ML110670535
| ML110670535 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/07/2011 |
| From: | Roth D NRC/OGC |
| To: | Atomic Safety and Licensing Board Panel |
| Roth, David E., 301-415-2749 | |
| Shared Package | |
| ML110670286 | List: |
| References | |
| 50-247-LR, 50-286-LR | |
| Download: ML110670535 (76) | |
Text
Indian Point License Renewal Docket No. 50-247 -LR 50-286-LR NRC STAFF'S ANSWER TO THE STATE OF NEW YORK'S MOTION FOR LEAVE TO FILE A NEW CONTENTION, AND NEW CONTENTION 37, CONCERNING THE FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT Attachment A
NUREG-1437. Vol. 1 Supplement 38
~U.S.NRC United Stares Nuclear Regulatory Commission Protecting People and the Environment Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 38 Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 Draft Report for Comment Main Report Office of Nuclear Reactor Regulation
1 Environmental Impacts of License Renewal Table 8-1 (continued)
New Closed-Cycle Existing Once-Through Cooling Impact Cooling Alternative with Restoration Alternatives Category Impact Comments Impact Comments Historical and SMALL Existing procedures SMALL to Impacts could reach Archeological are adequate to protect MODERATE moderate during Resources resources on the construction in largely-disturbed site.
sensitive areas.
Environmental SMALL No significant impacts SMALL No significant impacts Justice are anticipated that are anticipated that could disproportion-could disproportion ately affect minority or ately affect minority or low-income low-income communities.
communities.
2 8.2 No-Action Alternative 3
The NRC regulations implementing the National Environmental Policy Act of 1969, as amended 4
(NEPA) (see 10 CFR Part 51, Subpart A, Appendix A, paragraph 4), specify that the no-action 5
alternative will be discussed in an NRC environmental impact statement.
6 For license renewal, the no-action alternative refers to a scenario in which the NRC would not 7
renew the IP2 and IP3 operating licenses and Entergy would then cease operating both units on 8
or before the expiration of their current operating licenses. Following the shutdown of each unit, 9
Entergy would initiate decommissioning of the facility in accordance with the NRC 10 decommissioning requirements in 10 CFR 50.82, "Termination of License," Full dismantling of 11 structures and decontamination of the site may not occur for up to 60 years after plant 12 shutdown.
13 Regardless of whether or not the IP2 and IP3 operating licenses are renewed, the facility's 14 owner will eventually be required to shut down the reactors and decommission the IP2 and IP3 15 facility. If the operating licenses are renewed, shutdown and decommissioning activities would 16 not be avoided but would be postponed for up to an additional 20 years.
17 The environmental impacts associated with decommissioning, following a license renewal 18 period of up to 20 years or following the no-action alternative, would be bounded by the 19 discussion of impacts in Chapter 7 of the GElS, Chapter 7 of this draft SEIS, and NUREG-0586, 20 "Final Environmental Impact Statement on Decommissioning of Nuclear Facilities" (NRC 2002).
21 The impacts of decommissioning after 60 years of operation are not expected to be significantly 22 different from those occurring after 40 years of operation.
December 2008 8-25 Draft NUREG-1437, Supplement 38
1 Environmental Impacts of License Renewal Table 8*2. Summary of Environmental Impacts of the No*Action Alternative Impact Category Impact Comment Land Use Ecology Water Use and Quality Air Quality Waste Human Health Socioeconomics Socioeconomics (Transportation)
Aesthetics Historic and Archeological Resources Environmental Justice SMALL SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL SMALL Impacts are expected to be SMALL because plant shutdown is expected to result in few changes to offsite and onsite land use, and transition to alternate uses is expected over an extended timeframe.
Negative impacts to aquatic ecology of the Hudson River will cease. The overall impact is SMALL.
Impacts are expected to be SMALL as no new impacts occur with plant shutdown.
Impacts are expected to be SMALL because emissions related to plant operation and worker transportation will decrease.
Impacts are expected to be SMALL because generation of high-level waste will stop and generation of low-level and mixed waste will decrease.
Impacts are expected to be SMALL because radiological doses to workers and members of the public, which are within regulatory limits, will be reduced.
Impacts vary by jurisdiction, with some areas experiencing MODERATE effects.
Impacts are expected to be SMALL because the decrease in employment would reduce traffic.
Impacts are expected to be SMALL because plant structures will remain after plant shutdown.
Impacts are expected to be SMALL because shutdown of the plant will not immediately change land use.
Impacts are expected to be SMALL because there are no significant disproportionate impacts to minority or low-income Draft NUREG-1437, Supplement 38 8-26 December 2008
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2 Impacts from the decision to permanently cease operations are not considered in NUREG-0586, or its Supplement 1 Y) Therefore, immediate impacts that occur between plant shutdown and 3
the beginning of decommissioning are considered here, These impacts will occur when the 4
units shut down regardless of whether the license is renewed (see Table 8-2),
Plant shutdown will result in a net loss of power generating capacity, The power not generated 6
by IP2 and IP3 during the license renewal term would likely be replaced by (1) power supplied 7
by other producers (either existing or new units) using generating technologies that may differ 8
from that employed at IP2 and IP3, (2) demand-side management and energy conservation, or 9
(3) some combination of these options, The environmental impacts of these options are discussed in Section 8.3 of this draft SEIS. While these options can be alternatives to license 11 renewal (given sufficient resource availability), they also constitute potential consequences of 12 the no-action alternative, Impacts from these options will addressed in their respective portions 13 of this Section, 14 This draft SEIS does not assess the specifics of the need for corrections to reactive power that would be required if IP2 and IP3 were shut down, Reactive power (I.e" power stored in 16 magnetic fields throughout the power grid) is essential for the smooth operation of the 17 transmission grid because it helps hold the voltage to desired levels, It may be possible to use 18 the existing generators at IP2 and IP3 as a source of reactive power even if IP2 and IP3 are 19 shut down, As "synchronous condensers," the generators could add reactive power (but not real power) to the transmission system (National Research Council 2006). Because it is 21 assumed that the generators would be operated as synchronous condensers only until the 22 reactive power could be supported by new, real replacement power generation, their operation 23 is not considered as a significant contributor to the impacts described below. Further, as a shut 24 down nuclear power plant may not be decommissioned for many years after shutdown, the continued operation of IP2 and IP3 generators would not necessarily slow or impede 26 decommissioning activities.
27 Land Use 28 In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued plant 29 operation on land use would be SMALL. Onsite land use will not be affected immediately by plant shutdowns. Plant structures and other facilities are likely to remain in place until 31 decommissioning. In the near term, the transmission lines associated with IP2 and IP3 will 32 likely remain in place, In the long term, it is possible that the transmission lines that extend from 33 the onsite switch yard to major transmission corridors will be removed, As a result, the 34 transmission line ROWs will no longer be maintained and the ROW will be available for other uses. Also, as a result of plant shutdowns, there would be a reduction in uranium mining activity 36 on approximately 870 ha (2160 ac), or 405 ha (1000 ac) per 1000 MW(e) (NRC 1996).
37 Therefore, the staff concludes that the impacts on land use from plant shutdown would be 38 SMALL.
39 Ecology In Chapter 4 of this draft SEIS, the NRC staff concluded that aquatic ecological impacts of (2)
Appendix J, "Socioeconomic and Environmental Justice Impacts Related to the DeciSion to Permanently Cease Operations," to 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.
December 2008 8-27 Draft NUREG-1437, Supplement 38
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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 42 43 Environmental Impacts of License Renewal continued plant operation were SMALL to LARGE because of the entrainment and impingement of aquatic species, depending on the species. The NRC staff also concluded that thermal shock could have a SMALL to MODERATE impact. Terrestrial ecological impacts were SMALL.
Cessation of operations will eliminate cooling water intakes from and discharges to the Hudson River. The environmental impacts to aquatic species, including threatened and endangered species, associated with these changes are generally positive because entrainment and impingement issues will be eliminated, as would impacts from the plant's thermal plume. The NRC staff expects that impacts to aquatic ecology, including to the endangered shortnose sturgeon, would decline to SMALL if the plant shuts down.
The impacts of plant closure on the terrestrial ecosystem could be both negative and positive, depending on final disposition of the IP2 and IP3 site. Currently, there isa fragment of eastern deciduous hardwood habitat in the exclusion area of the facility that Entergy indicates has not been previously developed. This fragment could be destroyed by new development once access is no longer restricted. Plant closure will not directly affect this fragment, however, and a prolonged period prior to site decontamination may also provide protection for this fragment.
Overall, the NRC staff concludes that ecological impacts from shutdown of the plant would be SMALL.
Water Use and Quality When the plant stops operating and cooling water is no longer needed, there will be an immediate reduction in water withdrawals from and discharge to the Hudson River. This will reduce evaporation from the river in the vicinity of the plant and will result in decreased discharges of biocides and other chemicals. Therefore, the staff concludes that the impacts on surface water use and quality from plant shutdown would be less noticeable than current operations and would remain SMALL.
Ground water at the IP2 and IP3 site contains elevated concentrations of tritium (EPA 2004). In Sections 2.2.7 and 4.5 of this draft SEIS, the NRC staff examined available information on leakage to ground water and determined that the issue, while new, is not significant. The source of the contamination is believed to be historical leakage from the IP1 and IP2 spent fuel pools. Since discovering the leaks, Entergy has removed fuel from the IP1 spent fuel pool and drained it. The no-action alternative would not, on its own, affect ground water contamination.
Consequently, the NRC staff concludes that ground water quality impact$ from shutdown of the plant would be SMALl.
Air Quality In Chapter 4 of this draft SEIS, the NRC staff adopted the findings in the GElS that the impacts of continued plant operation on air quality would be SMALL. When the plant stops operating.
there will be a reduction in emissions from activities related to plant operation (e.g., use of diesel generators and vehicles to transport workers to the site). As such, the NRC staff concludes that the impact on air quality from shutdown of the plant would be SMALL.
Waste The impacts of waste generated by continued plant operation are discussed in Chapter 6 of this draft SEIS. The impacts of low-level and mixed waste from plant operation are characterized as SMALl. When IP2 and IP3 stop operating, the plant will stop generating, high-level waste and generation of low-level and mixed waste associated with plant operation will briefly increase, Draft NUREG-1437, Supplement 38 8-28 December 2008
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Wastes associated with plant decommissioning are unavoidable and will be significant whether the plant is decommissioned at the end of the initial license term or at the end of the period of extended operation. The no-action alternative will not have an appreciable affect on waste volumes associated with decommissioning.
Human Health In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued plant operation on human health are SMALL. After cessation of plant operations, the amount of radioactive material released to the environment in gaseous and liquid forms, which are currently within regulatory limits, will be reduced. Therefore, the NRC staff concludes that the impact of plant shutdown on human health also would be SMALL. In addition, the variety of potential accidents at the plant will be reduced to a limited set associated with shutdown events and fuel handling. In Chapter 5 of this draft SEIS, the staff concluded that impacts of accidents during operation are SMALL. Therefore, the NRC staff concludes that the impacts of potential accidents following shutdown of IP2 and IP3 also would be SMALL.
Socioeconomics In Chapter 4 of this draft SEIS, the NRC staff concluded that the socioeconomic impacts of continued plant operation would be SMALL. Should the plant shut down,. there would be immediate socioeconomic impacts from loss of jobs (some, though not all, of the approximately 1255 full-time employees and baseline contractors would begin to leave ~he site); there may also be an immediate reduction in property tax revenues for Westchester County. These impacts, however, would not be considered significant on a countywide basis because of the large population in the area and because plant workers' residences are not concentrated in a single municipality or county.
PILOT payments and other taxes from IP2 and IP3 are paid directly to the Town of Cortlandt, the Village of Buchanan, and the Hendrick Hudson Central School District. Entergy paid a combined $21.2 million in PILOT payments, property taxes, and other taxes to Westchester County, the Town of Cortlandt, the Village of Buchanan, the Verplanck Fire District, and the Hendrick Hudson Central School District in 2005 (Entergy 2007). PILOT payments, property taxes, and other taxes paid by the site account for a significant portion of revenues for these Government agencies.
The Village of Buchanan, which has over 2100 residents, is the principal local jurisdiction that receives direct revenue from IP2 and IP3. In fiscal year 2005, PILOT payments, property taxes, and other taxes from Entergy contributed about 39 percent of the Village of Buchanan's total revenue of $5.08 million (Entergy 2007). The revenues generated from IP2 and IP3 are used to fund police, fire, health, transportation, recreation, and other community services. Additionally in fiscal year 2005, PILOT payments, property taxes, and other taxes from Entergy contributed over 35 percent of the total revenue collected for the Hendrick Hudson Central School District.
which serves approximately 3000 students (Entergy 2007).
The shutdown of IP2 and IP3 may result in increased property values of the homes in the communities surrounding the site (Levitan and Associates, Inc. 2005). This would result in some increases in tax revenues. However, to fully offset the revenues lost from the shutdown of December 2008 8-29 Draft NUREG-1437. Supplement 38
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Revenue losses from Indian Point operation would likely affect only the communities closest to and most reliant on the plant's tax revenue and PILOT. If property values and property tax revenues increase, some of these effects would be smaller. The NRC staff concludes that the socioeconomic impacts of plant shutdown would likely be SMALL to MODERATE (MODERATE effects for the Hendrick Hudson Central School District, Village of Buchanan, Town of Cortlandt, and the Verplanck Fire District). See Appendix J to NUREG-0586, Supplement 1 (NRC 2002),
for additional discussion of the potential impacts of plant shutdown.
Transportation In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued plant operation on transportation would be SMALL. Cessation of operations will be accompanied by reduced traffic in the vicinity of the plant. Most of the reduction will be aSl50ciated with a reduction in plant workforce, but there will also be a reduction in shipment of maintenance materials to and from the plant. Therefore, the staff concludes that the impacts of plant closure on transportation would be SMALL Aesthetics In Chapter 4 of this draft SEIS, the NRC staff concluded that the aesthetic impacts of continued plant operation would be SMALL. Major plant structures and other facilities, such as the containment buildings and turbine buildings, are likely to remain in place until decommissioning begins. The NRC staff also anticipates that the overall appearance of the facility and its grounds would be maintained through the decommissioning. Since no sisnificant changes would occur between shut down and decommissioning, the staff concludes that the aesthetic impacts of plant closure would be SMALL.
Historic and Archeological Resources In Chapter 4 of this draft SEIS, the staff concluded that the impacts of continued plant operation on historic and archeological resources would be SMALL. Onsite land use will not be affected immediately by the cessation of operations since plant structures and other facilities are likely to remain in place until decommissioning. Following plant shutdown, there would be no foreseeable need for archeological surveys of the area. Therefore, the NRC staff concludes that the impacts on historic and archeological resources from plant shutdown would be SMALL.
Environmental Justice In Chapter 4 of this draft SEIS, the NRC staff concluded that the environf1l1ental justice impacts of continued operation of the plant would be SMALL because continued 9peration of the plant would not have a disproportionately high and adverse impact on minority and low-income populations. Although the NRC staff concluded that the socioeconomic impacts of the plant shutdown would be MODERATE for some jurisdictions, the impacts of the plant shutdown are likely to be felt across the entire community and are not expected to be significantly disproportionate to minority and low-income populations.
Draft NUREG-1437, Supplement 38 8-30 December 2008
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As described in Section 2.2.8.6, the site contributed over 35 percent of the total revenue 2
collected for the Hendrick Hudson Central School District in 2005. The Hendrick Hudson 3
Central School District has only an 18-percent minority population (compared to a 47-percent 4
Statewide average) and only 5 percent of the students are eligible for a free or reduced-price lunch program (compared to a Statewide average of 44 percent). Therefore, the loss of funding 6
to the Hendrick Hudson Central School District would not disproportionat~ly affect minority and 7
low-income populations (GreatSchools 2008).
