 LARGE.24 25 Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation at 26the WCGS Site (Once-Through-Cooling) and at an Alternate Site (Closed-Cycle Cooling) 27 28WCGS Site - Open Cycle Cooling Alternate Site - Cooling Towers ImpactCategory ImpactComments ImpactComments Land Use MODERATE to LARGE Less than 2,100 ac for plant, offices, coal handling, waste disposal and rail access. MODERATE to LARGE Approximately 2,100 ac for plant, offices, coal handling, waste disposal and rail access, including the additional land requirements for transmission lines and cooling towers.
Environmental Impacts of License Renewal September 2007 8-19 Draft NUREG-1437, Supplement 32 Table 8-2. (contd) 1 2WCGS Site - Open Cycle Cooling Alternate Site - Cooling Towers ImpactCategory ImpactComments ImpactComments EcologyMODERATE to LARGE Similar cooling water use as current operations; additional terrestrial impacts would occur due to habitat loss and fragmentation associated
with new construction. MODERATE to LARGE Significantly reduced cooling water requirements but impacts due to habitat loss and fragmentation associated with new construction. Water Use and
Quality-Surface Water SMALL to MODERATE Potential discharges from coal storage and waste
disposal.
SMALL to MODERATE Uses significantly less cooling water than once through cooling system; potential discharges from coal storage and waste disposal areas. Water Use and Quality-Groundwater SMALL to MODERATE Potential discharges from coal handling and waste disposal areas.
SMALL to MODERATE Same as for WCGS site. Air Quality MODERATE
$ Sulfur oxides (2,060 tons/yr)
$ Nitrogen oxides (1,355 tons/yr)
$ Carbon monoxide (1,355 tons/yr)
$ Particulates TSP (150 tons/yr)
PM 10 (55 tons/yr) Small amounts of mercury and other hazardous air pollutants and naturally occurring radioactive materials - mainly uranium and thorium. MODERATE Same emissions as would occur at the WCGS site.
Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-20 September 2007 Table 8-2. (contd)1 2 WCGS Site - Open Cycle Cooling Alternate Site - Cooling Towers ImpactCategory ImpactComments ImpactComments Waste MODERATE Annually 412,000 tons of ash and scrubber waste produced; half of ash can be recycled. Total waste disposal area of approximately 231 ac. MODERATE Comparable waste production to that at
WCGS site. Human Health SMALLImpacts uncertain but considered SMALL because the plant will have to comply with health-based emissions standards. SMALLSame as at the WCGS site. Socioeconomics MODERATE to LARGE Approximately 1,000 to 2,000 construction work force. Loss of 1,525 current employees only partially replaced by 250 new employees. Loss of
WCGS tax base would
be partially replaced by new facility. MODERATE to LARGEApproximately 1,000 to 2,000 construction work force reduced to 250 permanent employees upon startup of new
facility.However, all 1,525 employees at WCGS would loose their jobs and majority of Coffey County tax base would be
lost. Socioeconomics (Transportation) MODERATE to LARGE Transportation impacts associated with construction workers and shipments of coal and
lime to plant site. MODERATE to LARGE Same as for WCGS site. Aesthetics MODERATE Impacts due to boiler house, stack and on-site coal handling operations.MODERATE to LARGECooling towers, cooling tower plume and transmission lines add to impacts.
Environmental Impacts of License Renewal September 2007 8-21 Draft NUREG-1437, Supplement 32 Table 8-2. (contd) 1 2WCGS Site - Open Cycle Cooling Alternate Site - Cooling Towers ImpactCategory ImpactComments ImpactComments Historic and Archeological Resources SMALLPotential impacts can likely be effectively managed. SMALLImpacts would likely be greater than for the WCGS site since WCGS land is already
disturbed. However, impacts can generally
be effectively managed.
Environmental Justice SMALLImpacts on minority and low-income communities should be similar to those experienced by the population as a whole.
SMALL to LARGEImpacts depend on population distribution at
the site.
38.2.2 Natural Gas-Fired Generation 4 5In this section, the Staff examined the environmental impacts of constructing a natural gas-fired 6alternative for both the WCGS site and an alternate site. The Staff assumed that a gas-fired 7plant at the WCGS site would use Coffey County Lake for cooling while a gas-fired plant located 8at an alternate site would utilize closed cycle cooling.
9 10The assumptions and numerical values used in Section 8.2.2 are based on the Staff's 11independent assessment and on information provided by WCNOC in the WCGS ER 12(WCNOC 2006). Where staff used information from the ER, they independently reviewed and 13compared it to environmental impact information in the GEIS. Impacts of the gas-fired 14alternative evaluated by the Staff assume that the new plant would have a gross electrical 15capacity of 1,212 MW(e); this is larger than the capacity assumption WCNOC made in the ER.
16 17WCNOC assumed that a replacement natural gas-fired plant would use combined-cycle 18technology (WCNOC 2006). The natural gas-fired facility described by WCNOC in the ER is a 19combined-cycle plant; it would include a gas turbine followed by a heat-recovery boiler, which 20uses waste heat from gas-fired turbines to generate steam. The steam would then turn a steam 21turbine-generator. Furthermore, WCNOC uses two standard-sized gas-fired combined-cycle 22units with net capacities of 585 MW(e) and heat rates of 5,940 BTU/kWh in their analysis. The 23Staff considers the combined-cycle technology to be a reasonable choice for the gas-fired 24replacement system but that the capacity selected by WCNOC underestimates impacts of this 25technology. Consequently, the Staff has evaluated impacts of a hypothetical 1,212 gross 26 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-22 September 2007 MW(e) gas-fired combined-cycle facility (consisting of multiple units) which would essentially 1fully replace the capacity of the WCGS OL. Staff estimated the gross capacity of the gas-fired 2facility based on the assumption that 4 percent of the plant's output would be consumed on-site.
3 4The Staff has assumed that approximately 75 ac would be needed to construct a new gas-fired 5complex at the WCGS site and approximately 100 ac at an alternate site. This would include 6land for the power block and associated infrastructure. Since the WCGS site does not have a 7natural gas supply that can support power plant operations, it will be necessary to construct a 8tie-in to the nearest gas pipeline. WCNOC states in the ER that approximately 10 miles of new 9pipeline would be needed to connect WCGS to the nearest transmission line and that 60 ac of 10land would be disrupted for pipeline construction.
11 12Some of the existing infrastructure at WCGS can be used to serve operations of the gas-fired 13alternative. Most significantly this would include the transmission lines that currently transmit 14electric power from the plant to the regional electric grid. At an alternate site, it is almost certain 15that a new transmission line would need to be constructed to deliver the plant's output.
16 17In performing the impact analysis in Section 8.2.2 the Staff reviewed information provided by 18WCNOC, environmental information in the GEIS, and data available in the technical literature.
19Although the OL renewal period is only 20 years, the Staff considered the impact of operating 20the natural gas-fired alternative for 40 years. This assumption was used to maintain 21consistency between the alternative evaluations, even though a combined-cycle plant may have 22a shorter life expectancy.
23 24The overall impacts of a natural gas-fired system located at either the WCGS site or an 25alternate site are discussed below and summarized in Table 8-3, at the end of this section 26(Section 8.2.2.1).
27 288.2.2.1 Land Use 29 30Should a gas-fired generating facility be built at WCGS, existing facilities and infrastructure 31would be used to the extent practicable, limiting the amount of new construction that would be 32required. Specifically, the Staff assumed that the natural gas-fired replacement plant would use 33the switchyard, offices, and transmission lines from the existing WCGS. Some of the land that 34would be used has been previously disturbed. At WCGS, the Staff assumed that approximately 3575 ac would be needed for the plant and associated infrastructure. There would be an 36additional temporary impact of up to approximately 60 ac to bring natural gas to the WCGS site 37from the nearest gas transmission line.
38 39The Staff estimates that approximately 100 ac would be needed to construct a gas-fired 40complex, using closed cycle cooling, at an alternate site. It is likely that a gas-fired alternative at 41an alternate site would require additional infrastructure, including high voltage electric 42 Environmental Impacts of License Renewal September 2007 8-23 Draft NUREG-1437, Supplement 32 transmission lines and a natural gas pipeline. Constructing a gas pipeline would result in some 1temporary off-site land disturbance.
2 3Regardless of where the gas-fired replacement plant is built, additional offsite land would be 4required for natural gas wells and collection stations. In the GEIS, the Staff estimated that 53,600 ac would be needed for gas wells and collection stations to support a 1,000 MW(e) plant 6or about 4,300 ac for a 1,212 MW(e) facility (NRC 1996). Overall, land-use impacts of the gas-7fired alternative are considered to be MODERATE at the WCGS site and MODERATE to 8 LARGE at an alternate site.
9 108.2.2.2 Ecology 11 12At the WCGS site, a gas-fired alternative would continue to use of Coffey County Lake for 13cooling purposes. The gas-fired alternative is more thermally efficient than the existing WCGS, 14and thus requires less cooling water. The Staff concludes that water use may not decrease 15sufficiently to eliminate water use conflicts during low-flow conditions in the Neosho River, so 16aquatic ecological impacts of a gas-fired alternative would be SMALL to MODERATE. With 17regard to the terrestrial ecological impacts of building a gas-fired alternative, additional land 18clearing would be necessary to develop the gas-fired complex. This could entail some loss of 19natural habitat with a corresponding impact to terrestrial species. Also, bringing a natural gas 20pipeline onto the WCGS site may result in some further disturbance to undeveloped areas but it 21is expected that most of the pipeline construction would be in or along roadways and, therefore, 22would not be expected to impact terrestrial species. Overall, the ecological impacts of 23developing a gas-fired facility at the WCGS site are considered SMALL to MODERATE.
24 25Ecological impacts at an alternate site would depend on the nature of the land converted to 26industrial usage and the length of gas and electric transmission lines that would be constructed 27to support plant operations. Construction of transmission lines would be expected to have 28temporary ecological impacts, with continued impacts from ROW maintenance. Ecological 29impacts at the plant site and along transmission corridors could include impacts to threatened 30and endangered species, wildlife habitat loss and reduced productivity, habitat fragmentation, 31and a local reduction in biological diversity.
32 33Some aquatic ecological impacts would also be expected due to withdrawal of surface water for 34cooling tower makeup and for other in-plant needs. Overall, the ecological impacts of 35developing a gas-fired facility at an alternate site are considered MODERATE.
36 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-24 September 2007 8.2.2.3 Water Use and Quality 1 28.2.2.3.1 Surface Water 3
4Since the natural gas-fired facility described by WCNOC in the ER is a combined-cycle plant, 5the net result is improved plant efficiency and a significant overall reduction in the amount of 6waste heat that would be discharged to the environment in comparison to an equivalent 7capacity nuclear plant. Consequently, the gas-fired alternative would require considerably less 8cooling water than would the current WCGS. The gas-fired alternative may still result in water 9use conflicts associated with water availability from the John Redmond Reservoir and the 10Neosho River. In addition to cooling water discharges, a number of process waste streams 11could be discharged from the gas-fired complex. However, with the shutdown of the current 12WCGS, tritium concentrations in Coffey County Lake would stop increasing and gradually 13decay. All discharges would be regulated through a State-issued National Pollutant Discharge 14Elimination System (NPDES) permit. Finally, some erosion and sedimentation would probably 15occur during construction of the gas-fired plant (NRC 1996). Overall, the surface water use and 16quality impacts of implementing the natural gas-fired alternative at the WCGS site are 17considered SMALL to MODERATE since water use conflicts associated with water availability 18from the John Redmond Reservoir and the Neosho River could still occur.
19 20The Staff assumed that a natural gas-fired plant at an alternate site would employ a closed 21cycle cooling system. The Staff assumed that surface water would be used for cooling tower 22makeup and that the withdrawal rate of makeup water would be relatively small compared to an 23open-cycle system. The impact on surface water would depend on the volume of water needed 24for makeup and the characteristics of the receiving water body. Discharge to any surface water 25body would be regulated by the State of Kansas through the State-issued discharge permit.
26Overall the Staff expects that impacts to surface waters of constructing and operating a gas-27fired complex at an alternate site would be SMALL.
28 298.2.2.3.2 Groundwater 30 31In Chapter 4 of this draft SEIS, the Staff concluded that impacts of the use of cooling and 32service water on the availability of groundwater in the local area are SMALL. We would expect 33that a comparable capacity gas-fired alternative would also not use groundwater and, 34consequently, impacts to groundwater would be expected to be SMALL for a gas-fired 35replacement using once through cooling.
36 37At an alternate site, groundwater could be used for general plant purposes including as a 38potable water supply. Groundwater withdrawals would require a permit from either the State or 39a local permitting authority and impacts on groundwater would depend on the volume required 40and the characteristics of the water source. However, the Staff considers the likely impacts to 41 Environmental Impacts of License Renewal September 2007 8-25 Draft NUREG-1437, Supplement 32 groundwater of a gas-fired facility operating at an alternate site to be SMALL, provided the plant 1does not use groundwater for cooling tower makeup.
2 3 8.2.2.4 Air Quality 4 5Natural gas is a relatively clean-burning fuel. A new gas-fired generating plant located at either 6the WCGS or an alternate site would likely need a Prevention of Significant Deterioration permit 7and an operating permit under the CAA. A new combined-cycle natural gas power plant would 8also be subject to the new source performance standards for such units at 40 CFR Part 60, 9Subparts Da and GG. These regulations establish emission limits for particulates, opacity, SO x , 10 and NOx. 11 12In addition, EPA has various regulatory requirements for visibility protection in 40 CFR 51, 13Subpart P, including a specific requirement for review of any new major stationary source in an 14area designated attainment or unclassified under the CAA. Coffey County is a CAA attainment 15area and, therefore, a gas-fired replacement at the WCGS site would be subject to review under 16 40 CFR 51, Subpart P.
17 18Section 169A of the CAA establishes a national goal of preventing future and remedying 19existing impairments of visibility in mandatory Class I Federal areas when impairment results 20from man-made air pollution. EPA issued a new regional haze rule in on July 1, 1999 (64 FR 2135714 [EPA 1999]). The rule specifies that for each mandatory Class I Federal area located 22within a state, the State must establish goals that provide for reasonable progress towards 23achieving natural visibility conditions. The reasonable progress goals must provide for an 24improvement in visibility for the most impaired days over the period of the implementation plan 25and ensure no degradation in visibility for the least-impaired days over the same period (40 CFR 2651.308[d][1]). If a natural gas-fired plant were located close to a mandatory Class I area, 27additional air pollution control requirements could be imposed. There are no designated Class I 28areas in Kansas; however, EPA's regional haze rule could apply to a gas-fired complex at an 29alternate site.
30 31The Staff projects the following emissions for the natural gas-fired alternative:
32 33 SO x - 91 tons/yr 34 No x - 292 tons/yr 35 CO - 61 tons/yr 36 PM 10 - 51 tons/yr 37 38A natural gas-fired plant would also have unregulated CO 2 emissions that could contribute to 39global warming (NRC 1996).
40 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-26 September 2007 In December 2000, EPA issued regulatory findings on emissions of hazardous air pollutants 1from electric utility steam-generating units (EPA 2000b). Natural gas-fired power plants were 2found by EPA to emit arsenic, formaldehyde, and nickel (EPA 2000a). Unlike coal and oil-fired 3plants, EPA did not determine that emissions of hazardous air pollutants from natural gas-fired 4power plants should be regulated under Section 112 of the CAA.
5 6Construction activities for a gas-fired complex at either the WCGS site or an alternate site would 7result in temporary fugitive dust emissions. Fugitive dust emissions would also occur along the 8construction route for a new gas pipeline. These emissions would be short lived and 9intermittent and construction crews would likely mitigate some impacts through dust control 10measures. In addition, exhaust emissions would be released from vehicles and motorized 11equipment used during the construction process.
12 13The overall air quality impact of a new natural gas-fired complex sited at either the WCGS site 14or an alternate site is considered MODERATE.
15 16 8.2.2.5 Waste 17 18There will be spent SCR catalyst from NO x emissions control and small amounts of solid-waste 19products (i.e., ash) from burning natural gas. In the GEIS, the Staff concluded that waste 20generation from gas-fired technology would be minimal (NRC 1996). Gas-firing results in very 21few combustion by-products because of the clean nature of the fuel. Waste-generation impacts 22 would be so minor that they would not noticeably alter any important resource attribute.
23Construction-related debris would be generated during construction activities. Overall, impacts 24associated with waste generation at either the WCGS site or an alternate site would be SMALL 25for a natural gas-fired facility.
26 27 8.2.2.6 Human Health 28 29In Table 8-2 of the GEIS, the Staff identifies cancer and emphysema as potential health risks 30from gas-fired plants (NRC 1996). The risk may be attributable to NO x emissions that contribute 31to ozone formation, which in turn contribute to health risks. NO x emissions from any gas-fired 32plant would be regulated by a State air quality control agency, subject to New Source 33Performance Standards (NSPS), as well as Title IV, Section 407, of the CAA. Human health 34effects from gas-fired operations are not expected to be detectable and, therefore, the impacts 35on human health of the natural gas-fired alternative sited at either the WCGS site or an alternate 36site are considered SMALL.
37 38 8.2.2.7 Socioeconomics 39 40Construction of a natural gas-fired plant would take approximately 3 years. Peak employment 41would be approximately 600 workers (NRC 1996). At the WCGS site the Staff assumed that 42 Environmental Impacts of License Renewal September 2007 8-27 Draft NUREG-1437, Supplement 32 construction would take place while WCGS continues operation and would be completed by the 1time the nuclear plant permanently ceases operations. During construction, communities 2surrounding either the WCGS or the alternate site would experience demands on housing and 3public services that could have MODERATE impacts. After construction, nearby communities 4could be impacted by the loss of jobs. The current WCGS work force (1,525 permanent and 5long-term contract employees) would decline through a decommissioning period to a minimal 6maintenance staff. The gas-fired plant would introduce a replacement tax base at WCGS or a 7new tax based at an alternate site and approximately 200 new permanent jobs.
8 9In the GEIS (NRC 1996), the Staff concluded that socioeconomic impacts from constructing a 10natural gas-fired plant would not be very noticeable and that the small operational work force 11would have the lowest socioeconomic impacts of any nonrenewable technology. Compared to 12the coal-fired and nuclear alternatives, the smaller size of the construction work force, the 13shorter construction time frame, and the relatively small operations work force would mitigate 14socioeconomic impacts of a new plant. For these reasons, socioeconomic impacts associated 15with construction and operation of a natural gas-fired power plant at an alternate site would be 16SMALL to MODERATE, depending on the characteristics of the population near the site.
17However, the loss of a net 1,525 permanent jobs at the WCGS site could have a LARGE 18socioeconomic impact in the immediate WCGS locale.
19 20Transportation impacts associated with construction and operating personnel commuting to the 21plant site would depend on the population density and transportation infrastructure in the vicinity 22of the site. Overall the Staff expects that transportation impacts would be SMALL at either the 23WCGS site or an alternate site.
24 25 8.2.2.8 Aesthetics 26 27The gas-fired facility's turbine building (approximately 100 ft tall) and exhaust stacks 28(approximately 250 ft tall) would be visible during daylight hours from adjacent properties, 29though they are not significantly taller than the visible structures of the existing facilities (e.g., 30the domed reactor containment building is approximately 234 ft tall and the turbine building is 31approximately 150 ft tall). For the closed cycle cooling option at an alternate site, the cooling 32 tower and its evaporative plume can be expected to be visible from the nearby communities.
33Noise and light from the plant would be detectable in the immediate plant vicinity. Overall, the 34aesthetic impacts associated with the gas-fired facility at WCGS are categorized as SMALL. At 35an alternate site the cooling tower, the tower plume and the new transmission line would be 36expect to result in MODERATE to LARGE aesthetic impacts. However, the utilization of 37mechanical draft cooling towers could reduce the aesthetic impacts.
38 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-28 September 2007 8.2.2.9 Historic and Archaeological Resources 1 2Before construction begins studies would likely be needed to identify, evaluate, and address 3mitigation of the potential impacts of the new plant on cultural resources. The studies would 4likely be needed for all areas of potential disturbance at the proposed plant site and along 5associated corridors where new construction would occur. Because the gas-fired alternative 6occupies relatively little land, impacts to cultural resources can be effectively managed under 7current laws and regulations and are likely to be SMALL at either the WCGS site or an alternate 8 site.9 10 8.2.2.10 Environmental Justice 11 12No environmental pathways or locations have been identified that would result in dispro-13portionately high and adverse environmental impacts on minority and low-income populations if 14a replacement natural gas-fired plant were built at either the WCGS site or an alternate site.
15Some impacts on housing availability and prices during construction might occur, but it is not 16expected this would disproportionately affect minority and low-income populations. Closure of 17WCGS would result in a decrease in employment of approximately 1,325 permanent jobs if a 18gas-fired alternative were located at the WCGS site. If the plant were located elsewhere, 19surrounding communities would lose 1,525 jobs. Although the Staff concluded that the 20socioeconomic impacts of construction of a gas-fired generating plant at either the WCGS site 21or an alternate site would be MODERATE to LARGE, no environmental pathways or locations 22have been identified that would result in disproportionately high and adverse environmental 23impacts on minority and low-income populations. Therefore, environmental justice impacts of 24terminating nuclear operations at WCGS and replacing its output with a gas-fired facility at the 25same site are expected to be SMALL. Impacts at an alternate site would depend on the site 26chosen and the nearby population distribution, but are likely to be SMALL to MODERATE.
27 28 Table 8-3. Summary of Environmental Impacts of Natural Gas-Fired Generation at 29WCGS Site (Once-Through-Cooling) and at an Alternate Site (Closed-Cycle Cooling) 30 31WCGS Site Alternate Site ImpactCategory ImpactComments ImpactComments Land Use MODERATE 75 ac for powerblock, offices, roads, parking areas. Additional temporary impact of approximately 60 ac for construction of underground gas pipeline. MODERATE to LARGE 100 ac for plant and additional area for gas and electric transmission lines.
Environmental Impacts of License Renewal September 2007 8-29 Draft NUREG-1437, Supplement 32 Table 8-3. (contd) 1 2WCGS Site Alternate Site ImpactCategory ImpactComments ImpactComments EcologySMALL to MODERATE Reduced water withdrawals from Coffey County Lake. MODERATE Construction and long-term impacts of plant and transmission lines. Water Use and Quality-Surface Water SMALL to MODERATE Uses less cooling water than comparable nuclear
plant, but could still result in some water use conflicts. SMALL Cooling towers use relatively little water; impacts depend on water volume needed and water body characteristics.Water Use and Quality-Groundwater SMALLPlant would likely not use groundwater. SMALLImpacts depend on volume withdrawn; groundwater not likely to be used as cooling
water.Air Quality MODERATE
$ Sulfur oxides (91 tons/yr)
$ Nitrogen oxides (292 tons/yr)
$ Carbon monoxide (61 tons/yr)
$ PM 10 particulates (51 tons/yr) Some hazardous air pollutants. MODERATE Same emissions as for WCGS site. Waste SMALLSmall amount of ash produced. SMALLSame as at WCGS site. Human Health SMALL Impacts considered to be minor.SMALLSame as at WCGS site.
Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-30 September 2007 Table 8-3. (contd) 1 2WCGS Site Alternate Site ImpactCategory ImpactComments ImpactComments Socioeconomics MODERATE to LARGE Impacts of 600 construction jobs at peak; reduction in permanent work force by 1,325; partial tax base preserved. MODERATE to LARGE Impacts of 600 construction jobs and 200 new permanent jobs; enhanced tax base. However, all 1,525 employees at WCGS would loose their jobs
and the majority of Coffey County tax base would be lost. Socioeconomics (Transportation) SMALLTransportation impacts associated with construction. SMALLSame as at WCGS site.
Aesthetics SMALLPlant structures comparable in visibility to existing WCGS structures. MODERATE to LARGECooling towers, evaporative plume and transmission lines add to plant visual intrusion. Historic and Archeological Resources SMALLPotential impacts can likely be effectively managed. SMALLSame as at WCGS site.
Environmental Justice SMALLImpacts on minority and low-income communities should be similar to those experienced by the population as a whole.
SMALL to MODERATE Impacts would depend on the site chosen and the nearby population
distribution.
38.2.3 Nuclear Power Generation 4 5Since 1997, the NRC has certified four new standard designs for nuclear power plants under 10 6CFR Part 52, Subpart B. These designs are the 1,300 MW(e) U.S. Advanced Boiling Water 7Reactor (10 CFR 52, Appendix A), the 1,300 MW(e) System 80+ Design (10 CFR 52, Appendix 8B), the 600 MW(e) AP600 Design (10 CFR 52, Appendix C) and the 1,000 MW(e) AP1000 9Design (10 CFR Part 52, Appendix I). All of these plants are light-water reactors. Although 10NRC has yet to receive a complete Combined License (COL) application, the submission of 11one-half of the COL application and two Early Site Permits (ESPs) indicates strong interest in 12 Environmental Impacts of License Renewal September 2007 8-31 Draft NUREG-1437, Supplement 32 the possibility of licensing new nuclear power plants. In addition, recent escalation in prices of 1natural gas and oil has made new nuclear power plant construction more attractive from a cost 2 standpoint.
3 4As a result of the increased interest in new nuclear facilities, construction of a nuclear power 5plant at an alternate site is considered in this section. The Staff assumed that the new nuclear 6plant would have a 40-year lifetime and would operate with a closed cycle cooling system.
7 8NRC has summarized environmental data associated with the uranium fuel cycle in Table S-3 of 910 CFR 51.51. The impacts shown in Table S-3 are representative of the impacts that would be 10associated with a replacement nuclear power plant built to one of the certified designs, sited at 11an alternate site. The impacts shown in Table S-3 are for a 1,000 MW(e) reactor and would 12need to be adjusted to reflect impacts of a new nuclear facility, to replace the output of WCGS, 13with a net capacity of 1,165 MW(e). The environmental impacts associated with transporting 14fuel and waste to and from a light-water cooled nuclear power reactor are summarized in 15Table S-4 of 10 CFR 51.52. The summary of NRC's findings on NEPA issues for license 16renewal of nuclear power plants in Table B-1 of 10 CFR 51 Subpart A, Appendix B, is also 17relevant, although not directly applicable, for consideration of environmental impacts associated 18with the operation of a replacement nuclear power plant. Additional environmental impact 19information for a replacement nuclear power plant using closed-cycle cooling is presented in 20Section 8.2.3.1.
21 228.2.3.1 Land Use 23 24Land-use impacts at an alternate site would be significant since the new nuclear plant, with its 25associated closed-cycle cooling system, would entail development on approximately 500-1,000 26ac of land area. In addition, property would be needed to construct a transmission line form the 27site to the nearest tie-in with the regional transmission system. A rail spur could also be 28constructed to deliver materials and equipment during construction. A nuclear alternative would 29require approximately the same amount of land for uranium mining as currently required for 30WCGS. Development of a new nuclear project at an alternate site could result in MODERATE 31to LARGE land-use impacts.
32 338.2.3.2 Ecology 34 35Ecological impacts would result from both construction and operation of the replacement 36nuclear facility. The terrestrial ecological impacts could include wildlife habitat loss, reduced 37productivity, habitat fragmentation and a local reduction in biological diversity. Construction of a 38transmission line would further exacerbate terrestrial impacts but would be highly dependent on 39the length of line and the specific habitat conditions that occur long the transmission corridor.
40 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-32 September 2007 Drawing on local surface water resources for cooling tower makeup could have some adverse 1aquatic resource impacts. Additional impacts could occur from the discharge of cooling tower 2 blow-down.
3 4Overall, ecological impacts are expected to range from MODERATE to LARGE with the 5principal issue being loss of habitat due to on-site and off-site construction.
6 7 8.2.3.3 Water Use and Quality 8 9 8.2.3.3.1 Surface Water 10 11Construction and operation of a nuclear facility could potentially impact water use and quality in 12several ways. Construction of the plant would entail disruption to undeveloped portions of the 13alternate site resulting in potential soil erosion and sediment discharge to local surface waters.
14In addition, construction activities involve substantial use of diesel-driven equipment and 15lubricants and cleaning agents. While construction activities are regulated under various 16Federal and State stormwater management programs, some potential will exist for release of 17construction related contaminants to nearby surface water bodies.
18 19During operation, the facility's cooling tower(s) would draw on local surface waters for makeup 20of evaporative losses. In addition, various plant systems may use surface waters for 21supplemental cooling and plant potable water needs could also be derived from a surface water 22body. Discharges to surface waters could include cooling tower blowdown and treated process 23 and sanitary wastes.
24 25All withdrawals from and discharges to surface waters would be regulated by Federal and State 26programs designed to protect water quality. While actual impacts would be site dependent, the 27Staff concludes that impacts to water quality resulting from construction and operation of a new 28nuclear facility at an alternate site would be SMALL.
29 30 8.2.3.3.2 Groundwater 31 32It is possible that groundwater could be used as a source of service and/or potable water by a 33nuclear plant on an alternate site. In addition, it would be possible to discharge process water 34and sanitary wastes to groundwater after those waste streams receive an appropriate level of 35treatment. Withdrawals from and discharges to groundwater are regulated by Federal and State 36environmental agencies under programs intended to protect such resources. Thus, the impacts 37of an operating nuclear plant on groundwater resources at an alternate site are expected to be 38 SMALL.39 Environmental Impacts of License Renewal September 2007 8-33 Draft NUREG-1437, Supplement 32 8.2.3.4 Air Quality 1 2Construction of a new nuclear plant would result in fugitive emissions during the construction 3process. Exhaust emissions would also come from vehicles and motorized equipment used 4during the construction process. An operating nuclear plant would have minor air emissions 5associated with diesel generators and other intermittent sources. Overall, air emissions and 6associated impacts resulting from operation of a replacement nuclear facility at an alternate site 7are considered SMALL.
8 9 8.2.3.5 Waste 10 11Siting a replacement nuclear plant at an alternate site would not alter radwaste generation rates 12currently occurring at WCGS. The waste impacts associated with operation of a nuclear power 13plant are set out in Table B-1 of 10 CFR 51, Subpart A, Appendix B. However, considerable 14debris would be generated during construction of the new facility, resulting in the need to 15dispose of the material at an appropriate off-site disposal facility. Overall, waste impacts of 16constructing and operating a nuclear facility are considered SMALL.
17 18 8.2.3.6 Human Health 19 20Human health impacts for an operating nuclear power plant are set out in 10 CFR 51 Subpart A, 21Appendix B, Table B-1. Overall, the Staff concludes that human health impacts would be 22 SMALL.23 24 8.2.3.7 Socioeconomics 25 26The construction period peak work force associated with construction of a new nuclear power 27plant is currently unquantified (NRC 1996). In the absence of quantitative data, the Staff 28assumed a construction period of 6 years and a peak work force of up to 2,500 for a 1,165 net 29MW(e) nuclear facility at an alternate site.
30 31The communities around the alternate site would have to absorb the impacts of the large, 32temporary construction work force and a permanent and long-term contract work force of 33approximately 1,525 (same employment level as at WCGS). In the GEIS (NRC 1996), the Staff 34indicated that socioeconomic impacts of the temporary and permanent work forces would be 35larger at a rural site than at an urban site because more of the work force would need to move 36into the area. Furthermore, while employment levels would increase for communities adjacent 37to the alternate site, approximately 1,525 jobs would be lost over time within communities near 38the WCGS site. Also, property taxes would dramatically increase for communities near the 39alternate site and would significantly diminish for communities near WCGS. Consequently, the 40Staff concludes that socioeconomic impacts of constructing and operating a replacement 41nuclear facility at an alternate site would range from MODERATE to LARGE, with the WCGS 42 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-34 September 2007 site experiencing the larger impact due to the overall loss of permanent and long-term contract 1 employees.
2 3Transportation-related impacts associated with construction workers commuting to the alternate 4site would be site dependent but are expected to be MODERATE. Transportation impacts 5related to employees and contractors commuting to the operating nuclear facility would be also 6site dependent but typically are characterized as SMALL to MODERATE.
7 8 8.2.3.8 Aesthetics 9 10Developing an alternate site for a 1,165 net MW(e) nuclear facility would result in aesthetic 11impacts at that site from the new structures associated with the plant including buildings, cooling 12towers, and the plume associated with the cooling towers. There would also be a potentially 13significant aesthetic impact from construction of a new transmission line to connect the 14generating station to the regional transmission system.
15 16Noise and light related to construction and plant operations would be detectable off-site.
17However, under some circumstances noise and light impacts could be mitigated depending on 18local topography and the distances to nearby residences and other sensitive land uses. Overall, 19aesthetic impacts associated with locating a new nuclear facility at an alternate site can be 20categorized as MODERATE to LARGE. The greatest contributors to aesthetic impacts would 21be the cooling tower structures, the discharged vapor plume and the new transmission towers.
22 23 8.2.3.9 Historic and Archaeological Resources 24 25A cultural resource inventory would be needed before construction of a replacement nuclear 26plant could begin at an alternate site if the site had not been previously surveyed. Other lands, 27if any, that are acquired to support the plant would also likely need an inventory of field cultural 28resources, identification and recording of existing historic and archaeological resources, and 29possible mitigation of adverse effects from subsequent ground-disturbing actions related to plant 30construction. Impacts to cultural resources can be effectively managed under current law, and 31are likely to be SMALL.
32 33 8.2.3.10 Environmental Justice 34 35Whether or not there would be disproportionate impacts to minority and low income populations 36resulting from construction and operation of a nuclear facility at an alternate site would depend 37upon the site chosen and the nearby population distribution. Under a wide range of site 38circumstances, it is expected that the impacts would range from SMALL to MODERATE.