8 The site contributed about 39 percent of the Village of Buchanan's total revenue in 2005 9
(Entergy 2007). In 2000, less than 4 percent of the population were minorities and less than 4 percent of the individuals were below the poverty level (US Census Bureau 2000). Therefore, 11 the loss of funding to the Village of Buchanan would not disproportionately affect minority and 12 low-income populations.
13 The NRC staff concludes that the environmental justice impacts of plant shutdown would be 14 SMALL. See Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional discussion of these impacts.
16 8.3 Alternative Energy Sources 17 This section discusses the environmental impacts associated with developing alternative 18 sources of electric power to replace power generated by IP2 and IP3. The order of alternative 19 energy sources presented in this section does not imply which alternativ¢ would be most likely to occur or which is expected to have the least environmental impacts.
21 The following central generating station alternatives are considered in detail in the identified 22 sections of this draft SEIS:
23
- supercritical coal-fired generation at an alternate site (Section 8.3.1) 24
- natural gas-fired generation at either the IP2 and IP3 site or an alternate site (Section 8.3.2) 26 The NRC staff considers the following nongeneration alternatives to license renewal in detail in 27 the identified sections of this draft SEIS:
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- purchased power (Section 8.3.3) 29 The NRC staff also considers two combinations of alternatives that include new or existing generation along with conservation or purchased power in the identified sections of this draft 31 SEIS:
32 continued operation of either IP2 or IP3, construction and operation of a gas-fired unit, 33 renewable generation, and conservation programs (Section 8.3.5.1) 34
- construction and operation of new gas-fired plant, renewable generation, conservation, and purchased power (Section 8.3.5.2) 36 Alternatives considered by the NRC staff but dismissed from further evaluation as stand-alone 37 alternatives are addressed in Section 8.3.4 of this draft SEIS. Several of the alternatives 38 discussed in Section 8.3.4 are included in the combinations addressed in 8.3.5.
December 2008 8-31 Draft NUREG-1437, Supplement 38
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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 42 43 44 Environmental Impacts of License Renewal Alternatives Process Since IP2 and IP3 have a net electric output of 2158 MW(e), the NRC staff evaluated the impacts of alternatives with comparable capabilities.
Of the alternatives mentioned in this section, the NRC staff expects that only a natural gas-fired generation plant could be developed at the IP2 and IP3 facility because the site is too small to host other alternatives.
While the alternate site considered need not be situated in New York State, the availability of transmission line capacity to deliver power from a location outside the New York metropolitan region to current IP2 and IP3 customers could constrain siting choices. For instance, a recent analysis conducted by the U.S. Department of Energy (DOE) concluded that metropolitan New York southward through northern Virginia is a "critical congestion area" (DOE 2006). The DOE has identified critical congestion areas where it is critically important to remedy existing or growing electrical transmission congestion problems because the impacts of the congestion could be severe. It is conceivable that these transmission congestion patterns would influence selection of an alternate site for generating power that is needed in the New York metropolitan region.
All of New York's constrained transmission paths move power from areas to the west, south, and north of the State to the loads in and around New York City and Long Island. The New York City metropolitan area consumes major quantities of electricity with less generation capacity than load. Therefore, the region is dependent on imports. Because of the area's current dependence on local power generation from natural gas and oil fuels, the area has high electricity rates (DOE 2006). The replacement of limited local generation sources with additional imported power would place even more demands on the constrained transmission system moving power into the New York City area. As noted in Section 8.2, it may be necessary to continue operating the IP2 and IP3 generators as synchronous condensers to supply virtual power to the local transmission system after the IP2 and IP3 reactors shut down.
EIA Projections Each year the Energy Information Administration (EIA), a component of DOE, issues an annual energy outlook. In its "Annual Energy Outlook 2007 with Projections to 2030," EIA projects that natural gas-fired plants will account for approximately 26 percent of electric generating capacity in 2020, an increase of about 14 percent from 2005 levels (DOE/EIA 2007a). EIA projects that coal-fired plants will account for approximately 32 percent of generating capacity in 2020, increasing nearly 15 percent from 2005 levels (DOE/EIA 2007a). EIA projects that renewable energy sources, primarily hydropower and biomass, will account for 12 percent of capacity in 2020, increasing from 9 percent in 2005 (DOE/EIA 2007a). After 2020, however, new coal and nuclear plants are expected to displace some of the power currently generated at natural-gas fired plants (DOE/EIA 2007a).
EIA bases its projections on the assumption that providers of new generi$ting capacity will seek to add generating sources that are cost effective and meet applicable environmental requirements. According to EIA, advanced coal-fired and advanced combined-cycle natural gas generating facilities will be approximately competitive with each other in 2015, and advanced coal-fired facilities will likely gain a competitive edge by 2030 (DOE/EIA 2007a). In line with the EIA projections, the alternative of a new advanced coal-fired plant at an alternate location is considered in this draft SEIS. The resulting impacts are presented in Section 8.3.1 of this draft Draft NUREG-1437, Supplement 38 8-32 December 2008
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SEIS. The impacts of a new gas-fired combined-cycle plant located at either the IP2 and IP3 2
site or an alternate site are presented in Section 8.3.2 of this draft SEIS.
3 EIA indicated that, because of environmental needs and increasing fuel costs, oil-fired plants 4
will account for little or none of the new generating capacity added in the United States through 2030 (DOE/EIA 2007a). This projection assumed that world oil prices would reach a low of $50 6
per barrel in 2014 and rise to $59 in 2030. After recent sharp price increases and declines, the 7
EIA now projects that oil prices will average $51 per barrel in 2009 (DOEVEIA 2008b). The NRC 8
staff notes that future oil prices will be driven by supply and demand.
9 The EIA projects that U.S. generators will increase total nuclear and renewable generation capacity throughout the forecast term, due partly to tax credits and other incentives. As a 11 proportion of installed capacity, however, nuclear generation will decreaSe slightly through 2030, 12 while renewable generation remains relatively constant (EIA 2007). EIA indicates that changes 13 in electricity generation costs-which are highly dependent on emission control costs-will drive 14 utilities' choices in generating technologies (EIA 2007). About 70 percent of new nuclear generating capacity is expected to be directly related to the availability of production tax credits 16 under the Energy Policy Act of 2005 (EPACT2005; DOE/EIA 2007a).
17 The NRC staff uses EIA's analyses to help select reasonable alternative$ to license renewal. In 18 the following sections of this chapter, the NRC staff will examine several alternatives in depth, 19 and identify a range of others that staff considered but rejected.
8.3.1 Supercritical Coal-Fired Generation 21 In this section, the NRC staff analyzes new supercritical coal-fired boilers as an alternative to 22 nuclear power generation at the IP2 and IP3 site. Supercritical coal-fired plants are similar to 23 other coal burners except that they operate at higher temperatures and pressures, which allows 24 for greater thermal efficiency. Supercritical coal-fired boilers are commercially proven and represent an increasing proportion of new coal-fired power plants. In eV<i\\luating the 26 supercritical coal-fired alternative, the NRC staff assumed that a new plant located at an 27 alternate site would use a closed-cycle cooling system.
28 The NRC staff recognizes that some coal-fired power plant proposals have recently faced 29 opposition or rejection in some jurisdictions, though other projects continue to move forward.
Also, coal-fired generation faces greater regulatory uncertainty and risk from potential future 31 greenhouse gas regulation than other generation alternatives. In New York, coal-fired power 32 plants would need to comply with elements of the Regional Greenhouse Gas Initiative.
33 Nonetheless, given EIA's projections and the progress of some new coal-fired proposals, the 34 NRC staff has decided to include coal-fired generation as an alternative to license renewal.
Construction of a coal-fired plant at an alternate site may necessitate the acquisition of 36 additional ROWs for new transmission lines and construction of new lines to transmit power.
37 Transmission line and ROW length would vary with distance to suitable existing lines. In 38 addition, construction at an alternate site may necessitate the construction of an appropriate 39 railroad spur (or other transportation infrastructure) for coal and limestone (used in scrubbers to remove sulfur oxides) deliveries.
41 For purposes of this analysis, the NRC staff will rely on data published by EIA indicating that a 42 new, scrubbed coal plant constructed in 2015 will operate at a heat rate of 8661 BTU per December 2008 8-33 Draft NUREG-1437, Supplement 38
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Impacts of a coal-fired alternative evaluated by the NRC staff assume that the new plant would have a gross electrical capacity of 2200 MW(e). The NRC staff's analysis of the 2200-MW(e) coal-fired plant is based on the factors used to calculate the impacts of the plant that would replace the 2158 MW(e) of power produced by the IP2 and IP3 plants (Entergy 2007). Because up to 10 percent of gross generation may be consumed on site by the coal-fired plant (or its pollution control equipment), the NRC staffs evaluation of a 2200-MW(e) plant may actually slightly understate impacts from this alternative. This ensures, however, that impact levels for alternatives are not overstated when compared to the proposed action.
The NRC staff will present most impacts on an annualized basis. While the renewal period for the IP2 and IP3 operating licenses is only 20 years, the operating lifespan for a new coal-fired plant is likely closer to 40 years, and may even be longer given the lifespans of some existing coal-fired plants. Most impacts will be independent of plant lifespan, though total land area used for waste disposal, for example, will be larger after 40 years than after 20 years. Where these differences exist. the NRC staff will identify them.
For replacing IP2 and IP3, the NRC evaluated an alternative that would use four 550-MW(e)-net coal-fired units to replace the power output of IP2 and IP3. Advanced coal and conventional combined-cycle coal plants could operate at even greater efficiencies (about 7477 and 6866 BTU/kWh, respectively, or greater) by 2015 (DOE/EIA 2007b).
The supercritical coal-fired plant, with a gross output of about 2200 MW(e), would consume approximately 4.9 million metric tonnes (MT) (5,4 million tons) per year of pulverized bituminous coal with an ash content of approximately 7.11 percent and sulfur content of 1.12 percent (based on New York coal consumption) (DOE/EIA 2001). The NRC staff assumed a capacity factor of 0.85 for the supercritical coal-fired alternative.
Based on Table 8-1 of the GElS, a pulverized coal-fired facility requires approximately 0.7 ha (1.7 ac) of land per MW of generating capacity. Based on this relationship, a 1540-ha (3740-ac) site would be needed to replace the nuclear power output of IP2 and IP3with an equivalent capacity coal-fired facility. In more recent SEIS documents, however, thEF NRC staff indicated that smaller quantities of land may be sufficient to construct coal-fired facilities based on land use at eXisting coal-fired power plants. Because the existing IP2 and IP3 site includes only 239 ac (98 ha), and much of the area is occupied by plant structures, the NRC staff concludes that there is not sufficient land area at the IP2 and IP3 site to support operations of the alternative.
Thus, the coal-fired alternative is analyzed only for an unspecified alternate site. It should be noted that several of the newer coal utilization technologies (e.g., coal-fired integrated gasification combined-cycle systems) could be accommodated on smaller sites than would the conventional pulverized coal concept evaluated here, but likely not a site as small as the IP2 and IP3 site.
The overall impacts of the coal-fired generating facility are discussed in the following sections and summarized in Table 8-3, at the end of Section 8.3.1 of this draft SEIS. The implications of constructing a new coal-fired plant at an alternate site will depend on the actual location and characteristics of that site. For purposes of this section, the NRC staff assumes that a coal-fired plant located at an alternate site would require the construction of a new transmission line to Draft NUREG-1437, Supplement 38 8-34 December 2008
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Land Use In the GElS, the NRC staff estimated that about 0.7 ha (1.7 ac) of land are needed per MW(e) for the construction and operation of a coal-fired power plant. Constructing a 2200-MW(e) coal-fired facility would take approximately 1540 ha (3740 ac). In more recent SEIS documents, the NRC staff indicated that smaller quantities of land may be sufficient to construct coal-fired facilities based on land use at existing coal-fired power plants. A 2200-MW(e) facility may be able to fit on a site with several hundred acres of land rather than the 1540 ha (3740 ac) indicated in the GElS.
Committing land resources to a new coal-fired plant could result in the 10$s of wildlife habitat or agricultural land. The potential need for new transmission line corridors and ROWs also drive land use effects for the coal-fired facility. As a result of the substantial site area that would be dedicated to and disrupted by coal-fired operations, the NRC staff views this alternative as having potentially MODERATE land use impacts from construction.
Additionally, for the coal-fired alternative, land use changes would occur at an undetermined coal mining area where approximately 75 square miles (sq mi) (19,400 ha) would be affected for mining coal and disposing of mining wastes to support a 2200-MW(e) coal-fired power plant (the GElS estimates that approximately 34 sq mi (8800 ha) would be disturbed for a 1000-MW(e) coal-fired plant (NRC 1996). Offsite land use for coal mining would partially be offset by the elimination of the need for offsite uranium mining. In the GElS, the NRC staff estimated that approximately 405 ha (1000 ac) would be affected for mining the uranium and processing it during the operating life of a 1 OOO-MW(e) nuclear power plant (NRC 1996). Therefore the uranium mining offset would be about 890 ha (2,200 ac) of the 19,400 ha required for the coal-fired alternative. Impacts from the coal fuel cycle would add to the already MODERATE impacts from plant construction.
A coal-fired alternative would likely receive coal and limestone by rail. The coal-fired option would require approximately 10.4 coal unit trains per week (assuming each train has 100 cars with 100 tons of coal per car). For an undeveloped site, a new rail spur would be necessary.
For an existing industrial site, a rail spur may exist but could require improvements to handle these deliveries. Impacts from improving an existing rail spur would be small, as the area is already disturbed and used for industrial purposes. Installing a new rail spur could result in relatively minor impacts depending on the length of the rail spur.
Overall, impacts to land use from construction of the coal-fired alternative and its fuel cycle would be MODERATE to LARGE.
Ecology Siting a coal-fired plant at an alternate site would introduce construction iilnd operating impacts.
Converting as much as 1500 ha (3700 ac) of land to industrial use (generating facilities, coal storage, ash and scrubber sludge disposal) could significantly alter terrestrial ecological resources and could affect aquatic ecological resources. Construction and maintenance of a transmission line and rail spur would incrementally add to the terrestrial ecological impacts.
Impacts to terrestrial ecology from coal mining also could be substantial, though terrestrial ecology at many coal mining sites has already been disturbed. Therefore, the NRC staff concludes that the impact to terrestrial ecology would be MODERATE to LARGE, depending December 2008 8-35 Draft NUREG-1437, Supplement 38
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Use of surface water resources to provide makeup water for a closed-cycle cooling system would have some impact on local aquatic resources. Aquatic impacts of a supercritical coal-fired alternative would likely be similar to the impacts of the proposed closed-cycle cooling system proposed for the existing nuclear reactors described in Section 8.1.1 of this draft SEIS.
The supercritical coaHired power plant's greater thermal efficiency-when compared to the existing IP2 and IP3-would result in smaller impacts, while the coal-fired alternative has greater potential for deposition of pollutants or runoff from coal, ash, or scrubber waste areas.
On the whole, the level of impact would be similar. Therefore, the NRC staff concludes that the impact to aquatic ecology would be SMALL.
Due primarily to the potential effects on terrestrial ecology, the NRC staff concludes that the overall impacts of this alternative would be MODERATE to LARGE.
Water Use and Quality For coal-fired operations at an alternate site, impacts to surface waters would result from withdrawal of water for various operating needs of the facility. These operating needs would include cooling tower makeup and possibly auxiliary cooling for equipment and potable water requirements. Discharges to surface water could result from cooling tower blowdown, coal pile runoff, and runoff from coal ash and scrubber byproduct disposal areas. Both the use of surface waters and discharges to surface waters would be regulated by the State within which the coal-fired facility is located.
The NRC staff expects that any new coal-fired facility would comply with requirements of the discharge permits issued for its operation. Thus. the utility would be obligated to ensure that discharges from the plant conform to applicable water quality standards. Water withdrawals from a small river or cooling pond, however. could lead to potential water use conflicts. Overall, the NRC staff concludes that the potential impacts to surface water resources and water quality would be SMALL to MODERATE for a new coal-fired facility located at an alternate site.
Potential impacts to ground water quality at an alternate site may occur as a result of seepage to ground water from coal storage areas and onsite ash and scrubber sludge disposal areas. A coal-fired plant of this size is unlikely to use ground water for cooling tower makeup, however.
In all cases, the NRC staff expects that a coal-fired facility would comply with a ground water use and discharge permit issued by the State having jurisdiction over the plant. Complying with permit requirements should ensure a small impact. Therefore, the NRC staff concludes that the potential impacts to water resources would be SMALL to MODERATE.
Air Quality A coal-fired power plant emits a variety of airborne emissions, including SOx, NOx. particulate matter. CO. hazardous air pollutants (HAPs) (e.g., mercury). and naturally occurring radioactive materials.
A coal-fired alternative built in a nonattainment area (such as exists at the current IP2 and IP3 site) would require a nonattainment area permit and a Title V operating permit under the CM.
A new power plant would also be subject to the new source performance standards for such units in Subpart DA, "Standards of Performance for Electric Utility Steam Generating Units for Which Construction Is Commenced after September 18, 1978," of 40 CFR Part 60, "Standards Draft NUREG-1437, Supplement 38 8-36 December 2008
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NRC discussions of SOx and NOxemissions include the most recent relevant regulations, because the Clean Air Interstate Rule (CAIR) was vacated by the D.C. Circuit Court in July of 2008. On September 24, 2008, EPA filed for a rehearing of the D.C. Circuit Court decision.
Until EPA, Congress, or the courts act, elements of future SOx and NOx regulatory approaches remain uncertain.
Emissions of specific pollutants from coal-fired alternatives are as follows:
Sulfur oxides emissions. The NRC staff calculates that a new coal-fired power plant would emit 5236 MT/yr (5754 tons/yr) of SOx after limestone-based scrubbers remove approximately 99 percent of sulfur compounds from plant exhaust. This plant would be subject to the requirements in Title IV of the CAA. Title IV was enacted to reduce emissions of SOx and NOx, the two principal precursors of acid rain, by restricting emissions of these pollutants from power plants. Title IV caps aggregate annual power plant SOx emissions and imposes controls on SOx emissions through a system of marketable allowances. EPA issues one allowance for each ton of SOx that a unit is allowed to emit.
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Nitrogen oxides emissions. Title IV of the CM directed EPA to establish technology-based emission limitations for NOx emissions (see Section 407), rather than a market-based allowance system as is used for SOx emissions. A new coal-fired power plant would be subject to the new source performance standards for such plants in 40 CFR 60.44a(d)(1). That regulation, issued September 16, 1998 (Volume 63, page 49453 of the Federal Register (63 FR 49453)), limits the discharge of any gases that contain nitrogen oxides (expressed as nitrogen dioxide (N02)) to 200 nanograms per joule of gross energy output (1.6 pound/megawatt-hour (MW(h)), based on a 30-day rolling average.
As previously discussed, IP2 and IP3 are located within the New Jersey-New York-Connecticut Interstate Air Quality Control Region (40 CFR 81.13). All of the States of New Jersey and Connecticut, as well as several counties in Central and Southeastern New York within a 80-km (50-mi) radius of IP2 and IP3, are designated as nonattainment areas for ozone (8-hour standard) (EPA 2008b). Operators or owners of a coal-fired power plant constructed in a nonattainment area would need to purchase offsets for ozone precursor emissions. In this case, NOx is the major ozone precursor emitted by a coal-fired power plant. In accordance with NYSDEC regulations, "Emission offsets must exceed the net increase in annual actual emissions from the air contamination source project" (NYSDEC, Chapter 3, Parts 231-15). By design, this regulatory requirement should result in a net reduction in ozone emissions in the region.
This new coal-fired plant would likely use a variety of NOx control technologies, including low-NOxburners, overfire air, and selective catalytic reduction. EPA notes that when these emissions controls are used in concert, they can reduce NOxemissions by up to 95 percent (EPA 1998), for total annual emissions of approximately 1230 MT/yr (1352 tons/yr) or 0.14 pounds/MW(h). This is significantly less than the amount allowed by Title IV of the CM.
Particulate emissions. The NRC staff estimates that the total annual stack emissions would include 175 MT (192 tons) of total suspended particulates and 40 MT (44 tons) of particulate matter having an aerodynamic diameter less than or equal to 10 IJm (PM 1O ) (40 CFR 50.6, "National Primary and Secondary Ambient Air Quality Standards for PM10"). Some of this PM10 would also be classified as primary PM2.5*
As indicated in the IP2 and IP3 ER, fabric filters or electrostatic precipitators would be used for particulate control. EPA notes that filters or precipitators are each capable of removing more than 99 percent of particulate matter, and that S02 scrubbers further reduce particulate matter emissions (EPA 1998). In addition to flue emissions, coal-handling equipment would introduce fugitive particulate emissions from coal piles, reclamation equipment, conveyors, and other sources.
Fugitive dust also would be generated during the construction of a coal-fired plant, and construction vehicles and motorized eqUipment would further contribute to construction-phase air emissions. These emissions would be short lived and intermittent, and construction crews would likely mitigate some impacts through dust control measures.
Draft NUREG-1437, Supplement 38 8-38 December 2008
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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 42 43 44 45 Environmental Impacts of License Renewal Carbon monoxide emissions. The NRC staff estimates that the total CO emissions from coal combustion would be approximately 1230 MT/yr (1352 tons/yr) based on EPA~calculated emissions factors for coal~fired power plants.
Hazardous air pollutants including mercury. Following the D.C. Circuit Court's February 8, 2008, ruling that vacated its Clean Air Mercury Rule (CAMR), EPA is working to evaluate how the court's ruling will affect mercury regulation (EPA 2008d). Before CAMR, EPA determined that coal~ and oil-fired electric utility steam-generating units are significant emitters of HAPs (EPA 2000a). EPA determined that coal plants emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000a).
EPA concluded that mercury is the HAP of greatest concern and that (1) a link exists between coal combustion and mercury emissions, (2) electric utility steam-generating units are the largest domestic source of mercury emissions, and (3) certain segments of the U.S population (e.g., the developing fetus and subsistence fish~eating populations) are believed to be at potential risk of adverse health effects resulting from mercury exposures caused by the consumption of contaminated fish (EPA 2000a). In light of the recent court decision, EPA will revisit mercury regulation, although it is possible that the agency will continue to regulate mercury as a HAP, thus requiring the use of best available control technQlogy to prevent its release to the environment.
Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring elements. According to Alex Gabbard of Oak Ridge National Laboratory, uranium concentrations are generally in the range of 1 to 10 parts per million (ppm), and thorium concentrations are generally about 2.5 times this level (Gabbard 1993). The U.S. Geological Survey (USGS) indicates that Western and Illinois Basin coals contain uranium and thorium at roughly equal concentrations, mostly between 1 and 4 ppm, but also indicates that some coals may contain concentrations of both elements as high as 20 ppm {USGS 1997). Gabbard indicates that a 1000-MW{e) coal-fired plant could release roughly 4.7 MT (5.2 tons) of uranium and 11.6 MT (12.8 tons) of thorium to the atmosphere each year (1993).
Both USGS and Gabbard, however, indicate that almost all of the uranium, thorium, and most decay products remain in solid coal wastes, especially in the fine glass spheres that constitute much of coal's fly ash. Modern emissions controls, such as those included for this coal-fired alternative, allow for recovery of greater than 99 percent of these solid wastes (EPA 1998), thus retaining most of coal's radioactive elements in solid form rather than releasing it to the atmosphere. Even after concentration in coal waste, the level of radioactive elements remains relatively low-typically 10 to 100 ppm-and consistent with levels found in naturally occurring granite rocks, shales, and phosphate rocks (USGS 1997). The levels of uranium and thorium contained in coal wastes and discharged to the environment exceed the levels of uranium and thorium released to the environment by IP2 and IP3.
Carbon dioxide: A coal~fired plant would have unregulated CO2 emissions that could contribute to global warming. Under the current regulatory framework, a coal~fired plant would have unregulated CO2 emissions during operations as well as during coal mining and processing, and coal and lime transportation. Burning bituminous coal in the United States emits roughly 93.3 kg (205.3 pounds) of CO2 per million BTU (DOE/EIA 2008a). The four-unit 2200-MW(e) supercritical coal-fired plant would emit approximately 13.1 million MT (14.5 million tons) of CO2 per year assuming a heat rate of 8661 BTU/kWh (DOE/EIA 2007b). Section 6.2 of this draft SEIS contains a discussion of current and likely future relative GHG emissions from several December 2008 8-39 Draft NUREG-1437, Supplement 38
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Visibility Regulations: Section 169A of the CAA (42 USC 7491) establishes a national goal of preventing future and remedying existing impairment of visibility in mandatory Class I Federal areas when impairment results from manmade air pollution. EPA issued a new regional haze rule in 1999 (64 FR 35714). The rule specifies that for each mandatory Class I Federal area located within a State, the State must establish goals that provide for reasonable progress towards achieving natural visibility conditions. The reasonable progress goals must provide for an improvement in visibility for the most-impaired days over the period of the implementation plan and ensure no degradation in visibility for the least-impaired days over the same period (40 CFR 51.308{d)(1 )). If a coal-fired alternative were located close to a mandatory Class I area, additional air pollution control requirements would be imposed. New York has no Class I areas; of the neighboring States, New Jersey and Vermont each have one-the Brigantine Wilderness Area and the Lye Brook Wilderness, respectively. Brigantine is located about 225 km (140 mi) south of IP2 and IP3, while Lye Brook is roughly 215 km (135 mi) north-northeast.
A coal-fired alternative located near these areas or any other Class I area may need additional pollution controls to keep from impairing visibility.
Summary. The GElS analysis did not quantify emissions from coal-fired power plants, but implied that air impacts would be substantial. The GElS also mentioned global warming from unregulated CO2 emissions and acid rain from SOx and NO. emissions as potential impacts (NRC 1996). The NRC staff's analysis shows that emissions of air pollutants, including SOx, NOx, and CO, would be significant and would be greater than all other alternatives. Operational emissions of CO2 are also greater under the coal-fired alternative than under any other alternative.
The NRC analysis for a coal-fired alternative at an alternative site indicates that impacts from the coal-fired alternative would have clearly noticeable effects, but given existing regulatory regimes, permit requirements, and emissions controls, the coal-fired alternative would not destabilize air quality. Thus, the appropriate characterization of air impacts from coal-fired generation would be MODERATE.
Waste A four-unit 2220-MW(e) coal-fired plant with a heat rate of 8661 BTU/kWh (DOE/EIA 2007b) would annually consume approximately 5.4 million tons of coal having an ash content of 7.11 percent (Entergy 2007). After combustion, 99.9 percent of this ash, approximately 345,800 MT (380,000 tons) per year, would be collected and disposed of at either an onsite or offsite landfill, or recycled. Based on industry-average recycling rates, approximately 155,610 MT (171,000 tons), or 45 percent, of the ash content would be recycled, leaving a total of approximately 190,190 MT (209,000 tons) for disposal (ACAA 2007). In addition, approximately 300,300 MT (330,000 tons) of scrubber waste would be disposed of or recycled each year.
Based on industry-average recycling rates, approximately 237,000 MT (260,700 tons), or 79 percent of gypsum scrubber waste would be recycled (ACAA 2007). As mentioned in the Air Quality section, this waste also would contain levels of uranium and thorium in concentrations similar to those found in naturally occurring granites, shales, and phosphate rocks (USGS 1997). In addition to coal combustion wastes, a supercritical coal-fired alternative Draft NUREG-1437, Supplement 38 8-40 December 2008
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Disposal of the waste could noticeably affect land use and ground water quality, but with appropriate management and monitoring, it would not destabilize any resources. After closure of the waste site and revegetation, the land could be available for other uses.
In May 2000, EPA issued a "Notice of Regulatory Determination on Wastes from the Combustion of Fossil Fuels" (EPA 2000b). EPA concluded that some form of national regulation is warranted to address coal combustion waste products because (1) the composition of these wastes could present danger to human health and the environment under certain conditions, (2) EPA has identified 11 documented cases of proven damages to human health and the environment by improper management of these wastes in landfills and surface impoundments, (3) disposal practices are such that, in 1995, these wastes were being managed in 40 to 70 percent of landfills and surface impoundments without reasonable controls in place, particularly in the area of ground water monitoring, and (4) EPA identified gaps in State oversight of coal combustion wastes. Accordingly, EPA announced its intention to issue regulations for disposal of coal combustion waste under Subtitle D of the Resource Conservation and Recovery Act (RCRA). EPA has not yet issued these regulations.
In addition to the waste streams generated during plant operations, considerable debris would be generated during construction of a coal-fired facility. Crews would likely dispose of land-clearing debris on site.
For all of the preceding reasons, the NRC staff considers the impacts of managing waste generated by a coal facility (construction and operating phases) to be MODERATE-the impacts would be clearly noticeable, but would likely not destabilize any important resource.
Human Health Coal-fired power generation introduces risks to workers at many points in the fuel cycle. These risks include risks from mining coal and limestone, transportation of raw materials, plant construction and operation, and waste management. There also may be public health risks from a coal-fired plant's operation (routine emissions and coal-pile fires) and fuel cycle (mining and transportation).
During construction activities there would be risk to workers from typical industrial incidents and accidents. Accidental injuries are not uncommon in the construction industry and accidents resulting in fatalities do occur. However, the occurrence of such events is mitigated by the use of proper industrial hygiene practices, complying with worker safety requirements, and training.
Occupational and public health impacts during construction are expected to be controlled by continued application of accepted industrial hygiene protocols, occupational health and safety controls, and radiation protection practices.
In the GElS, the NRC staff stated that human health impacts (cancer and emphysema) could arise from chronic exposures to coal-fired plant emissions. Emissions contain pollutants such as toxins, particulates, and low levels of naturally occurring radioactive elements. However, Federal and/or State agencies regulate these emissions and enforce emissions standards that are designed to be protective of human health. As a result, power plants install appropriate emission controls to meet regulatory standards.
Coal-fired generation would introduce mechanical sources of noise that would be audible off site. Sources contributing to total noise produced by plant operations are both continuous and December 2008 8-41 Draft NUREG-1437, Supplement 38
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Based on the cumulative potential impacts of construction activities, emissions, and noise on human health, the !\\IRC staff considers the impact of constructing and operating a new coal-fired facility to be MODERATE.
Socioeconomics Construction of a coal-fired facility at an alternate site would take approximately 4 years (DOE/EIA 2007b). Based on estimates given in Table 8.1 of the GElS, the peak workforce is estimated to range from 1.2 to 2.5 additional workers per MW(e) during the construction period.
For the 2200-MW(e) plant utilized in this analysis, the peak workforce would range from approximately 2640 to as many as 5500 workers during the 4-year construction period (NRC 1996). During construction, the surrounding communities would experience demands on housing and public services unless some of the workforce is composed of local residents. In the GElS, the NRC staff stated that socioeconomic impacts would depend on the location of the new plant. For example, at a rural site more of the peak construction workforce would need to relocate (temporarily or permanently) to the area to work. Therefore, socioeconomic impacts could range from SMALL to LARGE depending on whether workers would relocate to be near the site, as well as depending on the size and makeup of the existing community.