39 Environmental Impacts of License Renewal September 2007 8-35 Draft NUREG-1437, Supplement 32 Table 8-4. Summary of Environmental Impacts of New Nuclear Power Generation at 1at an Alternate Site Using Closed-Cycle Cooling 2 3Alternate Site Impact Category ImpactComments Land Use MODERATE to LARGE Approximately 500-1,000 ac required on-site. EcologyMODERATE to LARGE Impacts depend on location and ecology of site; the principal issue is loss of habitat due to on-site and off-site construction. Water Use and Quality-Surface water SMALLImpacts are site dependent but surface water use is a regulated activity. Water Use and Quality-Groundwater SMALLImpacts are site dependent but groundwater use is a regulated activity. Air Quality SMALLEmissions from new nuclear plant expected to be minor. Waste SMALLConsiderable debris would be generated during construction, and would be disposed at an appropriate off-site facility. Human Health SMALLHuman health impacts for nuclear facility considered small.Socioeconomics LARGEImpacts at the alternate site due to construction and permanent work force and long-term increased tax revenues; at WCGS the impacts would be LARGE due to a reduction in tax revenues and decrease in employment levels. Socioeconomics (Transportation) MODERATE Impacts due to construction workers and permanent staff commuting to the alternate site. Aesthetics MODERATE to LARGEImpacts expected from cooling towers, vapor plume, and transmission lines. Historic and Archeological Resources SMALLAny potential impacts can likely be effectively managed. Environmental Justice SMALL to MODERATE Impacts will vary depending on population distribution near the alternate site.
48.2.4 Purchased Electrical Power 5 6If available, purchased power could potentially obviate the need to renew the WCGS OL. If the 7OL were not renewed, replacing the lost 1,165 MW(e) of capacity with purchased power without 8building new generating facilities is not a likely scenario. It is not likely because demand in the 9Southwest Power Pool Region, in which WCGS is located, is projected to continue to increase 10by 1.3 percent per year for the period 2006 thru 2015 (NERC 2006).
11 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-36 September 2007 If power to replace WCGS capacity were to be purchased from sources within the United 1States, the generating technology would likely be one of those described in this draft SEIS and 2in the GEIS (probably coal, natural gas, nuclear and some contribution from wind projects). The 3description of the environmental impacts of other technologies in Chapter 8 of the GEIS is 4representative of the impacts of purchasing electrical power from a domestic source. Thus, the 5environmental impacts of purchased power would still occur, but those impacts would occur 6elsewhere in the region or nation.
7 8Beyond domestic sources of purchased power, imported power from Canada or Mexico is 9unlikely to be available for replacement of WCGS capacity. In Canada, approximately 25 10percent of the energy consumed within the country comes from renewable energy sources, 11principally hydropower (DOE/EIA 2005). Canada's output of electricity from nuclear power is 12projected to remain more or less flat between 2010 (114 billion kWh) and 2025 (112 billion kWh) 13(DOE/EIA 2005). EIA projects that total gross U.S. imports of electricity from Canada and 14Mexico will decrease from 42.3 billion kWh in 2010 to 29.4 billion kWh in year 2020 and to 26.9 15billion kWh in year 2030 (DOE/EIA 2007). Over the same period there is essentially no firm 16power projected to be exported from the U.S. to either Canada or Mexico. Consequently, it is 17unlikely that electricity imported from Canada or Mexico would be able to replace the capacity 18 lost at WCGS if the OL is not renewed.
19 208.2.5 Other Alternatives 21 22Other generation technologies considered by NRC are discussed in the following paragraphs.
23 248.2.5.1 Oil-Fired Generation 25 26The EIA projects that oil-fired plants will account for very little of the new generating capacity in 27the United States during the 2004 to 2030 timeframe because of continually rising fuel costs 28(DOE/EIA 2007). Thus, NRC staff has not considered an oil-fired replacement for the capacity 29that would be lost if WCGS ceases operation.
30 318.2.5.2 Wind Power 32 33Wind power, by itself, is not suitable for large base load capacity. As discussed in Section 8.3.1 34of the GEIS, wind has a high degree of intermittency, and average annual capacity factors for 35wind plants are relatively low (on the order of 30 percent). Wind power, in conjunction with 36energy storage mechanisms, might serve as a means of providing base load power. However, 37current energy storage technologies are too expensive for wind power to serve as a large base 38load generator.
39 Environmental Impacts of License Renewal September 2007 8-37 Draft NUREG-1437, Supplement 32 Most regions of the United States have been classified according to available wind power. Wind 1power classifications are based on typical wind speeds at 50 meters (m; approximately 164 ft) 2elevation above local grade. These classifications range from Class 1 (the lowest available 3wind power) to Class 7 (the highest). Regions classified as being in wind power Class 4 or 4higher can typically be useful for siting large wind power turbines. Given advances in 5technology, a number of locations in Class 3 areas may be suitable for utility-scale wind 6development. Taller wind turbines can also take advantage of some Class 3 locations with high 7wind shear.
8 9The State of Kansas has wind resources consistent with utility-scale production. The state's 10wind resources are ranked among the top three in the nation (U.S. Public Interest Research 11Group 2003). Large areas with outstanding potential for siting wind energy farms can also be 12found throughout central portions of the State (KCC 2004). In Kansas, as of May 2007, there 13 were five operating wind farms with a total name plate capacity of 363 MW(e) and there were 24 14projects in planning with a total capacity of 3,234 MW(e) (KEIN 2007).
15 16Construction of a wind energy farm with a name plate rating of 1,165 MW(e) would require a 17land area of at least 25 sq mi. (16,000 ac). Turbine footprints would require a small portion of 18this land, while the remaining area could be used for farming or ranchland. More significantly, 19though, wind generators provide output when meteorological conditions are appropriate and 20may operate with capacity factors of only 30 percent, or even less. As stated by the Southwest 21Power Pool in their regional self-assessment (NERC 2006), wind farms can only be expected to 22contribute between zero and 20 percent of name plate rating during summer peak load 23conditions. In contrast, WCGS contributed between 86 and 101 percent of nameplate capacity 24from 2000 to 2005. As a result, at least 5 times as much wind capacity, using approximately 25125 sq mi or more, would need to be constructed to replace WCGS. This capacity would need 26to be distributed across different areas of the state or region to account for local wind variability.
27Given the extensive land requirements and uncertain capacity factors, wind energy generators 28are not considered a reasonable alternative to WCGS.
29 308.2.5.3 Solar Power 31 32Solar power generation uses the sun's energy to produce electricity. In the GEIS, the Staff 33noted that by its nature, solar power is intermittent. Therefore, solar power by itself is not 34suitable for base load capacity and is not a feasible alternative to license renewal of WCGS.
35The average capacity factor of photovoltaic cells is about 25 percent, and the capacity factor for 36solar thermal systems is about 25 to 40 percent. Solar power, in conjunction with energy 37storage mechanisms, could potentially serve as a means of providing base load power.
38However, current energy storage technologies are too expensive to permit solar power to serve 39as a large base load generator. Therefore, solar power technologies (photovoltaic and thermal) 40cannot currently compete with conventional fossil-fueled technologies in grid-connected 41applications, due to high costs per kilowatt of capacity (NRC 1996).
42 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-38 September 2007 The State of Kansas receives, depending on location, approximately 3.5 to 5.0 kWh of solar 1radiation per square meter per day (KEC 2005).The ER (WCNOC 2006) states that between 13 2and 19 sq. mi. (8,320 and 12,160 ac) would be needed to accommodate solar power systems 3that provide a capacity equivalent to that of WCGS. The Staff agrees with those estimates. As 4a result of such extensive land requirements, construction of a solar system of comparable 5capacity to WCGS could generate significant impacts to natural resources (wildlife habitat, land 6use, and aesthetic impacts). For that reason and because of the system's low capacity factor 7and high cost, solar power is not deemed a feasible baseload alternative to renewal of the 8WCGS OL.
9 108.2.5.4 Hydropower 11 12In Section 8.3.4 of the GEIS, the Staff points out hydropower's percentage of U.S. generating 13capacity is expected to decline because hydroelectric facilities have become difficult to site as a 14result of public concern about flooding, destruction of natural habitat, and alteration of natural 15 river courses.
16 17The Staff estimated in the GEIS that land requirements for hydroelectric power are 18approximately 1 million ac per 1,000 MW(e). Due to the relatively low amount of undeveloped 19hydropower resource in Kansas (EG&G Idaho, Inc. 1993) and elsewhere in nearby states, and 20the large land use and related environmental and ecological resource impacts associated with 21siting hydroelectric facilities of a scale to replace WCGS, the Staff concludes that hydropower is 22 not a feasible alternative to OL renewal.
23 248.2.5.5 Geothermal Energy 25 26Geothermal energy has an average capacity factor of 90 percent and can be used for baseload 27power where available. However, geothermal technology is not widely used as baseload 28generation due to the limited geographical availability of the resource and immature status of 29the technology (NRC 1996). As illustrated by Figure 8.4 in the GEIS, geothermal plants are 30most likely to be sited in the western continental United States, Alaska, and Hawaii where 31hydrothermal reservoirs are prevalent. Since such resources are not available in the State of 32Kansas, the Staff concludes that geothermal energy is not a feasible alternative to renewal of 33the WCGS OL.
34 358.2.5.6 Wood Waste 36 37The use of wood waste to generate electricity is largely limited to those states with significant 38wood resources, such as California, Maine, Georgia, Minnesota, Oregon, Washington, and 39Michigan. Electric power is generated in these states by the pulp, paper, and paperboard 40 Environmental Impacts of License Renewal September 2007 8-39 Draft NUREG-1437, Supplement 32 industries, which consume wood and wood waste for energy, benefiting from the use of waste 1materials that could otherwise represent a disposal problem.
2 3A wood-burning facility can provide baseload power and operate with an average annual 4capacity factor of around 70 to 80 percent and with 20 to 25 percent efficiency (NRC 1996).
5However, the fuels required are variable and site-specific. A significant barrier to the use of 6wood waste to generate electricity is the high delivered-fuel cost and high construction cost per 7MW of generating capacity. The larger wood-waste power plants have electrical output 8capacities in the range of 40 to 50 MW(e). Estimates in the GEIS suggest that the overall level 9of construction impact per MW of installed capacity should be approximately the same as that 10for a coal-fired plant, although facilities using wood waste for fuel would be built at smaller 11scales. Like coal-fired plants, wood-waste plants require large areas for fuel storage and 12processing and involve somewhat comparable combustion equipment.
13 14According to researchers from Oak Ridge National Laboratory, the University of Tennessee, 15and Science Applications International Corporation (Walsh, et al 1999), Kansas contains 16relatively little wood waste at costs of up to $50 per ton. When converted to potential power 17output (using factors from the National Renewable Energy Laboratory [DOE/NREL 2004]), the 18total annual potential is approximately one-sixth the annual output of WCGS. Even if a wood-19burning facility could also consume all crop residues in the state potentially available for less 20than $50 per ton, the total plant output would be only 25% greater than the output of WCGS.
21Walsh, et al, note that their analysis includes significant uncertainty and that collecting available 22wood residues could prove to have significant environmental consequences. As such, NRC 23staff believes wood and crop residue would be insufficient to support a wood-waste-fired 24 alternative.
25 26Due to the lack of wood and wood waste resources in Kansas, the ecological impacts of large-27scale wood waste collection (for example, soil erosion and loss of wildlife habitat), high 28transportation costs, and low plant efficiency the Staff has determined that wood and wood 29waste generating facilities are not feasible alternatives to renewing the WCGS OL.
30 318.2.5.7 Municipal Solid Waste 32 33Municipal waste combustors incinerate the waste and use the resultant heat to generate steam, 34hot water, or electricity. The combustion process can reduce the volume of waste by up to 90 35percent and the weight of the waste by up to 75 percent. Municipal waste combustors use two 36basic types of technologies: mass burn and refuse-derived fuel. Mass burning technologies are 37most commonly used in the United States. These technologies process raw municipal solid 38waste "as is", with little or no sizing, shredding, or separation before combustion.
39 40Growth in the municipal waste combustion industry slowed dramatically during the 1990s after 41 rapid growth during the 1980s. The slower growth was due to three primary factors: (1) the Tax 42 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-40 September 2007 Reform Act of 1986, which made capital-intensive projects such as municipal waste combustion 1facilities more expensive relative to less capital-intensive waste disposal alternative such as 2landfills; (2) the 1994 Supreme Court decision (C&A Carbone, Inc. v. Town of Clarkstown
), 3which struck down local flow control ordinances that required waste to be delivered to specific 4municipal waste combustion facilities rather than landfills that may have had lower fees; and (3) 5increasingly stringent environmental regulations that increased the capital cost necessary to 6construct and maintain municipal waste combustion facilities (DOE/EIA 2007).
7 8The decision to burn municipal waste to generate energy is usually driven by the need for an 9alternative to landfills rather than by energy considerations. The use of landfills as a waste 10disposal option is likely to increase in the near term; however, it is unlikely that many landfills 11will begin converting waste to energy because of unfavorable economics.. For instance, 12DOE/EIA projects that between 2006 and 2030, the average price of electricity in constant 13dollars will fall in the intermediate term (thru 2015) and then rise steadily resulting in a net 14 modest decline over the entire study period (DOE/EIA 2007).
15 16Currently there are approximately 89 waste-to-energy plants operating in the United States.
17These plants generate approximately 2,700 MW(e), or an average of approximately 30 MW(e) 18per plant (IWSA 2006). The initial capital costs for municipal solid-waste plants are greater than 19for comparable steam-turbine technology at wood-waste facilities. This is due to the need for 20specialized waste-separation and handling equipment for municipal solid waste (NRC 1996).
21 22The GEIS estimates that the overall level of construction impact from a waste-fired plant should 23be approximately the same as that for a coal-fired plant. Additionally, waste-fired plants have 24the same or greater operational impacts (including impacts on the aquatic environment, air, and 25waste disposal). Some of these impacts would be moderate, but still larger than the 26environmental effects of renewal of the WCGS OL. Therefore, municipal solid waste facilities, 27at the scale required to replace WCGS, would not be feasible alternatives to renewal of the 28 WCGS OL. 29 308.2.5.8 Other Biomass-Derived Fuels 31 32In addition to wood and municipal solid-waste fuels, there are several other concepts for fueling 33electric generators, including burning crops, converting crops to a liquid fuel such as ethanol, 34and gasifying crops (including wood waste). In the GEIS, the Staff points out that none of these 35technologies has progressed to the point of being competitive on a large scale, or of being 36reliable enough to replace a baseload plant such as WCGS. In developing this SEIS, staff 37reevaluated this assertion and determined that other biomass-derived fuels do not yet offer a 38feasible alternative to renewing the WCGS OL.
39 Environmental Impacts of License Renewal September 2007 8-41 Draft NUREG-1437, Supplement 32 8.2.5.9 Fuel Cells 1 2Fuel cells work without combustion and, consequently, avoid the environmental effects of 3combustion processes. Power is produced electrochemically by passing a hydrogen-rich fuel 4over an anode and air over a cathode and separating the two by an electrolyte. The only by-5products are heat, water, and CO
- 2. Hydrogen fuel can come from a variety of hydrocarbon 6resources by subjecting them to steam under pressure. Natural gas is typically used as the 7 source of hydrogen.
8 9Phosphoric acid fuel cells are generally considered first-generation technology. These fuel cells 10are commercially available at a cost of approximately $4,500 per kW of installed capacity 11(DOE/NETL 2005). Higher-temperature second-generation fuel cells achieve higher fuel-to-12electricity and thermal efficiencies. The higher temperatures contribute to improved efficiencies 13and give the second-generation fuel cells the capability to generate steam for cogeneration and 14 combined-cycle operations.
15 16The DOE has an initiative to reduce fuel cell costs to as low as $400 per kW of installed 17capacity. For comparison, the installed capacity cost for a natural gas-fired combined-cycle 18plant is about $456 per kW (DOE/NETL 2005). As market acceptance and manufacturing 19capacity increase, natural gas fuel cells plants in the 50- to 100-MW(e) range are expected to 20become available. At the present time, however, fuel cells are not economically competitive 21with other alternatives for base-load electricity generation. Fuels cells are, consequently, not a 22feasible alternative to renewal of the WCGS OL.
23 248.2.5.10 Delayed Retirement 25 26It is possible that the power being provided by WCGS could be replaced by delaying the 27retirement of other generating assets located throughout the State of Kansas or the Southwest 28Power Pool region. The applicant states that they are unaware of any plans for retiring Kansas' 29generating plants (WCNOC 2006). During conversations with staff of the Kansas Corporation 30Commission, (e) it was determined that there are no designated retirements of generating 31capacity within the State. The State's older coal and gas-fired units have been included in 32capacity projections in relationship to meeting demand. These older units operate at peak 33demand times, are used for voltage control, and assist in balancing the load when wind 34generators in Western Kansas are not operating.
35 (e)Personal communication: Larry Holloway, Chief of Energy Operations, Kansas Corporation Commission, June 21, 2007. (Accession No. ML072420250).
Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-42 September 2007 In addition, based on an assessment developed by the Southwest Power Pool (NERC 2006), 1electricity consumption throughout the region is projected to grow at 1.3 percent/yr. The Kansas 2Energy Council (KEC 2007) projects that electricity demand will increase by 2.5 percent 3annually in Kansas over the next ten years. These projections suggest that that capacity 4additions will be required in the region and that retirements are probably being avoided to the 5extent that economics and environmental regulation allow. Given that there are no plans to 6retire existing generating facilities and the fact that demand for electricity is projected to 7increase for the next ten years, the Staff considers delayed retirement not to be a feasible 8alternative to license renewal of WCGS.
9 108.2.5.11 Conservation 11 12Kansas, as have most other states, has initiated a range of state-wide programs to reduce 13energy demand through conservation and efficiency (KEC 2007). Among the existing 14conservation and efficiency policies/programs in the State are the following:
15 161) State adoption of the International Energy Conservation Code in 2003 as applicable to 17new industrial and commercial structures; 18 192) State requirement for sellers of new homes to disclose, upon request, information 20regarding the thermal efficiency of the structure; 21 223) Several Kansas cities have adopted the International Residential Code which, in part, 23addresses energy efficiency; 24 254) State adoption of the International Energy Efficiency Code for new state-owned facilities; 26 275) Several Kansas utilities, including the owners of WCGS (WCNOC 2006) offer energy 28conservation services to their customers; 29 306) Offer the Kansas Weatherization Program to moderate income households; and 31 327) State launches KEEP (Kansas Energy Efficiency Program) to provide low interest loans 33to low and moderate income households for energy efficiency improvements.
34 35Several additional conservation and efficiency programs that require either legislative or 36administrative action have been recommended including the following (KEC 2007):
37 381) Establish state-wide utility operated energy education and conservation programs; 39 402) Amend existing laws relating to energy efficiency disclosures for new homes; 41 Environmental Impacts of License Renewal September 2007 8-43 Draft NUREG-1437, Supplement 32 3) Encourage local units of government to adopt minimum energy efficiency standards for 1new construction; and 2 34) Encourage utilities to implement PAYS (Pay as You Save) -type pilots that allows 4customers to fund certain efficiency improvements through their utility bills.
5 6These conservation and efficiency programs have had an impact on demand for electricity and 7that impact has been factored into the projections for demand developed by the Southwest 8Power Pool and by the State of Kansas. These conservation and efficiency programs have had 9an impact on demand for electricity that State and regional planners have factored into 10electricity demand projections for the State of Kansas and for the Southwest Power Pool. NRC 11staff notes that Kansas has been recognized for some of its achievements in energy efficiency, 12while staff also notes that quantifiable program impacts, as well as potential conservation 13capacity projections, have not been forthcoming. In the absence of quantifiable potential or 14program achievements to date, the Staff will not evaluate conservation or efficiency programs 15as replacements for the full output of WCGS. Staff will, however, consider conservation as part 16of a combination alternative.
17 188.2.6 Combination of Alternatives 19 20Even though individual alternatives might not be sufficient on their own to replace the WCGS 21capacity due to lack of cost-effectiveness or availability, it is conceivable that a combination of 22alternatives might be sufficient, as well as cost-effective. WCGS has a net generating capacity 23of 1,165 MW(e) and a number of combinations could potentially be considered to replace the 24plant. Table 8-5 contains a summary of the environmental impacts of an assumed combination 25of alternatives consisting of a 585 MW(e) natural gas combined-cycle complex (50 percent of 26the WCGS net output), 290 MW(e) of purchase power (25 percent of the WCGS net output) and 27290 MW(e) of conservation. The summary in Table 8-5 assumes that the gas-fired facility 28operates at either the WCGS site (once through cooling) or an alternate site (closed cycle 29 cooling).30 31Environmental impacts of the natural gas combined-cycle unit are based on the analysis 32presented in Section 8.2.2, adjusted for the reduced capacity. The analysis shows that the 33principal impacts of the natural gas combined cycle unit are related to construction activity, use 34of additional undeveloped land, increased air emissions, loss of permanent jobs in the WCGS 35vicinity, and aesthetics (due to cooling tower). Table 8-5 shows no particular impacts ascribed to 36the conservation measures that would need to be implemented to replace 25 percent of WCGS 37capacity, as the GEIS notes that impacts from a conservation alternative would be mostly 38SMALL, and, in some cases, negligible. The environmental impacts associated with purchased 39power (25 percent of WCGS output) are not shown on Table 8-5. Impacts of purchased power 40would still occur but would be located elsewhere in the region (see Section 8.2.4).
41 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-44 September 2007 Table 8-5. Summary of Environmental Impacts of 585 MW(e) of Natural Gas-Fired Generation, 290 1MW(e) Purchase Power, and 290 MW(e) Conservation 2 3WCGS - Open Cycle Alternate Site - Closed Cycle ImpactCategory ImpactComments ImpactComments Land Use MODERATE 40 ac for powerblock, offices, roads, parking areas. Additional temporary impact of approximately 60 ac for construction of underground gas pipeline. MODERATE 50 ac for plant and additional area for gas and electric transmission lines. EcologySMALL to MODERATE Reduced water withdrawals from Coffey County Lake. MODERATE Construction and long term impacts of plant and transmission lines. Water Use and Quality-Surface Water SMALL to MODERATE Considerably less water use than WCGS, but could still
result in some water use conflicts. SMALLCooling tower significantly reduces water withdrawals. Water Use and Quality-Groundwater SMALLDoes not use groundwater. Impacts to aquifers controlled by State. SMALLImpacts depend on volume withdrawn. Air Quality MODERATE
$ Sulfur oxides (46 tons/yr)
$ Nitrogen oxides (146 tons/yr)
$ Carbon monoxide (31 tons/yr)
$ PM 10 particulates (26 tons/yr) Some hazardous air pollutants. MODERATE Same emissions as for WCGS site. Waste SMALLSmall amount of ash produced.
SMALL to MODERATE Impacts would depend on the site chosen and the nearby population
distribution.
Environmental Impacts of License Renewal September 2007 8-45 Draft NUREG-1437, Supplement 32 Table 8-5.(contd)1 2WCGS - Open Cycle Alternate - Closed Cycle ImpactCategory ImpactComments ImpactComments Human Health SMALLImpacts considered to be minor.SMALLSame as at WCGS site. Socioeconomics MODERATE to LARGE Impacts due to 300 construction workers during peak construction period; reduction in permanent work force by 1,425; tax base partially preserved.MODERATE to LARGE Impacts due to 300 construction worker; 100 new permanent jobs;
enhanced tax base.
However, all 1,525 employees at WCGS would loose their jobs
and the majority of
Coffey County tax base would be lost. Socioeconomics (Transportation) SMALLTransportation impacts associated with construction. SMALLSame as at WCGS site. Aesthetics SMALLPlant structures comparable in visibility to existing WCGS structures. MODERATE to LARGE Cooling towers, evaporative plume and transmission lines add
to plant visibility. Historic and Archeological Resources SMALLPotential impacts can likely be effectively managed. SMALLSame as at WCGS site.
Environmental Justice SMALLImpacts on minority and low-income communities should be similar to those experienced by the population as a whole. SMALLSame as at WCGS site.
38.3 Summary of Alternatives Considered 4 5The environmental impacts of the proposed action, renewal of the WCGS OL are either SMALL 6or SMALL to MODERATE for all impact categories, except for collective off-site radiological 7impacts from the fuel cycle and from high-level waste (HLW) and spent fuel disposal. Collective 8
Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-46 September 2007 off-site radiological impacts from the fuel cycle and from HLW and spent fuel disposal were not 1assigned a single significance level but were determined by the Commission to be Category 1 2issues nonetheless.
3 4In comparison, impacts from alternatives to license renewal would be greater than the impacts 5of license renewal. For example, the land-disturbance impacts resulting from construction of 6any new facility would be greater than the impacts of continued operation of WCGS. The 7impacts of electrical power purchased outside of Kansas would still occur, but would occur 8elsewhere. In addition, Staff finds it very unlikely that the environmental impacts of any 9reasonable combination of generation and conservation options could be reduced to the level of 10impacts associated with renewal of the WCGS OL. In conducting this analysis, NRC staff 11considered impacts from the no-action alternative (discussed in Section 8.1), new generation 12alternatives (from coal, natural gas, and nuclear; discussed in Sections 8.2.1 through 8.2.3, 13respectively), purchased electrical power (discussed in Section 8.2.4), alternative technologies 14unable to individually replace WCGS (discussed in Section 8.2.5), and a combination of 15alternatives (discussed in Section 8.2.6).
16 17If NRC renews the WCGS license, NRC leaves the decision of whether to continuing operating 18WCGS or to rely on an energy alternative to the appropriate state- and utility-level 19 decisionmakers. If NRC takes no action, i.e., NRC does not renew the license, then appropriate 20decisionmakers would have to replace existing WCGS capacity by using one of the alternatives 21staff considered in Section 8.2.
22 23Based on analysis in the preceding chapter, the Staff concludes that the environmentally 24preferred alternative for meeting future electrical system needs is renewal of the WCGS OL, 25thereby allowing decisionmakers the option of operating WCGS for an additional 20 years 26beyond expiration of its existing OL.
27 28 8.4 References 29 3010 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 31Production and Utilization Facilities."
32 3310 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 34Protection Regulations for Domestic Licensing and Related Regulatory Functions."
35 3610 CFR Part 52. Code of Federal Regulations, Title 10, Energy,Part 52, "Early Site Permits; 37Standard Design Certifications; and Combined Licenses for Nuclear Power Plants."
38 3940 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 40"National Primary and Secondary Ambient Air Quality Standards."
41 Environmental Impacts of License Renewal September 2007 8-47 Draft NUREG-1437, Supplement 32 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 1"Requirements for Preparation, Adoption, and Submittal of Implementation Plans."
2 340 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 4"Standards of Performance for New Stationary Sources."
5 6 Clean Air Act of 1970, as amended (CAA). 42 USC 7401, et seq.7 8C & A Carbone, Inc. v. Town of Clarkstown, New York, 511 U.S. 383, (U.S. Supreme Court 9 1994).10 11Department of Energy (DOE). 2006. "National Electric Transmission Study". August 2006.
12 13Department of Energy, Energy Information Administration (DOE/EIA). 2005. International 14Energy Outlook 2005. USDOE/EIA-0484(2005). Washington, DC. Accessed at:
15http://www.eia.doe.gov/oiaf/ieo/index.html on April 21, 2006.
16 17Department of Energy, Energy Information Administration (DOE/EIA). 2007.
Annual Energy 18Outlook 2007 with Projections to 2030. February 2007.
19 20Department of Energy, National Energy Technology Laboratory (DOE/NETL). 2005.
2005 21Office of Fossil Energy Fuel Cell Program Annual Report. September.
22 23EG&G Idaho, Inc. 1993. U.S. Hydropower Resource Assessment for Kansas. Accessed at:
24http://hydropower.id.doe.gov/resourceassessment/pdfs/states/ks.pdf.
25 26Environmental Protection Agency (EPA). 1998. "Revision of Standards of Performance for 27Nitrogen Oxide Emissions From New Fossil-Fuel Fired Steam Generating Units; Revisions to 28Reporting Requirements for Standards of Performance for New Fossil-Fuel Fired Steam 29Generating Units, Final Rule."
Federal Register Volume 63, Number 179, pp. 49442-49455.
30Washington, DC, September 16, 1998.
31 32Environmental Protection Agency (EPA). 1999. "Regional Haze Regulations, Final Rule" 33 Federal Register Volume 64, Number 126, pp. 35714-3577. Washington, DC, July 1, 1999.
34 35Environmental Protection Agency (EPA). 2000a. "Regulatory Finding on the Emissions of 36Hazardous Air Pollutants from Electric Utility Steam Generating Units." Federal Register
.37Volume 65, Number 245, pp. 79825-79831. Washington, DC, December 20, 2000.
38 39Environmental Protection Agency (EPA). 2000b. "Notice of Regulatory Determination on 40Wastes from the Combustion of Fossil Fuels." Federal Register, Volume 65, pp. 32214-32237.
41Washington, DC, May 22, 2000.
42 Environmental Impacts of License Renewal Draft NUREG-1437, Supplement 32 8-48 September 2007 Environmental Protection Agency (EPA). 2007. Clean Air Mercury Rule." Accessed at:
1http://www.epa.gov/mercury /oar/mercuryrule/. July 9, 2007.
2 3Gabbard, Alex. 1993. "Coal Combustion: Nuclear Resource or Danger,"
Oak Ridge National 4 Laboratory Review. Oak Ridge National Laboratory: Oak Ridge, Tennessee. Summer/Fall 51993. Accessed at: http://www.ornl.gov/ORNLReview/rev26-34/text/colmain.html on 6September 29, 2006.
7 8Integrated Waste Services Association. (IWSA).
Energy Overview. Accessed at:
9http://www.wte.org/energy on September 19, 2006.
10 11 Kansas Corporation Commission (KCC). 2004. Kansas Wind Resource Map, 2004. Accessed 12at: http://www.kcc.state.us/energy/wind.htm. on June 18, 2007.
13 14Kansas Energy Council (KEC). 2005. Kansas Energy Report 2005 , Compiled by Liz Brosius, 15Scott White, and M. Lee Allison, Kansas Geological Survey, Published by the Kansas 16Geological Survey, in cooperation with the Kansas Corporation Commission. Kansas 17Geological Survey, Open-file Report 2004-59.
18 19Kansas Energy Council (KEC). 2007. Kansas Energy Plan 2007 , Kansas Energy Chart Book.
20 January 2007.
21 22Kansas Energy Information Network (KEIN). 2007. Proposed and Existing Wind Power Projects 23in Kansas. May 2007. Accessed at: www.KansasEnergy.org/wind_projects.htm on 24June 18, 2007.
25 26National Environmental Policy Act of 1969, as amended (NEPA). 42 USC 4321, et seq. 27 28North American Electric Reliability Council (NERC). 2006. Long-Term Reliability Assessment-29The Reliability of the Bulk Power Systems in North America. October 2006.
30 31 Nuclear Regulatory Commission (NRC). 1996.NUREG-1437, Generic Environmental Impact 32Statement for License Renewal of Nuclear Power Plants (GEIS), Volumes 1 and 2.
33Washington, DC, May, 1996.
34 35Nuclear Regulatory Commission (NRC). 2001. "NRC Organizes Future Licensing Project 36Organization." Press Release Number 01-035, March 30, 2001.
37 38 Nuclear Regulatory Commission (NRC). 2002.Generic Environmental Impact Statement on 39Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 40 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, DC.
41 Environmental Impacts of License Renewal September 2007 8-49 Draft NUREG-1437, Supplement 32 Nuclear Regulatory Commission (NRC). 2006.
"NRC Establishing Office of Near Reactors, 1Additional Region II Deputy Regional Administrator". Press Release Number 06-096, 2 July 24, 2006.
3 4U.S. Geological Survey (USGS). 1997. "Radioactive Elements in Coal and Fly Ash:
5Abundance, Forms, and Environmental Significance; USGS Fact Sheet FS-163-97." Available 6URL: http://greenwood.cr.usgs.gov/enerfy/factshts/163-97/FS-163-97.pdf.
7 8 U.S. Public Interest Research Group. 2003.
Generating Solutions: How Clean, 9Renewable Energy is Boosting Local Economies and Saving Consumers Money
.10 11Wolf Creek Nuclear Operating Corporation (WCNOC). 2006. Applicant's Environmental Report 12- Operating License Renewal Stage, Wolf Creek Generating Station. Docket Number 50-482.
13 Burlington, Kansas.
14
September 2007 9-1 Draft NUREG-1437, Supplement 32 9.0 Summary and Conclusions 1 2 3By letter dated September 27, 2006, Wolf Creek Nuclear Operating Corporation (WCNOC) 4submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the 5operating license (OL) for Wolf Creek Generating Station (WCGS) for an additional 20-year 6period (WCNOC 2006a). If the OL is renewed, State and Federal (other than NRC) regulatory 7agencies and WCNOC would ultimately decide whether the plant will continue to operate based 8on factors such as the need for power, power availability from other sources, regulatory 9mandates, or other matters within the agencies' jurisdictions or the purview of the owners. If the 10OL is not renewed, then the plant must be shut down at or before the expiration of the current 11OL, which expires on March 11, 2025.
12 13Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA) (42 USC 144321) directs that an environmental impact statement (EIS) is required for major Federal actions 15that significantly affect the quality of the human environment. The NRC has implemented 16Section 102 of NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. 10 CFR 17Part 51 identifies licensing and regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), 18NRC requires preparation of an EIS or a supplement to an EIS for renewal of a reactor OL; 1910 CFR 51.95(c) states that the EIS prepared at the OL renewal stage will be a supplement to 20 theGeneric Environmental Impact Statement for License Renewal of Nuclear Plant s (GEIS), 21NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(a)22 23Upon acceptance of the WCGS application, the NRC began the environmental review process 24described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and conduct 25 scoping (Federal Register, Volume 71, page 70997-70999 [NRC 2006]) on December 7, 2006.
26The Staff visited the WCGS site in September 2006, held two public scoping meetings on 27December 19, 2006, and conducted a site audit in March 2007. The Staff reviewed the WCGS 28Environmental Report (ER) (WCNOC 2006b) and compared it to the GEIS, consulted with other 29agencies, and conducted an independent review of the issues following the guidance set forth in 30NUREG-1555, Supplement 1, the Standard Review Plans for Environmental Reviews for 31Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC 2000). The Staff also 32considered the public comments received during the scoping process for preparation of this 33draft Supplemental Environmental Impact Statement (SEIS) for WCGS. The public comments 34received during the scoping process that were considered to be within the scope of the 35environmental review are provided in Appendix A, Part 1, of this draft SEIS.