At the end of construction, the local population would be affected by the loss of as many as 5000 construction jobs. However, this loss would be partially offset by a postconstruction permanent employment rate of 0.25 workers per MW(e) based on Table 8.2 of the GElS, or a total of 550 total workers. An additional construction workforce would be needed for the decommissioning of IP2 and IP3 which could temporarily offset the impacts of the lost construction and IP2 and IP3 jobs at the site.
The coal-fired plant would provide new tax revenue to its community. Because this plant would be located in another community, it would have a positive impact on its community while the shutdown of IP2 and IP3 will have a negative impact on the tax base of the IP2 and IP3 community.
The NRC staff concludes that the overall socioeconomic impacts of changes in the local population from the influx of the construction workforce and changes to community tax revenues could be SMALL to LARGE during construction and SMALL to MODERATE during operation, depending on the size and economic structure of the affected communities.
Transportation During the 4-year construction period of the coal-fired unit, as many as 2600 to 5500 construction workers may be working at the site. During this same time period, trucks and trains would likely be delivering construction materials to the site. The addition of these workers would increase traffic on highways and local roads that lead to the construction site. The impact of this additional traffic could have a MODERATE to LARGE impact on nearby roadways, particularly if Draft NUREG-1437, Supplement 38 8-42 December 2008
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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 42 Environmental Impacts of License Renewal the alternate site is in a rural area. Impacts associated with plant operating personnel commuting to work are likely to be SMALL.
For rail transportation of coal and limestone to the alternate site, impacts are likely to range from SMALL to LARGE, depending on local rail characteristics. On average, more than ten 100-car trains per week would deliver coal to the new generating station, and two 10-car trains per week would deliver limestone to the facility. Transportation impacts associated with coal and limestone delivery could range from SMALL to LARGE Overall, transportation impacts could range from MODERATE to LARGE during construction, and SMALL to LARGE during operation.
Aesthetics At an alternate site, plant buildings, exhaust stacks, cooling towers, and cooling tower plumes would create aesthetic impacts. The coal-fired alternative's four power plant units would be up to 200 ft (61 m) tall and may be visible off site in daylight hours. The three exhaust stacks could be up to 600 ft (183 m) high (at least 500'ft (152 m) for good engineering practice). If the coal-fired alternative makes use of natural-draft cooling towers, then additional visual impacts will occur from the towers, which may be several hundred feet tall and topped with condensate plumes. Mechanical-draft towers would also generate condensate plumes, but would be markedly shorter than natural-draft towers (or they may use hybrid towers like the alternative described in Section 8.1 of this draft SEIS). Other buildings on site may also affect aesthetics, as could construction of new transmission lines. Noise and light from plant operations, as well as lighting on plant structures, may be detectable off site.
Aesthetic impacts at the plant site would be minimized if the plant were located in an industrial area adjacent to other power plants or industrial facilities. Development of a new coal-fired facility at an undeveloped alternate site, however, would entail construction of a new transmission line and a new rail spur to bring coal and lime to the plant. The rail spur and transmission line could extend many miles from the site to tie-in points with existing rail and transmission systems. The visual intrusion of these two linear elements, particularly the transmission line, could be significant.
Overall the aesthetic impacts associated with locating at an alternate site would be categorized as MODERATE to LARGE for an undeveloped site, and may be SMALL to MODERATE at a site previously developed for industrial uses.
Historic and Archeological Resources A cultural resource inventory would be needed for any property that has not been previously surveyed. The survey would include an inventory of Field cultural resources, identification and recording of existing historic and archeological resources, and possible mitigation of adverse effects from subsequent ground-disturbing actions related to physical expansion of the plant site. The studies would likely be needed for all areas of potential disturbance at the proposed plant site and along associated corridors where new construction would occur (e.g., roads, transmission corridors, rail lines, or other ROWs).
Historic and archeological resource impacts can generally be effectively managed and, as such, would be considered SMALL to MODERATE at a new undeveloped site, depending on the sensitivity of the site. For a previously developed site, most of which have already been December 2008 8-43 Draft NUREG-1437, Supplement 38
Environmental Impacts of License Renewal 1
intensively developed, impact on cultural and historic resources would also be SMALL.
2 Previous development would likely have either removed items of archeological interest or may 3
have included a survey for sensitive resources. Any significant resources identified would have 4
to be handled in accordance with the NHPA.
As described in Section 8.2 of this draft SEIS, no environmental impacts were identified that 7
would result in disproportionately high and adverse environmental impacts on minority and low 8
income populations if IP2 and IP3 were shut down.
9 Impacts at the location of the new four-unit coal-fired plant would depend upon the site chosen 10 and the nearby population distribution, but would likely be SMALL to MODERATE for most 11 alternate sites, but could reach LARGE. For previously developed industrial sites, impacts 12 could be larger or smaller, depending on the relative proximity of low-income populations.
13 Table 8-3. Summary of Environmental Impacts of the Coal-Fired Plant Alternative Located 14 at an Alternate Site Impact Category Impact Comment Land Use MODERATE to Uses up to 1500 ha (3700 ac) for plant, offices, parking, and LARGE waste disposal; additional impacts from transmission line and rail spur, as well as coal and limestone mining.
Ecology MODERATE to Impacts to terrestrial ecology would likely be MODERATE to LARGE LARGE, while impacts to aquatic ecology would likely be SMALL.
Draft NUREG-1437, Supplement 38 8-44 December 2008
1 Environmental Impacts of License Renewal Table 8-3 (continued)
Impact Category Impact Comment Water Use and SMALL to With closed-cycle cooling, the impact would likely be SMALL, Quality MODERATE though it would depend on the volume of water withdrawn and discharged and the characteristics of the surface water body.
Air Quality MODERATE SOx: 5230 MT/yr (5748 tons/yr)
NOx: 1129 MT/yr (1351 tons/yr)
Total suspended particulates: 175 MT/yr (192 tons/yr)
PM1Q: 40 MT/yr (44 tons/yr)
CO: 1129 MT/yr (1315 tons/yr)
Small amounts of mercury and other hazardous air pollutants Extensive emissions controls and regulations limit impacts to MODERATE.
Waste MODERATE Total waste production would be approximately 645,000 MT/yr (710,000 tons/yr) of ash (after some is recycled) and scrubber sludge requiring approximately 150 ha (370 ac) for disposal during the 40-year life of the plant. The plant would also generate relatively small amounts of conventional, hazardous, and universal wastes during operation.
Human Health MODERATE Impacts are uncertain, but considered MODERATE as the plant would comply with health-informed standards in the CAA and other relevant emissions regulations. Minor risk to workers associated with construction and industrial accidents.
Socioeconomics SMALL to Construction impacts depend on location, but would be LARGE LARGE if the plant is located in an area that is rural or is growing less quickly than areas near lP2 and lP3. IP2 and IP3 communities may lose tax revenue and employment, though economic growth would likely offset much of this loss.
Impacts from placement of a plant near to an urban area may be MODERATE. Impacts during operation would be smaller than during construction.
Transportation MODERATE to Transportation impacts could be MODERATE to LARGE, LARGE during construction, though operational impacts may be smaller during operations.
Aesthetics SMALL to The greatest impacts would be from new transmission lines, LARGE plant stacks, and rail lines to transport coal and lime. Impacts would be lareest at an undeveloeed site.
December 2008 8-45 Draft NUREG-1437, Supplement 38
1 Environmental Impacts of License Renewal Table 8-3 (continued)
Impact Category Impact Comment Historic and SMALL to Construction at an alternate location would necessitate Archeological Resources MODERATE cultural resource studies; construction would likely avoid highly sensitive areas.
Environmental SMALL to LARGE Impacts would vary depending on population distribution and Justice location of the new plant site.
2 8.3.2 Natural Gas-Fired Combined-Cycle Generation 3
In this section, the NRC staff examines the environmental impacts of the natural gas-fired 4
alternative at both IP2 and IP3 and at an alternate site. The NRC staff assumed that a natural 5
gas-fired plant would use a closed-cycle cooling system.
S This replacement natural gas-fired plant would likely use combined-cycle technology.
7 Compared to simple-cycle combustion turbines, combined-cycle plants are significantly more 8
efficient. and thus provide electricity at lower costs. Combined-cycle gas-fired power plants also 9
tend to operate at markedly higher thermal efficiencies than other fossil-fuel or nuclear power 10 plants, and require less water for condenser cooling than other thermoelectric alternatives. As 11 such, the gas-fired alternative would require smaller cooling towers and substantially less 12 makeup water than the cooling system proposed in Section 8.1.1 of this draft SEIS. Typically.
13 these plants support intermediate loads but they are capable of supporting a baseload duty 14 cycle; thus they provide an alternative to renewing the IP2 and IP3 operating licenses. Levitan 15 and Associates indicated that gas-fired generation was the most likely alternative to take the 16 place of IP2 and IP3 (2005).
17 The NRC evaluated environmental impacts from gas-fired generation alternatives in the GElS.
18 focusing on combined-cycle plants (NRC 1996). In a combined-cycle unit. hot combustion 19 gases in a combustion turbine rotate the turbine to generate electricity. Waste combustion heat 20 from the combustion turbine is routed through a heat-recovery steam generator. which then 21 powers a steam turbine electrical generator. The combination of two cycles can be as much as 22 60 percent efficient.
23 Combined-cycle gas turbines that are currently on the market can operate at a heat rate as low 24 as 5700 BTU/kWh for units with net output of 400 MW(e) (GE Energy 2005). These units are 25 more efficient than the 408-MW(e) units Entergy considered in its ER, and would consume 26 about 30 percent less fuel, while producing approximately 30 percent fewer emissions per unit 27 of electrical output. Using five, 400-MW(e) units would slightly underestimate the total impact to 28 some resources, but it provides a useful approximation using more-current technology. Other 29 options would include four. 530-MW(e) units with heat rates of approximately 6000 BTU/kWh 30 (GE Energy 2005). resulting in 2120 MW{e) net output.
31 The NRC staff discusses the overall impacts of the natural gas-fired generating system in the 32 following sections and summarizes them in Table 8-4 of this draft SEIS. The extent of impacts 33 at an alternate site would depend on the location of the site selected.
Draft NUREG-1437, Supplement 38 8-46 December 2008
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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 42 43 44 Environmental Impacts of License Renewal Land Use Existing facilities and infrastructure would be used to the extent practicable if a gas-fired complex were to be developed at IP2 and IP3. Specifically, the NRC staff assumed that this alternative would use the existing switchyard, offices, and transmission line ROWs. However, a new mechanical-draft cooling tower would need to be constructed to support the new closed-cycle cooling system.
The GElS estimated that 45 ha (110 ac) are needed for a 1000-MW(e) natural gas-fired facility.
Scaling up for the 2000-MW(e) facility would indicate a land requirement of approximately 90 ha (220 ac). The NRC staff notes that some existing combined-cycle facilities require less space than the GElS indicates, and may be more on the order of 16 ha (40 ac) per 1000 MW(e).
(Entergy's withdrawn proposal for combined-cycle capacity on the IP2 and IP3, for example, required only 2 ha (5 ac) for 330 MW(e) of capacity (as noted in Levitan and Associates 2005)).
The IP2 and IP3 site is only 98 ha (239 ac) with some land unsuitable for construction. Also, much of the site is covered by the IP2 and IP3 containment structures, turbine buildings, other IP2 and IP3 support facilities, and AGTC gas pipeline. Land covered by some IP2 and IP3 facilities would not be available until decommissioning, though land covered by some support facilities may be available prior to the end of the current license. The AGTC pipeline ROW would remain unavailable. Based on previous Entergy proposals and experience at other combined-cycle plants, however, the NRC staff finds it possible that a gas-fired alternative could be constructed and operated on the IP2 and IP3 site.
As reported by Levitan and Associates, Inc. (2005), the existing Algonquin pipeline that passes through the IP2 and IP3 site may be adequate for a 330-MW(e) simple-cycle plant that would operate in peaking mode during the summer season, when gas supplies are less constrained by winter-season heating demands. Levitan and Associates (2005) concluded that SUbstantial and expensive pipeline upgrades would probably be necessary to supply natural gas to a combined-cycle alternative throughout the winter heating season and for the additional baseload capacity throughout the year. Given firm demand for natural gas during the winter heating season, it is possible that the gas-fired alternative may need to burn fuel oil during several weeks of the year, should conditions of limited supply emerge. This practice is common at gas-fired power plants in the northeastern United States.
The environmental impacts of locating the gas-fired generation facility at an alternate location would depend on the past use of the location. If the site is a previously undisturbed site the impacts would be more significant than if the site was a previously developed site. Construction and operation of the gas-fired facility at an undeveloped site would require construction of a new cooling system, switchyard, offices, gas transmission pipelines, and transmission line ROWs. A previously industrial site may have closer access to existing infrastructure, which would help to minimize environmental impacts. A gas-fired alternative constructed at the IP2 and IP3 site would have direct access to a transmission system, an existing pipeline ROW, and an existing dock to receive major components.
Regardless of where a gas-fired alternative is built, the GElS indicates that additional land would be required for natural gas wells and collection stations. According to the GElS, a 1000 MW(e) gas-fired plant requires approximately 1500 ha (3600 ac) for wells, collection stations, and pipelines, or about 3000 ha (7300 ac) for a 2000-MW(e) facility (NRC 1996).
Overall, land use impacts of the gas-fired alternative are considered SMALL to MODERATE at December 2008 8-47 Draft NUREG-1437, Supplement 38
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Ecology At the IP2 and IP3 site, there would be terrestrial ecological impacts associated with siting a gas-fired facility. These impacts would be similar to those described in Section 8.1.1.2 of this draft SEIS, which discusses the ecological impacts of the construction of a closed-cycle cooling system to support IP2 and IP3. The gas-fired facility would likely utilizing most previously undeveloped property on site. Improvements to the existing pipeline network would also be necessary, with some impacts along the already-disturbed ROW. Levitan and Associates (2005) indicated that no transmission system improvements would be necessary to accommodate the gas-fired alternative at the IP2 and IP3 site. Overall, construction effects are limited in both scope and duration. Impacts to terrestrial ecology of constructing the gas-fired alternative on site are likely to be SMALL.
Ecological impacts at an alternate site would depend on the nature of the land used for the plant and the possible needs for a new gas pipeline and/or transmission lines. Construction of the transmission line and construction and/or upgrade of the gas pipeline to serve a new plant at an alternate site would have substantial ecological impacts, though these would be temporary.
Ecological impacts to the plant site and utility ROWs could include impacts on threatened or endangered species, habitat loss or fragmentation, reduced productivity, and a local reduction in biological diversity. Impacts to terrestrial ecology, however, are likely to be smaller than for a coal-fired facility and would likely be SMALL to MODERATE, depending on site characteristics.
Operation of the gas-fired alternative at the IP2 and IP3 site or another site would likely not introduce new terrestrial ecological effects after construction.
The gas-fired alternative is unlikely to create significant impacts for aquatic ecology during construction, regardless of location. Because the plant has a relatively small footprint, and because crews would likely implement some measures to control site runoff, it is unlikely that impacts to aquatic ecology would be noticeable. Noticeable effects could occur during construction if new transmission line ROWs or gas pipelines would need to cross streams or rivers.
During operations, aquatic ecological resources would experience significantly smaller effects than they would from a comparable nuclear or coal-fired power plant. The combined-cycle gas plant using closed-cycle cooling would require less than half the cooling water of IP2 and IP3 using closed-cycle cooling. Construction of intake and discharge structures at an alternate site could trigger some impacts to aquatic ecology, but because these impacts are very limited in scope and time, they will likely not affect any important resource characteristics. Thus, aquatic ecological impacts of the gas-fired alternative are likely to be SMALL.
At an alternate site, impacts to ecology may range from SMALL to MODERATE, while they are likely to be SMALL if constructed at the existing IP2 and IP3 site.