36 37The Staff plans to hold public meetings in Burlington, Kansas, in November 2007 to describe the 38preliminary results of the NRC environmental review and to answer questions to provide 39members of the public with information to assist them in formulating their comments on this draft 40 (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.
Summary and Conclusions Draft NUREG-1437, Supplement 32 9-2 September 2007 SEIS. When the comment period ends, the Staff will consider and address all of the comments 1received. These comments will be addressed in Appendix A, Part 2, of the final SEIS.
2This draft SEIS includes the NRC staff's preliminary analysis that considers and weighs the 3environmental effects of the proposed action (including cumulative impacts), the environmental 4impacts of alternatives to the proposed action, and mitigation measures available for reducing or 5avoiding adverse effects. This draft SEIS also includes the Staff's preliminary recommendation 6regarding the proposed action.
7 8The NRC has adopted the following statement of purpose and need for license renewal from the 9 GEIS: 10 11The purpose and need for the proposed action (renewal of an operating license) is to 12provide an option that allows for power generation capability beyond the term of a 13current nuclear power plant operating license to meet future system generating needs, 14as such needs may be determined by State, utility, and, where authorized, Federal 15 (other than NRC) decisionmakers.
16 17The evaluation criterion for the Staff's environmental review, as defined in 10 CFR 51.95(c)(4) 18and the GEIS, is to determine:
19
- 20. . . whether or not the adverse environmental impacts of license renewal are so great 21that preserving the option of license renewal for energy planning decisionmakers would 22be unreasonable.
23 24Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 25there are factors, in addition to license renewal, that would contribute to NRC's ultimate 26determination of whether an existing nuclear power plant continues to operate beyond the 27period of the current OL.
28 29NRC regulations (10 CFR 51.95(c)(2)) contain the following statement regarding the content of 30SEISs prepared at the license renewal stage:
31 32The supplemental environmental impact statement for license renewal is not required to 33include discussion of need for power or the economic costs and economic benefits of the 34proposed action or of alternatives to the proposed action except insofar as such benefits 35and costs are either essential for a determination regarding the inclusion of an 36alternative in the range of alternatives considered or relevant to mitigation. In addition, 37the supplemental environmental impact statement prepared at the license renewal stage 38need not discuss other issues not related to the environmental effects of the proposed 39action and the alternatives, or any aspect of the storage of spent fuel for the facility 40 Summary and Conclusions September 2007 9-3 Draft NUREG-1437, Supplement 32 within the scope of the generic determination in § 51.23(a) and in accordance with § 1 51.23(b).[b]2 3The GEIS contains the results of a systematic evaluation of the consequences of renewing an 4OL and operating a nuclear power plant for an additional 20 years. It evaluates 92 environmen-5tal issues using the NRC's three-level standard of significance-SMALL, MODERATE, or 6LARGE-developed using the Council on Environmental Quality guidelines. The following 7definitions of the three significance levels are set forth in the footnotes to Table B-1 of 10 CFR 8 Part 51, Subpart A, Appendix B:
9 10SMALL - Environmental effects are not detectable or are so minor that they will neither 11destabilize nor noticeably alter any important attribute of the resource.
12 13MODERATE - Environmental effects are sufficient to alter noticeably, but not to 14destabilize, important attributes of the resource.
15 16LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 17important attributes of the resource.
18 19For 69 of the 92 issues considered in the GEIS, the Staff analysis in the GEIS shows the 20 following:
21 22(1) The environmental impacts associated with the issue have been determined to apply 23either to all plants or, for some issues, to plants having a specific type of cooling system 24or other specified plant or site characteristics.
25 26(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 27the impacts (except for collective off-site radiological impacts from the fuel cycle and 28from high-level waste and spent fuel disposal).
29 30(3) Mitigation of adverse impacts associated with the issue has been considered in the 31analysis, and it has been determined that additional plant-specific mitigation measures 32are likely not to be sufficiently beneficial to warrant implementation.
33 34These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and 35significant information, the Staff relied on conclusions as amplified by supporting information in 36the GEIS for issues designated Category 1 in Table B-1 of 10 CFR Part 51, Subpart A, 37Appendix B.
38 (b) The title of 10 CFR 51.23 is "Temporary storage of spent fuel after cessation of reactor operations-generic determination of no significant environmental impact."
Summary and Conclusions Draft NUREG-1437, Supplement 32 9-4 September 2007 Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 1issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, 2environmental justice and chronic effects of electromagnetic fields, were not categorized.
3Environmental justice was not evaluated on a generic basis and must also be addressed in a 4plant-specific supplement to the GEIS. Information on the chronic effects of electromagnetic 5fields was not conclusive at the time the GEIS was prepared.
6 7This draft SEIS documents the Staff's consideration of all 92 environmental issues identified in 8the GEIS. The Staff considered the environmental impacts associated with alternatives to 9license renewal and compared the environmental impacts of license renewal and the alterna-10tives. The alternatives to license renewal that were considered include the no-action alternative 11(not renewing the OL for WCGS), alternative methods of power generation, and conservation.
12These alternatives were evaluated assuming that the replacement power generation plant is 13located at either the WCGS site or some other unspecified location.
14 159.1 Environmental Impacts of the Proposed Action - License 16 Renewal 17 18WCNOC and the Staff have established independent processes for identifying and evaluating 19the significance of any new information on the environmental impacts of license renewal.
20Neither WCNOC nor the Staff has identified information that is both new and significant related 21to Category 1 issues that would call into question the conclusions in the GEIS. Similarly, neither 22the scoping process, WCNOC, nor the Staff has identified any new issue applicable to WCGS 23that has a significant environmental impact. Therefore, the Staff relies upon the conclusions of 24the GEIS for all Category 1 issues that are applicable to WCGS.
25 26WCNOC's license renewal application presents an analysis of the Category 2 issues that are 27applicable to WCGS, plus environmental justice and chronic effects from electromagnetic fields.
28The Staff has reviewed the WCNOC analysis for each issue and has conducted an independent 29review of each issue plus environmental justice and chronic effects from electromagnetic fields.
30Two Category 2 issues are not applicable because they are related to plant design features or 31site characteristics not found at WCGS. Four Category 2 issues are not discussed in this draft 32SEIS because they are specifically related to refurbishment. WCNOC (WCNOC 2006a) has 33stated that its evaluation of structures and components, as required by 10 CFR 54.21, did not 34identify any major plant refurbishment activities or modifications as necessary to support the 35continued operation of WCGS for the license renewal period. In addition, any replacement of 36components or additional inspection activities are within the bounds of normal plant component 37replacement and, therefore, are not expected to affect the environment outside of the bounds of 38the plant operations evaluated in the Final Environmental Statement Related to Operation of 39 Wolf Creek Generating Station, Unit 1 (NRC 1982).
40 Summary and Conclusions September 2007 9-5 Draft NUREG-1437, Supplement 32 Fifteen Category 2 issues (including fourteen Category 2 issues plus the severe accident 1mitigation alternatives [SAMAs] issue from Chapter 5) related to operational impacts and 2postulated accidents during the renewal term, as well as environmental justice and chronic 3effects of electromagnetic fields, are discussed in detail in this draft SEIS. Five of the Category 42 issues and environmental justice apply both to refurbishment and to operation during the 5renewal term and are only discussed in this draft SEIS in relation to operation during the 6 renewal term. For the fifteen Category 2 issues and environmental justice, the Staff concludes 7that the potential environmental effects are of SMALL and SMALL to MODERATE significance 8in the context of the standards set forth in the GEIS. A SMALL to MODERATE impact was 9determined based on water-use conflicts (plants with cooling ponds or cooling towers using 10makeup water from a small river with low flow). If water use conflicts occur, associated impacts 11in the Neosho River due to impingement and habitat reduction on aquatic organisms, including 12threatened and endangered species, would be SMALL to MODERATE. Research is continuing 13in the area of chronic effects on electromagnetic fields, and a scientific consensus has not been 14reached. Therefore, no further evaluation of this issue is required
. For SAMAs, the Staff 15concludes that a reasonable, comprehensive effort was made to identify and evaluate SAMAs.
16Based on its review of the SAMAs for WCGS, and the plant improvements already made, the 17Staff concludes that WCNOC identified seven potentially cost-beneficial SAMAs. However, 18these SAMAs do not relate to adequately managing the effects of aging during the period of 19extended operation. Therefore, they need not be implemented as part of license renewal 20pursuant to 10 CFR Part 54.
21 22Cumulative impacts of past, present, and reasonably foreseeable future actions were 23considered, regardless of what agency (Federal or non-Federal) or person undertakes such 24other actions. The Staff concludes that cumulative impacts of WCGS license renewal would be 25SMALL for most potentially affected resources, with the exception of some aquatic resources.
26The Staff concluded that water use conflicts (plants with cooling ponds or cooling towers using 27 makeup water from a small river with a low flow), would experience SMALL to MODERATE 28cumulative impacts. In addition, due to the increased potential for impingement and habitat 29reduction during periods with water use conflicts, cumulative impacts on aquatic organisms, 30including threatened and endangered species, would also be SMALL to MODERATE.
31 32Mitigation measures were considered for each Category 2 issue. For all issues, current 33measures to mitigate the environmental impacts of plant operation were found to be adequate.
34 35The following sections discuss unavoidable adverse impacts, irreversible or irretrievable 36commitments of resources, and the relationship between local short-term use of the 37environment and long-term productivity.
38 Summary and Conclusions Draft NUREG-1437, Supplement 32 9-6 September 2007 9.1.1 Unavoidable Adverse Impacts 1 2An environmental review conducted at the license renewal stage differs from the review 3conducted in support of a construction permit because the plant is in existence at the license 4renewal stage and has operated for a number of years. As a result, adverse impacts associated 5with the initial construction have been avoided, have been mitigated, or have already occurred.
6The environmental impacts to be evaluated for license renewal are those associated with 7 refurbishment and continued operation during the renewal term.
8 9All unavoidable adverse impacts of continued operation identified are considered to be of 10SMALL significance. The unavoidable adverse impacts of likely alternatives if WCGS ceases 11operation at or before the expiration of the current OL will not be smaller than those associated 12with continued operation of this unit, and they may be greater for some impact categories in 13 some locations.
14 159.1.2 Irreversible or Irretrievable Resource Commitments 16 17The commitment of resources related to construction and operation of WCGS during the current 18license period was made when the plant was built. The resource commitments to be 19considered in this draft SEIS are associated with continued operation of the plant for an 20additional 20 years. These resources include materials and equipment required for plant 21maintenance and operation, the nuclear fuel used by the reactors, and ultimately, permanent 22off-site storage space for the spent fuel assemblies.
23 24The most significant resource commitments related to operation during the renewal term are the 25fuel and the permanent storage space. WCGS replaces a portion of its fuel assemblies during 26every refueling outage, which occurs on an 18-month cycle (WCNOC 2006b).
27 28The likely power generation alternatives if WCGS ceases operation on or before the expiration 29of the current OLs would require a commitment of resources for construction of the replacement 30plants as well as for fuel to run the plants.
31 329.1.3 Short-Term Use Versus Long-Term Productivity 33 34An initial balance between short-term use and long-term productivity of the environment at 35WCGS was set when the plant was approved and construction began. That balance is now well 36established. Renewal of the OL for WCGS and continued operation of the plant would not alter 37the existing balance, but may postpone the availability of the site for other uses. Denial of the 38application to renew the OL would lead to shutdown of the plant and will alter the balance in a 39manner that depends on subsequent uses of the site.
40 Summary and Conclusions September 2007 9-7 Draft NUREG-1437, Supplement 32 9.2 Relative Significance of the Environmental Impacts of 1 License Renewal and Alternatives 2 3The proposed action is renewal of the OL for WCGS. Chapter 2 describes the site, power plant, 4and interactions of the plant with the environment. As noted in Chapter 3, no refurbishment and 5no refurbishment impacts are expected at WCGS. Chapters 4 through 7 discuss environmental 6issues associated with renewal of the OL. Environmental issues associated with the no-action 7alternative and alternatives involving power generation and use reduction are discussed in 8 Chapter 8.
9 10The significance of the environmental impacts from the proposed action (approval of the 11application for renewal of the OL), the no-action alternative (denial of the application), 12alternatives involving coal, gas, or nuclear-fired generating capacity at an unspecified greenfield 13site, gas-fired generation of power at WCGS, and a combination of alternatives are compared in 14Table 9-1. Continued use of open-cycle cooling is assumed for WCGS. All fossil fueled 15alternatives presented in Table 9-1 are assumed to use closed-cycle cooling systems.
16Substitution of once-through cooling for the recirculating cooling system in the evaluation of the 17nuclear and gas and coal-fired generation alternatives would result in greater environmental 18impact to categories related to water use and aquatic ecology. Alternatively, land use and 19aesthetic impacts are somewhat reduced with open-cycle cooling.
20 21Table 9-1 shows that the significance of the plant specific environmental effects of the proposed 22action would be SMALL for all impact categories except for the following:
23 24 Water use conflicts (plants with cooling ponds and cooling towers using makeup water 25from a small river with low flow), for which a SMALL to MODERATE level of significance 26was assigned; 27 28 if water use conflicts occur, associated impacts in the Neosho River due to impingement 29and habitat reduction on aquatic organisms, including threatened and endangered 30species, for which a SMALL to MODERATE level of significance was assigned; 31 32 collective offsite radiological impacts from the fuel cycle and from high-level radioactive 33waste, for which a single significance level was not assigned (see Chapter 6); and 34 35 spent fuel disposal, for which a single significance level was not assigned (see Chapter 36 6).37 Table 9-1. Summary of Environmental Significance of License Renewal, the No Action Alternative, and Alternative Methods of Generation Using Once-Through Cooling (a)Proposed Action No Action Alternative Coal-Fired Generation Natural-Gas-Fired Generation (b)New Nuclear Generation (b)Combination of Alternatives Gas Fired with Purchased Power and Conservation Impact Category License Renewal Denial of Renewal WCGS Site Alternate Site (b)WCGS Site Alternate Site Alternate Site WCGS Site Alternate Site Land UseSMALLSMALLMODERATE to LARGEMODERATE to LARGEMODERATEMODERATE to LARGEMODERATE to LARGEMODERATEMODERATE EcologySMALL to MODERATESMALL MODERATE to LARGEMODERATE to LARGESMALL to MODERATEMODERATE MODERATE to LARGESMALL to MODERATEMODERATE Water Use and Quality -Surface WaterSMALL to MODERATESMALLSMALL to MODERATESMALL to MODERATESMALL to MODERATESMALLSMALLSMALL to MODERATESMALL Water Use and Quality -GroundwaterSMALL SMALL SMALL to MODERATESMALL to MODERATESMALL SMALL SMALL SMALL SMALLAir QualitySMALLSMALLMODERATEMODERATEMODERATEMODERATESMALLMODERATEMODERATE WasteSMALL SMALL MODERATE MODERATE SMALL SMALL SMALL SMALL SMALL Human HealthSMALL (c)SMALLSMALLSMALLSMALLSMALLSMALLSMALLSMALL Socio-economicsSMALLLARGE MODERATE to LARGEMODERATE to LARGEMODERATE -LARGESMALL to MODERATELARGE MODERATEto LARGEMODERATE to LARGETransportationSMALLSMALLMODERATE to LARGEMODERATE to LARGESMALLSMALLMODERATESMALLSMALL AestheticsSMALL SMALL MODERATE MODERATE to LARGESMALL MODERATE to LARGEMODERATE to LARGESMALL MODERATE to LARGE Historical and Archeological ResourcesSMALLSMALLSMALLSMALLSMALLSMALLSMALLSMALLSMALL Environmental JusticeSMALL SMALL SMALL SMALL to LARGESMALL SMALL to MODERATESMALL to MODERATESMALL SMALL to MODERATE(a) The majority of impacts shown are negative; however, several impacts are positive. See Chapters 4 and 8 for details. (b) Analysis based on use of a closed-cycle cooling system. (c) Except for the collective offsite radiological impacts from the fuel cycle and from high level waste and spent-fuel disposal, for which a significance level was not assigned. See Chapter 6 for details Summary and Conclusions NUREG-1437, Supplement 32 9-8 September 2007 Summary and Conclusions September 2007 9-9 NUREG-1437, Supplement 32 Cumulative impacts on the proposed action would be SMALL, with the exception of some 1aquatic resources. The Staff concluded that water use conflicts (plants with cooling ponds or 2cooling towers using makeup water from a small river with a low flow), would experience SMALL 3to MODERATE cumulative impacts. In addition, due to the increased potential for impingement 4and habitat reduction during periods with water use conflicts, cumulative impacts on aquatic 5organisms, including threatened and endangered species, would also be SMALL to 6MODERATE 7 8The alternative actions, excluding the no-action alternative, may have environmental effects in 9at least some impact categories that reach MODERATE or LARGE significance.
10 119.3 Staff Conclusions and Recommendations 12 13Based on (1) the analysis and findings in the GEIS (NRC 1996,1999), (2) the ER submitted by 14WCNOC, (3) consultation with Federal, State, and local agencies, (4) the Staff's own 15independent review, and (5) the Staff's consideration of public comments received, the 16preliminary recommendation of the Staff is that the Commission determine that the adverse 17environmental impacts of license renewal for WCGS are not so great that preserving the option 18of license renewal for energy planning decisionmakers would be unreasonable.
19 20 9.4 References 21 2210 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 23Protection Regulations for Domestic Licensing and Related Regulatory Functions."
24 2510 CFR Part 54. Code of Federal Regulations, Title 10, Energy,Part 54, "Requirements for 26Renewal of Operating Licenses for Nuclear Power Plants."
27 28National Environmental Policy Act of 1969, as amended (NEPA). 42 USC 4321, et seq.
29 30 Nuclear Regulatory Commission (NRC). 1982.Final Environmental Statement Related to 31Operation of Wolf Creek Generating Station, Unit 1.
NUREG-0878. Office of Nuclear 32Regulation. Washington, DC.
33 34Nuclear Regulatory Commission (NRC). 1996. NUREG-1437, Generic Environmental Impact 35Statement for License Renewal of Nuclear Power Plants (GEIS), Volumes 1 and 2. Washington, 36DC, May, 1996.
37 Summary and Conclusions NUREG-1437, Supplement 32 9-10 September 2007 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 1License Renewal of Nuclear Plants: Main Report
,Section 6.3, Transportation, Table 9.1, 2Summary of findings on NEPA issues for license renewal of nuclear power plants
, Final Report
.3NUREG-1437, Volume 1, Addendum 1, Washington, D.C.
4 5 Nuclear Regulatory Commission (NRC). 2000. "Standard Review Plans for Environmental 6Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal." NUREG-71555, Supplement 1, Washington, DC.
8 9Nuclear Regulatory Commission (NRC). 2006. "Notice of Acceptance for Docketing of the 10Application, Notice of Opportunity for Hearing, and Notice of Intent to Prepare an Environmental 11Impact Statement and Conduct the Scoping Process for Facility Operating License 12Number NPF-42 for an Additional Twenty-Year Period; Wolf Creek Nuclear Operating 13Corporation; Wolf Creek Generating Station, Unit 1."
Federal Register. Volume 71, Number 235, 14 pp. 70997-70999. December 7, 2006.
15 16Wolf Creek Nuclear Operating Corporation (WCNOC). 2006a. License Renewal Application, 17 Wolf Creek Generating Station, Docket Number 50-482, Facility Operating License Number 18NPF-42, Burlington, Kansas.
19 20Wolf Creek Nuclear Operating Corporation (WCNOC). 2006b. Applicant's Environmental 21Report - Operating License Renewal Stage, Wolf Creek Generating Station. Docket Number 22 50-482, Burlington, Kansas.
23 Appendix A Comments Received on the Environmental Review
September 2007 A-1 Draft NUREG-1437, Supplement 32 Appendix A 1 2 Comments Received on the Environmental Review 3 4 5Part I - Comments Received During Scoping 6 7On December 7, 2006, the NRC published a Notice of Intent in the Federal Register 8(71 FR 70997), to notify the public of the Staff's intent to prepare a plant-specific supplement to 9the GEIS regarding the renewal application for the WCGS operating license. The plant-specific 10supplement to the GEIS will be prepared in accordance with NEPA, Council on Environmental 11Quality (CEQ) guidelines, and 10 CFR Part 51. As outlined by NEPA, the NRC initiated the 12scoping process with the issuance of a Federal Register Notice (71 FR 70997). The NRC 13invited the applicant, Federal, State, local, and tribal government agencies, local organizations, 14and individuals to participate in the scoping process by providing oral comments at the 15scheduled public meetings and/or submitting written suggestions and comments no later than 16 January 29, 2007.
17 18The scoping process included two public scoping meetings, which were held on December 19, 192006, at the Coffee County Library, Burlington Branch, 410 Juniatta Street, Burlington, Kansas.
20The NRC issued press releases, placed newspaper ads, and distributed flyers locally.
21Approximately 40 people attended the meetings. Both sessions began with NRC staff members 22providing a brief overview of the license renewal process and the NEPA process. Following the 23NRC's prepared statements, the meetings were open for public comments. There were no 24public comments or questions at the meetings. The meeting summary, which was issued on 25January 19, 2007, and the associated transcripts are available for public inspection in the NRC 26Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, 27 Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and 28Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at 29http://www.nrc.gov/reading-rm/adams/web-based.html. The meeting summary can be found in 30ADAMS at Accession No. ML070170473. The transcripts of the meeting can be found in 31ADAMS at Accession Nos. ML070120121 and ML070120114. Persons who do not have 32access to ADAMS, or who encounter problems in accessing the documents located in ADAMS, 33 should contact the NRC's PDR reference staff by telephone at 1-800-397-4209, or 301-415-34 4737, or by e-mail at pdr@nrc.gov.
35 36At the conclusion of the scoping period, the NRC staff and its contractor reviewed the 37transcripts and all written material received, and identified individual comments. Two (2) letters 38and one (1) e-mail containing comments were received during the scoping period. No 39comments were received orally or in writing at the scoping meetings. Each set of comments 40from a given commenter was given a unique alpha identifier (Commenter ID letter), allowing 41 Appendix A Draft NUREG-1437, Supplement 32 A-2 September 2007 each set of comments from a commenter to be traced back to the transcript, letter, or e-mail in 1which the comments were submitted.
2 3Comments were consolidated and categorized according to the topic within the proposed 4supplement to the GEIS or according to the general topic if outside the scope of the GEIS.
5Comments with similar specific objectives were combined to capture the common essential 6issues that had been raised in the source comments. Once comments were grouped according 7to subject area, the Staff and contractor determined the appropriate action for each comment.
8 9Table A-1 identifies the individuals providing comments and the Commenter ID letter associated 10with each person's set(s) of comments. The Commenter ID letter is preceded by WCGS.
11 12 Table A.1Individuals Providing Comments During Scoping Comment Period 13 14Commenters IDCommenterAffiliation (If Stated)Comment SourceWCGS-AMike SeymourLocal ResidentWritten comments WCGS-BMichael J. LeValleyUS Department of the Interior, Fish and Wildlife Services Written commentsWCGS-CKimberly O. JohnsonUS Environmental Protection Agency, NEPAWritten comments 15Comments are grouped in the following categories:
16 17A.1.1 Comments Concerning Aquatic Ecology 18A.1.2 Comments Concerning Threatened and Endangered Species 19A.1.3 Comments Concerning Transmission Lines 20A.1.4 Comments Concerning General Environmental Impacts 21A.1.5 Comments Concerning Decommissioning 22A.1.6 Comments Concerning License Renewal and Its Processes 23 24A.1 Comments and Responses 25 26A.1.1 Comments Concerning Aquatic Ecology 27 28 Comment:Impingement and entrainment at the intakes for the cooling system should also be 29addressed in the EIS. As you are probably aware, on January 26, 2007, the United States 30 Court of Appeals for the Second Circuit issued a decision remanding to EPA the 2004 Clean 31Water Act Section 316(b) Phase II rule, which regulates cooling water intake structures at 32 Appendix A September 2007 A-3 Draft NUREG-1437, Supplement 32 existing power producing facilities, (Riverkeeper, Inc. v EPA, 2d Cir. Jan. 25, 2007). Although 1this decision may modify the regulations, 316(b) will still apply to the Wolf Creek facility.
2(WCGS-C) 3 4 Response:The comment is related to operation of the plants cooling system, specifically the 5effects of impingement and entrainment. A discussion of the potential impacts associated with 6the plants cooling system will be presented in Chapter 4 of the SEIS. Additionally a brief 7discussion of potential mitigation measures to limit impingement and entrainment impacts will be 8presented in Chapter 4 of the SEIS.
9 10A.1.2 Comments Concerning Threatened and Endangered Species 11 12 Comment:In accordance with section 7(c) of the Endangered Species Act, we have 13determined that the Federally-listed threatened bald eagle (Haliaeetus leucocephalus
), the 14 threatened Mead's milkweed (Asclepias meadii) and the threatened Neosho madtom (Norturus 15 placidus) may occur in the project area. If the project may adversely affect listed species, the 16 Nuclear Regulatory Commission (NRC) should initiate informal or formal section 7 consultation 17 with this office. (WCGS-B) 18 19 Response:The comment is noted. The impacts on any Federally-threatened or endangered 20species will be evaluated and discussed in Chapter 4 of the SEIS and the Biological 21Assessment. Informal or formal consultations with the Fish and Wildlife Service will be initiated 22as appropriate.
23 24 Comment:There has been an active bald eagle nest at WCGS since 1994; however, the pair 25has not successfully fledged any young since 1999. Because of the uncertain reproductive 26status of this nesting pair and it's proximity to potential source contaminants from WCGS, we 27recommend further evaluation of the potential affects of WCGS on the bald eagle and other 28piscivorous bird and mammal species that may occur in the project area. (WCGS-B) 29 30 Response:The comment is noted. An evaluation of the current status and potential impacts of 31WCGS on the bald eagle (Haliaeetus leucocephalus) pair at the site will be evaluated and 32discussed in Chapters 2 and 4 of the SEIS and also in the Biological Assessment.
33 34 Comment:The many acres of native prairie and rangeland found on WCGS may provide 35suitable habitat for Mead's milkweed. If these habitats have not been previously surveyed for 36Mead's milkweed, we recommend a field survey by the Kansas Biological Survey or other 37qualified botanists. The Kansas Biological Survey may be contacted by writing at 2041 38 Constant Avenue, Lawrence, Kansas 66047-2906, or by telephone at (785) 864-1538. In 39addition, if suitable Mead's milkweed habitat is found on-site or could be made suitable through 40management, we would like to discuss with the applicant the potential for transplant and 41management of this plant on the WCGS site. (WCGS-B) 42 Appendix A Draft NUREG-1437, Supplement 32 A-4 September 2007 Response:The comment is noted. As part of the environmental review process, the Staff will 1evaluate the existing conditions, including any existing survey data, at the site as well as the 2potential impacts likely to result from operation of the WCGS for an additional 20 years. This 3evaluation will be documented in the Biological Assessment that will be submitted to the U.S.
4Fish and Wildlife Service. However, requiring the applicant to conduct additional biological 5surveys or requiring a Mead's milkweed transplant and monitoring program is not within the 6 purview of the NRC.
7 8 Comment:The Neosho madtom occurs in the Neosho River both upstream and downstream 9of John Redmond Reservoir. Your National Environmental Policy Act (NEPA) analyses should 10evaluate the potential direct and indirect effects of water withdrawal from the Neosho River on 11this species, especially during drought years. (WCGS-B) 12 13 Response:The comment is noted. The potential direct and indirect effects of water withdrawal 14from the Neosho River on the Neosho madtom will be evaluated and discussed in Chapter 4 of 15the SEIS and also in the Biological Assessment.
16 17 Comment:Also, due to the aging of the facility and corrosion within the cooling tower structure, 18trace elements such as nickel, iron, and chromium may be accumulating in Coffey County Lake 19at higher than background levels. The potential exposure of Neosho madtom, bald eagle and 20the Neosho mucket to these trace elements should be addressed in the NEPA documents.
21(WCGS-B) 22 23 Response:The comment is noted. The WCGS utilizes a once through cooling system, not a 24cooling tower structure for heat dissipation. Regardless of the cooling system, the discharge of 25other metals in cooling system waste water is considered a Category 1 issue. These 26discharges have not been found to be a problem at operating nuclear power plants with cooling-27tower-based heat dissipation systems and have been satisfactorily mitigated at other plants (i.e., 28once through cooling water systems) and are not expected to be a problem during the license 29renewal term. As part of the environmental review, the Staff will conduct an independent review 30of existing information to determine if there is any new and significant information that would 31alter the conclusions of the GEIS and the findings will be presented in Chapter 4 of the SEIS.
32 33 Comment:The candidate species Neosho mucket (Lampsilis rafinesqueana), which is a 34freshwater unionid mussel, occurs in the Neosho River within the project area. Candidates are 35those species for which the USFWS has on file substantial information on biological vulnerability 36and threats to support proposals to list them as endangered or threatened species.
37Development and publication of proposed rules to list candidate species as threatened or 38endangered are anticipated at some point in the future. Candidate species have no legal 39protection under the Endangered Species Act; however, the USFWS is concerned for their 40 conservation due to their uncertain status. (WCGS-B) 41 Appendix A September 2007 A-5 Draft NUREG-1437, Supplement 32 Response:The comment is noted. An evaluation of the current status and potential impacts of 1WCGS on the Neosho mucket will be evaluated and discussed in Chapters 2 and 4 of the SEIS 2and also in the Biological Assessment.
3 4A.1.3 Comments Concerning General Environmental Impacts 5
6 Comment:Transmission lines have been documented as constituting a significant collision 7hazard to migratory birds including waterfowl, wading birds, shorebirds, and raptors. Project 8lines occurring within one mile of streams, wetlands, and other water bodies such as the 9Neosho River, Coffey County Lake, John Redmond Reservoir, and Flint Hills National Wildlife 10Refuge, should be evaluated for their potential to impact migratory birds. If project lines meet 11these criteria, and there is little existing field data documenting the presence or absence of a 12collision hazard, we recommend that line segments be monitored during the renewal process to 13determine whether a collision hazard exists. If a hazard is identified, line segments should be 14marked for enhanced visibility following established guidelines. (WCGS-B) 15 16 Response:The comment is noted. Bird collisions with power lines is a Category 1 issue, 17determined to be of small significance at all sites and not required to be reevaluated in the site-18specific SEIS, unless new and significant information is identified that would lead the NRC staff 19to reevaluate the GEIS's conclusions. As part of the environmental review, the Staff will 20evaluate existing data to determine if there is any new and significant information that would 21change the GEIS conclusions. This review would include all available data, including the wildlife 22monitoring program that included avian collision surveys of the transmission lines that was 23conducted by the applicant from 1982 through 1986. However, requiring the applicant to 24conduct additional monitoring for collision hazards is outside NRC regulatory purview.
25 26 Comment:Our main environmental and human health concerns with nuclear generating 27stations include safety, water quality, and spent fuel storage. The unintended release of tritium 28and strontium from plant operations and the impacts on groundwater is an emerging issue at 29some power plants, as well as the local impacts of transporting high-level waste (spent fuel) 30once a long-term repository is finalized. We recommend that these issues be analyzed and 31discussed in the EIS. (WCGS-C) 32 33 Response:The comment is noted. Safety will be addressed as a separate part of the license 34review process. The NRC staff performs a safety review, on-site inspections, and audits to 35determine if the applicant has adequately demonstrated that the effects of aging will not have 36adverse impacts during the extended period operation. In addition, a safety evaluation report 37(SER) documents the results of the NRC's staff's review of aging-management and the 38applicant's programs to address these matters during the period of extended operation. Water 39and groundwater issues, as well as potential mitigation measures, if applicable, will be 40addressed in Chapters 2 and 4 of the SEIS. Currently, the transportation of high-level waste 41(spent fuel) is considered a Category 1 issue, determined to be of small significance at all sites 42 Appendix A Draft NUREG-1437, Supplement 32 A-6 September 2007 and not required to be reevaluated in the site-specific SEIS, unless new and significant 1information is identified that would lead the NRC staff to reevaluate the GEIS's conclusions. As 2part of the environmental review, the Staff will evaluate existing data to determine if there is any 3new and significant information that would change the GEIS conclusions.
4 5 A.1.4 Comments Concerning Decommissioning 6 7 Comment:Wolf Creek is probably half way to the time of decommission. Approximate costs 8for decommission will be around $1.5 Billion. Half of that sum is $750 million. Is there enough 9money in that fund or will other environmental issues be left begging when our children are 10forced to use scarce tax dollars for this inevitable cleanup? No one likes to talk about this major 11issue. It is my belief that the present stockholders intend to take a profit and then bail out 12leaving a huge cleanup cost for my grandchildren to pay for. Please ask two direct questions. 1) 13How much money is in the cleanup fund? 2) Who controls it? The answers should be: 1) No 14less than $750 million. 2) Some unbiased third party. Any other answer means we have a 15 serious problem here. (WCGS-A) 16 17 Response:NRC regulations that establish the requirements for how a licensee will provide 18reasonable assurance that funds will be available for the decommissioning process are provided 19in 10 CFR 50.75. The Commission's final rule on "Financial Assurance Requirements," 20published in the Federal Register on September 22, 1998 (63 FR 50465), required, among other 21things, that power reactor licensees submit decommissioning funding status reports to the NRC 22by March 31, 1999, and every 2 years thereafter. In response to the site specific questions, the 23most recent (March 2005) 10 CFR 50.75 Report on Status of Decommission Funding provided 24by WCGS (ADAMS Accession No. ML0509603661) details the amount collected to date for 25decommissioning, and the amounts yet to be collected. As of the March 2005 report, the NRC 26has projected that the WCGS will have sufficient funds for decommissioning in the year 2025.
27This money has been placed in an external sinking fund. An external sinking fund is a fund 28established and maintained by setting funds aside periodically into an account segregated from 29licensee assets and outside the licensee's administrative control. The total amount of these 30funds would be sufficient to pay decommissioning costs at the time that it is anticipated that the 31licensee will cease operations. An external sinking fund may be in the form of a trust, escrow 32account, government fund, certificate of deposit, or deposit of government securities. If the 33NRC issues a new license to WCGS, then NRC regulations would require the licensee to 34provide sufficient funds to the trust to support decommissioning by the new license expiration 35date. Although this comment is noted, the cost of renewal versus decommissioning is a 36business decision that NRC does not control. The Commission has determined these issues 37are outside the scope of the environmental analysis for license renewal.
38 Appendix A September 2007 A-7 Draft NUREG-1437, Supplement 32 A.1.5 Comments Concerning License Renewal and Its Processes 1 2 Comment:We are also interested in how the Nuclear Regulatory Commission will address 3issues and actions that may arise between the license renewal date in 2009 and 2025 when the 4renewed license becomes effective. The useful "life" of an EIS is considered to be 5 years; after 5that time period, additional analysis and documentation may be required. (WCGS-C) 6 7 Response:If the license is renewed, the licensee will be issued a new license that 8incorporates and supersedes the existing license. The new license will have a new expiration 9date, which is up to twenty years past the expiration date of the original operating license.
10Therefore, issues and actions that may arise between 2009 and 2025 and through the 11remaining term of the new license would be addressed as current operating issues.
12
Appendix B Contributors to the Supplement
September 2007 B-1 Draft NUREG-1437, Supplement 32 Appendix B 1 2 Contributors to the Supplement 3 4 5The overall responsibility for the preparation of this supplement was assigned to the Office of 6Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). The statement was 7prepared by members of the Office of Nuclear Reactor Regulation with assistance from other 8NRC organizations, Earth Tech, Inc. and Information Systems Laboratories, Inc.
9 10NameFunction or ExpertiseNuclear Regulatory CommissionChristian JacobsEnvironmental Project ManagerAlicia Williamson Back-up Environmental Project ManagerRani FranovichBranch ChiefDennis BeisselTechnical Monitor/HydrologyAndrew Stuyvenberg Alternatives Scott Werts Hydrology Harriet Nash Ecology Dennis Logan Ecology Jeffrey Rickoff Cultural Resources/
Socioeconomics/ Land UseSteve Klementowicz Radiation ProtectionAndrew Luu Radiation ProtectionRobert Palla Severe Accident Mitigation AlternativesEarth TechRoberta HurleyProject ManagerJohn SzeligowskiAlternativesStephen DudaLead EcologistStephen DillardTerrestrial EcologyLeslie Howard Aquatic Ecology Matthew GoodwinCultural Resources Susan ProvenzanoLand Use Robert DoverWater QualityKatie Broom Project Coordinator Nikki Thomas Technical Editor Nicole SpanglerProject SupportBonnie FreemanAdministrative Support 11 12 Appendix B Draft NUREG-1437, Supplement 32 B-2 September 2007 1NameFunction or ExpertiseInformation Systems LaboratoriesLauren FleishmanSevere Accident Mitigation AlternativesBruce MrowchaSevere Accident Mitigation AlternativesJosh ReinertSevere Accident Mitigation Alternatives 2
Appendix C Chronology of NRC Staff Environmental Review Correspondence Related to Wolf Creek Nuclear Operating Corporation's Application for License Renewal of Wolf Creek Generating Station
September 2007 C-1 Draft NUREG-1437, Supplement 32 Appendix C 1 2 3Chronology of NRC Staff Environmental Review Correspondence 4 Related to Wolf Creek Nuclear Operating Corporation's 5 Application for License Renewal of 6 Wolf Creek Generating Station 7 8 9This appendix contains a chronological listing of correspondence between the U.S. Nuclear 10Regulatory Commission (NRC) and Wolf Creek Nuclear Operating Corporation (WCNOC) and 11other correspondence related to the NRC staff's environmental review, under 10 CFR Part 51, 12of WCNOC's application for renewal of the Wolf Creek Generating Station (WCGS) operating 13license. All documents, with the exception of those containing proprietary information, have 14been placed in the Commission's Public Document Room, at One White Flint North, 1511555 Rockville Pike (first floor), Rockville, MD, and are available electronically from the Public 16Electronic Reading Room found on the Internet at the following Web address:
17<http://www.nrc.gov/reading-rm.html>. From this site, the public can gain access to the NRC's 18Agencywide Documents Access and Management System (ADAMS), which provides text and 19image files of NRC's public documents in the publicly available records component of ADAMS.
20The ADAMS accession number for each document is included below.
21 22September 27, 2006 Letter from Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 23Corporation, to NRC submitting the application for the renewal of the 24operating license for Wolf Creek Generating Station.
25 (Accession No. ML062770301).
26 27October 12, 2006 Letter from NRC to Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 28Corporation, regarding receipt and availability of the License Renewal 29Application for Wolf Creek Generating Station, Unit 1.
30 (Accession No. ML062840512).
31 32October 18, 2006 Federal Register Notice of receipt of application for renewal of Facility 33Operating License No. NPF-42 for an additional 20-year period.
34 (71FR61512).
35 36November 3, 2006 Letter from Ms. V.M. Rodriguez, NRC, Washington, DC, to Mr. T.J.
37Garrett, WCNOC regarding License Renewal Application for Wolf Creek 38Generating Station, Unit 1. (Accession No. ML063260283).
39 Appendix C Draft NUREG-1437, Supplement 32 C-2 September 2007 November 17, 2006 Letter from Mr. M.W. Sunseri, Wolf Creek Nuclear Operation Corporation 1to NRC Document Control Desk, Docket No. 50-482: Supplemental 2Environmental Information to Support the Application for Renewed 3 Operating License for Wolf Creek Generating Station.
4(Accession No. ML063070581).
5 6November 22, 2006 Letter from NRC to Mr. Don L. Klima, Advisory Council on Historic 7Preservation regarding Wolf Creek Generating Station License Renewal 8Application Review. (Accession No. ML063210199).
9 10November 29, 2006 Letter from NRC to Mr. Rey Kitchkumme, Prairie Band of Potawatomi 11Tribal Council regarding request for comments on the Wolf Creek 12Generating Station License Renewal Application Review.
13(Accession No. ML063280160).
14 15November 29, 2006 Letter from NRC to Ms. Fredia Perkins, Sac and Fox Nation of Missouri 16regarding request for comments on the Wolf Creek Generating Station 17License Renewal Application Review. (Accession No. ML063280164).
18 19November 29, 2006 Letter from NRC to Mr. Steve Cadu, Kickapoo Tribe in Kansas 20regarding request for comments on the Wolf Creek Generating Station 21License Renewal Application Review. (Accession No. ML063280165).
22 23November 29, 2006 Letter from NRC to Mr. Paul Spicer, Seneca-Cayuga Tribe of Oklahoma 24regarding request for comments on the Wolf Creek Generating Station 25License Renewal Application Review. (Accession No. ML063280168).
26 27November 29, 2006 Letter from NRC to Mr. Jim Gray, Osage Tribe of Oklahoma 28regarding request for comments on the Wolf Creek Generating Station 29License Renewal Application Review. (Accession No. ML063280169).
30 31November 29, 2006 Letter from NRC to Mr. Eugene Little Coyote, Northern Cheyenne Tribal 32Council regarding request for comments on the Wolf Creek Generating 33Station License Renewal Application Review.
34(Accession No. ML063280170).
35 36November 29, 2006 Letter from NRC to Mr. Darrell Flyingman, Cheyenne-Arapaho Tribe 37regarding request for comments on the Wolf Creek Generating Station 38License Renewal Application Review.
39(Accession No. ML063310013).
40 Appendix C September 2007 C-3 Draft NUREG-1437, Supplement 32 November 29, 2006 Letter from NRC to Mr. Leon Campbell, Iowa Tribe of Kansas and 1Nebraska regarding request for comments on the Wolf Creek Generating 2Station License Renewal Application Review.
3(Accession No. ML063310014).
4 5November 29, 2006 Letter from NRC to Mr. Ivan Posey, Shoshone and Arapaho Joint Tribal 6Business Council regarding request for comments on the Wolf Creek 7Generating Station License Renewal Application Review.
8(Accession No. ML063310016).
9 10November 29, 2006 Letter from NRC to Ms. Jennie Chinn, State Historical Preservation 11 Officer, Kansas State Historical Society regarding Wolf Creek Generating 12Station License Renewal Application. (Accession No. ML063210171).
13 14November 30, 2006 Letter from NRC to Mr. Mike LeValley, U.S. Fish and Wildlife Service, 15regarding request for a list of the protected species within the area under 16evaluation for the Wolf Creek Generating Station License Renewal 17Application Review. (Accession No. ML063340137).
18 19November 30, 2006 Letter from NRC to Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 20Corporation, regarding Determination of Acceptability and Sufficiency for 21Docketing, Proposed Review Schedule, and Opportunity for a Hearing 22regarding the Application from Entergy for Renewal of the Operating 23License for the Wolf Creek Generating Station, Unit 1.
24 (Accession No. ML063240216).
25 26December 5, 2006 NRC press release announcing the opportunity to request a hearing on 27license application for Wolf Creek Nuclear Power Plant.
28 (Accession No. ML063390067).
29 30December 7, 2006 Federal Register Notice of acceptance for docketing of the application 31and notice of opportunity for a hearing regarding the application for 32license renewal of Wolf Creek Generating Station. (71 FR 70997).
33 34December 12, 2006 Letter from NRC to Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 35Corporation, regarding Request for Additional Information for the Review 36of the Wolf Creek Generating Station, Unit 1, License Renewal 37Application. (Accession No. ML063420403).
38 39December 13, 2006 NRC press release announcing two public meetings to discuss license 40renewal process for Wolf Creek Nuclear Power Plant.
41 (Accession No. ML063470208) 42 Appendix C Draft NUREG-1437, Supplement 32 C-4 September 2007 January 11, 2007 Letter from NRC to Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 1Corporation, regarding Response to Request for Additional Information 2Regarding the Review of the License Renewal Application.
3 (Accession No. ML070180367).
4 5January 19, 2007 Summary of Public Scoping Meetings Conducted Related to the Review 6of the Wolf Creek Generating Station, License Renewal Application.
7(Accession No. ML070220041).
8 9January 29, 2007 Letter from U.S. Fish and Wildlife Service, providing a response to the 10December 7, 2006 NRC staff letter requesting a list of protected species 11within the area under evaluation for license renewal of Wolf Creek 12Generation Station. (Accession No. ML070330025).
13 14January 31, 2007 Letter from U.S. Environmental Protection Agency, Wolf Creek 15Generating Station, License Renewal, Coffey County, Kansas.
16(Accession No. ML070430252).
17 18February 7, 2007 Letter from NRC to Mr. Terry J. Garrett, Wolf Creek Nuclear Operation 19Corporation, regarding Request for Additional Information pertaining to 20Severe Accident Mitigation Alternatives for Wolf Creek Generating Station 21(TAC No. MD3182). (Accession No. ML070240554).
22 23February 21, 2007 Letter from NRC to Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 24Corporation, regarding Environmental Site Audit Regarding Wolf Creek 25Generating Station License Renewal Application. (TAC No. MD3182) 26(Accession No. ML070230546).
27 28May 1, 2007 Issuance of Environmental Scoping Summary Report Associated with the 29Staff's Review of the Application by Entergy Nuclear Operations, Inc., for 30Renewal of the Operating License for Wolf Creek Generating Station.
31(TAC NO. MD3182) (Accession No. ML070850538).
32 33April 4, 2007 Email from NRC to Mr. Charlie M. Medenciy, Wolf Creek Nuclear 34Operation Corporation, regarding Extension Request for SAMA RAIs.
35(Accession No. ML070960083).
36 37April 7, 2007 Letter from NRC to Wolf Creek Nuclear Operating Corporation Regarding 38Summary of Telephone Conference Call held on March 20, 2007, 39between the U.S. Nuclear Regulatory commission and Wolf Creek 40Nuclear Operating Corporation, concerning the analysis of severe 41 Appendix C September 2007 C-5 Draft NUREG-1437, Supplement 32 accident mitigation alternatives pertaining to the Wolf Creek Generating 1Station, Unit 1, License Renewal Application.
2 (Accession No. ML070930584).
3 4April 9, 2007 Letter from NRC to Mr. Terry J. Garrett, Wolf Creek Nuclear Operation 5Corporation, Request for Additional Information Regarding the 6Environmental Review for Wolf Creek Generating Station License.
7(Accession No. ML070851188).
8 9April 18, 2007 E-mail from Ms. Lorrie Bell, Wolf Creek Nuclear Operating Corporation to 10Mr. Christian Jacobs, NRC regarding Response to questions posed by 11NRC during March 20, 2007 telecon. (Accession No. ML071080261) 12 13April 20, 2007 Letter from Mr. Terry J. Garrett, Wolf Creek Nuclear Operation 14Corporation to NRC Document Control Desk.
Subject:
Docket No. 50-15 482: Response to Request for Additional Information Regarding Severe 16Accident Mitigation Alternatives for Wolf Creek Generating Station.
17(Accession No. ML071160203).
18 19April 27, 2007 Letter from NRC to Wolf Creek Nuclear Operating Corporation Regarding 20Summary of Environmental Site Audit Related to the Review of the 21License Renewal Application for Wolf Creek Generating Station, Unit 1.
22(Accession No. ML071030077).
23 24May 23, 2007 Email from Mr. Christian Jacobs, NRC to Mr. Charlie Medenciy, Wolf 25 Creek Nuclear Operating Corporation regarding SAMA questions on Wolf 26Creek LRA. (Accession No. ML071590342).
27 28June 1, 2007 Email from Mr. Charlie Medenciy, Wolf Creek Nuclear Operating 29Corporation to Mr. Christian Jacobs, NRC Regarding SAMA Follow-up 30Response. (Wolf Creek Generating Station) 31 (Accession No. ML071590339).
32 33June 20, 2007 Fax from Mr. Charlie Medenciy, Wolf Creek Nuclear Operating 34Corporation to Mr. Christian Jacobs, NRC Regarding an error in the 35output of the SECPOP2000 program. (Accession No. ML071720273).
36 37June 26, 2007 Letter from Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 38Corporation, to NRC, ET 07-0023, Docket No. 50-482: Response to NRC 39Requests for Follow-up Information Regarding Severe Accident Mitigation 40Alternatives for Wolf Creek Generating Station License Renewal 41Application. (Accession No. ML071840190).
42 Appendix C Draft NUREG-1437, Supplement 32 C-6 September 2007 June 26, 2007 Letter from Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 1Corporation, to NRC, ET 07-0026, Docket No. 50-482: Response to NRC 2Requests for Follow-up Information Regarding Severe Accident Mitigation 3Alternatives for Wolf Creek Generating Station License Renewal 4Application. (Accession No. ML071840188).
5 6July 6, 2007 Letter from Mr. Christian Jacobs, NRC, to Wolf Creek Nuclear Operating 7Corporation, Summary of Telephone Conference Call Held on May 24, 82007, Between the U.S. Nuclear Regulatory Commission and Wolf Creek 9Nuclear Operating Corporation, Concerning the Analysis of Severe 10Accident Mitigation Alternatives Pertaining to the Wolf Creek Generating 11Station, Unit 1, License Renewal Application.
12(Accession No. ML071602012).
13 14July 11, 2007 Emails between Mr. Christian Jacobs, NRC, and Mr. Charlie Medenciy, 15 Wolf Creek Nuclear Operating Corporation Regarding CR Fire CDF Issue 16Clarification. (Accession No. ML071940442).
17 18July 13, 2007 Letter from the Mr. Christian Jacobs, NRC to Wolf Creek Nuclear 19Operating Corporation, Summary of Telephone Conference Call held on 20June 21, 2007, Between the U.S. Nuclear Regulatory Commission and 21Wolf Creek Nuclear Operating Corporation, Concerning Water Use of 22 John Redmond Reservoir by the Wolf Creek Generating Station.
23(Accession No. ML071840181).
24 25July 13, 2007 Letter from Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 26Corporation, to NRC, ET 07-0029, Docket No. 50-482: Summary of the 27Impact to Wolf Creek Generating Station License Renewal Application 28Severe Accident Mitigation Alternatives Analysis due to Computer 29Program Error. (Accession No. ML072000312).
30 31August 15, 2007 Letter from Mr. Terry J. Garrett, Wolf Creek Nuclear Operating 32Corporation, to NRC, ET 07-0035, Docket No. 50-482: Summary of the 33Impact to Wolf Creek Generating Station License Renewal Application 34Severe Accident Mitigation Alternatives Analysis due to Computer 35Program Error. (Accession No.ML072340443).
36 Appendix D Organizations Contacted
September 2007 D-1 Draft NUREG-1437, Supplement 32 Appendix D 1 2 Organizations Contacted 3 4 5During the course of the Staff's independent review of environmental impacts from operations 6during the renewal term, the following Federal, State, regional, local, and Native American tribal 7agencies were contacted:
8 9 City of Burlington, Kansas 10 11City of Emporia, Kansas 12 13Coffey County, Kansas 14 15Corporation Commission, Topeka, Kansas 16 17Kansas Department of Agriculture, Division of Water Resources 18 19Kansas Department of Health and Environment (KDHE), Division of Environment, Bureau of Air 20 and Radiation 21 22Kansas Department of Health and Environment (KDHE), Division of Environment, Bureau of 23 Water, Watershed Management Section 24 25Kansas Department of Health and Environment (KDHE), Division of Environment, Bureau of 26 Water, Public Water Supply Section 27 28Kansas Department of Health and Environment (KDHE), Division of Environment, Bureau of 29Water, Industrial Programs Section 30 31Kansas Department of Transportation 32 33Kansas Department of Wildlife and Parks 34 35Kansas State Historical Society, State Historic Preservation Office 36 37Kansas Water Office 38 39Lyon County, Kansas 40 Organizations Contacted Draft NUREG-1437, Supplement 32 D-2 September 2007 U.S. Army Corps of Engineers 1 2U.S. Environmental Protection Agency, Region 7 3
4 U.S. Fish and Wildlife 5
6U.S. Geological Survey 7
Appendix E Wolf Creek Generating Station Compliance Status and Consultation Correspondence
September 2007 E-1 NUREG-1437, Supplement 32 Appendix E 1 2 Wolf Creek Generating Station 3 Compliance Status and Consultation Correspondence 4 5 6Correspondence received during the process of evaluation of the application for renewal of the 7license for Wolf Creek Generating Station (WCGS) is identified in Table E-1. Copies of the 8correspondence are included at the end of this appendix.
9 10The licenses, permits, consultations, and other approvals obtained from Federal, State, 11regional, and local authorities for WCGS are listed in Table E-2.
12 13 Table E-1.
Consultation Correspondence 14 15SourceRecipientDate of LetterU.S. Fish and Wildlife Service (M. J. LeValley)U.S. Nuclear Regulatory Commission January 29, 2007 U.S. Environmental Protection Agency (K.O. Johnson) U.S. Nuclear Regulatory Commission January 31, 2007 16 Table E.2 Federal, State, Local, and Regional Licenses, Permits, Consultations, and Other Approvals for Wolf Creek Generating Station Agency Authority Requirement Number Issue or Expiration Date Activity Covered Kansas Department of Health and Environment Nuclear Development and Radiation Control Act (L. 1963, Ch. 290); Kansas Annotated Regulations 28-35-133 through 28-35-363 Radioactive Materials License 21-B690-01 Issued on 09/30/2005 Expires on 06/30/2006 Authorizes the transfer, receipt, possession, and use of radioactive material. Kansas Department of Health and Environment Aboveground Storage Tank Permits Facility ID 23762 Issued on 08/01/2005 Expires on 7/31/2006 Authorizes operation of aboveground storage tanks Kansas Department of Health and Environment Underground Storage Tank
Permits Facility ID 23762 Issued on 08/01/2005 Expires on 7/31/2006 Authorizes operation of underground storage tanks Kansas Department of Health and Environment, Bureau of Air and Radiation K.S.A. 65-3008; K.A.R. 28-19-540 Air Emission Source Class II Operating Permit0310021 Issued on 09/08/2005 No expiration date Establishedemissions limits Appendix E Draft NUREG-1437, Supplement 32 E-2 September 2007 Table E.2 (contd)Agency Authority Requirement Number Issue or Expiration Date Activity Covered Kansas Department of Health and Environment, Bureau of Epidemiology and Disease Prevention Consultation Requires the applicant to consult
with the State agency as to whether there is a concern about the potentialexistence and concentration of Naegleria fowleri in the receiving
waters for plant cooling water discharge. Kansas Department of Health and
Environment, Bureau of Epidemiology and Disease Prevention Kansas State Historical
Society Consultation Requires Federal agency issuing license to consider cultural impacts
and consult with State Historic Preservation Officer (SHPO).
Kansas State Historical Society Kansas Water Resources Board Use of State water76-2 Issued on 01/01/1978 Expires on 12/31/2017 Authorizes withdrawal of water from John Redmond Reservoir South Carolina
Department of Health and Environmental Control, Division of Waste Management Act No. 429 of 1980, South Carolina Radioactive Waste Transportation and
Disposal Act South Carolina Waste Transport Permit0223-15-06-X Issued on 11/18/2005 Expires on 12/31/2006 Authorizes transportation of waste into or within the State of South
Carolina Appendix E September 2007 E-3 Draft NUREG-1437, Supplement 32 Table E.2 (contd)Agency Authority Requirement Number Issue or Expiration Date Activity Covered Tennessee Department of Environment and Conservation - Division of Radiological Health Tennessee Code Annotated 68-202-206 License to Ship Radioactive
MaterialT-KS001-L06 Issued on 11/17/2005 Expires on 12/31/2006 Authorizes shipment of radioactive
material to a licensed disposal/processing facility within the
State of Tennessee U.S. Department of Transportation 79 CFR Part 107, Subpart G; 49 USC
5108Hazardous Materials
Certificate of Registration 052703 001 005LN Issued 05/28/2003 Expires 06/30/2006 U.S. Environmental Protection Agency (EPA); Kansas
Department of Health and Environment - Bureau of Water Clean Water Act (33 USC Section 1251 et seq.); Kansas Statutes Annotated 65-164 and 65-165 Kansas Water PollutionControl Permit Kansas: I-NE07-PO02 Federal:
KS0079057 Issued on 02/01/2005 Expires on 12/31/2008 Contains effluent limits for WCGS discharges to the Neosho River via Wolf Creek via Wolf Creek Cooling Impoundment, Neosho River Basin U.S. Fish and Wildlife Service (USFWS) Endangered Species Act Section 7 (16 USC 1536) Consultation Requires Federal agency issuing a license to consult with USFWS.
U.S. Fish and Wildlife Service (USFWS) Endangered Species Act Section 7 (16 USC 1536) U.S. Nuclear Regulatory Commission Atomic Energy Act (42 USC 2011, et seq.), 10 CFR 50.10 License to OperateNPF-42 Issued on 06/04/1985 Expires on 03/11/2025 Operation of Unit 1 App endix E Draft NUREG-1437, Supplement 32 E-4 September 2007 Table E.2 (contd)Agency Authority Requirement Number Issue or Expiration Date Activity Covered U.S. Nuclear Regulatory Commission Atomic Energy Act (42 USC 2011 et seq.) License Renewal Environmental Report submitted in
support of license renewal application U.S. Nuclear Regulatory Commission Atomic Energy Act (42 USC 2011 et
seq.) Utah Department of Environmental Quality -
Division of Radiation ControlR313-26 of the Utah Radiation Control Rules Generator Site Access Permit 0309 002 468 Issued on 11/23/2005 Expires on 11/23/2006 Authorizes delivery of radioactive material to a land disposal facility within Utah. September 2007 E-5 Draft NUREG-1437, Supplement 32 App endix E Appendix E Draft NUREG-1437, Supplement 32 E-6 September 2007 Appendix E September 2007 E-7 Draft NUREG-1437, Supplement 32 Appendix E Draft NUREG-1437, Supplement 32 E-8 September 2007 Appendix E September 2007 E-9 Draft NUREG-1437, Supplement 32
Draft NUREG-1437, Supplement 32 E-10 September 2007 1 2 3
4 5
6 7
8 9 10 11 Appendix E 12 13 Biological Assessment for License Renewal for 14 Wolf Creek Generating Station 15
September 2007 E-11 Draft NUREG-1437, Supplement 32 1 2 3
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6 7
8 9 10 11This Page Intentionally Left Blank 12 13 Draft NUREG-1437, Supplement 32 E-12 September 2007 Biological Assessment 1 2 3 4 5
6 Wolf Creek Generating Station 7License Renewal 8 9 10 11 12 September 2007 13 14 Docket Number 50-482 15 16 17 18 19 20U.S. Nuclear Regulatory Commission 21Rockville, Maryland 22 Appendix E September 2007 E-13 Draft NUREG-1437, Supplement 32 Biological Assessment of the Potential Effects on Federally Listed 1 Endangered or Threatened Species from the Proposed License 2 Renewal for the Wolf Creek Generating Station 3 4 5 1.0 Introduction 6 7 The U.S. Nuclear Regulatory Commission (NRC) issues operating licenses (OLs) for domestic 8 nuclear power plants in accordance with the provisions of the Atomic Energy Act of 1954, as 9 amended, and NRC implementing regulations. The purpose and need for this proposed action, 10 the renewal of the OL for Wolf Creek Generating Station (WCGS), is to provide an option that 11 permits electric power generation to continue beyond the term of the current nuclear power 12 plant OL. This would allow future electric generating needs to be met, if the operator and State 13 regulatory agencies pursue that option.
14 15 The NRC is reviewing an application submitted by the Wolf Creek Nuclear Operating 16 Corporation (WCNOC) for the renewal of OL NPF-42 for WCGS for 20 years beyond the current 17 OL expiration date of March 11, 2025. The WCNOC, which operates WCGS, prepared an 18 Environmental Report (ER; WCNOC 2006a) as part of its application for the renewal of the 19 WCGS OL. In the ER, WCNOC analyzed the environmental impacts associated with the 20 proposed license renewal action, considered alternatives to the proposed action, and evaluated 21 mitigation measures for reducing adverse environmental effects. The NRC is using the ER and 22 additional information as the basis for this Biological Assessment (BA) and a Supplemental 23 Environmental Impact Statement (SEIS), a plant-specific supplement to the Generic 24Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437 25 (NRC 1996). Unless stated otherwise, much of the information in this BA is taken from the ER.
26 27 Pursuant to Section 7 of the Endangered Species Act of 1973, as amended, NRC staff 28 requested in a letter dated December 7, 2006 (NRC 2006), that the U.S. Fish and Wildlife 29 Service (FWS) provide information on Federally listed endangered or threatened species, as 30 well as proposed or candidate species, and any designated critical habitats that may occur in 31 the vicinity of WCGS. In a letter to the NRC dated January 29, 2007 (FWS 2007a), the FWS 32 provided information about three Federally listed species and one candidate species with the 33 potential to occur in the project area. One of the three species, the bald eagle (Haliaeetus 34 leucocephalus
), has been delisted (FWS 2007b) since receipt of the FWS letter. Because 35 Section 7 consultations do not address candidate species, this BA does not include information 36 on the candidate species Neosho mucket (Lampsilis rafinesqueana) that may occur in the area.
37 Therefore, this BA examines the potential effects of the continued operation of WCGS on two 38 Federally threatened species: the threatened Neosho madtom (Noturus placidus) and the 39 threatened Mead's milkweed (Asclepias meadii)
.40 Appendix E Draft NUREG-1437, Supplement 32 E-14 September 2007 2.0 The Proposed Federal Action 1 2 The proposed Federal action is renewal of the OL for WCGS. The WCGS facility is located in 3Coffey County in eastern Kansas approximately 75 miles southwest of Kansas City. The 4 location of the facility and the areas within 50-miles (mi) and 6-mi radii of the facility are shown 5 in Figures 2-1 and 2-2, respectively. The plant has one Westinghouse pressurized water 6 reactor with a reactor core power of 3,565 megawatts thermal, and a design net electrical 7 capacity of 1,165 megawatts electric. Plant cooling is provided by a once-through heat 8 dissipation system that withdraws cooling water from, and discharges it to, a cooling pond, 9 Coffey County Lake. The current OL for WCGS expires on March 11, 2025. By letter dated 10 September 27, 2006, WCNOC submitted an application (WCNOC 2006b) to the NRC to renew 11 this OL for an additional 20 years of operation, that is, until March 11, 2045.
12 13 There would be no major construction, refurbishment, or replacement activities associated with 14 the license renewal. If the NRC approves the license renewal application, the reactor and 15 support facilities, including the cooling system, would be expected to continue to be operated 16 and maintained until the renewed license expires in 2045. Maintenance activities would also 17 continue to be performed on the transmission lines that connect WCGS to the electric grid, 18 including inspection, surveillance, and vegetation management within the right-of-ways (ROWs).
19 203.0 The Plant and Associated Transmission Line System 21 223.1 Cooling and Auxiliary Water Systems 23 24 WCGS operates as a once-through cooling facility, with Coffey County Lake being the water 25 source for the circulating water condenser cooling system as well as the Service Water System 26 (SWS) and Essential Service Water System (ESWS). Coffey County Lake (formerly known as 27 the Wolf Creek Cooling Lake) also serves as the receiving water body, or cooling pond, for the 28 discharges from the condenser cooling system as well as the other two systems. The source of 29makeup water for Coffey County Lake is the Neosho River immediately downstream of the John 30 Redmond Reservoir dam. Figure 3-1 shows the locations of WCGS facilities in relation to these 31 water bodies.
32 333.1.1 Cooling Water Intake 34 35 Condenser cooling water is withdrawn from Coffey County Lake through the circulating water 36 intake structure (CWIS). The CWIS is within the Circulating Water Screenhouse, which is 37 located in the southeast corner of the main facility area on the shore of Coffey County Lake.
38 The screenhouse contains the major equipment associated with the circulating water system 39 and the SWS. The ESWS, described below, is located in a separate building to the northeast of 40 the CWIS.41 Appendix E September 2007 E-15 Draft NUREG-1437, Supplement 32 1 2 3
4 5
6 7
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Figure 2-1.
Location of WCGS, 50-mile radius 41 Source: WCNOC 2006a Appendix E Draft NUREG-1437, Supplement 32 E-16 September 2007 1 2 3
4 5
6 7
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Figure 2-2.
WCGS, 6-mile radius 42 Source: WCNOC 2006a Appendix E September 2007 E-17 Draft NUREG-1437, Supplement 32 2 4 Figure 3-1.
WCGS Property Boundaries and Environs Source: WCNOC 2006a Appendix E Draft NUREG-1437, Supplement 32 E-18 September 2007 The circulating water and service water flow from the lake past a vertical steel plate used to 1 keep ice from entering the circulating water intake structure (CWIS) and then through bar grills 2 (trash racks) into three separate bays where the traveling screens are located. The bar grills 3 are used for removing the larger debris while the traveling screens are designed to remove 4 smaller debris. The bar grill, located at the inlet of the intake bays, is constructed of 1-inch (in.)
5 vertical bars spaced at 3-in. intervals. These bars have not been cleaned throughout the history 6 of the plant. Behind the bar grill, there are six traveling screens with two traveling screens per 7 bay. The traveling screens are of a vertical single entry/exit type with standard 0.375-in. mesh.
8 The traveling water screens are operated intermittently either by a timer or automatically due to 9 a high-differential-pressure sensor.
10 11 There are low- and high-pressure screen washes to rinse debris and organisms off the screens.
12 Typically, the low-pressure wash is used to remove debris and organisms on the screens, but a 13 high-pressure wash can be activated for cleaning or heavy fouling. Debris and organisms 14 washed from the screens are directed to a concrete sluiceway, then to a basket on the outside 15 of the building. From the sluiceway to the basket, there is an approximate 2-foot (ft) drop to the 16grated basket. Larger debris and organisms remain in the basket until they are manually 17 removed. Cleaning of the basket occurs every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when there is heavy loading; at other 18 times it may be a few days until the basket is emptied. Smaller debris and organisms pass 19 through the grates and fall approximately 3 to 4 ft to the water surface. Some service water is 20 also discharged into the grated area. The traveling screens are continuously turned if there are 21 winds greater than 25 miles per hour (mph) from the south in October or November or if there is 22 a fish kill. Records are not kept regarding the operation of the screens at Coffey County Lake, 23 but generally they are turned for 30 minutes every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
24 25 The CWIS operates continuously during power generation, including startup and shutdown.
26 Three one-third capacity, motor-driven, vertical, wet-pit circulating water pumps pump the 27 circulating water from the cooling lake to the main condenser. They are designed to operate 28 through the expected range of cooling lake levels. When lake water temperatures are greater 29 than 50 degrees Fahrenheit (°F), three pumps provide the design flow rate of approximately 30 500,000 gallons per minute (gpm). Under normal conditions all three pumps would be operating 31 at a total capacity of 1,178 cubic feet per second (cfs). Because condenser cooling is more 32 efficient with colder intake water, only two pumps are operated with a design flow of 365,000 33gpm when lake temperatures are below 50°F.At these pumping rates, through screen velocity 34 is less than 1.0 foot per second (fps). Based on a total flow rate of 1,256 cfs (circulating water 35 and service water combined), the average intake water velocities are 0.87 fps (approach 36 velocity to the CWIS); 1.06 fps (velocity through the bar grills), 1.06 fps (approach velocity to the 37 traveling screens), and 1.95 fps (velocity through the traveling screens). WCNOC injects anti-38 scalants and dispersants, biocides, and corrosion inhibitors into the CWIS to maintain the 39 system and prevent fouling by corrosion and biological organisms. Additions of these 40 constituents to the CWIS is limited by the facility's National Pollutant Discharge Elimination 41 System (NPDES) permit.