Water Use and Quality Surface Water: Combined-cycle gas-fired plants are highly efficient and require less cooling water than other generation alternatives. Plant discharges would consist mostly of cooling Draft NUREG-1437, Supplement 38 8-48 December 2008
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tower blowdown, with the discharge having a slightly higher temperature and increased 2
concentration of dissolved solids relative to the receiving water body, as well as intermittent, low 3
concentrations of biocides (e.g., chlorine). All discharges from a new plant at the IP2 and IP3 4
site would be regulated through a New York SPDES permit, which would be issued by NYSDEC. Finally, some erosion would probably occur during construction (NRC 1996). though 6
the GElS indicates this effect would be SMALL. Plant construction crews would employ at least 7
basic runoff control measures. Because crews would likely not have to construct entirely new 8
intake structures, transmission lines, or a gas pipeline, most activities that could affect water use 9
and quality will not occur for an alternative constructed at the IP2 and IP3 site. Like the existing IP2 and IP3, a gas-fired alternative located on the site would likely not rely on ground water.
11 Overall, impacts to water use and quality at the IP2 and IP3 site from a gas-fired alternative 12 would likely be SMALL for both construction and operation.
13 At an alternate site, a gas-fired alternative would likely rely on surface water for cooling makeup 14 water and blowdown discharge. Intake and discharge would involve relatively small quantities of water compared to once-through cooling and less than the nuclear or coal-fired alternatives.
16 The impact on the surface water would depend on the volume of water needed for makeup 17 water, the discharge volume, and the characteristics of the receiving body of water. If a gas 18 fired plant discharges to surface water, the plant would have to meet the requirement of a 19 SPDES permit. The NRC staff expects that any new facility would comply with requirements of the discharge permits issued for its operation. Thus discharges from the plant would be legally 21 obligated to conform to applicable water quality standards. Water withdrawals from a small river 22 or cooling pond, however, could lead to potential water use conflicts. The impacts would be 23 SMALL to MODERATE during operations depending on receiving water characteristics. During 24 construction, some erosion would probably occur though the GElS indicates this would have a SMALL effect (NRC 1996).
26 Ground Water: IP2 and IP3 currently use no ground water. It is likely that a gas-fired 27 alternative at the IP2 and IP3 site would also use no ground water. Impacts at the IP2 and IP3 28 site would thus be SMALL. Ground water impacts from operations at an alternate site may vary 29 widely depending on whether the plant uses ground water for any of its water needs, though it would be unlikely that a plant on an alternate site would use ground water for cooling system 31 makeup water given the quantity of water required. Ground water impacts at an alternate site 32 could range from SMALL to MODERATE, depending on the quantity of ground water used and 33 characteristics of aquifers used. Construction-stage impacts at both the existing site and a new 34 site are likely to be SMALL.
Air Quality 36 Natural gas is a clean-burning fuel relative to coal. The gas-fired alternative would release 37 emissions similar to those from the coal-fired alternative, but in lesser quantities.
38 The NRC staff calculates that approximate emissions from the five-unit, 2000-MW gas-fired 39 alternative using combined-cycle gas units with a heat rate of about 5700 BTU/kWh would be:
SOx-135 MT/yr (148 tons/yr) 41 NOx-444 MT/yr (475 tons/yr) 42 CO-93 MT/yr (135 tons/yr)
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Filterable particulates (PM 10)-75 MT/yr (83 tons/yr)(3) 2 Gas-fired power plants primarily emit pollutants as a result of combustion conditions. These 3
pollutants include NOx, CO, and particulates. Regulations in place to reduce potential health 4
effects from air emissions, especially those promulgated in response to the CM, drive the types of emissions controls this gas-fired alternative would use to limit its effects on air quality. CAA 6
mechanisms like new source performance standards, nonattainment areas, State 7
implementation plans, and specialized programs, including one that limited overall NOx 8
emissions throughout the Eastern United States, all drive emissions control technologies used 9
in this gas-fired alternative.
NOx is typically the pollutant of greatest concern for a gas-fired power plant. Given the proper 11 atmospheric conditions, NOx helps to form ozone, as well as smog. The gas-fired alternative in 12 this case relies on selective catalytic reduction (SCR) to reduce NOx emissions. As previously 13 discussed, IP2 and IP3 are located within the New Jersey-New York-Connecticut Interstate Air 14 Quality Control Region (40 CFR 81.13). All of the States of New Jersey and Connecticut, as well as several counties in Central and Southeastern New York within a 80-km (50-mi) radius of 16 IP2 and IP3, are designated as nonattainment areas for ozone (8-hour standard) (EPA 2008b).
17 Operators or owners of a gas-fired power plant constructed in a nonattainment area would need 18 to purchase offsets for ozone precursor emissions. In this case, NOx is the major ozone 19 precursor emitted by a coal-fired power plant. In accordance with NYSDEC regulations, "Emission offsets must exceed the net increase in annual actual emissions from the air 21 contamination source project" (NYSDEC, Chapter 3, Parts 231-15). By design, this regulatory 22 requirement should result in a net reduction in ozone emissions in the region.
23 A new gas-fired generating plant located in a nonattainment area (like that at the IP2 and IP3 24 site) would need a nonattainment area permit and a Title IV operating permit under the CAA.
The plant would need to comply with the new source performance standards for such plants set 26 forth in 40 CFR Part 60, Subpart DA. The standards establish limits for particulate matter and 27 opacity (40 CFR 60.42(a)), S02 (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)).
28 In December 2000, EPA issued regulatory findings on emissions of HAPs from electric utility 29 steam-generating units (EPA 2000a). Natural gas-fired power plants were found by EPA to emit arsenic, formaldehyde, and nickel (EPA 2000a). Unlike coal-and oil-fired plants, EPA did not 31 determine that emissions of HAPs from natural gas-fired power plants should be regulated 32 under Section 112 of the CM.
33 A natural gas-fired plant would have unregulated CO2emissions of about 117 pounds per 34 MMBtu (DOE/EIA 2008a). The NRC staff calculates that a five-unit gas-fired alternative with technologically advanced turbines rated at 5700 BTU/kWh would emit approximately 4,965,000 36 MT (5,462,000 tons) of CO2per year. Section 6.2 of this draft SEIS contains a discussion of 37 current and future relative GHG emissions from several energy alternatives including coal, 38 natural gas, nuclear, and renewables. Other emissions and losses during natural gas 39 production or transportation could also increase the relative GHG impact.
Construction activities also would result in some air effects, including those from temporary 41 fugitive dust, though construction crews likely would employ dust control practices to limit this 42 impact. Exhaust emissions also would come from vehicles and motorized equipment used (3)
Additional particulate emissions associated with the cooling towers were not quantified.
Draft NUREG-1437, Supplement 38 8-50 December 2008
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The overall air quality impact for operation of a new natural gas-fired plant at the IP2 and IP3 or at an alternate site would be SMALL to MODERATE, depending on air quality in the surrounding airshed. Air quality impacts during construction would be SMALL.
Waste Burning natural gas fuel generates small amounts of waste. However, a plant using SCR to control NOx will generate spent SCR catalyst and small amounts of solid waste products (i.e.,
ash). In the GElS, the NRC staff concluded that waste generation from gas-fired technology would be minimal (NRC 1996). Waste generation impacts would be minor and would not noticeably alter any important resource attribute.
Constructing a gas-fired alternative would generate small amounts of waste, though many construction wastes can be recycled. Land-clearing debris from construction at an alternate location could be land filled on site. Overall, the waste impacts would be SMALL for a natural gas-fired plant sited at an alternate site.
Cooling towers for a new gas-fired alternative would be much smaller than those proposed in 8.1.1, and would not need to be constructed on slopes near the Hudson. Waste generation from plant construction, then, is much less than in 8.1.1. The waste-related impacts associated with construction of a five-unit gas-fired plant with closed-cycle cooling systems at the IP2 and IP3 site would be SMALL.
Human Health Human health effects from the operation of a gas-fired alternative with SCR emissions controls would likely not be detected or would be sufficiently minor that they would neither destabilize nor noticeably alter any important attribute of the resource.
During construction activities there would be a risk to workers from typical industrial incidents and accidents. Accidental injuries are not uncommon in the construction industry, and accidents resulting in fatalities do occur. However, the occurrence of such events is mitigated by the use of proper industrial hygiene practices, complying with worker safety requirements, and training. Occupational and public health impacts during construction are expected to be controlled by continued application of accepted industrial hygiene protocols, occupational health and safety controls, and radiation protection practices. Fewer workers would be on site for a shorter period of time to construct a gas-fired plant than other new generation alternatives, and so exposure to occupational risks tends to be lower than other alternatives.
Overall, the impacts on human health of a natural gas-fired alternate sited at IP2 and IP3 or at an alternate site would be considered SMALL.
Socioeconomics Construction of a natural gas-fired plant would take approximately 3 years (DOE/EIA 2007b).
Peak labor force would be approximately 1090 workers (NRC 1996). The NRC staff assumed that construction of an offsite alternative would take place while IP2 and IP3 continue operation and would be completed by the time the plants permanently cease operations. Entergy December 2008 8-51 Draft NUREG-1437, Supplement 38
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At the end of construction, the local population would be affected by the loss of as many as 1090 construction jobs. However, this loss would be partially offset by a postconstruction permanent employment. An additional construction workforce would be needed for the decommissioning of IP2 and IP3 which could temporarily offset the impacts of the lost construction and IP2 and IP3 jobs at the IP2 and IP3 site. A new gas-fired plant at the IP2 and IP3 site would offset a small portion of lost employment, though, according to Levitan and Associates, it may provide more revenues to the surrounding jurisdictions than IP2 and IP3 do (2005). The large and diverse economic base of the region would help to offset or minimize the significance of job losses.
The NRC staff concludes that the overall socioeconomic impacts from the gas-fired alternative could be SMALL to MODERATE during construction and could be SMALL to MODERATE during operation at most sites, depending largely on tax impacts.
Transportation I mpacts associated with transportation of the construction and operating personnel to the plant site would depend on the population density and transportation infrastructure in the vicinity of the site. During the 3-year construction period of the gas-fired facility, approximately 1090 construction workers may be working at the site. The addition of these workers would increase traffic on highways and local roads that lead to the construction site. The impact of this additional traffic would have a SMALL to MODERATE impact on nearby roadways, depending on road infrastructure and existing traffic demands. Rural areas would typically experience a greater impact than urban or suburban areas. Impacts associated with plant operating personnel commuting to and from work are considered SMALL at all sites. Because the gas-fired alternative relies on pipelined fuel, transportation impacts from natural gas supply are not likely to be noticeable, though plant operators will have to ensure that sufficient gas transportation capacity exists.
Aesthetics The combustion turbines and the heat-recovery boilers of the gas-fired plant would be relatively low structures compared to existing plant facilities, but could be visible from the Hudson River if located at the current IP2 and IP3 site. Some facility structures could be visible from offsite locations as well. The impact on aesthetic resources of a gas-fired plant is likely less than the impact the current nuclear plant, excepting when cooling towers produce noticeable plumes.
Overall, aesthetic impacts from a gas-fired plant constructed at the IP2 and IP3 site would likely be SMALL.
At an alternate site, new buildings, cooling towers, cooling tower plumes, and electric transmission lines would be visible off site. Visual impacts from new transmission lines or a pipeline ROW would also be significant, though these may be minimized by building near existing transmission lines or on previously developed land. Additionally, aesthetic impacts would be minimized if the plant were located in an industrial area adjacent to other power plants. Overall, the aesthetic impacts associated with the gas-fired alternative at alternate site could be SMALL to LARGE.
Historic and Archeological Resources Draft NUREG-1437, Supplement 38 8-52 December 2008
Environmental Impacts of License Renewal 1
According to the IP2 and IP3 relicensing case study in the GElS, archeological sites at or near 2
the power plant were disturbed before construction of the plant, and so the impacts from plant 3
construction and operation were not significant (NRC 1996). Section 2.2.9.2 of this draft SEIS 4
also supports this conclusion.
5 A cultural resource inventory would be needed for any property at a new site or adjacent to the 6
IP2 and IP3 site that has not been previously surveyed. The survey would include an inventory 7
of field cultural resources, identification and recording of existing historic and archeological 8
resources, and possible mitigation of adverse effects from subsequent ground-disturbing actions 9
related to physical expansion of the plant site. The studies would likely be needed for all areas 10 of potential disturbance at the proposed plant site and along associated corridors where new 11 construction would occur (e.g., roads, transmission corridors, rail lines, or other ROWs).
12 The impacts to historic and archeological resources for the gas-fired alternative at the IP2 and 13 IP3 site would be similar to those described in Section 8.1.1.2 of this draft SEIS for the closed 14 cycle cooling alternative, can generally be effectively managed, and are considered SMALL.
15 Historic and archeological resource impacts can generally be effectively managed and, as such, 16 would be considered SMALL to MODERATE at a new, undeveloped site. For a previously 17 developed site, impact on cultural and historic resources would also be SMALL. Previous 18 development would likely have either removed items of archeological interest or may have 19 included a survey for sensitive resources. Any significant resources identified would have to be 20 handled in accordance with the NHPA.
21 Environmental Justice 22 As described in Section 8.1.1.2 of this draft SEIS, impacts to the environment or community 23 from actions at the IP2 and IP3 site, including the construction of a gas-fired plant, are not likely 24 to disproportionately affect minority or low-income populations because these populations in the 25 area around the site are proportionately small compared to the the geographical region's 26 population. Therefore, the gas-fired alternative constructed at the IP2 and IP3 site would have 27 SMALL impacts on environmental justice.
28 Impacts at an alternate site would depend upon the site chosen, nearby population 29 characteristics, and economic conditions. These impacts would range from SMALL to LARGE, 30 depending on impacts and the distribution of low-income and minority populations.
31 Table 8-4. Summary of Environmental Impacts of the Natural Gas-Fired Plant Alternative 32 Located at IP2 and IP3 and an Alternate Site Impact Category 5 Units Located at IP2 and IP3 Site Impact Comments 5 Units Located at Alternative Site Impact Comments Land Use SMALL to Onsite land used; most SMALL to About 92 ha (224 ac)
MODERATE has been previously LARGE needed for plant disturbed.
construction; additional land may be needed for pipeline and transmission line ROWs.
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Environmental Impacts of License Renewal Ecology SMALL Water Use and SMALL Quality Air Quality SMALL to MODERATE Both terrestrial and SMALL to Impacts would depend aquatic impacts would MODERATE on the nature of the be SMALL because land used for the plant the plant uses mostly and whether a new disturbed land and gas pipeline and/or uses relatively little transmission lines are water.
needed; cooling water iwould have SMALL aquatic resource impacts.
Minor erosion and SMALL to With closed-cycle sedimentation may MODERATE cooling, the impact occur during would likely be construction. The SMALL. Impact plant would use no depends on the groundwater.
volume of used and characteristics of the water body; impacts from water use conflicts could be MODERATE.
SOx: 135 MT/yr SMALL to Operational impacts (148 tons/yr)
MODERATE are the same as onsite NOx: 444 MT/yr plant but more (475 tons/yr) emissions from additional construction
- PM10 : 75 MT/yr activities.
(83 tons/yr)
CO: 93 MT/yr (102 tons/yr)
- CO2: 5 million MT/yr (5.5 million Draft NUREG-1437, Supplement 38 8-54 December 2008
1 Environmental Impacts of License Renewal Table 8-4 (continued) 5 Units Located at IP2 and IP3 5 Units Located at Alternative Site Impact Site Category Imeact Comments Imeact Comments Waste SMALL Small amounts of SMALL Small amounts of construction waste construction waste would be generated.
with some recycling options; land-clearing debris could be land filled on site.
Human Health SMALL Minor risk to workers SMALL Same as onsite plant.
associated with construction and industrial accidents.
Health effects from operational emissions are likely to be SMALL.