42 Appendix E September 2007 E-19 Draft NUREG-1437, Supplement 32 3.1.2 Cooling Water Discharge 1 2 After passing through the condenser, the heated water is returned to Coffey County Lake 3 through the circulating water discharge structure located at the northeast corner of the facility 4 (Figure 3-2). This structure has a discharge well that overflows into a 40-ft wide apron and then 5 onto the surface of the lake. The heated effluent is discharged from the circulating water 6 discharge structure into an approximately 290-acre (ac) cove in Coffey County Lake. A baffle 7 dike directs the effluent along a northwesterly path as it leaves the discharge cove to allow 8 greater heat dissipation before warm water mixes with water in the main body of the lake 9 (WCNOC 2006a). Baffle dikes prevent short-circuiting of the discharge water back to the intake 10 (Figure 3-1). The discharged water takes approximately 38 days to travel from the discharge to 11 the intake structure (WCNOC 2007). The maximum increase in discharged water temperature 12 relative to the ambient water temperature of the lake is 30°F, but the normal temperature 13 increase ranges from 0.8°F to 7.6°F.
14 153.1.3 Service Water Systems 16 17 There are two service water systems at WCGS, the main SWS and ESWS. The SWS takes 18 water from the circulating water intake structure and returns the warmed water to the 19 circulating water discharge pipe. The flow rate is variable, but flow rates can be as high as 20 50,000 gpm. Three service water pumps are housed in the CWIS. Typically, two service water 21 pumps are operating at a total capacity of 90 cfs with one pump serving as a standby. During 22 normal plant operation, the SWS supplies water to the turbine plant auxiliary equipment and the 23 steam generator blowdown nonregenerative heat exchanger. The SWS is the normal water 24 supply for the demineralized water makeup system, the fire protection diesel and electric fire 25 pumps, and the ESWS. Both the SWS and ESWS incorporate the use of oxidants such as 26 chlorine for control of biofouling. Per the facility's NPDES permit, a maximum of 1.0 milligram 27 per liter (mg/L) total residual oxidants is allowed, with up to 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of continuous chlorination 28 (Hammond 2006).
29 30 The ESWS cools several safety-class systems and provides cooling for safe shutdown in an 31 accident. During accident conditions, the ESWS intake structure takes water from the Ultimate 32 Heat Sink, a specially designed impoundment within Coffey County Lake in the cove southeast 33 of the facility. An underwater dam prevents draining of the Ultimate Heat Sink in the event of 34 the failure of the Coffey County Lake dam. The ESWS intake structure consists of two totally 35 independent intake systems. Each has a forebay with the same type of trash racks as found in 36 the CWIS; however, there are no vertical steel plates, used for ice protection, as seen in the 37 CWIS. Each system also has a traveling screen similar to the CWIS. Debris and organisms 38 trapped on the traveling screens are diverted to a shared sluiceway that discharges to the 39 Appendix E Draft NUREG-1437, Supplement 32 E-20 September 2007 Source: WCNOC 2006a Figure 3-2.
WCGS Facility Layout Appendix E September 2007 E-21 Draft NUREG-1437, Supplement 32 outside of the building. Similar to the CWIS, the ESWS screens can be operated automatically 1 or manually. Some service water is diverted to the ESWS consistently to keep the system 2 clean. Heated effluent can also be directed to the intake for ice control. The ESWS is operated 3 infrequently. The discharge goes to a separate discharge structure on the Ultimate Heat Sink.
4 53.1.4 Makeup Water System 6 7 Makeup water for Coffey County Lake is drawn from the Neosho River through the Makeup 8 Water Screen House (MUSH) located approximately 300 ft downstream of the John Redmond 9 Reservoir dam. Water for WCGS leaves John Redmond Reservoir through a 30-in. supply pipe 10 that empties into the Neosho River, where the flow is diverted into a channel on the east side of 11 the river at the MUSH. The MUSH contains three makeup water pumps, each with a dedicated 12 bar grill and 3/8-in. traveling screens. Only two pumps can be used at a time. Each pump is 13 designed to provide 60 cfs through a 54-in.-diameter supply line to Coffey County Lake. This 14 supply line is designed for 130 cfs, with an optimum flow rate of 120 cfs (WCNOC 2006c).
15 16 The design and operation of the bar grill and traveling screens are similar to the CWIS. There 17 are no provisions for returning fish that survive impingement to the Neosho River. However, 18 according to WCGS, the design intake velocity of less then 0.5 fps at the normal water level in 19 the river at the MUSH (1,007.5 feet above mean sea level [MSL]) should minimize fish 20 impingement (WCNOC 2006c). From the MUSH, water flows through the supply line to Coffey 21 County Lake and discharges at the makeup water discharge structure on the western shore of 22 the lake, immediately adjacent to the Coffey County Lake boat ramp. The structure consists of 23 a stilling basin/sump wherein the makeup water pipeline discharges. From this sump, the 24 makeup water flows over a weir and down a spillway to the lake.
25 263.2 Power Transmission System 27 28 The applicant identified three 345-kilovolt (kV) transmission lines that were constructed in 29 conjunction with the construction of WCGS in order to connect the facility to the electric power 30 grid: 31 32 Wolf Creek to pre-existing Benton line 33 Wolf Creek to pre-existing La Cygne line 34 Wolf Creek to Rose Hill substation 35 36 Prior to construction of WCGS, a 345-kV transmission line ROW extended from La Cygne 37 (located approximately 60 miles east of WCGS) to Benton (located northwest of Wichita) and 38 traversed the site. This line was rerouted around Coffey County Lake and connected to the 39 WCGS switchyard by constructing a 7-mi segment around the lake on the east end of what 40 became the Wolf Creek - Benton line and a 0.7-mi segment on the west end of what became 41 the Wolf Creek - La Cygne line (Figure 3-3). Both of these lines have 150-ft-wide ROWs that 42 Appendix E Draft NUREG-1437, Supplement 32 E-22 September 2007 are almost entirely on WCGS property. In addition, a new 345-kV transmission line was built in 1 conjunction with the construction of WCGS, the Wolf Creek - Rose Hill line. This line extends 2 southwest from WCGS for 98 miles within a 150-foot-wide ROW to the Rose Hill Substation 3 located southeast of Wichita (WCNOC 2006a).
4 5 These lines are contained within approximately 106 miles of 150-ft-wide ROWs that include a 6 total area of over 1920 ac in Coffey, Greenwood, and Butler Counties. The transmission line 7 ROWs primarily occur within agricultural and open range lands and cross numerous county, 8State, and Federal highways. They do not cross any national or State parks, wildlife refuges, or 9 wildlife management areas. The Wolf Creek - Benton line crosses over several inlets and 10 tributaries of Coffey County Lake, and the Wolf Creek - La Cygne and Wolf Creek - Rose Hill 11 lines cross over one inlet of the lake east of the WCGS facility. The Wolf Creek - Rose Hill line 12 also crosses the Neosho, Verdigris, Fall, Little Walnut, and Walnut Rivers, as well as many 13 smaller creeks. It does not cross any major lakes or ponds outside of the WCGS property.
14 154.0 Environmental Setting 16 17 WCGS is located on Coffey County Lake, a man-made lake constructed on Wolf Creek 18 specifically to act as a cooling water reservoir for the facility (WCNOC 2006a). The major 19 features of the WCGS site are the reactor containment building, turbine building, auxiliary 20 building, control building, fuel handling facility, switchyard, radioactive waste building, training 21 center, visitor's center (with associated Emergency Operations Facility and simulator), outdoor 22 firing range, and other supporting buildings (WCNOC 2006a). The area within the site 23 boundaries (Figure 3-1) owned by WCGS includes the 500-ac Wolf Creek Environmental 24 Education Area at the northern end of Coffey County Lake (WCNOC 2006a). The general 25 facility layout is depicted on Figure 3-2.
26 274.1 Aquatic Resources 28 29 The aquatic resources relevant to the operation of WCGS are those associated with Coffey 30 County Lake; Wolf Creek, on which the lake was constructed; and the Neosho River and John 31 Redmond Reservoir, which are affected by the transfer of makeup water to Coffey County Lake.
32 This section provides a description of the aquatic resources potentially affected by the 33 operations of the WCGS.
34 Appendix E September 2007 E-23 Draft NUREG-1437, Supplement 32 Figure 3-3.
WCGS Transmission Lines Source: WCNOC 2006a Appendix E Draft NUREG-1437, Supplement 32 E-24 September 2007 4.1.1 Wolf Creek and Coffey County Lake 1 2 Wolf Creek is a small, intermittent tributary of the Neosho River that begins to the north of 3 Coffey County Lake. The total annual flow for Wolf Creek is approximately 12,985 ac-ft or 18 4 cfs (WCNOC 2006a). Wolf Creek contributes approximately one percent of the 1,865 cfs 5 average Neosho River water flow measured at Iola (Putnam and Schneider 2005), which is 6 downstream of the confluence of Wolf Creek with the Neosho River.
7 8 Coffey County Lake was created by erecting an earthen dam across Wolf Creek that, along with 9 five perimeter saddle dams, serves to impound the creek approximately 5 miles above its 10confluence with the Neosho River (KG&E 1984).Filling of Coffey County Lake using water from 11 John Redmond Reservoir released into the Neosho River began in October 1989 and was 12 completed in June 1982 (EA 1988). The tops of the dams are at an elevation of 1,100 ft above 13 MSL to allow for sufficient freeboard. Service and auxiliary spillways with ogee crests of 1,088 ft 14 above MSL and 1,090.5 ft above MSL, respectively, were constructed on the east abutment of 15 the main dam to prevent overtopping of the dams by the probable maximum flood and wind and 16 wave action. The normal operating elevation of Coffey County Lake is 1,087 ft above MSL; at 17 this elevation the lake has a capacity of 111,280 ac-ft and covers 5,090 ac (EA 1988), with a 18 maximum depth of 60 ft (KDWP 2007), and an average depth of 21.5 ft (KG&E 1986). At this 19 pool level, the lake is designed to provide adequate cooling water to the plant during a 1 in 50 20 year drought.
21 22 The water level in Coffey County Lake is normally maintained by the watershed; however, 23 during dry months, it is sometimes necessary to pump water to the lake from the Neosho River 24 through the MUSH below the John Redmond Dam. If the flow rate within the Neosho River is 25 below 250 cfs downstream of the intake, then water may be purchased from the conservation 26 pool within John Redmond Reservoir and delivered to the MUSH via a bypass pipe (WCNOC 27 2006a).28 29 During times of flooding, service and auxiliary spillways provide for controlled release of lake 30 water to prevent overtopping of the Coffey County Lake dam. Although the dam has provisions 31 for releasing water to Wolf Creek (blowdown for chemistry control), such release is infrequently 32 performed. A strong north wind would cause waves to break over the spillways thus causing a 33 release of water to Wolf Creek. Per the facility's NPDES permit, sampling must be conducted 34 whenever a discharge occurs. Discharge occurs relatively infrequently. In 1997, there were 6 35 separate discharge events; in 1998, 34; 1999, 19; 2000, 3; 2001, 1 event; no events in 2002 to 36 2004; 7 events in 2005; and 2 events in 2006.
37 384.1.2 Neosho River and John Redmond Reservoir 39 40 The John Redmond Reservoir was created by the construction of John Redmond Dam across 41 the Neosho River approximately 3 miles north and 1 mile west of Burlington, Kansas. The dam 42 Appendix E September 2007 E-25 Draft NUREG-1437, Supplement 32 and reservoir were completed for full flood control in September 1964. John Redmond 1 Reservoir has a surface area of 9,400 ac with an average depth of 6 ft and a maximum depth of 2 12 ft. The current water supply, the conservation pool of John Redmond Reservoir, is now at 3 1,039 ft above MSL (USACE 2007). The amount of water-supply storage in the conservation 4 pool has been reduced by unforeseen sedimentation (Engineering-Environmental Management, 5 Inc. 2002). The reservoir bottom is shallow and flat, which allows for a rapid vegetative 6 response when water is lowered (Jirak 2005). The slope of the Neosho River is very flat as it 7 enters John Redmond Reservoir, contributing to the creation of a mudflat near the entrance to 8 the reservoir and the collection upstream of a large logjam of woody debris approximately 1.5 9 miles long (USACE 2005).
10 11 The Neosho River below the John Redmond Dam to the Kansas-Oklahoma State line is 12 characterized by a meandering channel with a bed that typically consists of a combination of 13 bedrock, cobble, gravel, sand, and silt. The channel slope of the Neosho River below John 14 Redmond Reservoir averages about 1.2 ft/mi (Juracek and Perry 2005). The riverbank height 15 varies from about 15 to 30 ft (Juracek and Perry 2005) with a channel bank that consists of 16 mostly cohesive silt and clay (Osterkamp and Hedman 1981 as cited in Juracek and Perry 17 2005) and is typically covered by partial to complete mature trees (Juracek and Perry 2005).
18 Changes in the downstream flow as a result of the John Redmond Dam have included a 19 decrease in the magnitudes of peak flows and increase in the magnitude of low flows (Studley 20 1996). A study conducted by M. Wildhaber, et al. (2000) on the Neosho River, found that the 21 water temperature was cooler, turbidity was higher, and the fredle index (a measure of sediment 22 particle size) was marginally lower above the dam than below the dam. Dissolved oxygen 23 increased downriver of the dam, but conductivity, alkalinity, and hardness were all higher above 24 the dam.25 26 The minimum desirable streamflow (MDS) in the Neosho River, downstream of John Redmond 27 Reservoir, is 40 cfs during all times of the year (USGS 2007). As required by the Kansas Water 28 Appropriation Act (KWAA 2004), a minimum flow of 40 cfs in the Neosho River at Iola 29 (approximately 55 river mi south of the John Redmond Dam) is required during the months of 30 July to March, 60 cfs is required in April, and 200 cfs is required in May and June. These flow 31 rates were established as the minimum flows allowable to avoid adverse impacts to the Neosho 32 River instream and riparian communities (WCNOC 2006a). WCGS, however, is not subject to 33 withdrawal restrictions to maintain these minimum flows.
34 35 The withdrawal of water from the natural flows within the Neosho River is regulated by the 36 conditions of the two appropriation mechanisms used by WCGS to acquire the water. These 37 conditions require that withdrawals of natural flows can only be made when the flow rate 38 remaining within the Neosho River downstream of the MUSH intake structure is 250 cfs or 39 greater (WCNOC 2006c). However, the appropriation mechanism allows WCNOC to request a 40 variance from the 250 cfs limitation from the Chief Engineer of the Division of Water Resources 41 Appendix E Draft NUREG-1437, Supplement 32 E-26 September 2007 (DWR). The appropriation mechanisms are not subject to the MDS restriction of 40 to 200 cfs 1 for the Neosho River.
2 3 The resources that could be affected by the purchase of water from the conservation pool are 4 the same as those that could be affected by the WCGS appropriations from the natural flows of 5 the Neosho River. The purchase of the conservation pool water would only occur when the 6 water elevation within John Redmond Reservoir is below 1,039 ft above MSL, and under these 7 conditions, the flow rate within the Neosho River would already be below the 250 cfs required to 8 acquire water through the appropriations (WCNOC 2006c). Therefore, the Neosho River would 9 already be in a low-flow or drought condition (WCNOC 2006c).
10 11 Prior to the beginning of facility operations, the NRC conducted an analysis of the impact of 12 water withdrawal from the Neosho River during severe and prolonged drought conditions (NRC 13 1975). This analysis evaluated the expected water withdrawal rates from WCGS during what 14 was considered to be a 1 in 50 year drought. The precipitation and water volume data to 15 support the study were taken from actual measurements on the Neosho River during the period 16 from January 1951 to December 1959, which corresponded with a 1 in 50 year drought. The 17 results of this analysis were that withdrawal of stored contract water by WCGS at 41 cfs would 18 cause reduced flows within the river, would extend the duration and severity of low-flow 19 conditions, and could cause stress to aquatic communities and fish populations (NRC 1982).
20 21 Similar to the Neosho River appropriations, the withdrawal of water from the conservation pool 22 through the purchase contracts is regulated by the conditions of the purchase contract and also 23 is restricted by the physical limitations of the MUSH withdrawal system (WCNOC 2006c).
24 These restrictions result in a maximum withdrawal rate of 70 cfs for stored water from the 25 conservation pool (WCNOC 2006c). This volume of water exceeds the 41 cfs estimate 26 established by NRC as the volume of withdrawal that could cause reduced flows within the river.
27 28 Although MDS levels have been established to protect aquatic resources in the Neosho River, 29 the appropriations and water purchase contract mechanisms under which WCGS obtains 30 makeup water are not subject to these restrictions. The MDS restrictions apply only to junior 31 water rights obtained after April 12, 1984, and Kansas Statutes Annotated (KSA) 82a-703b(b) 32 states that "all vested rights, water appropriation rights and applications for permits to 33 appropriate water having a priority date on or before April 12, 1984, shall not be subject to any 34 minimum desirable streamflow requirements." As the WCGS appropriations were established 35 prior to April 12, 1984, they are not subject to the restrictions. The water purchase contract is 36 also not subject to MDS restrictions. A comparison of water withdrawal dates with Neosho 37 River streamflows indicates that withdrawals have occurred in the past on days when the 38 Neosho River flow rate was below the 40 cfs MDS.
39 40 The proposed action described in the WCGS ER (WCNOC 2006a) assumes that John 41 Redmond Reservoir would continue to be the primary source of makeup water, but does not 42 Appendix E September 2007 E-27 Draft NUREG-1437, Supplement 32 address the likelihood that the availability of this source is being reduced through sedimentation.
1 The documentation of the sedimentation issue in the draft Environmental Impact Statement 2Prepared for the: Reallocation of Water Supply Storage Project: John Redmond Lake (USACE 3 2002) and the Kansas Water Office Fact Sheet for John Redmond Reservoir (KWO 2007) 4 strongly suggest that future actions would be required to ensure the continuity of the water 5 supply. In the worst case, if no actions are taken, the volume of water available within the 6 conservation pool would continue to decrease, and the supply of water to WCGS would 7 compete with the volumes of water available to maintain adequate streamflow and provide flow 8 to the Cottonwood and Neosho River Basins Water Assurance District Number 3. If this 9 situation coincides with a drought condition, continued water withdrawal by WCGS could 10 severely deplete habitat and affect biota within and along the Neosho River. Such conditions 11 could result in derating the plant temporarily during drought periods. Actions that may be taken 12 to increase the water availability during the relicensing period may include additional 13 reallocations of the conservation and flood pools within the reservoir, dredging of sediment from 14 the reservoir, or accessing alternative water supplies (groundwater or surface water based) from 15 the local area. Once a proposal is developed and evaluated, it is likely that the impacts and 16 specific mitigation measures would be evaluated in future environmental analyses and 17 documentation developed by U.S. Army Corps of Engineers (USACE) or the State of Kansas.
18 194.2 Terrestrial Resources 20 214.2.1 Terrestrial Upland Plant Communities 22 23 4.2.1.1 WCGS Property 24 25 The lands on WCGS property outside the immediate area surrounding the station facilities are 26 managed to achieve a balance between agricultural production and conservation. Some land 27 areas have been reserved for educational purposes and maintained as natural communities for 28 wildlife habitat, including a strip around the shoreline of Coffey County Lake. The remaining 29 land has been leased for grazing, hay, and crop production. In 2005, approximately 1,422 ac 30 were leased for grazing, 508 ac were leased for hay production, and 1,282 ac were leased for 31 crops such as soybeans, milo, corn, and wheat. WCNOC's agricultural leases require 32 conservation practices such as contour plowing, construction and/or maintenance of terraces to 33 reduce soil erosion, and at harvest, leaving grain around field edges for wildlife (WCNOC 34 2006a).35 36 Grazing restrictions, pasture rotation, and controlled burning are used to ensure continued 37 health of the native rangeland on WCGS property (WCNOC 2005). Fire has always been an 38 essential part of prairie communities, and prescribed burning is used on grasslands at WCGS to 39 control woody brush invasion, control less desirable cool-season grasses or weeds, increase 40 wildlife value, and increase prairie vigor and production. Controlled burning was completed on 41 Appendix E Draft NUREG-1437, Supplement 32 E-28 September 2007 approximately 1,197 ac in 2005. Most grassland units at WCGS are scheduled to be burned 1 once every 3 years (WCNOC 2006a).
2 3 A 200 to 400-ft wide strip surrounding the Coffey County Lake shoreline has been managed 4 since 1980 as a buffer zone of natural vegetation between the lake and the agricultural areas.
5Agricultural activities are not allowed in this area, and previously cultivated lands have been 6 allowed to advance through the stages of natural succession. Native grasses have been re-7 established in some portions of the lakeside buffer zone, and land management activities here 8 include controlled burning, tree and brush control in native grass prairie areas, and noxious 9 weed control (WCNOC 2006a). Native prairie at WCGS is categorized as "bluestem prairie" 10 and is typically composed of tall grasses and many species of forbs (NRC 1975). Most forested 11 areas on WCGS property are in lowlands and riparian areas upstream and downstream of 12 Coffey County Lake (WCNOC 2007a).
13 14 The Wolf Creek Environmental Education Area is an approximately 500-ac nature area near the 15 north end of the site property. It includes five trails that guide visitors through a variety of 16 habitats, including native tall grass prairie, native and planted forests, wetlands, and wildlife 17 food plots. In addition to the natural areas, there are shelterbelts, planted trees, restored native 18 grasses, developed wetlands, and planted winter food plots for wildlife. The Wolf Creek 19 Environmental Education Area is the result of a partnership between private citizens, civic 20 organizations, local, State, and Federal governments, and WCGS (WCNOC 2006a).
21 22 The area surrounding the WCGS property consists mainly of rangeland and farmland, with 23 occasional forested areas in bottomlands along the Neosho River and other streams. The 24 rangeland is vegetated mostly by native and tame (introduced) grasses, mixed grass-brush, and 25 managed pastures. There are no Federally designated or proposed critical habitats for 26 threatened or endangered terrestrial species in the vicinity of WCGS or its associated 27 transmission lines (WCNOC 2006a).
28 29 4.2.1.2 Transmission Line ROWs 30 31 The transmission lines included in this assessment are those with voltages exceeding 98 kV 32 that were originally constructed for the specific purpose of connecting WCGS to the existing 33 transmission system. These transmission lines extend approximately 106 miles and their 34 ROWs cover a total area of approximately 1,922 ac. The ROWs cross land that is primarily 35 agricultural or open range, and the areas are mostly remote with few human residents. The 36 lines also cross numerous county, State, or U.S. highways. ROW that passes through farmland 37 generally is used as farmland. The ROW does not cross any State or Federal parks, wildlife 38 refuges, or wildlife management areas. State and Federal lands in the vicinity of the WCGS 39 transmission line ROW are associated with the John Redmond Reservoir to the west: the John 40 Redmond Wildlife Area, which is managed by the Kansas Department of Wildlife and Parks 41 (KDWP), and the Flint Hills National Wildlife Refuge, an 18,500-ac refuge located on the 42 Appendix E September 2007 E-29 Draft NUREG-1437, Supplement 32 upstream portion of John Redmond Reservoir on land owned by the USACE and managed by 1 the FWS (WCNOC 2006e).
2 3 Wolf Creek - Rose Hill Transmission Line:
4 5 The Wolf Creek - Rose Hill 345-kV line extends approximately 98 miles from WCGS in a 6 southwesterly direction to the Rose Hill substation east of Wichita. The ROW is 150 ft in width, 7 resulting in a total of approximately 1,782 ac within the ROW. Land uses in the area traversed 8 by this ROW include cropland (402 ac, 24 percent of the total ROW area), grazing lands (1,187 9 ac, 70 percent), woodlands (63 ac, 4 percent), idle land (27 ac, 2 percent), and roads (9 ac, 0.5 10 percent. The Wolf Creek-Rose Hill line passes approximately 6 miles south of the John 11 Redmond Wildlife Area and 9 miles south of the Flint Hills National Wildlife Refuge (WCNOC 12 2007a).13 14 La Cygne - Benton Transmission Line (rerouted portion):
15 16 The portion of the La Cygne - Benton 345-kV transmission line rerouted around Coffey County 17 Lake, which includes sections of the Wolf Creek - Benton line and the Wolf Creek - La Cygne 18line, is approximately 7.7 miles long. Most of this line was constructed on WCGSproperty. The 19 ROW is 150 ft wide and covers nearly 140 ac. Land uses within the upland areas of this ROW 20 include cropland (27 ac, 20 percent of the total ROW area); grazing land (43 ac, 31 percent);
21 hay meadow (15 ac, 11 percent); woodland (7 ac, 5 percent); wildlife habitat such as native 22 grasses, grass-brush, and brush habitats (23 ac, 16 percent); and roads, gravel areas, and 23 WCGS yard areas (11 ac, 8 percent) (WCNOC 2007a).
24 254.2.2 Riparian and Wetland Plant Communities 26 27 The WCGS site encompasses approximately 9,818 ac located in Coffey County approximately 28 3.5 miles east of the Neosho River and 5 miles east of the John Redmond Reservoir. The site 29 includes the 5,090-ac Coffey County Lake, which was formed by the construction of an earthen 30 dam across Wolf Creek, and the 31-ac Lime Sludge Pond.
31 32 4.2.2.1 Coffey County Lake and Wolf Creek 33 34 The riparian areas of Wolf Creek upstream and downstream of Coffey County Lake are typical 35 of the oak-hickory forests found in east-central Kansas. They are medium to tall, multilayered, 36 broadleaf deciduous forests typically occurring on the first and second terraces adjacent to 37 streams. Within the oak-hickory forest, lowland woods occupy the riparian areas of Wolf Creek.
38 The shoreline and shallow water habitats of Coffey County Lake have been colonized by 39 species typical of wet soils or periodically flooded habitats, such as cottonwood (Populus spp.), 40 black willow (Salix nigra
), and cattails (Typha spp.). As the water level of the lake fluctuates, 41 Appendix E Draft NUREG-1437, Supplement 32 E-30 September 2007 mudflat areas develop and are colonized by common herbaceous and woody species (WCNOC 1 2007a).2 3 Since WCGS operation began in 1985, activities have been performed to protect and enhance 4 riparian areas on the station property. These have included the construction of approximately 5 25 ac of shallow-water, ephemeral wetlands; protection of old-growth, oak-hickory woodland; 6 planting of bottomland forest; establishment of native grasses for buffers along the shoreline of 7 Coffey County Lake; preservation of areas for natural succession; and exclusion of livestock 8 (WCNOC 2007a).
9 10 4.2.2.2 Lime Sludge Pond 11 12 The Lime Sludge Pond is a 31-ac unlined pond located north of the switchyard and adjacent to 13 Coffey County Lake. It was originally constructed to receive lime sludge but was never used for 14 that purpose. The pond provides shoreline and shallow water habitats supporting communities 15 similar to those described above for the lake (WCNOC 2006a).
16 17 4.2.2.3 Neosho River and the John Redmond Reservoir 18 19 The wetlands and shallow coves of John Redmond Reservoir are dominated by smartweeds 20 (Polygonum spp.), rushes (Juncus spp.), cattails, and sedges. Some stands of silver maple 21 (Acer saccharinum
), black willow, and eastern cottonwood (Populus detoides) also are present.
22 On the mudflats exposed during reservoir drawdown, weedy annuals such as cocklebur 23 (Xanthium strumarium
), and grasses are common (WCNOC 2007a).
24 25 The riparian areas of the Neosho River upstream and downstream of John Redmond Reservoir 26 are bottomland hardwood forest. Downstream from John Redmond Reservoir, most of the 27 floodplain vegetation along the Neosho River and its major tributaries can be described as 28 riparian woodland. Islands, point bars, and first terraces are dominated by species more 29 tolerant of wet soil, such as eastern cottonwood, silver maple, and box elder (Acer negundo
).30 Second terraces, which are slightly higher in elevation, support green ash (Fraxinas 31 pennsylvanica
), American elm (Ulmus americana
), black walnut (Juglans nigra
), hackberry 32 (Celtis occidentalis
), and bur oak (Quercas macrocarpa) (WCNOC 2007a).
33 34 4.2.2.4 Transmission Line ROWs 35 36 Riparian and wetland communities are a small component of the natural communities present 37 within the transmission line ROWs.
38 Appendix E September 2007 E-31 Draft NUREG-1437, Supplement 32 Wolf Creek - Rose Hill Transmission Line:
1 2 The Wolf Creek - Rose Hill 345-kV line traverses a total of approximately 4,950 ft (18.2 ac) of 3 riparian woods and 480 ft (1.8 ac) of stream channel. Thus, a total of approximately 1 mile of 4 riparian communities and waterways is traversed by the 98-mi line, representing approximately 5 1 percent of the total ROW area. Major rivers and associated watersheds traversed by the Wolf 6 Creek - Rose Hill transmission line include the Neosho River, primarily in Coffey County, the 7 Verdigris and Fall Rivers, primarily in Greenwood County, and the Walnut River, primarily in 8 Butler County. Riparian vegetation communities along these rivers are substantially similar to 9 the community described above for the Neosho River (WCNOC 2007a).
10 11 La Cygne - Benton Transmission Line (rerouted portion):
12 13 The portion of the La Cygne - Benton 345-kV transmission line rerouted around Coffey County 14Lake is approximately 7.7 miles long and mainly on WCGSproperty. The ROW is 150 ft wide 15 and covers nearly 140 ac. There are approximately 12 ac of riparian (bottomland woodland), 16 surface water, shoreline, and wetland habitats included in the ROW, or 8.7 percent of the total 17 ROW area (WCNOC 2007a).
18 195.0 Evaluation of Federally Listed Endangered and Threatened 20 Species 21 225.1 Neosho Madtom (Notorus placidus
)23 24 The Neosho madtom, a small catfish usually less than 3 in. long, is listed as Federally 25 threatened. Its typical habitat is riffles and sloping gravel bars with moderate to swift currents in 26 relatively clear rivers of moderate size (KDWP 2004). It prefers a substrate of fine gravel but 27 has been reported in areas with bottoms that have large stones and cobbles or are sandy. It 28 feeds on aquatic insects and has a lifespan of 3 to 4 years (FWS 1991).
29 30 The Neosho madtom is native to the Neosho River Basin of Kansas, Oklahoma, and Missouri, 31 including its tributaries the Cottonwood and Spring Rivers. The largest populations are believed 32 to be those of the Neosho and Cottonwood Rivers in Kansas. Smaller populations are found in 33 the Spring River in Kansas and in adjacent areas of Oklahoma (Ottawa and Craig Counties) and 34 Missouri (Jasper County). Within this limited range, the Neosho madtom has experienced 35 population declines resulting from factors such as drought-related habitat degradation, removal 36 of gravel bars, and water pollution from feedlot runoff. Habitat loss also has resulted from the 37 construction of mainstream impoundments in Kansas and Oklahoma that inundated Neosho 38 madtom habitat (FWS 1991).
39 Appendix E Draft NUREG-1437, Supplement 32 E-32 September 2007 The Neosho madtom occurs in the Neosho River upstream and downstream of its confluence 1 with Wolf Creek. The populations of the Neosho madtom that potentially are affected by WCGS 2 are those inhabiting the Neosho River from the John Redmond Dam downstream and extending 3 past the Wolf Creek confluence. KDWP has designated portions of the Neosho, Cottonwood, 4 and Spring Rivers as critical habitat for the Neosho madtom, including the main stem of the 5 Neosho River from its point of discharge from the John Redmond Reservoir to the Kansas-6 Oklahoma border (KDWP 2004). There is no Federally designated critical habitat for the 7 Neosho madtom.
8 9 In the 1970s, biologists conducting baseline surveys for WCGS occasionally collected Neosho 10 madtoms in kick-seine samples from the Neosho River upstream and downstream of the Wolf 11 Creek-Neosho River confluence. After WCGS became operational in 1985, Neosho madtoms 12 continued to be collected in Neosho River kick-seine samples. Over the period 1985 to 1991, a 13 total of 110 Neosho madtoms was collected (and released unharmed) from Neosho River 14 monitoring stations. In 1992, flooding hindered seining, and no Neosho madtoms were 15 collected. In 1993, WCGS discontinued its monitoring of fish in the Neosho River and changed 16 its focus to the fish community of Coffey County Lake (WCNOC 2006a).
17 18 Researchers from the FWS and U.S. Geological Survey (USGS; Wildhaber et al. 2000) 19 compared densities of the Neosho madtom and several other catfish species from the family 20 Ictaluridae at locations upstream and downstream of John Redmond Reservoir. The study 21 utilized data from an 8-year period (1991 to 1998) to assess the effects of the dam and reservoir 22 on population trends as well as habitat, hydrology, and water quality. The study found that 23 Neosho madtom densities (fish per 100 square mile [sq mi]) were significantly higher above 24 John Redmond Reservoir than below the dam, and researchers concluded that the lower 25 downstream densities may result from the decreased turbidity and increased substrate size 26 created by the operation of the dam and flood control reservoir (Wildhaber et al. 2000).27 28 In addition to the removal of particulates, Wildhaber et al. (2000) found that the presence of 29 John Redmond Dam and Reservoir changed annual flow regimes below the dam, resulting in 30 lower minimum flows, more frequent low-flow events, lower short-term (1-day and 3-day) 31 maximum flows, reduced variability in flow rates, increased winter flows, increased long-term 32 (30-day and 90-day) maximum flows, increased length and variability in duration of high-flow 33 events, and a later and more variable date of maximum annual flow below the dam. Thus, the 34 Neosho River below John Redmond Reservoir has become characterized by lower minimum 35 flows, lower short-term flows, and higher long-term flows as a result of management of the 36 reservoir to maintain water levels in the reservoir and minimize downstream flooding. The study 37 results suggested that minimum flows and their timing are critical to the reproductive success of 38 the Neosho madtom and may be critical to its overwinter survival. Certain minimum flows and 39 the timing of the spring water rise appeared to be critical to reproduction, and certain minimum 40 flows in late summer and fall appeared to improve overwinter survival of young of year (YOY) 41 madtoms. The FWS and USGS researchers recommended that additional data be collected on 42 Appendix E September 2007 E-33 Draft NUREG-1437, Supplement 32 changes in water quality and habitat downstream of the dam and, in order to test their 1 hypotheses about the effects of the flow regime, they also recommended that populations be 2 monitored for several years while flows below the John Redmond Dam are increased during 3 critical periods (Wildhaber et al. 2000).4 5 Factors associated with WCGS operations that potentially could affect the Neosho madtom in 6 this reach of the river include: (1) reduction in Neosho River flow due to makeup water 7 withdrawals, (2) increase in mortality due to entrainment and/or impingement, and (3) toxic 8 effects from chemical constituents in surface water of Coffey County Lake and the Neosho 9 River. Each of these factors is addressed below.