Socioeconomics SMALL to Impacts on housing SMALL to Construction impacts MODERATE and jobs in the area MODERATE would likely be no surrounding IP2 and larger than IP3 during onsite MODERATE at most construction and sites. The largest operation would be impacts occur during relatively minor based construction.
on the large population of the area surrounding IP2 and IP3.
Transportation SMALL to Increased traffic SMALL to Transportation impacts MODERATE associated with MODERATE associated with construction could be construction and noticeable, though the operating personnel to number of construction the plant site would workers is smaller than depend on the the number of workers population density and currently at IP2 and infrastructure in the IP3.
vicinity of the site.
Aesthetics SMALL The impact is likely SMALL to The greatest impacts less than the impacts LARGE would be from new of the current nuclear transmission lines, gas plant; more land would line ROW, and plant be cleared and new structures. Impacts structures built.
depend on the nature of the site.
December 2008 8-55 Draft NUREG-1437, Supplement 38
1 Environmental Impacts of License Renewal Table 8-4 (continued)
Impact Category 5 Units Located at IP2 and IP3 Site Impact Comments 5 Units Located at Alternative Site Impact Comments Historical and SMALL A cultural resources SMALL to An alternate location Archeological inventory would be MODERATE would necessitate Resource needed to identify, cultural resource evaluate, and mitigate studies; construction potential impacts from would likely avoid construction.
highly sensitive areas.
Impacts likely would be managed or mitigated.
Environmental SMALL No significant impacts SMALL to Impacts would vary Justice are anticipated that LARGE depending on could disproportion population distribution ately affect minority and location of the or low-income new plant site.
communities.
2 8.3.3 Purchased Electrical Power 3
Based on currently scheduled retirements and demand growth projections, the New York 4
Independent System Operator (NYISO) predicted in 2006 that up to 1600 MW(e) from new 5
projects not yet under construction would be needed by 2010 and a total of up to 3300 MW(e) 6 by 2015 (National Research Council 2006).
7 Within the New York Control Area (NYCA), State power regulators require that load-serving 8
entities (LSE), or power buyers, purchase enough generating capacity to meet their projected 9
needs plus a reserve margin (National Research Council 2006). Entergy is not an LSE. In New 10 York, Entergy owns and operates power plants, but not transmission or distribution systems; 11 therefore, Entergy does not purchase power from other power generators. To replace the 12 output from IP2 and IP3, LSEs, like Consolidated Edison, would need to purchase additional 13 electric power from other sources, which could include new coal-and gas-fired power plants or 14 renewable alternatives, or it could purchase power from existing facilities at other sites outside 15 the NYCA (National Research Council 2006).
16 Power sources within I\\JYCA have an installed capacity of about 38,000 MW(e) and more than 17 6,300 km (4,000 mi) of high-voltage transmission lines (National Research Council 2006). The 18 current power transmission infrastructure makes it difficult to purchase power from outside the 19 southern regions of the NYCA (namely the New York City and Long Island load zones) because 20 there are power transmission constraints or "bottlenecks" between the southern load zones and 21 other power generating areas to the east and north, including Canada. These neighboring 22 areas would be needed to supply additional purchased power to replace power generated by 23 IP2 and IP3. Because of the bottlenecks in the transmission lines, new transmission capacity 24 would likely be necessary to efficiently move purchased power into the southern load zones and Draft NUREG-1437, Supplement 38 8-56 December 2008
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Such new transmission capacity would likely come in the form of either an expansion of the existing high-voltage alternating current transmission system or the addition of new high-voltage direct current transmission facilities (National Research Council 2006).
The National Research Council found that improvements in transmission capability could significantly relieve congestion in the NYCA and increase delivery capacity from existing and potential electric generation resources to the southern load zones. The Council has proposed a 550-MW(e) west-to-east line across the Hudson River and a new north-to-south transmission line (up to 1000 MW) for better access to upstate New York and Canadian electric resources to provide useful capacity in the 2010 and 2015 time period (National Research Council 2006).
However, a variety of institutional and financial obstacles often stand in the way of such plans.
In 2006. the Council determined that a "concerted, well-managed. and coordinated effort would be required to replace IP2 and IP3 by 2015. Replacement in the 2008-2010 time frame would be considerably more difficult, probably requiring extraordinary, emergency-like measures to achieve" (National Research Council 2006).
As of March 2008. New York Regional Interconnect. Inc. (NYRI). was seeking the approval of the New York Public Service Commission (NYPSC) to build a 306-km (190-mi) transmission line with a rated power flow of 1200 MW(e) from the Town of Marcy in Oneida County to the towns of Hamptonburgh and New Windsor in Orange County, New York. In accordance with the NYRI application to the NYPSC. overhead transmission lines will make up approximately 89 percent of the proposed route, and underground cable will constitute the remainder of the route (NYRI 2008). NYRI has placed the proposed route within or parallel to existing or inactive railroads and energy ROWs for approximately 78 percent of its distance. For the remaining 22 percent of its distance. NYRI will construct the transmission lines in undeveloped areas or areas where there are no existing ROWs. The proposed transmission corridor includes 1155 ha (2855 ac).
If approved, NYRI will clear 768 ha (1899 ac) of forested habitat during construction. While the proposed route minimizes the amount of land clearing and habitat destruction necessary, the proposed route also crosses sensitive habitats such as streams and wetlands (NYRI 2008).
While NYRI has proposed to construct additional transmission capacity that could be used to import power into the southern load zones for the NYCA, the proposed 1200-MW(e) capacity is not sufficient to completely replace the generating capacity of IP2 and IP3. Also, the project faces many hurdles before construction can begin. Since the NYRI project is, at this time, the only serious transmission project proposed in the NYCA that would supply additional power to the New York City area, the NRC staff does not consider purchased power as a viable stand alone replacement aptian for IP2 and IP3. The NRC staff does, however, recognize that positive steps are being taken toward increasing the transmission capacity into the southern load zones of the NYCA. NYRI has evaluated the environmental impacts of its proposed project in Exhibit 4 of its petition to the NYPSC. Because the NRC staff does not consider purchased power as a viable stand-alone option for replacing IP2 and IP3, the staff did not conduct an independent evaluation of the NYRI findings. The NRC staff does. however, include purchased power across new transmission lines in the combination alternatives addressed in Section 8.3.7 of this draft SEIS.
December 2008 8-57 Draft NUREG-1437. Supplement 38
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8.3.4 Other Alternatives 2
Other generation technologies the NRC staff considered but determined to be individually 3
inadequate to serve as alternatives to IP2 and IP3 are discussed in the following paragraphs.
4 Conservation In this section, the NRC staff evaluates conservation(4)as an alternative to license renewal.
6 According to the American Council for an Energy-Efficient Economy (ACEEE) State Energy 7
Efficiency Scorecard for 2006, New York ranks seventh in the country in terms of 8
implementation of energy efficiency programs, suggesting that the State's conservation efforts 9
are significant when compared to other States (ACEEE 2006). New York scored well (2 out of
- 3) on tax incentives and appliance standards. The State scored low on energy efficiency 11 resource standards (0 out of 5) and utilities' per-capita spending on energy efficiency (5 out of 12 15), suggesting there is room for improvement in these areas.
13 The IP2 and IP3 ER (NYSDEC 2003a) dismissed conservation as a replacement alternative for 14 IP2 and IP3 because conservation does not meet the criterion of a "single, discrete source."
Also, because Entergy is a generator of electricity and not a distributor, it indicated that it does 16 not have the ability to implement regionwide conservation programs (Entergy 2007). However, 17 because of efforts made by the State of New York, and because additional conservation could 18 be a consequence of the no-action alternative, the NRC staff examines conservation in this draft 19 SEIS as an alternative to replace at least part of the output of IP2 and IP3.
The New York State Energy Research and Development Authority (NYSERDA) is pursuing 21 initiatives in conservation. Within NYSERDA, the Energy Efficiency Services Program and 22 Residential Efficiency and Affordability Program deploy programs and services to promote 23 energy efficiency and smart energy choices (NYSERDA 2007). According to the NYSERDA, 24 implementation of conservation in the following program areas has resulted in significant energy savings.
26 existing buildings and structures 27 new buildings and structures 28 market/workforce development 29 distributed generation and renewables industrial process 31 transportation 32 In 2006, the National Research Council's Committee on Alternatives to Indian Point for Meeting 33 Energy Needs developed a report that specifically addressed alternatives to IP2 and IP3 for 34 meeting Statewide power needs (National Research Council 2006). The document reports that in 2005, NYSERDA estimated that its energy efficiency programs had reduced peak energy 36 demands in New York by 860 MW(e). NYSERDA further forecasted that the technical potential (4)
The NRC staff notes that conservation typically refers to all programs that reduce energy consumption, while energy effiCiency refers to programs that reduce consumption without reducing services. For this section, some conservation measures considered by the NRC staff are also energy efficiency measures.
Draft NUREG-1437, Supplement 38 8-58 December 2008
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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 42 43 44 Environmental Impacts of License Renewal of its efficiency programs in New York would result in a cumulative 3800 MW(e)-reduction of peak load by 2012 and 7400 MW(e) by 2022 (National Research Council 2006). "Technical potential" refers to the complete deployment of all applications that are technically feasible.
In addition to the currently anticipated peak load reductions resulting from the NYSERDA energy efficiency initiatives, additional conservation measures and demand-side investments in energy efficiency, demand response, and combined heat and power facilities could significantly offset peak demand Statewide. The National Resource Council report estimates that peak demand could be reduced by 1000 MW(e) or more by 2010 and 1500 MW(e) by 2015 (National Research Council 2006).
The National Research Council estimates that economic potential peak demand in the I P2 and IP3 service area could be expanded by approximately 200 MW(e) by 2010 and 300 MW(e) by 2015 assuming a doubling of the program budgets (National Research Council 2006).
"Economic potential" is defined as that portion of the technical potential that the National Research Council judged to be cost effective. This estimate is based partly on the experience with three NYSERDA programs that avoided the need for 715 MW(e) of Statewide peak demand in 2004. Cost-effectiveness is based on a conservation option's ability to lower energy costs (consumers' bills) while energy prices continue to increase using EIA price forecasts. The National Research Council concludes that energy efficiency and demand-side management have great economic potential and could replace at least 800 MW(e) of the energy produced by IP2 and IP3 and possibly much more (National Research Council 2006).
The NRC staff notes that while Statewide conservation efforts could result in a peak demand reduction of about 75 percent of the power output of both IP2 and IP3 by 2015, the National Research Council predicted that only about 800 MW(e) could be reduced from the IP2 and IP3 service area (National Research Council 2006). As such, the NRC staff does not expect that conservation efforts alone will be sufficient to replace either of the IP2 or IP3 units and for this reason has not evaluated conservation or efficiency programs as replacements for the full output for IP2 or IP3. The NRC staff has, however, considered conservation as part of a combination of alternatives presented in Section 8.3.5 of this draft SEIS.
Wind Power New York State is recognized as having about 5000 MW(e) of land-based wind potential, enough to generate about 13 million MW(h) or equivalent to 10 percent of the State's electricity consumption. There are also sUbstantial offshore wind resources. The NYSERDA New York Energy $martSM program is currently supporting extensive wind resource prospecting efforts to identify promising new sites for wind development. Furthermore, NYSERDA is currently working with three developers to develop four projects totaling 425 MW (Power Naturally 2008).
Wind currently accounts for only about 1 percent of the generating capacity, or 391 MW(e),
Statewide (NYISO 2008). The NYSIO is managing wind generation projects that are proceeding through the grid interconnection process. These projects have a potential of generating almost 7000 MW(e) (NYISO 2008); however, there is no assurance that a project in this process will go into service.
Generally, wind power, by itself, is not suitable for large baseload capacity. As discussed in Section 8.2.1 of the GElS, wind has a high degree of intermittency, and average annual capacity factors for wind facilities are relatively low (on the order of 30 to 40 percent). Wind power, in conjunction with energy storage mechanisms or other readily dispatchable power December 2008 8-59 Draft NUREG-1437, Supplement 38
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Areas of class 3 or higher wind energy potential occur throughout much of the northeastern United States (DOE 1986,2008). The primary areas of good wind energy resources are the Atlantic coast, the Great Lakes, and exposed hilltops, ridge crests, and mountain summits.
Winter is the season of maximum wind power throughout the Northeast when all except the most sheltered areas have class 3 or better wind resource; exposed coastal areas and mountain summits can expect class 6 or 7 wind resource. In summer, the season of minimum wind power, class 3 wind resource can be found only on the outer coastal areas and highest mountain summits (DOE 1986).
Wind power of class 3 and higher is estimated for the high elevations of the Adirondack Mountains of northeastern New York (DOE 1986,2008). Annual average wind power of class 3 or 4 is found along the coastal areas of both Lake Erie and Lake Ontario, while class 5 winds are estimated to exist in the central part of both lakes (DOE 1986, 2008).
The National Research Council estimates that offshore wind could meet most of the IP2 and IP3 load by 2014 (National Research Council 2006). Currently, Winergy Power of Hauppauge, New York, is proposing to complete construction of a wind farm about 19 km (12 mil off the south shore of Long Island by 2014. Winergy has recently increased the size of its project to 940 MW(e) (WINS 2008). This would mean building as many as 260 wind turbines off the shore of Long Island. Winergy says the number of turbines would decrease if turbine technology improves at the time construction begins in 2012.
It is currently unknown whether the Winergy project will be completed. The proposed 420 MW(e). 130-turbine Cape Wind project off Cape Cod-the East Coast's offshore wind farm project that is farthest along in its approval process-faces opposition.
Because of the scale of a single wind farm project that would be needed to replace the power from IP2 and IP3 and the obstacles that the project would face, the NRC staff does not consider wind power to be a suitable stand-alone alternative that could be implemented before the IP2 and IP3 licenses expire. The staff does, however, recognize that New York has utility-scale wind resources and that NYSERDA is actively pursuing economic potential in wind-derived power supplies. Therefore, the NRC staff includes wind power in the combination alternatives addressed in Section 8.3.7 of this draft SEIS.
Wood and Wood Waste Wood-burning electric generating facilities can provide baseload power. However, the economic feasibility of a wood-burning facility is highly dependent on the availability of fuel sources and the location of the generating facility. Most wood-fired and other biomass plants are independent power producers and cogenerating stations with capacities on the order of 10 to 25 MW(e), with some plants operating in the 40 to 50 MW(e) range. In the 2006 New York Renewable Electricity Profile (DOE/EIA 2008b). New York's power industry reported only 37 MW(e) of generating capacity for wood or wood waste derived power.
Wood-burning energy generation continues to be developed in the northeastern U.S. In 2005, about 16 percent of the nation's energy derived from wood and wood wastes was generated in the New England and Middle Atlantic census divisions (DOE/EIA 2007). Within the region, Draft NUREG-1437, Supplement 38 8-60 December 2008
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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 42 43 Environmental Impacts of License Renewal about 12 percent of the generating capacity is from wood and wood wastes. In New York, the Laidlaw Energy Group, Inc. (Laidlaw 2008), is planning to convert a retired gas-fired cogeneration facility into a 7-MW(e) wood-fired power plant in Ellicottville, Cattaraugus County.
The plant will supply about 1 MW(e) to a lumber drying business located adjacent to the plant and export about 6 MW(e) to the power grid {Laidlaw 2008}. However, the project has not yet been finalized, and the future of the plant is uncertain.
Walsh et al estimated New York's wood resources in a study published in 1999 (Walsh et al 1999). The study presents the amount of resourced available in tons per year given a specified price per dry ton delivered. Wood feedstock categories included forest residues, defined as "logging residues; rough, rotten, and salvable dead wood; excess saplings; and small pole trees," and primary mill residues (Walsh 1999). The annual resources available for each of these categories at a delivery cost of less than $50 per dry ton are 1,746,400 and 1,274,000 tons, respectively (Walsh 1999). These volumes, respectively, account for about 4 percent and 1.5 percent of the total resource available in the 48 contiguous States. The neighboring States of New Jersey, Connecticut, Massachusetts, and Vermont have significantly less wood resource. Pennsylvania, however, has comparable resources to New York available.