10 11 (1) The State of Kansas has established MDS levels in the Neosho River that are 12 protective of rare aquatic species. The lowest MDS established for the Neosho River at 13 the Iola river gage station (approximately 55 river mi downstream of the John Redmond 14 Dam) is 40 cfs from July to March. To maintain flows in the Neosho River supportive of 15 fish spawning, the MDS increases to 60 cfs in April and 200 cfs in May and June if the 16 water levels in the reservoir are adequate; otherwise, the MDS in April through June is 17 40 cfs (KWAA 2004). Calculations performed by WCGS indicate that the lowest MDS of 18 40 cfs maintained at Iola is sufficient for the needs of the Neosho madtom (WCNOC 19 2007b). Severe and extended droughts prohibiting the MDS of 40 cfs during the OL 20 renewal period would affect the Neosho madtom as they have historically (FWS 1991).
21 There is a possibility that WCGS may withdraw water from the Neosho River during low-22 flow or drought events, which could adversely affect habitat of the Neosho madtom.
23 24 (2) The MUSH intake in the Neosho River generally is operated only as necessary to 25 provide makeup water to maintain the pool at Coffey County Lake. Therefore, under 26 conditions of normal or higher rainfall, the MUSH would be utilized only sparingly, and 27 entrainment and impingement of organisms from the Neosho River would be minimized.
28 A 1981 study of larval fish drift in the Neosho River included sample locations upstream 29 of John Redmond Reservoir, in the tailwaters of John Redmond Dam, and at Burlington.
30 The only Noturus species collected and identified were two individuals at the upstream 31 location, and these were not believed to be the Neosho madtom (Wedd 1985). No data 32 are available regarding the species of fish eggs and larvae that have been entrained by 33 the intake since 1982. However, available lines of evidence indicate that entrainment of 34 the Neosho madtom is very unlikely.
35 36 The impingement of healthy juvenile and adult fish at the MUSH is expected to be 37 minimal because the operational intake velocity of up to approximately 0.5 fps is low in 38 comparison to the stream flows in habitats where the Neosho madtom and other native 39 fish occur (WCNOC 2006c). In the MUSH vicinity, Neosho River flows typically range 40 from 0.8 to 4.9 fps (Wedd 1985). Thus, impingement of adult fish is expected to occur 41 rarely and then only when the fish are in a weakened condition or dead and unable to 42 Appendix E Draft NUREG-1437, Supplement 32 E-34 September 2007 avoid even the low current velocity near the MUSH intake (WCNOC 2006c). In addition, 1 the Neosho madtom was not among the species impinged in a 1-year impingement 2 study at the MUSH conducted between November 1980 and October 1981 (KG&E 3 1981). These lines of evidence indicate that the potential for Neosho madtom larvae, 4 juveniles, or adults to be present at the intake and subject to entrainment or 5 impingement is very low.
6 7 (3) Contaminant concentrations in the aquatic environment at WCGS are monitored on 8 an ongoing basis by WCNOC and Kansas Department of Health and Environment 9 (KDHE). These studies have not found toxic effects levels of any of the constituents 10 evaluated in Coffey County Lake. Given that discharges from Coffey County Lake to 11 Wolf Creek are limited and infrequent, the potential for chemicals that have entered 12 surface water from WCGS operations to reach the Neosho River and result in 13 concentrations that would be toxic to fish, mussels, or other aquatic organisms is 14 negligible.
15 16 However, to address possible concerns related to this issue and its potential to affect the 17 Neosho madtom, the concentrations of relevant metals were examined by the applicant.
18 The average concentrations of chromium, copper, iron, mercury, and nickel in Coffey 19 County Lake in 2005 and 2006 were compared to the concentrations of these metals in 20 the Neosho River at Leroy, approximately 10 miles downstream of the Coffey County 21 Lake dam (WCNOC 2007b). Only copper, iron, and nickel were detected, and the 22 concentrations of each of these metals was higher in the Neosho River at Leroy than in 23 Coffey County Lake. The concentrations of these three metals in both the river and 24 Coffey County Lake were well below their respective National Recommended Water 25 Quality Criteria for the protection of freshwater aquatic life under continuous (chronic) 26 exposure conditions (EPA 2006).
27 28 Because the future actions needed to minimize water use conflicts in the Neosho River have not 29 yet been proposed, continued operation of the MUSH has the potential to adversely affect the 30 Neosho madtom during low-flow and/or drought conditions in the Neosho River. However, 31 during normal flow conditions, continued operation of WCGS is not expected to adversely affect 32 the Neosho madtom.
33 345.2 Mead's Milkweed (Asclepias meadii
)35 36 Mead's milkweed was Federally listed as threatened in 1988. Mead's milkweed is a perennial 37 herb of the tallgrass prairie. It produces a single cluster of greenish-white flowers at the top of a 38 2-ft stalk in May and early June. Mead's milkweed has low reproductive rates but is a long-lived 39 plant that may persist indefinitely unless destroyed by humans, animals, or pathogens. Studies 40 based on growth of seedlings suggest that Mead's milkweed may require 15 years or more to 41 mature from a germinating seed to a flowering adult. The habitat of Mead's milkweed principally 42 Appendix E September 2007 E-35 Draft NUREG-1437, Supplement 32 is mesic to dry mesic, upland, tallgrass prairie. It generally is found in full sun and on slopes of 1 less than 20 percent (FWS 2003).
2 3 Its populations have declined due to the fragmentation and destruction of tall-grass prairie as a 4 result of intense agricultural use, urban growth, development, recreational use of sites, and hay 5 mowing that disrupts the reproductive cycle. Mead's milkweed continues to be threatened by 6 these factors as well as effects of habitat fragmentation that include the loss of genetic diversity, 7 lack of pollinators, and increased insect predation (FWS 2003).
8 9 Mead's milkweed formerly was widespread over much of the eastern tallgrass prairie region of 10 the central United States. It has been extirpated from Wisconsin and Indiana and currently is 11 known to occur at approximately 170 sites within 34 counties in eastern Kansas, Missouri, 12 south-central Iowa, and southern Illinois. Kansas populations are in the eastern counties from 13 north of the Kansas River south to Neosho County in the southeastern corner of the State.
14 Almost all of the Mead's milkweed population sites in Kansas are on privately owned land that is 15 being used as prairie hay meadows. Mowing of these prairies typically occurs in late June to 16 early July and results in the removal of immature fruits, thus preventing the plants from 17 completing their life cycle (FWS 2003). The FWS Mountain-Prairie Region records this species 18 as occurring in Coffey County (FWS 2007c). Surveys to determine the presence of Mead's 19 milkweed on WCGS property or within the transmission line ROWs have not been performed.
20 The presence of tallgrass prairie communities on these properties within Coffey County 21 indicates that habitat with the potential to support Mead's milkweed may be present, although 22 the plant is not currently known to occur in these areas.
23 24 Because there is no planned expansion of existing facilities, change in ROW maintenance 25 procedures, or disturbance of additional land anticipated during the renewal period, continued 26 operation of WCGS is not likely to adversely affect Mead's milkweed.
27 28 6.0 Conclusions 29 30 The Staff has identified two Federally listed threatened species, the Neosho madtom and 31 Mead's milkweed, that are under FWS jurisdiction and have a potential to occur in the vicinity of 32 WCGS or along the associated transmission line ROWs. These species may be affected by 33 continuing operations of WCGS. WCNOC and Westar Energy Inc. (Westar), the owner of the 34 transmission lines, have ongoing ecological studies and monitoring systems in place to evaluate 35 the impacts of these facilities on aquatic and terrestrial organisms. Water use agreements with 36 the State and the use of best management practices for facility operation and maintenance of 37 transmission line corridors are expected to protect endangered, threatened, and candidate 38 species that are present in the affected environment.
39 40 The NRC staff has evaluated the species that may be present in the vicinity of WCGS, the 41 known distributions and available habitat for those species, the potential effects of the operation 42 Appendix E Draft NUREG-1437, Supplement 32 E-36 September 2007 of WCGS on the species, and the studies and mitigation measures that WCNOC and Westar 1 employ to protect the species. Based on this analysis, the Staff has determined that continued 2 operation of WCGS for an additional 20 years is not likely to adversely affect Mead's milkweed.
3 Likewise, during periods with no water use conflicts, the proposed action is not likely to 4 adversely affect the Neosho madtom. However, when water use conflicts exist during low-flow 5 or drought conditions in the Neosho River, continued operation of WCGS may adversely affect 6 the Neosho madtom.
7 8 7.0 References 9 EA Engineering, Science, and Technology, Inc. (EA). 1988.
Wolf Creek Generating Station 10Operational Phase Environmental Monitoring Program, Final Report.
Prepared for Wolf Creek 11 Nuclear Operating Corporation. Great Plains Regional Office.
12 13 Engineering-Environmental Management, Inc. 2002.Draft Supplement to the Final 14Environmental Impact Statement prepared for the Reallocation of Water Supply Storage Project:
15John Redmond Lake, Kansas. Volume I. USACE, Tulsa District. June.
16 17 Environmental Protection Agency (EPA). 2006. "National Recommended Water Quality 18 Criteria." Office of Water.
19 20 Fish & Wildlife Service (FWS). 1991.Neosho Madtom Recovery Plan. FWS Region 6, Denver, 21 CO.22 23 Fish and Wildlife Service (FWS). 2003.Mead's Milkweed (Asclepias meadii)
Recovery Plan
.24 Great Lakes-Big Rivers Region, Fort Snelling, Minnesota.
25 26 Fish and Wildlife Service (FWS). 2007a. Letter from Michael J. LeValley, Field Supervisor, 27 Kansas Ecological Services Field Office, FWS, Manhattan, KS, to Chief, Rules and Directives 28 Branch, NRC, Washington, DC. Response to December 7, 2006 letter from NRC requesting 29 information on Federally listed, proposed, and candidate species and critical habitat that may be 30 in the vicinity of WCGS and its transmission line ROW. January 29, 2007.
31 32 Fish and Wildlife Service (FWS). 2007b. "Final Rule: Endangered and Threatened Wildlife and 33 Plants; Removing the Bald Eagle in the Lower 48 States from the List of Endangered and 34 Threatened Wildlife."
Federal Register , Volume 72, pgs. 37345 - 37372. Washington, DC.
35 36 Fish and Wildlife Service (FWS). 2007c. Mountain-Prairie Region, Endangered Species 37 Program. Accessed at: http://www.fws.gov/mountain%2Dprairie/endspp/ on Feb - June 2007.
38 Appendix E September 2007 E-37 Draft NUREG-1437, Supplement 32 Hammond, R. 2006. Microfouling, Asiatic Clam and Zebra Mussel Control Program for Wolf 1 Creek Generating Station. Wolf Creek Nuclear Operating Corporation, Burlington, Kansas.
2 WCEM-05-012.
3 4 Jirak, Leonard. 2005. Progress and Management Report; John Redmond Reservoir. Kansas 5 Department of Wildlife and Parks.
6 7 Juracek, Kyle E. and Perry, Charles A. 2005. Gravel Sources for the Neosho River in Kansas, 8 2004. USGS Scientific Investigations Report 2005-5282. Accessed at:
9 http://pubs.usgs.gov/sir/2005/5282/ on May 21, 2007.
10 11 Kansas Department of Wildlife and Parks (KDWP). 2004. Species Information: Neosho 12 madtom (Noturus placidus). Accessed at:
13 http://www.kdwp.state.ks.us/news/other_services/threatened_and_endangered_species/threate 14 ned_and_endangered_species/species_information on Jan - June 2007.
15 16 Kansas Department of Wildlife and Parks (KDWP). 2007. "Coffey County Lake". Accessed at:
17 http://kdwp.state.ks.us/news/fishing/where_to_fish_in_kansas/fishing_locations_publicwaters/re 18 gion_5/coffey_county_lake on May 22, 2007.
19 20 Kansas Gas and Electric Company (KG&E). 1981.
Wolf Creek Generating Station, Makeup 21Screenhouse Impingement Monitoring Report, November 1980 - October 1981
.22 23 Kansas Gas and Electric Company (KG&E). 1984.
Wolf Creek Generating Station 24Preoperational Fishery Monitoring Report, March 1983-November 1983
.25 26 Kansas Gas and Electric Company (KG&E). 1986.
Wolf Creek Generating Station 1984-1985 27 Preoperational Wildlife Monitoring Report, May 1984-April 1985
.28 29 Kansas Water Appropriation Act (KWAA). 2004. Statutes K.S.A. 82A-701 through 82A-737, 30 and K.S.A.42-313, 42-314 as Amended 2004. Accessed at:
31 http://www.accesskansas.org/kda/dwr/laws-rules/kwaa.pdf on March 1, 2007.
32 33 Kansas Water Office (KWO). 2007.John Redmond Lake Reservoir Fact Sheet.
Accessed at:
34 http://www.kwo.org/reservoirinformation/reservoirfactsheets/john_redmond_lake.pdf on June 12, 35 2007).36 37 Nuclear Regulatory Commission (NRC). 1975.Final Environmental Statement Related to 38 Construction of Wolf Creek Generating Station, Unit 1 , NUREG-175/096, Docket Number STN 39 50- 482. Office of Nuclear Reactor Regulation, Washington, DC.
40 Appendix E Draft NUREG-1437, Supplement 32 E-38 September 2007 Nuclear Regulatory Commission (NRC). 1982.Final Environmental Statement Related to the 1 Operation of Wolf Creek Generating Station Unit No. 1. NUREG-0878. Office of Nuclear 2 Reactor Regulation, Washington, DC.
3 4 Nuclear Regulatory Commission (NRC). 1996.Generic Environmental Impact Statement for 5 License Renewal of Nuclear Plants , NUREG-1437, Volumes 1 and 2, Washington, D.C.
6 7 Nuclear Regulatory Commission (NRC). 2006. Letter to Mike LeValley, Project Leader, U.S.
8 Fish and Wildlife Service, Manhattan, KS: Request for list of protected species within the area 9 under evaluation for the Wolf Creek Generating Station License Renewal Application review.
10 December 7.
11 12 Osterkamp, W. R., and Hedman, E. R. 1981. "Channel geometry of regulated streams in 13 Kansas as related to mean discharge, 1970-1980: Kansas Water Office Technical Report 14 Number 15".
15 16 Putnam, J. E., and D. R. Schneider. 2005.
Water Resources Data - Kansas, Water Year 2004
.17 Water-Data Report KS-04-1. U.S. Geological Survey, Lawrence, Kansas.
18 19 Studley, Seth E. 1996. Changes in High-Flow Frequency and Channel Geometry of the 20 Neosho River Downstream from John Redmond Dam, Southeastern Kansas. USGS Water-21 Resources Investigations Report 96-4243. Accessed at:
22 http://ks.water.usgs.gov/Kansas/pubs/reports/wrir.96-4243.html on May 28, 2007.
23 24 U.S. Army Corp of Engineers (USACE). 2002.Draft Supplement to the Final Environmental 25Impact Statement Prepared for the: Reallocation of Water Supply Storage Project: John 26Redmond Lake, Kansas
.27 28 U.S. Army Corp of Engineers (USACE). 2005.Initial Appraisal of the Neosho River Logjam, 29John Redmond Reservoir, Kansas
.30 31 U.S. Army Corp of Engineers (USACE). 2007. "Tulsa District, Recreation - John Redmond 32 Reservoir." Accessed at:
33 http://www.swt.usace.army.mil/recreat/ViewHistoryMessage.cfm?tblMessages__LakeName=Jo 34 hn%20Redmond%20Reservoir on May 22, 2007.
35 36 U.S. Geological Survey (USGS). 2007. "Kansas Minimum Desirable Streamflows (MDS), in 37 cubic feet per second (ft3/s).". Accessed at:
38 http://ks.water.usgs.gov/Kansas/waterwatch/drought/mds.alpha.html on June 8, 2007.
39 40 Wedd, G. R. 1985. "Observations on Neosho River Larval Fish in Coffey County, Kansas."
41The Emporia State Research Studies, Volume XXXIV, Number 1. pp. 5-56.
42 Appendix E September 2007 E-39 Draft NUREG-1437, Supplement 32 Wildhaber, M. L., V. M. Tabor, J. E. Whitaker, A. L. Allert, D. W. Mulhern, P. J. Lamberson, and 1 K. L. Powell. 2000. "Ictalurid Populations in Relation to the Presence of a Main-Stem Reservoir 2 in a Midwestern Warmwater Stream with Emphasis on the Threatened Neosho Madtom."
3Transactions of the American Fisheries Society , 129, pp. 1264-1280.
4 5 Wolf Creek Nuclear Operating Corporation (WCNOC). 2005.
Wolf Creek Generating Station, 6Annual Environmental Operating Report 2004. Environmental Management Organization, 7 Burlington, Kansas. April.
8 9 Wolf Creek Nuclear Operating Corporation (WCNOC). 2006a.Applicant's Environmental 10 Report; Operating License Renewal Stage. Appendix E of License Renewal Application, Wolf 11 Creek Generating Station Unit 1, Docket No. 50-482, Facility Operating License Number NPF-12 42, (Revision 0).
13 14 Wolf Creek Nuclear Operating Corporation (WCNOC). 2006b. License Renewal Application, 15 Wolf Creek Generating Station , Docket No. 50-482, Facility Operating License Number NPF-42.
16 Burlington, Kansas.
17 18 Wolf Creek Nuclear Operating Corporation (WCNOC). 2006c. Enclosure 3 to WM 06-0046 An 19 Assessment of the Potential Impacts on Fish and Shellfish Resources from Impingement 20 Related to the Operating License Renewal for Wolf Creek Generating Station, Unit No. 1.
21 Contained in: Letter from Matthew W. Sunseri, Wolf Creek Nuclear Operating Corporation to 22 U.S. Nuclear Regulatory Commission regarding Docket 50-482: Supplementary Environmental 23 Information to Support the Application for Renewed Operating License for Wolf Creek 24 Generating Station. WM 06-0046. November 17, 2006.
25 26 Wolf Creek Nuclear Operating Corporation (WCNOC). 2006e.Land Management at Wolf 27Creek Generating Station: 2005 Progress Report and 2006 Land Management Plan. March 28 2006.29 30 Wolf Creek Nuclear Operating Corporation (WCNOC). 2007. "Docket 50-482: Response to 31 NRC Request for Additional Information Related to Wolf Creek Generating Station License 32 Renewal Application." Item Number 31. Cooling Water Intake Structures, Comprehensive 33 Demonstration Study, May 9, 2007.
34 35 Wolf Creek Nuclear Operating Corporation (WCNOC). 2007a. Docket 50-482: Wolf Creek 36 Nuclear Operating Corporation's Response to Request for Additional Information Regarding the 37 Review of the License Renewal Application for Wolf Creek Generating Station. ET 07-0001.
38 January 11.
39 Appendix E Draft NUREG-1437, Supplement 32 E-40 September 2007 Wolf Creek Nuclear Operating Corporation (WCNOC). 2007b. Docket 50-482: Wolf Creek 1 Nuclear Operating Corporation's Response to Request for Additional Information Regarding the 2 Review of the License Renewal Application for Wolf Creek Generating Station. Item Number 3 13. ET 07-0001. May 9.
4 Appendix F GEIS Environmental Issues Not Applicable to Wolf Creek Generating Station
September 2007 F-1 Draft NUREG-1437, Supplement 32 Appendix F 1 2 GEIS Environmental Issues Not Applicable 3 to Wolf Creek Generating Station 4 5 6 Table F-1 lists those environmental issues listed in the Generic Environmental Impact 7Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996; 1999)(a) and 10 CFR 8 Part 51, Subpart A, Appendix B, Table B-1, that are not applicable to Wolf Creek Generating 9 Station (WCGS) because of plant or site characteristics.
10 11 Table F-1. GEIS Environmental Issues Not Applicable to Wolf Creek Generating Station (WCGS) 12 13 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1Category GEISSectionsComment SURFACE WATER QUALITY ,H YDROLOGY , AND U SE (FOR ALL PLANTS
)Altered salinity gradients 1 4.2.1.2.2 4.4.2 WCGS does not discharge to an estuary or saltwater body.
Temperature effects on sediment
transport capacity14.2.1.2.3 4.4.2.2 WCGS does not discharge to a body of water that transports sediment.
Water-use conflicts (plants with once-through cooling systems) 14.2.1.3WCGS is categorized in the GEIS as having a cooling pond cooling system, and does not have a once-
through cooling system.
AQUATIC E COLOGY (FOR ALL PLANTS
)Thermal plume barrier to migrating fish 1 4.2.2.1.6 4.4.3 WCGS does not discharge to a surface water body that
supports migrating fish. (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all
references to the "GEIS" include the GEIS and its Addendum 1.
Appendix F Draft NUREG-1437, Supplement 32 F-2 September 2007 Table F-1. (contd) 1 2 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1Category GEISSectionsComment AQUATIC E COLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS
)Entrainment of fish and shellfish in early life stages14.3.3This issue is related to heat-dissipation systems that are
not installed at WCGS.Impingement of fish and shellfish14.3.3This issue is related to heat-dissipation systems that are
not installed at WCGS.Heat shock14.3.3This issue is related to heat-dissipation systems that are
not installed at WCGS.
GROUNDWATER USE AND QUALITY Groundwater use conflicts (potable and service water, and dewatering; plants that
use > 100 gpm)24.8.1.1 4.8.2.1 WCGS does not use >100 gpm of groundwater for any purpose.Groundwater-use conflicts (Ranney wells)24.8.1.4WCGS does not have or use Ranney wells.
Groundwater quality degradation (Ranney wells)14.8.2.2WCGS does not have or use Ranney wells.
Groundwater quality degradation (saltwater intrusion)14.8.2.1WCGS is not located adjacent to saltwater.
Groundwater quality degradation (cooling ponds in salt marshes)14.8.3WCGS is not located adjacent to salt marshes.
TERRESTRIAL R ESOURCES Cooling tower impacts on crops and ornamental vegetation14.3.4This issue is related to a heat-dissipation system that
is not installed at WCGS.Cooling tower impacts on native plants14.3.5.1This issue is related to a heat-dissipation system that
is not installed at WCGS.
Appendix F September 2007 F-3 Draft NUREG-1437, Supplement 32 Bird collisions with cooling towers14.3.5.2This issue is related to a heat-dissipation system that
is not installed at WCGS.
Appendix F Draft NUREG-1437, Supplement 32 F-4 September 2007 F.1 References 1 2 10 CFR 51. Code of Federal Regulations, Title 10 , Energy, Part 51, "Environmental Protection 3 Regulations for Domestic Licensing and Related Regulatory Functions."
4 5 Nuclear Regulatory Commission (NRC). 1996.Generic Environmental Impact Statement for 6 License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC.
7 8 Nuclear Regulatory Commission (NRC). 1999.Generic Environmental Impact Statement for 9 License Renewal of Nuclear Plants: Main Report
, Section 6.3, Transportation, Table 9.1, 10Summary of findings on NEPA issues for license renewal of nuclear power plants
, Final Report
.11 NUREG-1437, Volume 1, Addendum 1, Washington, DC.
12 Appendix GU.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) for Wolf Creek Generating Station in Support of License Renewal Application Review
September 2007 G-1 Draft NUREG-1437, Supplement 32Appendix G 1 2U.S. Nuclear Regulatory Commission Staff Evaluation of 3 Severe Accident Mitigation Alternatives (SAMAs) for 4 Wolf Creek Generating Station in 5 Support of License Renewal Application Review 6 7 8G.1 Introduction 9 10Wolf Creek Nuclear Operating Corporation (WCNOC) submitted an assessment of severe 11accident mitigation alternatives (SAMAs) for Wolf Creek Generating Station (WCGS) as part of 12the environmental report (ER) (WCNOC 2006). This assessment was based on the most recent 13WCGS probabilistic safety assessment (PSA) available at that time, a plant-specific off-site 14consequence analysis performed using the MELCOR Accident Consequence Code System 2 15(MACCS2) computer code, and insights from the WCGS individual plant examination (IPE) 16(WCNOC 1992), the WCGS IPE update (WCNOC 1996), and the IPE of external events 17(IPEEE) (WCNOC 1995a). In identifying and evaluating potential SAMAs, WCNOC considered 18SAMAs that addressed the major contributors to core damage frequency (CDF) and population 19dose at WCGS, as well as SAMA candidates for other operating plants which have submitted 20license renewal applications. WCNOC identified 19 potential SAMA candidates. This list was 21reduced to 15 unique SAMAs by eliminating SAMAs that were determined to provide no 22measurable benefit or have estimated costs that would exceed the dollar value associated with 23completely eliminating all severe accident risk at WCGS. WCNOC assessed the costs and 24benefits associated with each of the potential SAMAs and concluded in the ER that several of 25the candidate SAMAs evaluated are potentially cost-beneficial.
26 27Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) 28issued a request for additional information (RAI) to WCNOC by letter dated February 7, 2007 29 (NRC 2007). Key questions concerned: major plant and modeling changes incorporated within 30each evolution of the PSA model, the peer review of the internal flooding probabilistic risk 31assessment (PRA), internal flooding analysis results, IPE treatment of Steam Generator Tube 32Ruptures (SGTRs), and further information on several specific candidate SAMAs and low cost 33alternatives. WCNOC submitted additional information by letter dated April 20, 2007 (WCNOC 342007a) and by email on June 1, 2007 (WCNOC 2007b). In response to the RAIs, WCNOC 35 provided: a summary of the major changes made to each PSA model version and resultant 36changes to dominant risk contributors to CDF, a summary of the internal flooding peer review 37process and comments, a clarification of the internal flooding analysis assumptions and results, 38the treatment of SGTR in the IPE and its effect on the SAMA analyses, and additional 39information regarding several specific SAMAs. WCNOC's responses addressed the NRC staff's 40 concerns.41 42An assessment of SAMAs for WCGS is presented below.
43 Appendix G Draft NUREG-1437, Supplement 32G
-2 September 2007G.2 Estimate of Risk for Wolf Creek Generating Station 1 2WCNOC's estimates of off-site risk at the WCGS are summarized in Section G.2.1. The 3summary is followed by the NRC staff's review of WCNOC's risk estimates in Section G.2.2.
4 5G.2.1 WCNOC's Risk Estimates 6
7Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 8analysis: (1) the WCGS Level 1 and 2 PSA model, which is an updated version of the IPE 9(WCNOC 1992), and (2) a supplemental analysis of off-site consequences and economic 10impacts (essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The 11SAMA analysis is based on the most recent WCGS Level 1 and 2 PSA model available at the 12time of the ER, referred to as the WCGS 2002 PSA update. The scope of the WCGS PSA does 13not include external events.
14 15The baseline CDF for the purpose of the SAMA evaluation is approximately 3.0 x 10
-5 per year.
16The CDF is based on the risk assessment for internally-initiated events but does not include 17internal flooding. WCNOC did not include the contribution from external events and internal 18flooding within the WCGS risk estimates; however, it did account for the potential risk reduction 19benefits associated with external events and internal floods by doubling the estimated benefits 20for internal events. This is discussed further in Sections G.2.2 and G.6.2.
21 22The breakdown of CDF by initiating event is provided in Table G-1. As shown in this table, 23events initiated by loss of off-site power and small break loss of coolant accident (LOCA) are the 24dominant contributors to CDF. Although not separately reported, station blackout (SBO) 25sequences contribute 1.7 x 10
-5 per year (about 55 percent of the total internal events CDF), 26while anticipated transient without scram (ATWS) sequences are not present in the dominant 27 sequences.
28 29The current Level 2 WCGS PSA is based on a simplified model intended to estimate the 30frequencies of containment failure models that might lead to large early releases of 31radionuclides. This model, termed a Large Early Release Frequency (LERF) model, quantifies 32four distinct LERF contributors: Interfacing Systems Loss of Coolant Accidents (ISLOCAs), 33SGTRs, Containment Isolation Failures and Early Containment Failures. The frequency for 34each of these contributors was obtained by quantifying the fault tree gate corresponding to the 35contributor in the LERF model. Given that the LERF model does not explicitly provide risk 36information on non-LERF sequences, such as late containment failures and sequences 37involving only leakage or no containment failure, a process was developed to approximate the 38risk contribution from these non-LERF scenarios using information from the IPE.
39 Appendix G September 2007 G-3 Draft NUREG-1437, Supplement 32The IPE model utilizes a Containment Safeguards Event Tree (CSET) and a Containment Event 1Tree (CET) that address systemic and phenomenological events, respectively. The significant 2Level 1 core damage sequences were processed using the CSET to determine the applicable 3endstates and their frequencies. The CSET derived endstates were used as input into the CET 4in order to determine the containment response. The CET has 14 possible endstates which 5provide information about ex-vessel sequence progression, containment status, and source 6term release. These 14 end states were further binned into seven release categories of which 7three represent the non-LERF scenarios. The frequency of each release category was obtained 8by summing the frequency of the individual accident progression CET endpoints binned into the 9release category. In the SAMA analysis, two of the three IPE non-LERF release categories 10were combined, resulting in two non-LERF categories: leakage/no containment failure and late 11 containment failure.
12 13The result of the combined model (LERF contributions from the current Level 2 PSA and non-14LERF contributions from the IPE) is a set of six release categories with their respective 15frequency and release characteristics. The results of this analysis for WCGS are provided in 16Section F.2.8 of the ER (WCNOC 2006). The release frequencies were derived from their 17respective models as described above. The release characteristics for the LERF and non-LERF 18release categories are based on Modular Accident Analysis Program (MAAP) 3.0B analyses.
19 20 Table G-1. WCGS Core Damage Frequency 21 22 Initiating Event CDF(Per Year)
%Contribution to CDFLoss of Off-site Power 1.7 x 10
-5 57 Small LOCA 7.0 x 10
-6 23 Interfacing Systems LOCA 1.9 x 10
-6 6 Very Small LOCA 1.3 x 10
-6 4 Steam Generator Tube Rupture 8.7 x 10
-7 3 Transients With Power Conversion Systems Available 3.9 x 10-7 1 Reactor Vessel Failure 3.0 x 10
-7 1 Steamline Break 2.4 x 10
-7 1 Transients Without Power Conversion Systems Available 1.8 x 10-7 1 Loss of Vital DC Bus NK04 1.5 x 10
-7 1 Medium LOCA 1.4 x 10
-7 <1 Loss of Vital DC Bus NK01 1.2 x 10
-7 <1 Appendix G Draft NUREG-1437, Supplement 32G
-4 September 2007 Table G-1. (contd) 1 2 Initiating Event CDF(Per Year)
%Contribution to CDFLoss of All Service Water 8.6 x 10
-8 <1 Loss of Component Cooling Water 5.8 x 10
-8 <1 Feedwater Line Break 3.3 x 10
-8 <1 Large LOCA 2.8 x 10
-8 <1 Total CDF 3.0 x 10
-5 100 3The off-site consequences and economic impact analyses use the MACCS2 code to determine 4the off-site risk impacts on the surrounding environment and public. Inputs for these analyses 5include plant-specific and site-specific input values for core radionuclide inventory, source term 6and release characteristics, site meteorological data, projected population distribution (within an 780-kilometer [50-mile] radius) for the year 2040, emergency response evacuation modeling, and 8economic data. The magnitude of the on-site impacts (in terms of clean-up and 9decontamination costs and occupational dose) is based on information provided in NUREG/BR-100184 (NRC 1997a).
11 12In the ER, WCNOC estimated the dose to the population within 80 kilometers (50 miles) of the 13WCGS site to be approximately 0.0286 person-sievert (Sv) (2.86 person-rem) per year. The 14breakdown of the total population dose by containment release mode is summarized in Table G-152. Containment failures within the early time frame (less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following accident 16initiation) dominate the population dose risk at WCGS.
17 18 Table G-2. Breakdown of Population Dose by Containment Release Mode 19 20Containment Release Mode Population Dose (Person-Rem 1 Per Year) % Contribution Early Containment Failure 0.14 5 Late Containment Failure 0.04 1 Containment Bypass - SGTR 0.04 1 Containment Bypass - ISLOCA 2.55 89 Appendix G September 2007 G-5 Draft NUREG-1437, Supplement 32 Table G-2. (contd) 1 2Containment Release Mode Population Dose (Person-Rem 1 Per Year) % Contribution Containment Bypass - Isolation Failure Negligible <1 Intact Containment 0.09 3 Total 2.86 100 3 1One person-Rem = 0.01 person-Sv 4 5G.2.2 Review of WCNOC's Risk Estimates 6 7WCNOC's determination of off-site risk at WCGS is based on the following four major elements 8 of analysis:
9 10 The Level 1 and Level 2 risk models that form the bases for the 1992 IPE submittal 11(WCNOC 1992), and the external events analyses of the 1995 IPEEE submittal 12(WCNOC 1995a), 13 14 The major modifications to the IPE model that have been incorporated in the WCGS 15 2002 PSA Update, 16 17 The WCGS fire re-analysis completed in March 1998, and 18 19 The MACCS2 analyses performed to translate fission product source terms and release 20frequencies from the Level 2 PSA model into off-site consequence measures.
21 22Each of these analyses was reviewed to determine the acceptability of WCNOC's risk estimates 23for the SAMA analysis, as summarized below.