Assumptions in the analysis include transportation distances of less than 50 mi and accessibility of 50 percent of the forest residues from existing roads.
The NRC staff finds that New York has utility-scale wood waste resources, but given uncertainties in supply estimates, as well as the small size and high number of installed facilities necessary to replace IP2 and IP3, the NRC staff does not find wood biomass to be a suitable alternative to IP2 and IP3 operating license renewals. The NRC staff will include wood waste facilities in combinations of alternatives addressed in Section 8.3.7 of this draft SEIS.
Hydropower New York State receives an abundant supply of hydroelectric power from Niagara Falls and other sites. Hydropower accounts for 5990 MW{e)-or about 15 percent-of the State's generating capacity (NYISO 2008).
The Idaho National Energy and Environmental Laboratory (INEEL) estimated that the undeveloped hydropower potential total for New York is 1309 MW(e) with 134 undeveloped potential hydroelectric sites in the Hudson River basin (IN EEL 1998). Development of these sites could result in more than 300 MW(e) of baseload capacity (INEEL 1998). The Statewide potential is 40 percent less than IP2 and IP3's current capacity, and the regional potential is 86 percent less than the IP2 and IP3 capacity. Therefore, the NRC staff does not consider hydropower to be a viable stand-alone alternative to license renewal.
Oil-Fired Generation Oil accounts for about 8 percent of the generating capacity-or 3515 MW{e)-Statewide (NYISO 2008). EIA projects that oil-fired plants will account for very little new generation capacity in the United States during the next 20 years, and higher fuel prices will lead to a decrease in overall oil consumption for electricity generation (DOE/EIA 2007a).
EIA had indicated that oil prices are expected to make oil-fired generation an unlikely option for future generation additions (EIA/DOE 2007a), as discussed in Section 8.3. The relatively high cost of oil-even prior to 2008's record high prices-had prompted a steady decline for use in electricity generation. The NRC staff has not evaluated oil-fired generation as an alternative to December 2008 8-61 Draft NUREG-1437, Supplement 38
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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 42 43 Environmental Impacts of License Renewal the renewal of the IP2 and IP3 operating licenses, though the NRC staff notes that oil may temporarily be burned in a gas-fired alternative should gas capacity become constrained during winter heating season.
Solar Power New York has enacted demand-side policies aimed at encouraging the adoption of photovoltaic (PV) technology for residents and businesses. These policies had resulted in the installation of more than 1.5 MW(e) of demand-side PV energy as of summer 2005 (National Research Council 2006). Through its Clean Energy Initiative, the Long Island Power Authority had issued rebates for PV systems totaling more than 2.63 MW(e) (National Research Council 2006). The National Research Council indicates that PV systems may be in the economic interests of New York customers because of high retail electricity rates and the falling prices of PV-generated electricity (National Research Council 2006).
The National Research Council reports that PV-generated electricity can provide high-value peak-time distributed generation power with minimal environmental emissions, and PV can contribute significantly to grid stability, reliability, and security (National Research Council 2006).
Distributed generation refers to the production of electricity at or close to the point of use.
Under an aggressive development scenario, the National Research Council estimates that 70 MW(e) of distributed PV could be installed in the NYCA by 2010 and 335 MW(e) by 2015.
However, the National Research Council states that there would have to be "reductions in PV costs and a long-term commitment to expand New York's PV programs" in order to reach these goals (National Research Council 2006). Finally, the National Research Council considers most of the projected PV distributed generation as demand-side reductions in peak energy demands.
Therefore, the energy-saving impacts of solar power are included in the conservation estimates described in Section 8.3.4 of this draft SEIS.
The NRC staff does not consider solar power to be a suitable stand-alone alternative to the renewal of the IP2 and IP3 operating licenses. The NRC staff does, however, recognize that solar energy is an important component of the NYSERDA demand-side reductions in peak load demands from generating facilities, including IP2 and IP3. Therefore, the NRC staff includes solar power in the combination alternatives addressed in Section 8.3.7 of this draft SEIS as a part of the conservation-derived demand reductions (as described in Section 8.3.4).
New Nuclear Generation Given the expressed industry interest in new nuclear construction, the NRC staff has previously evaluated the construction of a new regional nuclear power plant as an alternative to license renewal in SEISs for other nuclear power plant license renewal requests. Based on the NRC's current proposed schedule, no combined license (COL) application review is expected to be complete until the middle of 2010, at the earliest. Necessary reviews include the acceptance review as well as the safety and environmental reviews. Upon completion of the reviews, a public hearing process is initiated that is estimated to take at least 1 year. This brings the earliest approval of the submitted COL applications out to the middle of 2011.
While some plant construction activities can begin before issuing the COL, construction of a new plant is not expected to be completed until several years beyond the date the COL is issued. In late 2007, NRG Energy was the first to submit a full COL application to the NRC for its South Texas Project. The target for completion of the construction of the first of two units is Draft NUREG-1437, Supplement 38 8-62 December 2008
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Given the current COL application schedule, the time needed to review an application, and the anticipated length of construction, the NRC staff does not consider the construction and operation of a new nuclear power plant specifically for the purpose of replacing IP2 and IP3 to be a feasible alternative to license renewal at this time.
Geothermal Energy Geothermal plants are most likely to be sited where hydrothermal reservoirs are prevalent, such as in the western continental United States, Alaska, and Hawaii. There are no feasible eastern locations for geothermal capacity to serve as an alternative to IP2 and IP3 (NRC 1996), and the New York Renewable Electricity Profile did not indicate any geothermal energy production in New York in 2006 (DOE/EIA 2008). As such, the NRC staff concludes that geothermal energy would not be a feasible alternative to renewal of the IP2 and IP3 operating licenses.
Municipal Solid Waste According to the Integrated Waste Services Association (IWSA), fewer than 90 waste-to-energy plants are operating in the United States, generating approximately 2700 MW(e) of electricity or an average of approximately 30 MW(e) per plant (IWSA 2007). The existing net capacity in the region of IP2 and IP3 is 156 MW(e) generated by six plants, while the technical potential within the region is 1096 MW(e) by 2014 (National Research Council 2006). The 2014 estimate includes production from fuels containing municipal solid waste and construction and demolition wood (a portion likely to be at least partially captured in Walsh et al and referenced in the Wood Waste section of 8.3.4).
Estimates in the GElS suggest that the overall level of construction impact from a waste-fired plant would be approximately the same as that for a coal-fired plant. Additionally, waste-fired plants have the same or greater operational impacts than coal-fired technologies (including impacts on the aquatic environment, air, and waste disposal). The initial capital costs for municipal solid waste plants are greater than for comparable steam turbine technology at coal facilities or at wood waste facilities because of the need for specialized waste separation and handling equipment.
The decision to burn municipal waste to generate energy (waste-to-energy) is usually driven by the need for an alternative to landfills rather than by energy considerations. The use of landfills as a waste disposal option is likely to increase in the near term; with energy prices increasing, however, it is possible that municipal waste combustion facilities may become attractive.
Congress has included waste-to-energy in the Production Tax Credit legislation to encourage development of waste-to-energy and other renewable technologies (IWSA 2008).
Given the small average installed size of municipal solid waste plants, it would take about 70 plants to replace IP2 and IP3. Furthermore, NYSERDA estimates that the Statewide economically achievable potential for summer peak load from municipal solid-waste-derived energy by 2022, well into the relicensing period for IP2 and IP3, is only 190 MW(e) (NYSERDA 2003). Therefore, the NRC staff does not consider municipal solid waste combustion to be a feasible alternative to license renewal..
Other Biomass Derived Fuels In addition to wood and wood waste fuels, there are several other biomass fuels used for December 2008 8-63 Draft NUREG-1437! Supplement 38
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In the period between 2005 and 2007, IP2 and IP3 produced more than 16 million MW(h) annually (Blake 2008). Furthermore, the New York Renewable Electricity Profile did not indicate any energy production in New York from biomass fuels other than wood and wood waste in 2006 (DOE/EIA 2008), which is considered above. For these reasons, the NRC staff concludes that power generation from biomass fuels does not offer a feasible alternative to the renewal of the I P2 and IP3 operating licenses.
Fuel Cells Fuel cells work by oxidizing fuels without combustion and the accompanying environmental side effects. The only byproducts are heat, water, and, if the fuel is not pure hydrogen, CO2.
Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically used as the source of hydrogen.
The only current program that was identified as being initiated by one of the three major power providers in downstate New York is a program being conducted by the New York Power Authority that involves nine fuel cell installations totaling 2.4 MW(e} using waste gas produced from sewage plants (National Research Council 2006).
At the present time, fuel cells are not economically or technologically competitive with other alternatives for baseload electricity generation. NYSERDA estimates that the Statewide technical potential for annual supply from fuel cells by 2022 is more than 37 million MW(h);
however, NYSERDA indicated that the economical potential for 2022 is zero (NYSERDA 2003).
NYSERDA defines economic potential as "that amount of technical potential available at technology costs below the current projected costs of conventional electric generation that these resources would avoid." Therefore, while it may be possible to use a distributed array of fuel cells to provide an alternative to IP2 and IP3, it currently would be prohibitively costly to do so.
Since fuel cells are not currently economically feasible on such a large scale, the NRC staff concludes that fuel cell-derived power is not a feasible alternative to the IP2 and IP3 license renewals.
Delayed Retirement Based on currently scheduled power plant retirements and demand growth projections by the NYISO, 1200 to 1600 MW(e) from new projects that are not yet under construction could be needed by 2010, and a total of 2300 to 3300 MW(e) could be needed by 2015 (National Research Council 2006). In 2006, there were six new generation projects adding 2228 MW(e) of new capacity and scheduled retirements of 2363 MW of generating capacity (National Research Council 2006). Recent or scheduled retirements included the New York Power Authority's 885-MW(e} Poletti Unit 1 and Lovett Units 3, 4, and 5 totaling 431 MW(e). Astoria Units 2 and 3, with a total capacity of 553 MW(e}, also are scheduled for retirement before the end of the current IP2 and IP3 license periods.
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Plants scheduled for retirement are aging and have higher emissions than newer plants.
2 Keeping older plants online may not be technically or economically achievable when emissions 3
controls or necessary environmental mitigation measures are taken into account. Furthermore, 4
given that the demand for electricity is increasing and, in the near term, planned new sources within the NYCA are just keeping pace with retirements, the NRC staff does not consider 6
additional delays in the retirements of existing plants to be a feasible alternative to compensate 7
for the loss of power from IP2 and IP3.
8 8.3.5 Combination of Alternatives 9
Even though individual alternatives to license renewal might not be sufficient on their own to replace the 2158-MW{e) total capacity of the IP2 and IP3 units because of the lack of resource 11 availability, technical maturity, or regulatory barriers, it is conceivable that a combination of 12 alternatives might be sufficient. Such alternatives may also include the continued operation of 13 either IP2 or IP3 combined with other alternatives.
14 There are many possible combinations of alternatives that could be considered to replace the power generated by IP2 and IP3. In the GElS, NRC staff indicated that consideration of 16 alternatives would be limited to single, discrete generating options, given the virtually unlimited 17 number of combinations available. In this section, the NRC staff examines two possible 18 combinations of alternatives in part because other efforts to examine alternatives to I P2 and 19 IP3, including Levitan and Associates (2005) and the National Research Council (2006), have addressed combinations of alternatives. The National Research Council (2006) noted, for 21 example, that "... the additional 2 GW required if IP2 and IP3 were to be closed could be met 22 by some suitable combination of new generation in the New York City area, efficiency 23 improvements and demand-side management, and new transmission capability from upstate."
24 The NRC staff presents two possible combinations based partly on analysis by the National Research Council. In one of these combinations, the NRC has included the continued operation 26 of either IP2 or IP3, and the second combination includes only alternative energy sources. The 27 second combination is based entirely on new generation, efficiency improvements or demand 28 side management Oointly addressed as conservation), and new transmission capacity carrying 29 power from upstate. These combinations include several alternatives that the NRC staff found to be unable to replace the entirety of IP2 and IP3 electrical capacity.
31 Combination Alternative 1 32 continuing operation of either IP2 or IP3 33 constructing a 330-MW(e) combined-cycle gas-fired plant at IP2 and IP3 34 obtaining 200 to 400 MW(e) from renewable energy sources (primarily wood and wind) implementing 300 to 500 MW(e) of conservation programs based on the potential 36 identified by the National Research CounCil and NYSERDA 37 Combination Alternative 2 38 constructing a 400-MW(e) gas combined-cycle plant at the IP2 and IP3 site 39 obtaining 200 to 400 MW(e) from renewable energy sources (primarily wood and wind)
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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 42 Environmental Impacts of License Renewal implementing 500 to 800 MW(e) of conservation programs based on the potential identified by the National Research Council and NYSERDA importing a net 800 MW(e) from upstate New York and Canada following the installation of a new transmission line The following sections analyze the impacts of the two options outlined above. In some cases, detailed impact analyses for similar actions are described in previous sections of this Chapter.
When this occurs, the impacts of the combined alternatives are discussed in a general manner with reference to other sections of this draft SEIS. A summary of the impacts from the two combined alternative options is presented in Table 8-5.
8.3.5.1 Impacts of Combination Alternative 1 Each component of the first combination alternative produces different environmental impacts, though several of the options would have impacts similar to-but smaller than-alternatives already addressed in this SEIS. Constructing closed-cycle cooling for one of the existing Indian Point generating units (either IP2 or IP3) would create impacts roughly equal to half of the impacts addressed in 8.1.1. Continued operations of either IP2 or IP3 would incur roughly half the impacts of continued operations described in Chapters 3, 4, and 6. (Decommissioning impacts, as described in Chapter 7 of this SEIS, as well as NUREG-0586, would still occur but may occur later than they would if both units retired at the end of their current Operating Licenses.) Constructing 330 MW(e) of gas-fired capacity would create roughly one-sixth the impacts of the on-site alternative described in 8.3.2, and would likely be able to make use of the AGTC pipeline on site without additional pipeline modifications (Levitan and Associates, Inc.
2005).
The NRC staff has not yet addressed in any depth in this SEIS the impacts of wind power, wood-fired generation, or conservation. A wind installation capable of yielding 100 to 200 MW(e) of capacity would likely entail placing wind turbines off Long Island on the Atlantic coast, in upstate New York, or on Lake Erie or Lake Ontario. A wind installation capable of delivering 100 to 200 MW(e) on average would require approximately 52 to 104 turbines with a capacity of 3.5 to 5 MW (Cape Wind Associates 2007). Because wind power installations do not provide full power all the time, the total installed capacity exceeds the capacity stated here.
As noted in Section 8.3.4, under Wood Waste, the wood-fired alternative would have impacts similar to a coal-fired plant of similar capacity. Unlike a coal-fired plant, however, the wood-fired plant does not release heavy metals (including mercury, uranium, and thorium) in fly ash.
Wood-fired plants also tend to be slightly less efficient with slightly lower capacity factors.
Impacts from conservation measures are likely to be negligible, as the NRC staff indicated in the GElS (1996). The primary concerns NRC staff identified in the GElS related to indoor air quality and waste disposal. In the GElS, NRC staff indicated that air quality appeared to become an issue when weatherization initiatives exacerbated existing problems, and were expected not to present significant effects. The NRC staff also indicated that waste disposal concerns related to energy-saving measures like fluorescent lighting could be addressed by recycling programs.
The NRC staff considers the overall impact from conservation to be SMALL in all resource areas, though measures that provide weatherization assistance to low-income populations may have positive effects on environmental justice.