24 25The NRC staff's review of the WCGS IPE is described in an NRC report dated November 18, 261996 (NRC 1996). Based on a review of the IPE submittal and responses to RAIs, the NRC 27Staff concluded that the IPE submittal met the intent of Generic Letter (GL) 88-20; that is, the 28licensee's IPE process is capable of identifying the most likely severe accidents and severe 29accident vulnerabilities. The IPE did not identify any severe accident vulnerabilities associated 30 with either core damage or poor containment performance.
31 32Although no vulnerabilities were identified in the IPE, several plant improvements were identified 33and considered for implementation at the plant. These enhancements included: (1) installing 34high temperature qualified reactor coolant pump (RCP) seal O-rings, (2) replacing the positive 35 Appendix G Draft NUREG-1437, Supplement 32G
-6 September 2007displacement charging pump with a third centrifugal charging pump, (3) installing a switch to 1bypass feedwater isolation in order to restore main feedwater, (4) proceduralizing actions to 2perform alternate cooling for several pumps and the emergency diesel generators (EDGs) to 3reduce the dependency on room cooling, (5) modifying emergency procedures to directly 4address total loss of component cooling water and service water initiating events, and (6) 5performing additional evaluations to identify any procedural or hardware modifications to reduce 6the risk due to internal flooding (WCNOC 1992).
7 8The WCGS IPE analysis of internal flooding yielded a CDF of 7.6 x 10
-6 per year. However, 9WCNOC stated that some of the flooding scenarios included in the IPE submittal were identified 10late in the IPE process and due to time constraints, were addressed in a conservative manner 11(WCNOC 1995b). Subsequent to the IPE, a re-analysis of internal flooding was performed to 12more realistically assess flood-related scenarios. Results for the re-analysis indicate that the 13CDF from flooding-related scenarios is reduced by approximately 70 percent (from 7.6 x 10
-6 per 14 year to 2.5 x 10
-6 per year) (WCNOC 2006).
15 16There have been three revisions to the IPE model since the 1992 IPE submittal, specifically, a 171996 revision to the IPE in response to NRC RAIs, a comprehensive PSA model update in 181998, and a comprehensive PSA model update in 2002 in response to the Westinghouse 19Owners Group peer review. A comparison of internal events CDF between the 1996 IPE 20revision and the current PSA model indicates a decrease of approximately 53 percent (from 21 6.31 x 10-5 per year to 2.98 x 10
-5 per year). A comparison of the contributors to the total CDF 22indicates that some have increased while others have decreased. A summary listing of those 23changes that resulted in the greatest impact on the internal events CDF was provided in 24response to a staff request for additional information and is summarized in Table G-3.
25 26 Table G-3. WCGS PSA Historical Summary 27 28 PSA VersionSummary of Changes from Prior ModelCDF(per year)1992IPE Submittal (including internal flooding CDF of 7.6 x 10
-6)4.2 x 10-51996Updated IPE model (including internal flooding CDF of 7.6 x 10
-6)- revised common-cause failure events to use generic common cause factor values - revised Human Reliability Analysis (HRA) values to address RAI comments
- modeling of additional HRA action dependencies 6.3 x 10-5 Appendix G September 2007 G-7 Draft NUREG-1437, Supplement 32 Table G-3. (contd) 1 2 PSA VersionSummary of Changes from Prior ModelCDF(per year)1998Comprehensive PSA model update (without internal flooding) - reduced the Loss of Off-site Power initiating event frequency - reduced the Transient with Main Feedwater initiating event frequency - added Test & Maintenance events which result in unavailability of an entire train of a risk significant support system
- made data analysis changes; in particular, incorporated NRC common-cause factors and updated plant-specific failure data for the major active risk-significant component groups
- re-evaluated Interfacing Systems LOCA using NUREG/CR-5928 and NUREG/CR -5744 5.48 x 10-52002Comprehensive PSA model update (without internal flooding) - reduced the Large and Medium LOCA initiating event frequencies - removed the "failure to close on demand" failure modes for Essential Service Water System (ESWS) valves EFHV0037 and EFHV0038
- added flag events to indicate that initiation of the feed portion of the feed and bleed function will result in automatic start of the ESWS pumps and isolation of the ESWS from the normal plant service water system 2.98 x 10-5 3The CDF value from the 1996 updated IPE submittal (6.31 x 10
-5 per year, including the 4contribution from internal flooding events) is near the average of the CDF values reported in the 5IPEs for pressurized water reactor (PWR) plants with dry containments. Figure 11.2 of NUREG-61560 shows that the IPE-based total internal events for these plants ranges from 9 x 10
-8 to 8 x 7 10-5 per year, with an average CDF for the group of 2 x 10
-5 per year (NRC 1997b). It is 8recognized that other plants have updated the values for CDF subsequent to the IPE submittals 9to reflect modeling and hardware changes. The current internal events CDF result for WCGS 10 (2.98 x 10
-5 per year, not including internal flooding) is comparable to that for other plants of 11similar vintage and characteristics.
12 13The NRC staff considered the peer reviews performed for the WGCS PSA, and the potential 14impact of the review findings on the SAMA evaluation. In the ER, WCNOC described the peer 15review by the Westinghouse Owner's Group (WOG) of the 1998 PSA Model conducted in 16August 2000. The WOG review concluded that all of the PSA technical elements were sufficient 17to support applications involving risk ranking and that the WCGS PSA provides an appropriate 18and sufficiently robust tool to support such activities as initial Maintenance Rule implementation, 19when supported as necessary by deterministic insights and plant expert panel input. The ER 20states that the 2002 PSA Update resolves nearly all peer review comments on the 1998 revision 21of the model. The ER lists all significant Facts and Observations (F&Os) and their applicable 22status in ER Table F.2.2. Twelve of the twenty-seven listed F&Os were not fully resolved. The 23Staff reviewed the F&Os and requested an assessment of the impact of several open items that 24 Appendix G Draft NUREG-1437, Supplement 32G
-8 September 2007could impact the SAMA evaluation (NRC 2007). WCNOC responded with additional discussion 1and clarification of the impact of these items on the SAMA analysis, and concluded that 2resolution of these comments would have minimal or no impact on the SAMA evaluation.
3Based on the information provided by the licensee, the NRC staff concurs with the licensee's 4 conclusion.
5 6The internal flooding analysis was included within the WOG peer review. Recommended areas 7for improvement consisted of including the contribution of internal flooding to LERF and using 8more recent and realistic methods to estimate piping failure probabilities and flooding 9frequencies. In response to an RAI associated with the exclusion of internal flooding from the 10PRA updates, WCNOC stated that the critical flood areas have been addressed (WCNOC 112007a) and that the WCGS's compartmentalization is expected to minimize any new 12hypothetical flooding scenarios that result from an update of the flood analysis (WCNOC 13 2007b).14 15Given that the WCGS internal events PSA model has been peer-reviewed and the peer review 16findings were either addressed or judged to have no adverse impact on the SAMA evaluation, 17and that WCNOC has satisfactorily addressed NRC staff questions regarding the PSA, the NRC 18staff concludes that the internal events Level 1 PSA model is of sufficient quality to support the 19SAMA evaluation.
20 21As indicated above, the current WCGS PSA does not include external events. In the absence 22of such an analysis, WCNOC used the WCGS IPEEE in conjunction with the fire re-analysis to 23identify the highest risk accident sequences and the potential means of reducing the risk posed 24by those sequences, as discussed below.
25 26The WCGS IPEEE was submitted in June 1995 (WCNOC 1995a), in response to Supplement 4 27of Generic Letter 88-20. This submittal included a seismic margins analysis, a fire PRA, and a 28screening analysis for other external events. While no fundamental weaknesses or 29vulnerabilities to severe accident risk in regard to the external events were identified, several 30opportunities for seismic risk reduction were identified as discussed below. In a letter dated 31February 29, 2000, the NRC staff concluded that the submittal met the intent of Supplement 4 to 32Generic Letter 88-20, and that the licensee's IPEEE process is capable of identifying the most 33likely severe accidents and severe accident vulnerabilities (NRC 2000).
34 35The WCGS IPEEE used a focused scope Electric Power Research Institute (EPRI) seismic 36margins analysis. This method is qualitative and does not provide numerical estimates of the 37CDF contributions from seismic initiators (EPRI 1991). For this assessment, a detailed 38walkdown was performed in which components were screened using an overall high confidence 39of low probability of failure (HCLPF) capacity of 0.3g, the review level earthquake (RLE) value 40for the plant, and the screening level that would be used for a focused-scope plant. A judgment 41 Appendix G September 2007 G-9 Draft NUREG-1437, Supplement 32was made that certain other components (including four station battery racks and eight cabinets 1for the engineered safety features actuation system) could not be screened at the RLE level.
2For these components a HCLPF capacity of 0.2g was assigned, which is the safe shutdown 3earthquake (SSE) level. WCNOC also identified four issues during the course of plant 4walkdowns where actual field installation did not conform with the seismic design configuration 5and several housekeeping issues with respect to temporary items stored near safety-related 6components. Corrective actions for these items have been completed (NRC 2000).
7 8The WCGS IPEEE fire analysis employed a combination of a probabilistic risk analysis and 9Electric Power Research Institute's fire-induced vulnerability evaluation (FIVE) methodology.
10The evaluation was performed in four phases: (1) qualitative screening, (2) quantitative 11screening, (3) fire damage evaluation screening, and (4) fire scenario evaluation and 12quantification. Each phase focused on those fire areas that did not screen out in the prior 13phases. The final phase involved using the IPE model for internal events to quantify the CDF 14resulting from a fire-initiating event. The CDF for each area was obtained by multiplying the 15frequency of a fire in a given fire area by the conditional core damage probability associated 16with that fire area including, where appropriate, the impact of fire suppression and fire 17propagation. In most cases, it was assumed that all equipment in the area was damaged by the 18fire. The potential impact on containment performance and isolation was evaluated following 19the core damage evaluation.
20 21The total fire CDF from the IPEEE was estimated to be 7.6 x 10
-6 per year. In the ER, WCNOC 22indicated that the fire CDF was subsequently revised to 5.9 x 10
-6 per year. In response to an 23RAI on the March 1998 fire re-analysis, WCNOC states that this value excludes control room 24fires (WCNOC 2007a). Thus, the total fire CDF, including control room fires, is 8.1 x 10
-6 per 25year. WCNOC also stated that the fire re-analysis used the same methodology as the original 26IPEEE, but quantified the model using the results from the 1996 updated IPE, which contained 27improvements to the human reliability analysis and common cause portions of the model 28(WCNOC 2007a). The dominant fire areas and their contributions to the fire CDF are listed in 29Table G-4. Excluding control room fires, although non-conservative, does not change any 30conclusion associated with the cost effectiveness of the evaluated SAMAs. The ER uses the 31assumption that the external event contributions are equal to the internal event contributions.
32With the addition of control room fires, the total external contribution remains comparable.
33Excluding control room fires, the external events and internal flooding contribution is 2.8 x 10
-5 34 per year compared to 2.98 x 10
-5 per year for internal events. Including control room fires, this 35 comparison becomes 3.1 x 10
-5 per year compared to 2.98 x 10
-5 per year.
36 Appendix G Draft NUREG-1437, Supplement 32G
-10 September 2007 Table G-4. Fire Areas and Their Contribution to Fire CDF 1 2CDF (per year) Fire Area Area Description IPEEE Fire Re-Analysis A-8D Auxiliary Building - El. 2000 3.43 x 10
-7 2.96 x 10
-7A-16 Auxiliary Building - El. 2026 2.19 x 10
-7 1.60 x 10
-7A-17 Electrical Penetration Room (south) 1.83 x 10
-7 1.97 x 10
-7A-18 Electrical Penetration Room (north) 5.36 x 10
-7 5.88 x 10
-7A-21 Control Room AC and Filtration Units Room1501 N/A 3.21 x 10
-7A-22 Control Room AC and Filtration Units Room1512 N/A 8.76 x 10
-7A-27 Reactor Trip Switchgear Room 1.98 x 10
-7 2.12 x 10
-7C-9 ESF Switchgear Room (north) 2.55 x 10
-6 1.76 x 10
-6C-10 ESF Switchgear Room (south) 2.12 x 10
-6 1.52 x 10
-6C-27 Control Room 1.43 x 10
-6 2.22 x 10-6Total Fire CDF 7.59 x 10
-6 8.14 x 10
-6 3In the ER, WCNOC states that the use of the fire analysis results as a reflection of CDF may be 4inappropriate and that while the fire analysis is generally self-consistent within its calculational 5framework, the fire analysis does not compare well with internal events PSAs because of the 6number of conservative assumptions that have been included in the fire analysis process.
7Several specific examples of conservatisms in the fire analysis are provided in the ER and 8include: conservative fire modeling to initially screen rooms and scenarios, generic cabinet fire 9analyses assuming non-IEEE-383 cables in the cabinets, no credit for manual suppression for 10any fire, no credit for Halon systems protecting cables that were directly above the fire, no credit 11for thermo-lag fire barrier wrap, and the failure of the entire cabinet is assumed for an electrical 12cabinet fire. The ER also provides a list of fire analysis topics (involving technical inputs, data 13and modeling) that prevent the effective comparison of the CDF between the internal events 14 PSA and the fire analysis. In response to an RAI requesting the applicability of the general 15topics to the WCGS fire analysis (NRC 2007), WCNOC provided WCGS-specific examples 16(WCNOC 2007a). Although arguments regarding the conservatisms in the fire analysis are 17presented in the ER, WCNOC used the baseline fire CDF of 5.92 x 10
-6 per year, with control 18room fires excluded, in the SAMA analysis rather than some reduced value.
19 Appendix G September 2007 G-11 Draft NUREG-1437, Supplement 32The IPEEE analysis of high winds, floods, and other external events followed the screening and 1evaluation approaches specified in Supplement 4 of FL 88-20 (NRC 1991) and did not identify 2any significant sequences or vulnerabilities (WCNOC 1995a). Based on this result, WCNOC 3concluded that these other external hazards would not be expected to impact the conclusions of 4the SAMA analysis and did not consider specific SAMAs for these events. However, for 5purposes of estimating the benefits of other SAMAs in these events, WCNOC assumed that the 6CDF from each other external initiator is comparable to the fire CDF (i.e., a CDF of 5.0 x 10
-6 7per year each for high wind events, external floods, and transportation and nearby facility 8accidents). It is noted that the risks from deliberate aircraft impacts were explicitly excluded 9since this was being considered in other forums along with other sources of sabotage.
10 11Based on the aforementioned results, WCNOC estimated that the external events CDF is 12approximately equal to the internal events CDF (based on a fire CDF of 5.92 x 10
-6 per year, a 13combined CDF from seismic, high wind, external flood, and transportation/nearby facility 14accidents of 2.0 x 10
-5 per year, and an internal flooding CDF of 2.53 x 10
-6 per year, compared 15to an internal events CDF of 2.98 x 10
-5 per year). Accordingly, the total CDF from internal and 16external events would be approximately 2 times the internal events CDF. In the SAMA analysis 17submitted in the ER, WCNOC doubled the benefit that was derived from the internal events 18model to account for the combined contribution from internal and external events. This doubling 19was not applied to the two SAMAs that specifically address fire risk. Doubling the benefit for 20these SAMAs is not appropriate since these SAMAs are specific to external event risks and 21would not have a corresponding benefit on the risk from internal events. The NRC staff agrees 22with the licensee's overall conclusion concerning the impact of external events and concludes 23that the licensee's use of a multiplier of 2 to account for external events is reasonable for the 24purposes of the SAMA evaluation.
25 26The NRC staff reviewed the general process used by WCNOC to translate the results of the 27Level 1 PSA into containment releases, as well as the results of the Level 2 analysis, as 28described in the ER and in response to NRC staff requests for additional information (WCNOC 29 2007a). The current Level 2 WCGS PSA is based on a simplified model intended to estimate 30the frequencies of containment failure modes that might lead to large early releases of 31radionuclides. This model, the LERF model, quantifies four distinct LERF contributors:
32ISLOCAs, SGTRs, Containment Isolation Failures and Early Containment Failures. As the 33current WCGS Level 2 analysis is only a LERF model, WCNOC developed a process to 34approximate the contributions from late containment failures and leakage/no containment failure 35scenarios to address the non-LERF cases. To accomplish this, WCNOC used the conditional 36probabilities of the various non-LERF release categories from the IPE model to obtain the 37 release category frequencies for the current PSA. In response to an RAI requesting justification 38for this assumption, WCNOC provided the results of a sensitivity analysis in which all of the non-39LERF contributors were assigned to the late containment failure release category (WCNOC 402007a). This sensitivity analysis produced an increase in the off-site economic cost risk of 41about 3 percent. As a result of this increase, three SAMAs that were not cost-beneficial in the 42 Appendix G Draft NUREG-1437, Supplement 32G
-12 September 2007baseline analysis would become marginally cost-beneficial (SAMAs 1, 3, and 13). However, 1these SAMAs were already identified as potentially cost-beneficial in the ER based on 2consideration of analysis uncertainties.
3 4WCNOC characterized the releases for the spectrum of possible radionuclide release scenarios 5using a set of 6 release categories, defined based on the timing and magnitude of the release 6and whether the containment remains intact or is bypassed. Each Level 2 endstate was 7assigned to one of the 6 release categories. The Staff noted that sequences assigned to 8Release Category A (no containment failure within mission time) were grouped with Release 9Category S (no containment failure), and requested an assessment of the impact on the SAMA 10analysis if the sequences were alternatively assigned to Release Category K (late containment 11failure) (NRC 2007). In response to the Staff's request, WCNOC demonstrated that changing 12the assigned categories would result in an increase in the off-site economic cost risk of about 1 13percent (WCNOC 2007a). This impact is bounded by the sensitivity analysis discussed above, 14and does not change the results of the SAMA analysis. The source term release fractions for 15the CET endstates were estimated based on the results of plant-specific analyses of the 16dominant scenarios using the MAAP computer program. The release categories and their 17frequencies and release characteristics are presented in Table F.3-2 of the ER.
18 19During the NRC staff review of the IPE, staff noted that the WCGS had excluded the possibility 20of natural circulation-induced creep rupture of hot legs and steam generator tubes in high 21pressure accident sequences. In response to a RAI requesting a description of the current 22treatment of induced SGTRs, WCNOC asserted that only 2 percent of the high pressure melt 23scenarios with dry steam generators would result in an induced SGTR while the remaining 24fraction of the scenarios would result in hot leg creep ruptures. They further stated that the 25applicability of this percentage is predicated on the conditions that the secondary side is not 26depressurized and that the RCPs are not operated, and demonstrated that the small increase in 27the Modified Maximum Averted Cost-Risk (MMACR) would not result in any additional cost-28beneficial SAMAs (WCNOC 2007a). The Staff asked a follow-up question on how the increased 29likelihood of induced SGTR for sequences with RCP Seal LOCAs are accounted for in the risk 30assessment. In its response, WCNOC indicated that making this adjustment to the total SGTR 31probability would result in a significant increase in the SGTR specific contribution, but 32demonstrated that there would be no impact on the overall SAMA conclusions (WCNOC 332007b). Based on the information provided by the licensee, the NRC staff finds the treatment of 34induced SGTR events to be reasonable for the purposes of the SAMA analysis.
35 36The NRC staff's review of the Level 2 IPE concluded that it addressed the most important 37severe accident phenomena normally associated with large, dry containments, and identified no 38significant problems or errors (NRC 1996). Based on the NRC staff's review of the Level 2 39methodology, the fact that the Level 2 model was reviewed in more detail as part of the WOG 40peer review, and the responses to the RAIs, the NRC staff concludes that the Level 2 PSA, as 41 Appendix G September 2007 G-13 Draft NUREG-1437, Supplement 32supplemented with additional modeling for non-LERF releases, provides an acceptable basis for 1evaluating the benefits associated with various SAMAs.
2 3As indicated in the ER, the reactor core radionuclide inventory used in the consequence 4analysis was derived from the plant's safety analysis based on Westinghouse Letter SAP 5145 (WEST 1999). In response to an RAI, WCNOC confirmed that the current core design 6practice is consistent with this letter and there are no plans to change the operating strategy 7(WCNOC 2007c). All releases were modeled as occurring at ground level. WCNOC assessed 8the impact of alternatively assuming an elevated release. The results of this sensitivity study 9showed that the elevated release produces about a 3 percent reduction in off-site economic cost 10 risk.11 12The NRC staff reviewed the process used by WCNOC to extend the containment performance 13(Level 2) portion of the PSA to an assessment of off-site consequences (essentially a Level 3 14PSA). This included consideration of the source terms used to characterize fission product 15releases for the applicable containment release categories and the major input assumptions 16used in the off-site consequence analyses. The MACCS2 code was utilized to estimate off-site 17consequences. Plant-specific input to the code includes the source terms for each release 18category and the reactor core radionuclide inventory (both discussed above), site-specific 19meteorological data, projected population distribution within an 80-kilometer (50-mile) radius for 20the year 2040, emergency evacuation modeling, and economic data. This information is 21 provided in Attachment F of the ER.
22 23WCNOC used site-specific meteorological data for the 2001 calendar year as input to the 24MACCS2 code. The data were collected from the on-site meteorological tower. Data from 2000 25through 2004 were also considered, but the 2001 data were chosen because they were the 26most complete and because results of a MACCS2 sensitivity case comparing the use of 2001 27data to 2004 data indicated that the 2001 data produced slightly more conservative results (i.e., 28about a 9 percent increase in off-site economic cost risk). Missing data were obtained by 29interpolation from 2004 data. Suspect data were taken from a backup meteorological system 30located three miles from the WCGS site. The NRC staff notes that previous SAMA analyses 31results have shown little sensitivity to year-to-year differences in meteorological data and 32concludes that the use of the 2001 meteorological data in the SAMA analysis is reasonable.
33 34The population distribution the licensee used as input to the MACCS2 analysis was estimated 35for the year 2040, based on the U.S. Census Bureau (USCB) population data for 2000, as 36provided by the sector population, land fraction and economic estimation program (SECPOP) 372000 program (NRC 2003), and the expected annual population growth rate (UCSB 2000a).
38The 2000 population was adjusted to account for transient population. The 1990 and 2000 39county-level census data were used to estimate the annual population growth rate (USCB 402000b). If a negative growth rate was calculated, then a growth rate of zero percent per year 41was used. It was assumed that the growth rate would remain the same as the average rate 42 Appendix G Draft NUREG-1437, Supplement 32G
-14 September 2007reported between 1990 and 2000. Using sector-specific population growth rates, projections 1were made by extrapolating the 2000 sector population data to year 2040. A population 2sensitivity case was performed by using a 30 percent uniform increase in population for all 3sectors. The 30 percent population case showed about a 14 percent change in population dose 4and a 29 percent change in off-site economic cost risk. The NRC staff considers the methods 5and assumptions for estimating population reasonable and acceptable for purposes of the 6SAMA evaluation.
7 8The emergency evacuation model was modeled as a single evacuation zone extending out 16 9kilometers (10 miles) from the plant. It was assumed that 95 percent of the population would 10move at an average speed of approximately 1.6 meters per second with a delayed start time of 1130 minutes (WCNOC 2006). This assumption is conservative relative to the NUREG-1150 12study (NRC 1990), which assumed evacuation of 99.5 percent of the population within the 13emergency planning zone. A sensitivity analysis was performed in which the evacuation speed 14was decreased by 50 percent. The result was a 0.3 percent increase in the total population 15dose, which is insignificant. The NRC staff concludes that the evacuation assumptions and 16analysis are reasonable and acceptable for the purposes of the SAMA evaluation.
17 18Much of the site-specific economic data was provided from SECPOP2000 (NRC 2003) by 19specifying the data for each of the counties surrounding the plant to a distance of 50 miles.
20SECPOP2000 utilizes economic data from the 1997 Census of Agriculture (USDA 1998). In 21addition, generic economic data that applied to the region as a whole were revised from the 22MACCS2 sample problem input when better information was available. Some of this data was 23adjusted using the consumer price index of 1.75. These revised parameters included the value 24of farm and non-farm wealth.
25 26The NRC staff concludes that the methodology used by WCNOC to estimate the off-site 27consequences for WCGS provides an acceptable basis from which to proceed with an 28assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based 29its assessment of off-site risk on the CDF and off-site doses reported by WCNOC.
30 31G.3 Potential Plant Improvements 32 33The process for identifying potential plant improvements, an evaluation of that process, and the 34improvements evaluated in detail by WCNOC are discussed in this section.
35 36G.3.1 Process for Identifying Potential Plant Improvements 37 38WCNOC's process for identifying potential plant improvements (SAMAs) consisted of the 39following elements:
40 Appendix G September 2007 G-15 Draft NUREG-1437, Supplement 32 Review of the most significant basic events from the current plant-specific PSA, 1 2 Review of potential plant improvements identified in the WCGS IPE and IPEEE, 3 4 Review of dominant fire areas from the Fire Re-Analysis and SAMAs that could 5potentially reduce the associated fire risk, 6 7 Review of Phase II SAMAs from license renewal applications for six other U.S. nuclear 8 sites, and 9 10 Review of other industry documentation discussing potential plant improvements.
11 12Based on this process, an initial set of 19 potential SAMA candidates, referred to as Phase I 13SAMAs, was identified. In Phase I of the evaluation, WCNOC performed a qualitative screening 14of the initial list of SAMAs and eliminated SAMAs from further consideration using the following 15 criteria: 16 17 The SAMA was determined to provide no measurable benefit, or 18 19 The SAMA has estimated costs that would exceed the dollar value associated with 20completely eliminating all severe accident risk at WCGS.
21 22Based on this screening, 4 SAMAs were eliminated leaving 15 unique SAMAs for further 23evaluation (13 SAMA candidates with two containing two options). The remaining SAMAs, 24referred to as Phase II SAMAs, are listed in Table F.5-4 of the ER (WCNOC 2006). In Phase II, 25a detailed evaluation was performed for each of the 15 remaining SAMA candidates, as 26discussed in Sections G.4 and G.6 below. To account for the potential impact of external 27events, the estimated benefits based on internal events were multiplied by a factor of 2 (except 28for those SAMAs specific to fire events, since those SAMAs would not have a corresponding 29benefit on the risk from internal events).
30 31G.3.2 Review of WCNOC's Process 32 33WCNOC's efforts to identify potential SAMAs focused primarily on areas associated with 34internal initiating events, but also included explicit consideration of potential SAMAs for fire 35events. The initial list of SAMAs generally addressed the accident sequences considered to be 36important to CDF from functional, initiating event, and risk reduction worth perspectives at 37WCGS, and included selected SAMAs from prior SAMA analyses for other plants.
38 39WCNOC provided a tabular listing of the PSA basic events sorted according to their risk 40reduction worth (RRW) (WCNOC 2006). SAMAs impacting these basic events would have the 41 Appendix G Draft NUREG-1437, Supplement 32G
-16 September 2007greatest potential for reducing risk. WCNOC used a RRW cutoff of 1.02, which corresponds to 1about a two-percent change in CDF given 100-percent reliability of the SAMA. This equates to 2a benefit of approximately $36,000 (after the benefits have been multiplied to account for 3external events). WCNOC also provided and reviewed the LERF-based RRW events down to 4 an RRW of 1.02. WCNOC correlated the basic events with highest risk importance in the Level 51 and 2 PSA with the SAMAs evaluated in Phase I or Phase II, and showed that, with a few 6exceptions, all of the significant basic events are addressed by one or more SAMAs (WCNOC 72006). Of the basic events of high risk importance that are not addressed by SAMAs, each is 8closely tied to other basic events that had been addressed by one or more SAMAs.
9 10For a number of the Phase II SAMAs listed in the ER, the information provided did not 11sufficiently describe the proposed modification. Therefore, the NRC staff asked the applicant to 12provide more detailed descriptions of the modifications for several of the Phase II SAMA 13candidates (NRC 2007). In response to the RAI, WCNOC provided the requested information 14(WCNOC 2007a).
15 16The NRC staff questioned WCNOC about lower cost alternatives to some of the SAMAs 17evaluated (NRC 2007), including:
18 19 Maintaining actions to improve the ability to align the Sharpe Station diesel generators 20to the WCGS emergency buses during an SBO, as an alternative to SAMA 2, 21 22 Installing a manual fuel oil transfer pump, as an alternative to SAMA 13, 23 24 Alternatives for reducing failure of the Sharpe Station, 25 26 Using a portable generator to extend the coping time in loss of alternating current (AC) 27power events (to power selected instrumentation and direct current (DC) power to the 28turbine-driven [TD] auxiliary feedwater pump[AFW])
29 30 Providing alternate DC feeds (using a portable generator) to panels supplied only by DC 31 bus, and 32 33 Adding an alternate AC source to the site as an alternative to Sharpe Station.
34 35In response to an RAI, WCNOC addressed the suggested lower cost alternatives (WCNOC 362007a). This is discussed further in Section G.6.2.
37 38Although the IPE did not identify any vulnerabilities, six potential enhancements to the plant, 39procedures, and training at WCGS were identified as part of the IPE process. WCNOC noted 40that two of these enhancements had been implemented. A third enhancement, to replace the 41 Appendix G September 2007 G-17 Draft NUREG-1437, Supplement 32positive displacement charging pump with a centrifugal pump has been implemented but does 1not include a backup AC supply. WCNOC has included a backup power source for the normal 2charging pump in the list of SAMA candidates (WCNOC 2006). The fourth enhancement, 3proceduralizing actions to perform alternate room cooling methods, has not been implemented, 4but has been included in the list of SAMA candidates. WCNOC indicated that the remaining two 5IPE-identified enhancements were not pursued further as they were screened out during the 6Phase I SAMA analysis. One enhancement, addition of a switch to bypass feedwater isolation 7for restoring main feedwater, was indicated in the IPE Safety Evaluation Report (SER) to have 8an impact on CDF of about 19 percent (NRC 1996), but in the ER was indicated to have an 9RRW of only 1.001. In response to a staff RAI, the licensee identified the significant reduction in 10the frequency of transients with power conversion systems available (from 4.3 to 1.05 events 11per year) and improvements in modeling of such transients as the major model changes that 12reduced the importance of this enhancement (WCNOC 2007a). The remaining IPE-identified 13enhancement involved performing an additional evaluation to identify any procedural or 14hardware modifications to reduce the risk due to internal flooding. Section F.5.1.7 of the ER 15presents a bounding estimate for internal flooding SAMAs and concludes that based on the total 16risk associated with all internal flooding events and the high costs associated with installing 17systems that could mitigate all flood scenarios or combinations of scenarios, no further 18investigation of internal flooding-based SAMAs would be warranted.
19 20Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, 21together with those identified in response to NRC staff RAIs, addresses the major contributors 22to internal event CDF.
23 24WCNOC did not identify WCGS-specific candidate SAMAs for seismic events. In the WCGS 25IPEEE, all HCLPF values were greater than the 0.3g review level earthquake except for four 26station battery racks and eight electrical cabinets, which had a HCLPF value of 0.20g. In the 27ER, WCNOC indicated that subsequent efforts by the plant resulted in the modification of the 28station battery racks to meet the 0.30g peak ground acceleration HCLPF criteria. WCNOC 29states that seismic-specific SAMAs were not included and that no further review is required 30because that HCLPF value is acceptable for reduced scope plants, such as WCGS. NRC staff 31requested that WCNOC evaluate modifications that would raise the HCLPF values for the 32electrical cabinets to 0.3g (NRC 2007). In response to the RAI, WCNOC showed that the 33maximum averted risk of this improvement did not justify its cost, even when the benefits and 34costs of the enhancement are conservatively assessed (WCNOC 2007a). Based on the 35information provided by the licensee, the NRC staff finds WCNOC's consideration of further 36seismic improvements to be reasonable for the purposes of the SAMA analysis.
37 38Based on the licensee's efforts to identify and address seismic outliers and the expected cost 39associated with further seismic risk analysis and potential plant modifications, the NRC staff 40concludes that the opportunity for seismic-related SAMAs has been adequately explored and 41that it is unlikely that there are any cost-beneficial, seismic-related SAMA candidates.
42 Appendix G Draft NUREG-1437, Supplement 32G
-18 September 2007While the IPEEE did not identify opportunities for improvements with respect to fire events, the 1licensee did consider potential SAMAs for fire, and identified SAMA 15, which includes two 2different alternatives, i.e., Case 1 - rerouting cables in the fire areas with the largest 3contributions to CDF, and Case 2 - placing protective barriers around these cables. The NRC 4staff concludes that the opportunity for fire-related SAMAs has been adequately explored and 5that it is unlikely that there are additional potentially cost-beneficial, fire-related SAMA 6candidates.
7 8The NRC staff notes that the set of SAMAs submitted is not all inclusive, since additional, 9 possibly even less expensive, design alternatives can always be postulated. However, the NRC 10staff concludes that the benefits of any additional modifications are unlikely to exceed the 11benefits of the modifications evaluated and that the alternative improvements would not likely 12cost less than the least expensive alternatives evaluated, when the subsidiary costs associated 13with maintenance, procedures, and training are considered.
14 15The NRC staff concludes that WCNOC used a systematic and comprehensive process for 16identifying potential plant improvements for WCGS, and that the set of potential plant 17improvements identified by WCNOC is reasonably comprehensive and therefore acceptable.
18This search included reviewing insights from the plant-specific risk studies and reviewing plant 19improvements considered in previous SAMA analyses. While explicit treatment of external 20events in the SAMA identification process was limited, it is recognized that the prior 21implementation of plant modifications for seismic and fire events and the absence of external 22event vulnerabilities reasonably justifies examining primarily the internal events risk results for 23this purpose.
24 25G.4 Risk Reduction Potential of Plant Improvements 26 27WCNOC evaluated the risk-reduction potential of the 15 remaining SAMAs that were applicable 28to WCGS. The SAMA evaluations were performed using realistic assumptions with some 29conservatism. On balance, such calculations overestimate the benefit and are conservative.
30 31For most of the SAMAs, WCNOC used model re-quantification to determine the potential 32benefits. The CDF and population dose reductions were estimated using the 2002 version of 33the WCGS PSA model. The changes made to the model to quantify the impact of the SAMAs 34are detailed in Section F.6 of Attachment F to the ER. Table G-5 lists the assumptions 35considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk 36reduction in terms of percent reduction in CDF and population dose, and the estimated total 37benefit (present value) of the averted risk. The estimated benefits reported in Table G-5 reflect 38the combined benefit in both internal and external events. The determination of the benefits for 39the various SAMAs is further discussed in Section G.6.
40 Table G-5.
SAMA Cost/Benefit Screening Analysis for WCGS (a)1 2 % Risk Reduction SAMA Assumptions CDFPopulationDose Total Benefit Using 7% Discount Rate ($)Total Benefit Using 3% Discount Rate (b)
($) Cost ($) 1 - Install a permanent, dedicated generator for the normal charging pump (NCP) with local operation of a TD AFW pump after 125V DC depletion. Reduce the total CDF frequency of SBO sequences SBOS02 through SBOS32 by a factor of ten. 49 5 650,000 810,000 800,000 2 - Modify the controls and operating procedures for Sharpe Station to allow for rapid response. Modify the SBO flag event to reduce the failure probability of the Sharpe Station to deliver power to the WCGS switchyard from a value of 1.0 to 0.294. 40 5 530,000 660,000 400,000 3 - Provide AC cross-tie capability Modify cutset frequencies to mimic the availability of the cross-tie. The cross-tie was assumed to have a failure probability of 5.0E-02. A cutset review/manipulation process was used for each Level II release category. 18 2 240,000 300,000 330,000 4 - ISLOCA isolation. Include isolation credit for the Low Pressure Safety Injection (LPSI) Cold Leg Injection line ISLOCA scenarios Case 1: Install new valves that are capable of isolating against RCS pressure. Set failure probabilities of the new valves to values developed as part of
the previous WCGS PSA ISLOCA analysis. 5 69 180,000 260,000 600,000 Appendix G September 2007 G-19 Draft NUREG-1437, Supplement 32 Table G-5. (contd) 1 2 % Risk Reduction SAMA Assumptions CDFPopulationDose Total Benefit Using 7% Discount Rate ($)Total Benefit Using 3% Discount Rate (b)
($) Cost ($) 4 - ISLOCA isolation Case 2: Proceduralize operator actions to perform local isolations of any valves that fail to close remotely. Set the local isolation failure probability to 3 times the remote isolation failure probability to account for stress and environmental challenges (approximately 0.4). 4 50 130,000 190,000 50,000 5 - Open doors for alternate EDG room cooling. Reduce the failure probability of the basic event representing outside temperature in the EDG rooms could exceed 79 degrees (OTH-OAT-OVER-78F) by a factor of ten. 3 0 44,000 57,000 50,000 6 - Improve reliability of manual recirculation switchover given refueling water storage tank (RWST) level instrumentation failure. Reduce the failure probability of common cause failure of 2 of 4 RWST level instrumentation channels (CABN-RWSTLLO-SA) by a factor of ten. NOT ESTIMATED 7 - Improve reliability of manual recirculation switchover given auto initiation failure. Reduce the failure probability of common cause failure of the Channel 1 and IV LOCA Sequencer (ESNFLOCASEQ12SF1) by a factor of ten. NOT ESTIMATED 8 - Install a hard piped connection to the fire protection system (FPS) to provide high
volume makeup to the RWST. Reduce the failure probability of common cause failure of the RHR pumps to start (MPEJ-01AB-12-BS1) by a factor of 100. 3 0 35,000 45,000 570,000 Draft NUREG-1437, Supplement 32 G-20 September 2007 Appendix G Table G-5. (contd)1 2 % Risk Reduction SAMA Assumptions CDFPopulationDose Total Benefit Using 7% Discount Rate ($)Total Benefit Using 3% Discount Rate (b)
($) Cost ($) 13 - Install an alternative fuel oil tank with gravity feed capability. Reduce the failure probability of the largest contributing fuel oil transfer events (MPEJ-01AB-12-BS1) by a factor of 100. 7 1 90,000 110,000 150,000 14 - Install a permanent, dedicated generator for the NCP, one motor driven AFW pump and a battery charger. Reduce all of the SBO sequences failure probabilities by a factor of 20. 54 5 720,000 890,000 1,200,000 15 - Prevention of propagation of the initial cabinet fire. Eliminate fire CDF contribution from propagation of the initial fire cabinet. 16 (c) 16(c) 320,000 410,000 Case 1: Reroute the safe shutdown equipment (SSE) cables so that they do not pass over other cabinets. 3,300,000 Case 2: Provide fire barriers capable of preventing fire propagation and damage to the overhead cables. 1,000,000 16 - Install inter-train CCW cross-tie lines for emergency operation. Reduce the failure probability by a factor of ten for all event sequences that would realize a risk benefit from a cross-tie between the two trains of CCW.1 <1 18,000 23,000 570,000 17 - Install a cross-tie between 125V DC divisions. Reduce all of the battery failure basic events failure probabilities by a factor
of 100. 4 0 53,000 67,000 550,000 3(a) SAMAs in bold are potentially cost-beneficial 4(b) Estimated benefits reflect revised values provided after correction of two SECPOP2000 economic data file errors (WCNOC 2007d and 2007e) 5(c) Estimated benefits are derived from information provided in the ER (WCNOC 2006) are stated as a percentage reduction ofrisk from external events, 6where risk from fire is assumed to be 85 percent of the total risk from external events.
7 8 Appendix G September 2007 G-21 Draft NUREG-1437, Supplem ent 32 Appendix G September 2007 G-22 Draft NUREG-1437, Supplement 32 The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction 1estimates of certain SAMAs provided in the ER (NRC 2007). For example, the NRC staff 2requested the bases for the assumption in SAMA 16 of a 0.1 failure probability for the operator 3action to diagnose and cross-tie the component cooling system (CCW) system. The licensee 4described the scenario involving the operator actions and justified the failure probability based 5on the complexity of the scenario. The licensee also provided a qualitative argument that the 6cost-risk assessment is not particularly sensitive to changes in SAMA failure probabilities in 7ranges below 0.1, as this value will provide 90 percent of the SAMA benefit. The NRC staff 8considers the assumptions, as clarified, to be reasonable and acceptable for purposes of the 9SAMA evaluation.
10 11For those SAMAs that specifically address fire events (i.e., SAMA 15, Cases 1 and 2), the 12reduction in CDF and population dose was not directly calculated. For these SAMAs, a 13bounding estimate of the impact of the SAMA was made based on general assumptions 14regarding the approximate contribution to total risk from external events (relative to that from 15internal events), the fraction of the external event risk attributable to fire events, and the fraction 16of the fire risk affected by the SAMA and associated with each fire compartment (based on 17information from the IPEEE.) For example, it is assumed that the contribution to risk from 18external events is approximately equal to that from internal events, and that internal fires 19contribute 85 percent of the external events risk. The fire re-analysis was then used to identify 20the fraction of the fire risk that could be eliminated by potential enhancements in various fire 21areas. A similar process was applied to the proposed fire enhancements for each fire area 22considered. (It was assumed that the SAMA was implemented in all 3 dominant fire areas.)
23 24The NRC staff has reviewed WCNOC's bases for calculating the risk reduction for the various 25plant improvements and concludes that the rationale and assumptions for estimating risk 26reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher 27than what would actually be realized). Accordingly, the NRC staff based its estimates of averted 28risk for the various SAMAs on WCNOC's risk reduction estimates.
29 30G.5 Cost Impacts of Candidate Plant Improvements 31 32WCNOC estimated the costs of implementing the 15 candidate SAMAs through the application 33of engineering judgment and use of other licensees' estimates for similar improvements. The 34cost estimates conservatively did not include the cost of replacement power during extended 35outages required to implement the modifications, nor did they include contingency costs 36associated with unforeseen implementation obstacles. The cost estimates provided in the ER 37also did not account for inflation, which is considered another conservatism.
38 39The NRC staff reviewed the bases for the licensee's cost estimates (presented in Section F.6 of 40Attachment F to the ER). For certain improvements, the NRC staff also compared the cost 41estimates to estimates developed elsewhere for similar improvements, including estimates 42 Appendix G Draft NUREG-1437, Supplement 32 G-23 September 2007developed as part of other licensees' analyses of SAMAs for operating reactors and advanced 1light-water reactors. The NRC staff reviewed the costs and found them to be reasonable, and 2generally consistent with estimates provided in support of other plants' analyses.
3 4The NRC staff concludes that the cost estimates provided by WCNOC are sufficient and 5appropriate for use in the SAMA evaluation.
6 7G.6 Cost-Benefit Comparison 8 9WCNOC's cost-benefit analysis and the NRC staff's review are described in the following 10 sections.
11 12G.6.1 WCNOC's Evaluation 13 14The methodology used by WCNOC was based primarily on NRC's guidance for performing 15cost-benefit analysis, i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation 16 Handbook (NRC 1997a). The guidance involves determining the net value for each SAMA 17according to the following formula:
18 19Net Value = (APE + AOC + AOE + AOSC) - COE, 20 where 21 22APE = present value of averted public exposure ($)
23AOC = present value of averted off-site property damage costs ($)
24AOE = present value of averted occupational exposure costs ($)
25AOSC = present value of averted on-site costs ($)
26COE = cost of enhancement ($).
27 28If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 29benefit associated with the SAMA and it is not considered cost-beneficial. WCNOC's derivation 30of each of the associated costs is summarized below.
31 32NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates.
33Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed: one at 3 34percent and one at 7 percent (NRC 2004). WCNOC provided both sets of estimates 35(WCNOC 2006).
36 37Averted Public Exposure (APE) Costs 38 39 The APE costs were calculated using the following formula:
40 Appendix G September 2007 G-24 Draft NUREG-1437, Supplement 32 APE = Annual reduction in public exposure (person-rem/year) 1x monetary equivalent of unit dose ($2000 per person-rem) 2x present value conversion factor (15.04 based on a 20-year period with a 3 3-percent discount rate).
4 5As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of 6the public health risk after discounting does not represent the expected reduction in public 7health risk due to a single accident. Rather, it is the present value of a stream of potential 8losses extending over the remaining lifetime (in this case, the renewal period) of the facility.
9Thus, it reflects the expected annual loss due to a single accident, the possibility that such an 10accident could occur at any time over the renewal period, and the effect of discounting these 11potential future losses to present value. For the purposes of initial screening, which assumes 12elimination of all severe accidents due to internal events, WCNOC calculated an APE of 13approximately $86,000 for the 20-year license renewal period.
14 15Averted Off-site Property Damage Costs (AOC) 16 17The AOCs were calculated using the following formula:
18 19AOC = Annual CDF reduction 20x off-site economic costs associated with a severe accident (on a per-event 21 basis)22x present value conversion factor.
23 24For the purposes of initial screening which assumes all severe accidents due to internal events 25are eliminated, WCNOC calculated an annual off-site economic risk of about $2,000 based on 26the Level 3 risk analysis. This results in a discounted value of approximately $29,700 for the 27 20-year license renewal period.
28 29Averted Occupational Exposure (AOE) Costs 30 31The AOE costs were calculated using the following formula:
32 33AOE = Annual CDF reduction 34 x occupational exposure per core damage event 35 x monetary equivalent of unit dose 36 x present value conversion factor.
37 38WCNOC derived the values for averted occupational exposure from information provided in 39Section 5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate values provided 40for immediate occupational dose (3300 person-rem) and long-term occupational dose (20,000 41person-rem over a 10-year cleanup period) were used. The present value of these doses was 42 Appendix G Draft NUREG-1437, Supplement 32 G-25 September 2007calculated using the equations provided in the handbook in conjunction with a monetary 1equivalent of unit dose of $2000 per person-rem, a real discount rate of 3 percent, and a time 2period of 20 years to represent the license renewal period. For the purposes of initial screening, 3which assumes all severe accidents due to internal events are eliminated, WCNOC calculated 4an AOE of approximately $18,500 for the 20-year license renewal period.
5 6Averted On-site Costs (AOSCs) 7 8The AOSCs include averted cleanup and decontamination costs and averted power 9replacement costs. Repair and refurbishment costs are considered for recoverable accidents 10only and not for severe accidents. WCNOC derived the values for AOSC based on information 11provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook (NRC 1997a).
12 13WCNOC divided this cost element into two parts - the on-site cleanup and decontamination 14cost, also commonly referred to as averted cleanup and decontamination costs, and the 15replacement power cost.
16 17Averted cleanup and decontamination costs (ACC) were calculated using the following formula:
18 19ACC = Annual CDF reduction 20 x present value of cleanup costs per core damage event 21 x present value conversion factor.
22 23The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 24NUREG/BR-0184 to be $1.3 x 10 9 (discounted over a 10-year cleanup period). This value is 25integrated over the term of the proposed license extension. For the purposes of initial 26screening, which assumes all severe accidents due to internal events are eliminated, WCNOC 27calculated an ACC of approximately $581,000 for the 20-year license renewal period.
28 29Long-term replacement power costs (RPC) were calculated using the following formula:
30 31 RPC = Annual CDF reduction 32 x present value of replacement power for a single event 33x factor to account for remaining service years for which replacement power is 34 required 35 x reactor power scaling factor 36 37WCNOC based its calculations on the value of 1165 megawatt electric (MWe), which is the 38current electrical output for WCGS. Therefore, WCNOC applied a power scaling factor of 391165/910 to determine the replacement power costs. For the purposes of initial screening, 40which assumes all severe accidents due to internal events are eliminated, WCNOC calculated 41an RPC of approximately $211,000 for the 20-year license renewal period. For the purposes of 42 Appendix G September 2007 G-26 Draft NUREG-1437, Supplement 32 initial screening, which assumes all severe accidents are eliminated, WCNOC calculated the 1AOSC to be approximately $792,000 for the 20-year license renewal period.
2 3Using the above equations, WCNOC estimated the total present dollar value equivalent 4associated with completely eliminating severe accidents due to internal events at WCGS to be 5about $926,000. Use of a multiplier of two to account for external events increases the value to 6$1.85M and represents the dollar value associated with completely eliminating all internal and 7external event severe accident risk at WCGS, also referred to as the Modified Maximum 8Averted Cost Risk (MMACR).
9 10 WCNOC's Results 11 12If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 13was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a 143 percent discount rate), WCNOC identified three potentially cost-beneficial SAMAs. The 15 potentially cost-beneficial SAMAs are:
16 17 SAMA 2 - Modify controls and operating procedures to permit the diesel generators at 18the Sharpe Station to be more rapidly aligned to the WCGS emergency buses in SBO 19 events.20 21 SAMA 4, Case 2 - Proceduralize operator actions to perform local isolations of any 22valves that fail to close remotely in an interfacing system LOCA.
23 24 SAMA 5 - Modify procedures to open emergency diesel generator room doors to provide 25alternate room cooling given failure of the heating ventilation and air-conditioning 26(HVAC) supply fan.
27 28WCNOC performed additional analyses to evaluate the impact of parameter choices and 29uncertainties on the results of the SAMA assessment (WCNOC 2006). If the benefits are 30increased by a factor of 1.9 to account for uncertainties, four additional SAMA candidates were 31determined to be potentially cost-beneficial (SAMAs 1, 3, 13, and 14).
32 33 SAMA 1 - Install a permanent, dedicated generator for the NCP in order to provide RCP 34seal cooling in SBO events.
35 36 SAMA 3 - Provide the capability to cross-tie between 4-kilovolts (kV) AC buses in the 37event of a loss of power to one bus.
38 Appendix G Draft NUREG-1437, Supplement 32 G-27 September 2007 SAMA 13 - Install an alternative fuel oil tank with gravity feed capability to address fuel 1oil transfer failure events.
2 3 SAMA 14 - Install a permanent, dedicated generator for the NCP (similar to SAMA 1), 4and a motor-driven AFW pump and battery charger to address SBO events in which the 5 TD AFW pump is unavailable.
6 7Subsequent to the ER, WCNOC identified an inconsistency in the format in which several 8economic parameters were output from the SECPOP2000 code and input to the MACCS2 code 9(WCNOC 2007d), and a second error that resulted in use of agricultural/economic data for the 10wrong counties in the SECPOP2000 calculations (WCNOC 2007e). WCNOC provided revised 11benefit estimates reflecting the results of correcting both errors (WCNOC 2007e). The re-12analysis produced an insignificant change to the MMACR (i.e., less than a 3 percent increase, 13from $1.85M to $1.90M), and an increase in the estimated benefits for the various SAMAs 14ranging from 1 percent to 9 percent. The corrections resulted in no change to the Phase I 15screening results, but resulted in one additional SAMA (SAMA 1) becoming potentially cost-16beneficial in the baseline analysis. However, this SAMA was already identified as potentially 17cost-beneficial in the ER based on consideration of analysis uncertainties. Thus, the overall 18results of the SAMA assessment were not affected.
19 20The potentially cost-beneficial SAMAs and WCNOC's plans for further evaluation of these 21SAMAs are discussed in more detail in Section G.6.2.
22 23G.6.2 Review of WCNOC's Cost-Benefit Evaluation 24 25The cost-benefit analysis performed by WCNOC was based primarily on NUREG/BR-0184 26(NRC 1997a) and was implemented consistent with this guidance.
27 28To account for external events, WCNOC multiplied the internal event benefits by a factor of 2 for 29each SAMA, except those SAMAs that specifically address external events (i.e., SAMA 15, 30Cases 1 and 2). Doubling the benefit for these SAMAs is not appropriate since these SAMAs 31are specific to external events and would not have a corresponding benefit in risk from internal 32events. Given that the CDF from internal flooding, internal fires, and other external events as 33 reported by WCNOC is less than the CDF for internal events, the NRC staff agrees that the 34factor of 2 multiplier for external events is reasonable.
35 36WCNOC considered the impact that possible increases in benefits from analysis uncertainties 37would have on the results of the SAMA assessment. In the ER, WCNOC presents the results of 38an uncertainty analysis of the internal events CDF which indicates that the 95th percentile value 39is a factor of 1.9 times the mean CDF. WCNOC reexamined the initial set of SAMAs to 40determine if any additional Phase I SAMAs would be retained for further analysis if the benefits 41MMACR were increased by a factor of 1.9. One such Phase I SAMA was identified, i.e., SAMA 42 Appendix G September 2007 G-28 Draft NUREG-1437, Supplement 32 12 - install SG isolation valves on the primary loop side. However, based on further 1consideration of the limited benefit of eliminating the events addressed by this SAMA, WCNOC 2concluded that this SAMA would not be cost-beneficial even if it were completely reliable. The 3specific rationale is provided in Section F.7.2.1 of the ER.
4 5WCNOC also considered the impact on the Phase II screening if the estimated benefits were 6increased by a factor of 1.9 (in addition to the factor of 2 multiplier). Four additional SAMAs 7became cost-beneficial in WCNOC's analysis (SAMAs 1, 3, 13, and 14 as described above.)
8Although not cost-beneficial in the baseline analysis, WCNOC included these four SAMAs within 9the set of potentially cost-beneficial SAMAs that they intend to examine further for 10implementation.
11 12WCNOC did not develop a cost-risk analysis for two Phase II SAMAs:
13 14 SAMA 6 - Manual recirculation with RWST level instrumentation failure 15 16 SAMA 7 - Manual recirculation with auto-initiation failure 17 18In the ER, WCNOC noted that the event importance measure values addressed by these 19SAMAs were calculated without credit for manually aligning safety injection to the recirculation 20 mode. To address this issue, WCNOC used conservative human reliability estimates to show 21that the importance values were inflated, and that the incorporation of actions to manually 22initiate recirculation reduces the importance of the common cause failure of RWST level 23instrumentation channels and the failure of auto initiation logic to below the review threshold.
24Therefore, the benefits and costs of these SAMAs were not evaluated. In response to an RAI, 25WCNOC stated that manual initiation of recirculation mode is fully proceduralized and guidance 26is available to direct manual initiation even if two of the four RWST level indicators fail (WCNOC 27 2007a). The NRC staff found this approach to be reasonable.
28 29The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives 30that could achieve much of the risk reduction at a lower cost. The NRC staff asked the licensee 31to evaluate several lower cost alternatives to the SAMAs considered in the ER, including an 32alternative to SAMA 2, which was already determined to be potentially cost-beneficial in the 33baseline analysis. The alternative, referred to as SAMA 2a, would involve continuously 34maintaining actions to improve the ability to align the diesel generators at the nearby Sharpe 35Station to the WCGS emergency buses during an SBO. These actions, which include training 36for operators, Sharpe Station battery bi-weekly surveillance testing, and additional dedicated 37operation staff, are currently only credited during an extended EDG maintenance period. In 38response to an RAI requesting an evaluation of this option, the licensee indicated that this 39alternative is also cost-beneficial, contingent on the ability to maintain the option to enter the 40extended EDG completion time (WCNOC 2007a). This option was approved in License 41Amendment 163 (NRC 2006).
42 Appendix G Draft NUREG-1437, Supplement 32 G-29 September 2007The NRC staff also asked the licensee to evaluate several lower cost alternative SAMAs that 1had been found to be potentially cost-beneficial at other PWR plants. These alternatives were:
2(1) using a portable generator to extend the coping time in loss of AC power events (to power 3selected instrumentation and DC power to the turbine-driven auxiliary feedwater pump), (2) 4providing alternate DC feeds (using a portable generator) to panels supplied only by a DC bus, 5and (3) adding an alternate AC source to the site as an alternative to Sharpe Station (NRC 62007). WCNOC provided a further evaluation of these alternatives, as summarized below.
7 8 Using a portable generator during a loss of AC power to power selected instrumentation 9and DC power - The impact of this SAMA on risk would be small because WCGS has 10reasonable means of coping with SBO events until seal LOCA induced core damage 11occurs, i.e., using existing procedures for operating the turbine-driven AFW pump after 12battery depletion. Therefore, there is a greater benefit by addressing primary side 13makeup, as provided through SAMAs 1, 2, and 14.
14 15 Providing alternate DC feeds to panels supplied only by the DC bus - The benefit of this 16alternative is similar to the one above, but does not require the battery chargers. The 17risk reduction worth of the battery chargers is 1.000, below the SAMA review threshold.
18Therefore, this alternative would not be cost-beneficial.
19 20 Including an alternate AC source as an alternative to Sharpe Station - The cost of a full-21size EDG or equivalent has been shown to be several million dollars. The benefits of 22this alternative are accomplished with SAMAs 1, 2, and 14 for a fraction of the cost.
23 24The NRC staff notes that the seven potentially cost-beneficial SAMAs 1, 2, 3, 4-2, 5, 13, and 14 25identified in either WCNOC's baseline analysis, or uncertainty analysis, are included within the 26 set of SAMAs that WCNOC will consider for implementation.
27 28The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs 29discussed above, the costs of the SAMAs evaluated would be higher than the associated 30 benefits.31 32G.7 Conclusions 33 34WCNOC compiled a list of 19 SAMAs based on a review of the most significant basic events 35from the current plant-specific PSA, insights from the plant-specific IPE and IPEEE, dominant 36fire areas from the Fire Risk Re-Analysis, Phase II SAMAs from license renewal applications for 37other plants, and review of other industry documentation. An initial screening removed SAMA 38candidates that (1) were determined to provide no measurable benefit, or (2) had estimated 39costs that would exceed the dollar value associated with completely eliminating all severe 40 Appendix G September 2007 G-30 Draft NUREG-1437, Supplement 32 accident risk at WCGS. Based on this screening, 4 SAMAs were eliminated leaving 15 1candidate SAMAs for evaluation.
2 3For the remaining SAMA candidates, a more detailed design and cost estimate was developed 4as shown in Table G-5. The cost-benefit analyses in the ER showed that three SAMA 5candidates were potentially cost-beneficial in the baseline analysis (Phase II SAMAs 2, 4-2, and 65). WCNOC performed additional analyses to evaluate the impact of parameter choices and 7uncertainties on the results of the SAMA assessment. As a result, four additional SAMAs 8(Phase II SAMAs 1, 3, 13 and 14) were identified as potentially cost-beneficial.(a) WCNOC has 9indicated that all seven potentially cost-beneficial SAMAs (1, 2, 3, 4-2, 5, 13, and 14) will be 10considered for implementation at WCGS.
11 12The NRC staff reviewed the WCNOC analysis and concludes that the methods used and the 13implementation of those methods were sound. The treatment of SAMA benefits and costs 14support the general conclusion that the SAMA evaluations performed by WCNOC are 15reasonable and sufficient for the license renewal submittal. Although the treatment of SAMAs 16for external events was somewhat limited, the likelihood of there being cost-beneficial 17enhancements in this area was minimized by improvements that have been realized as a result 18of the IPEEE process, and inclusion of a multiplier to account for external events.
19 20The NRC staff concurs with WCNOC's identification of areas in which risk can be further 21reduced in a cost-beneficial manner through the implementation of the identified, potentially 22cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff 23agrees that further evaluation of these SAMAs by WCNOC is warranted. However, these 24SAMAs do not relate to adequately managing the effects of aging during the period of extended 25operation. Therefore, they need not be implemented as part of license renewal pursuant to Title 26 10 of the Code of Federal Regulations, Part 54.
27 28G.8 References 29 3010 CFR Part 54. Code of Federal Regulations, Title 10, Energy,Part 54, "Requirements for 31Renewal of Operating Licenses for Nuclear Power Plants."
32 33Electric Power Research Institute (EPRI). 1991. A Methodology for Assessment of Nuclear 34Power Plant Seismic Margins, Revision 1. EPRI Report NP-6041-SL.
35 (a) Based on subsequent corrections involving the SECPOP2000 code, SAMA 1 was also identified as potentially cost-beneficial in the baseline analysis.
Appendix G Draft NUREG-1437, Supplement 32 G-31 September 2007 Nuclear Regulatory Commission (NRC). 1990.Severe Accident Risks: An Assessment for 1 Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C.
2 3Nuclear Regulatory Commission (NRC). 1991. "Individual Plant Examination of External 4Events (IPEEE) for Severe Accident Vulnerabilities," Supplement 4 to Generic Letter 88-20, 5June 28, 1991 6 7Nuclear Regulatory Commission (NRC). 1996. Letter from James C. Stone, U.S. NRC, to Neil 8S. Carns, WCNOC.
Subject:
Staff Evaluation Report for the Review of the Wolf Creek 9Generating Station Individual Plant Examination (TAC No. M74490), November 18, 1996.
10 11 Nuclear Regulatory Commission (NRC). 1997a.Regulatory Analysis Technical Evaluation 12 Handbook. NUREG/BR-0184, Washington, D.C.
13 14 Nuclear Regulatory Commission (NRC). 1997b.Individual Plant Examination Program:
15Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, D.C.
16 17 Nuclear Regulatory Commission (NRC). 2000. Letter from Jack Donohew, U.S. NRC to Otto L.
18Maynard, WCNOC.
Subject:
Review of Individual Plant Examination of External Events 19(IPEEE) for Wolf Creek Generating Station (TAC No. M83696), February 29, 2000.
20 21 Nuclear Regulatory Commission (NRC). 2003.SECPOP 2000: Sector Population, Land 22Fraction, and Economic Estimation Program. NUREG/CR-6525 Revision 1, Washington, D.C., 23 August 2003.
24 25 Nuclear Regulatory Commission (NRC). 2004.Regulatory Analysis Guidelines of the U.S.
26Nuclear Regulatory Commission. NUREG/BR-0058, Washington, D.C., September 2004.
27 28 Nuclear Regulatory Commission (NRC). 2006. Letter from Jack Donohew, U.S. NRC to Rick A.
29Muench, WCNOC.
Subject:
Wolf Creek Generating Station - Issuance of Amendment 30Regarding Extended Diesel Generator Completion Times (TAC No. MC1257), April 26, 2006.
31 32 Nuclear Regulatory Commission (NRC). 2007. Letter from Christian Jacobs, U.S. NRC, to 33Terry Garrett, WCNOC.
Subject:
Request for Additional Information Regarding Severe 34Accident Mitigation Alternatives for Wolf Creek Generating Station, Docket 50-482, February 7, 35 2007.36 37U.S. Census Bureau (USCB). 2000a. Census 2000 Summary File 1 (SF 1) - 100 percent data.
38 Available online at: http://www.census.gov/Press-Release/www/2001/sumfile1.html 39 Appendix G September 2007 G-32 Draft NUREG-1437, Supplement 32 U.S. Census Bureau (USCB). 2000b. Census 2000 Redistricting Data (P.L.94-171) Summary 1File and 1990 Census. Table 1 - Counties in Alphabetical Sort within State, 1990 and 2000 2Population, Numeric and Percent Change: 1990 to 2000. April 2, 2001. Available online at:
3<http://www.census.gov/population/cen2000/phc-t4/tab01.xls>
4 5U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National 6Agriculture Statistics Service, 1998. Available online at:
7<http://www.nass.usda.gov/census/census97/volume1/vol1pubs.htm>.
8 9Westinghouse (WEST). 1999. Core Inventory Radiation Sources. Letter. SAP-99-145.
10September 3, 1999.
11 12Wolf Creek Nuclear Operating Corporation (WCNOC). 1992. Letter from Bart D. Withers, 13WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket No.
14 50-482: Wolf Creek Generating Station Individual Plant Examination. September 28, 1992.
15 16Wolf Creek Nuclear Operating Corporation (WCNOC). 1995a. Letter from Robert C. Hagan, 17WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket No.
1850-482: Final Response to Generic Letter 88-20. Supplement 4 (IPEEE Submittal). June 27, 19 1995.20 21Wolf Creek Nuclear Operating Corporation (WCNOC). 1995b. Letter from Neil S. Carns, 22WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket No.
2350-482: Response to Request for Additional Information Concerning the Individual Plant 24Examination. August 30, 1995.
25 26Wolf Creek Nuclear Operating Corporation (WCNOC). 1996. Letter from Richard A. Muench, 27WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket No.
2850-482: Response to Request for Additional Information Associated to the Human Reliability 29 Analysis. May 30, 1996.
30 31Wolf Creek Nuclear Operating Corporation (WCNOC). 2006. Letter from Terry J. Garrett, 32WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket No.
3350-482: Application for Renewed Operating License, September 27, 2006.
34 35Wolf Creek Nuclear Operating Corporation (WCNOC). 2007a. Letter from Terry J. Garrett, 36WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket 3750-482: Response to Request for Additional Information Regarding Severe Accident Mitigation 38Alternatives for Wolf Creek Generating Station, April 20, 2007.
39 Appendix G Draft NUREG-1437, Supplement 32 G-33 September 2007Wolf Creek Nuclear Operating Corporation (WCNOC). 2007b. Letter from Terry J. Garrett, 1WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket 2No. 50-482: Response to NRC Requests for Follow-up Information Regarding Severe Accident 3Mitigation Alternatives for Wolf Creek Generating Station License Renewal Application, ET 07-40023, June 26, 2007.
5 6Wolf Creek Nuclear Operating Corporation (WCNOC). 2007c. Letter from Terry J. Garrett, 7WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Docket 8No. 50-482: Response to NRC Requests for Follow-up Information Regarding Severe Accident 9Mitigation Alternatives for Wolf Creek Generating Station License Renewal Application, ET 07-100026, June 26, 2007.
11 12Wolf Creek Nuclear Operating Corporation (WCNOC). 2007d. Letter from Terry J. Garrett, 13Wolf Creek Nuclear Operating Corporation, to NRC, ET 07-0029, Docket No. 50-482: Summary 14of the Impact to Wolf Creek Generating Station License Renewal Application Severe Accident 15Mitigation Alternatives Analysis due to Computer Program Error
.July 13, 2007.
16 17Wolf Creek Nuclear Operating Corporation (WCNOC). 2007e. Letter from Terry J. Garrett, 18Wolf Creek Nuclear Operating Corporation, to NRC, ET 07-0035, Docket No. 50-482: Summary 19of the Impact to Wolf Creek Generating Station License Renewal Application Severe Accident 20Mitigation Alternatives Analysis due to Computer Program Error
.August 15, 2007.
21
BIBLIOGRAPHIC DATA SHEET (See instructions on the reverse)
NRC FORM 335 (9-2004)NRCMD 3.7U.S. NUCLEAR REGULATORY COMMISSION
- 1. REPORT NUMBER (Assigned by NRC, Add Vol., Supp., Rev., and Addendum Numbers, if any.)
NUREG-1437, Supplement 32
- 2. TITLE AND SUBTITLEGeneric Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS)
Supplement 32
Regarding Wolf Creek Generating Station
Draft Report
- 5. AUTHOR(S)
See Appendix B of report.
- 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, Division of License Renewal
- 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, Same as (8) above.
p rovide name and mailing address.)
and mailing address.)
- 10. SUPPLEMENTARY NOTES Docket No. 50-482
- 11. ABSTRACT (200 words or less)This supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by WolfCreek Nuclear Operating Corporation (WCNOC) to the Nuclear Regulatory Commission (NRC) to renew the Operating License for Wolf Creek Generating Station (WCGS) for an additional 20 years under 10 CFR Part 54. This SEIS includes the NRC staff's analysis that considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the proposed action and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staff' s recommendation regarding the proposed action.The NRC staff's recommendation is that the Commission determine that the adverse environmental impacts of license renewalfor WCGS are not so great that preserving the option of license renewal for energy-planning decion makers would be unreasonable. This recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental Report submitted by WCNOC; (3) consultations with Federal, State and local agencies; (4) the staff's own independent review; and (5)
the staff's consideration of public comments.
- 12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)
Wolf Creek Generating Station
Supplement to the Generic Environmental Impact Statement
GEIS 32 NUREG 1437, Supplement 32
National Environmental Policy Act
WCGS Wolf Creek Nuclear Operating Corporation
WCNOC 14. SECURITY CLASSIFICATION
- 13. AVAILABILITY STATEMENT unlimited (This Page) unclassified (This Report) unclassified
- 15. NUMBER OF PAGES
- 16. PRICE NRC FORM 335 (9-2004)PRINTED ON RECYCLED PAPER Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 P r i n t e d o n r e c y c l e d p a p e r F e d e r a l R e c y c l i n g P r o g r a m