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The GE IS notes that gathering fuel for wood-fired plants can have significant environmental impacts. However, the NRC staff believes that the operation of 100 to 200 MW(e) of wood-fired generation would have minor impacts, especially if the plants were widely distributed and feedstocks were primarily preexisting waste streams. Construction impacts of the wood-fired plants on land use would be SMALL to MODERATE depending on plant cooling configurations and plant locations. These impacts would be minimized by locating plants on previously disturbed land near other industrial applications, including paper/pulp mills or other forest-product operations where fuels may be readily available. To fully utilize the power generated in these plants, they would need to be constructed inside the transmission bottlenecks leading to the NYCA discussed in Section 8.3.5 of this draft SEIS. Otherwise, new transmission capacity would have to be constructed resulting in additional land use impacts.
Impacts from the wind power portion of this alternative would depend largely on whether the wind facility is located onshore or offshore. Onshore wind facilities will incur greater land use impacts than offshore, simply because all towers and supporting infrastructure will be located on land. NRC observations indicate that onshore installations could require several hundred acres, though turbines and infrastructure would actually occupy only a small percentage of that land area. Land around wind installations COUld remain in use for activities like agriculture (a practice consistent with wind farm siting throughout the U.S.).
Overall, the NRC staff considers that the land use impacts from the first combination alternative would be SMALL to MODERATE.
Ecology As described in Section 8.1.1.2 of the draft SEIS, the construction of two hybrid cooling towers would have a SMALL impact on aquatic ecology and a SMALL impact on terrestrial ecology.
Because the combined alternative would involve construction and operation of only one cooling tower, the NRC staff considered the resulting impacts from the construction and operation of a single cooling to be SMALL on both the aquatic and terrestrial ecology. (If the remaining IP unit were to continue operating with once-through cooling, the impacts of impingement and entrainment would likely be at least MODERATE for some species, though the NRC staff have not analyzed the specific level of impact for this option. Thermal shock would also be less significant. Not constructing a cooling tower would mean a smaller terrestrial impact.)
The SMALL to MODERATE impacts from the construction of five gas-fired units at the IP2 and December 2008 8-67 Draft NUREG-1437, Supplement 38
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Offsite construction and operation of wood~fired plants may have a SMALL to MODE RATE impact on both aquatic and terrestrial ecology, depending heavily on the location of the plants.
The principal ecological impacts of an offshore wind farm as described earlier in this section would be to aquatic ecological resources. An onshore wind farm located in upstate New York would primarily affect terrestrial ecology. Neither wind farm would be likely to destabilize ecological resources. The NRC staff concludes that SMALL to MODERATE ecological impacts could occur during the construction phase but could be managed by choice of construction methods (e.g., avoiding particularly sensitive habitats).
Overall, the NRC staff considers that the ecological impacts, both aquatic and terrestrial, from this combination alternative would be SMALL to MODERATE.
Water Use and Quality The primary water use and quality issues from this alternative would occur from wood~fired generation and the gas~fired unit. While construction impacts could occur from a wind farm, particularly if located offshore, these impacts are likely to short lived. An offshore windfarm is unlikely to located immediately adjacent to any water users, though construction may increase turbidity. An onshore wind farm could create additional erosion during construction, as would wood~fired plants and a gas-fired unit on the IP2 and IP3 site. In general, site management practices keep these effects to a small level.
During operations. only the wood-fired and gas-fired plants would require water for cooling.
Because the wood-fired plants are less efficient than the gas-fired unit and rely on a steam cycle for the full measure of their output, the effects of the wood-fired plant is roughly similar to the effect of the larger gas-fired unit. All of these units would likely use closed-cycle cooling, however. and this would limit the effects on water resources. As the NRC staff indicated for the coal-fired and gas-fired alternatives, the gas-fired and wood-fired portions of this alternative are likely to rely on surface water for cooling (or. as is the case in some locations, treated sewage effluent).
Effects from the continued operation of one IP unit with closed-cycle cooling would be SMALL.
as would continued operation of one unit with the existing cooling system.
The NRC staff considers impacts on water use and quality to be SMALL for this combination alternative. The onsite impacts at the IP2 and IP3 facility would be expected to be similar to the impacts described in Sections 8.1.1.2 and 8.3.2 of this draft SEIS.
Air Quality The first combined alternative will have some impact on air quality as a result of emissions from the wood-fired plants and the onsite gas turbine. Because of the size of the units, an individual unit's impacts would be SMALl. Section 8.1.1.2 of this draft SEIS describes the impacts on air quality from the construction and operation of two hybrid COOling towers to be SMALL. For the construction and operation of a single tower, the impacts would be SMALL. The continued operation of one of the nuclear power units and construction and operation of the wind farm will have only minor impacts on air quality.
Draft NUREG-1437. Supplement 38 8-68 December 2008
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Waste The primary source of waste under this option would be from the construction of the new hybrid cooling tower. Constructing a wind farm, wood-fired generation, and a new gas turbine facility would also create waste, though significantly less than the 2 million cy (1.5 million m3) created during excavation of two cooling towers (roughly half would be attributable to one cooling tower). Operational wastes would come primarily from the wood-fired power plant. Most of the ash from burned wood waste could be recycled or reused. The waste contribution from the remaining IP2 or IP3 unit would be roughly half of the waste generated by the current plant.
Section 8.1.1.2 of this draft SEIS describes the impacts from waste generated during construction of two towers to be SMALL to LARGE, depending on whether excavation waste could be reused or recycled. Waste impacts could be substantial during construction of the alternatives, and would remain SMALL to LARGE, depending on how the various sites handled wastes. If the remaining IP unit were to continue operation with the existing once-through cooling system, waste impacts would be SMALL. During operations, waste volumes would have only SMALL impacts.
Human Health The primary heath concerns under this option would be occupational health and safety risks during the construction of the new gas turbine, the new cooling tower, the wood-fired plants, and the wind farm. As described in previous sections (for coal-fired and gas-fired alternatives), if the risks are appropriately managed, the human health impacts from these or similar alternatives are SMALL. Impacts from emissions are uncertain, but considered SMALL as the plants would comply with the CAA health-informed standards and other relevant emissions regulations.
Continued operation of one IP unit with the existing once-through cooling system would not change this assessment.
Therefore. the NRC staff concludes that the overall human health impact from the first combination alternative would be SMALL.
Socioeconomics This combination alternative involves the shutdown of either IP2 or IP3. As detailed in Section 8.2 of this draft SEIS, the socioeconomic impacts of shutting down the plants would be SMALL to MODERATE because of the loss of PILOT payments to local municipalities. Under this option, those payments would be expected to decrease but would not be completely eliminated.
Some IP2 or IP3 jobs would be lost, but some would be replaced with jobs associated with the construction and operation of the gas-fired plant. The gas-fired plant may generate additional PILOT payments, which may offset shutdown effects. Levitan and Associates (2005) indicates that PILOT payments from a gas-fired facility smaller than IP2 and IP3 may supply PILOT payments near those provided by the existing plant. Other jobs would be generated by the construction of the offsite power alternatives. Overall, the NRC staff concludes that the socioeconomic impacts from the first combined alternative would be SMALL.
Socioeconomics (Transportation)
As described in Section 8.1.1.2 of this draft SEIS, the construction of two hybrid cooling towers December 2008 8-69 Draft NUREG-1437. Supplement 38
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During operation, only the wood-waste facility is likely to create noticeable impacts (in gathering wood wastes), and these may not affect any important aspects of local transportation. No other transportation impacts for this alternative are considered to be as severe. Overall, the impact from this combined alternative would likely be MODERATE.
Aesthetics As described in Section 8.1.1.2 of this draft SEIS, the construction of two hybrid cooling towers would have a MODERATE impact on aesthetics. Aesthetic impacts from one cooling tower may be slightly smaller, though it would likely still affect the scenic value of the Hudson Valley.
Aesthetic impacts would occur during construction and operation of an offshore wind installation and would depend on its distance from the shore and on its orientation in regard to shoreline communities. The NRC staff estimates that the construction and operational impacts of the facility could be managed, though some may consider the impact to be LARGE, depending on the location of the turbines. An onshore wind facility would also have the potential to create LARGE effects. The aesthetic impacts from new wood-fired generating plants would likely not have a major effect on visual resources, because the plants are small. Impacts would depend on the plants' locations.
The NRC staff concludes that the overall aesthetic impacts from the first combination alternative could range from SMALL to LARGE, depending on the aesthetic effects of the wind power portion.
Historic and Archeological Resources Onsite impacts to historical and cultural resources from the construction of a hybrid cooling tower and a single gas turbine plant are expected to be SMALL. The offsite impacts from the construction of wood-fired units and a wind farm are also expected to be small given the opportunity to evaluate and select the sites in accordance with applicable regulations and the ability to minimize impacts before construction. Therefore, the NRC staff concludes that the overall impacts on historic and archeological resources from the first combination alternative would be SMALL.
Environmental Justice No impacts are anticipated in the IP2 and IP3 area that could disproportionately affect minority or low-income communities. Impacts from offsite activities would depend on the location of the activity. Many conservation measures, especially those involving weatherization or efficiency improvements to low-income households, can have disproportionately positive effects for low-Draft NUREG-1437, Supplement 38 8-70 December 2008
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income families. Overall, though, environmental justice impacts from the first combination 2
alternative would depend substantially on the location of the installations and the characteristics 3
of the surrounding populations. Impacts could range from SMALL to LARGE.
4 Impacts of Combined Alternative 2 The second combination alternative differs from the first in that it completely replaces IP2 and 6
IP3 capacity. In contrast to the first combination alternative, a 400-MW(e) gas-fired plant is 7
considered because it can be constructed on the site, making use of existing transmission lines 8
and the natural gas pipeline that transects the IP2 and IP3 site; however, modifications to the 9
pipeline would be necessary to provide firm year-round service to the site without removing the service rights of other customers in New York and Connecticut served by the pipeline (Levitan 11 and Associates, Inc. 2005). Quantifying pipeline service adequacy and upgrade costs was 12 beyond the scope of the Levitan report.
13 Like the first combination alternative, the second combination alternative employs 200 to 400 14 MW(e) from renewable energy sources (primarily wood and wind). The impacts of these sources are described in the discussion of Combination Alternative 1 in Section 8.3.7.1 of this 16 draft SEIS.
17 This option requires more aggressive energy conservation programs that would result in an 18 energy savings of 500 to 800 MW(e), the maximum potential expected by 2014 (National 19 Research Council 2006). As described in Section 8.3.4 of this draft SEIS and in the GElS, these conservation efforts would have overall SMALL impacts.
21 This alternative also includes importing 800 MW(e) from upstate New York or Canada, as 22 described in Section 8.3.5 of this draft SEIS. This power would be purchased by an LSE for 23 distribution in the New York City metropolitan area. However, to support such power imports, 24 new transmission capacity would have to be established.
Land Use 26 Siting a single 400-MW(e) gas-fired unit with a closed-cycle cooling system at the IP2 and IP3 27 site would require about 18 ha (45 ac) and would likely have SMALL impacts on land use as the 28 existing site as the unit could likely be constructed on previously-disturbed land.
29 The construction of new transmission lines to support the purchased-power portion of this alternative would result in MODERATE to LARGE impacts as the lines may be several hundred 31 miles in length. As described in Section 8.3.5 of this draft SEIS, a current plan for new 32 transmission lines would impact 1155 ha (2855 ac).
33 The GElS notes that gathering fuel for wood-fired plants can have significant environmental 34 impacts. However, the NRC staff believes that the operation of 100 to 200 MW(e) of wood-fired generation would have minor impacts, especially if the plants were widely distributed and 36 feedstocks were primarily preexisting waste streams. Construction impacts of the wood-fired 37 plants on land use would be SMALL to MODERATE depending on plant cooling configurations 38 and plant locations. These impacts would be minimized by locating plants on previously 39 disturbed land near other industrial applications, including paper/pulp mills or other forest-product operations where fuels may be readily available. To fully utilize the power generated in 41 these plants, they would need to be constructed inside the transmission bottlenecks leading to 42 the NYCA discussed in Section 8.3.5 of this draft SEIS, or in a location to access new December 2008 8-71 Draft NUREG-1437, Supplement 38
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Impacts from the wind power portion of this alternative would depend largely on whether the wind facility is located onshore or offshore. Onshore wind facilities will incur greater land use impacts than offshore, simply because all towers and supporting infrastructure will be located on land. NRC calculations indicate that onshore installations could require xx ha (xx ac)
(reference). Land around wind installations could remain in use for activities like agriculture (a practice consistent with wind farm siting throughout the U.S.).
Overall, the NRC staff considers that the land use impacts from this combination alternative would be MODERATE to LARGE.
Ecology As described in Section 8.3.2 of this draft SEIS, the impacts from the construction of five gas-fired units at the IP2 and IP3 site would have a SMALL to MODERATE impact on aquatic and terrestrial ecology. Because the second combination alternatives would use only one gas-fired unit, the NRC staff concluded the resulting impacts on both the aquatic and terrestrial ecology to be SMALL.
Offsite construction and operation of wood-fired plants and new transmission lines would have a SMALL to MODERATE impact on both aquatic and terrestrial ecology, depending heavily on the location of the plants and transmission lines. Transmission lines and their associated ROWs may noticeably affect terrestrial habitats if they contribute to habitat fragmentation. They may affect aquatic ecology when they cross water bodies, particularly if it is necessary to construct pylons in the water bodies.
The principal ecological impacts of an offshore wind farm as described earlier in this section would be to aquatic ecological resources. An onshore wind farm located in upstate New York would primarily affect terrestrial ecology. Neither type of wind farm would be likely to destabilize ecological resources. The NRC staff concludes that SMALL to MODERATE ecological impacts could occur during the construction phase but could be managed by choice of construction methods (e.g., avoiding particularly sensitive habitats).
Overall, the NRC staff considers that the ecological impacts from the second combination alternative would be SMALL to MODERATE.
Water Use and Quality The primary water use and quality issues from this alternative would occur from wood-fired generation and the gas-fired unit. While construction impacts could occur from a wind farm, particularly if located offshore, these impacts are likely to shortlived. An offshore windfarm is unlikely to located immediately adjacent to any water users, though construction may increase turbidity. An onshore wind farm could create additional erosion during construction, as would wood-fired plants and a gas-fired unit on the IP2 and IP3 site. In general, site management practices keep these effects to a small level. Construction of the transmission line would also like have minor, if any effects on water use and quality. Erosion controls would likely minimize sedimentation.
During operations, only the wood-fired and gas-fired plants would require water for cooling.
Because the wood-fired plants are less efficient than the gas-fired unit and rely on a steam cycle Draft NUREG-1437, Supplement 38 December 2008
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The overall effects on water use and quality of the second combination alternative would likely be SMALL.
Air Quality The second combination alternative will have some impact on air quality as a result of emissions from the wood-fired plants and the on site gas-Fired unit. Because of the size of the wood-fired units and the gas-fired unit, an individual unit's impacts would be SMALL. However, the NRC staff concludes that the cumulative impacts from all of the new plants would be SMALL to MODERATE.
Waste The primary source of waste under the second combination alternative would be from the construction of the new power generation facilities, both on site and off site. Waste could include land clearing debris from all aspects of this combination alternative, excepting the wind farm if built offshore. Additional wastes would result from operation of the wood-fired plants.
Additional wastes could be generated during operations of the gas-fired plants, or during maintenance at the wind power installations and the new transmission line. Overall, the NRC staff concludes that the impacts will be SMALL to MODERATE.
Human Health The primary heath concerns under this option would be occupational health and safety risks during the construction of the new gas turbine, transmission lines, the wood-fired plants, and the wind farm. As described in previous sections (for coal-fired and gas-fired alternatives), if the risks are appropriately managed, the human health impacts from these or similar alternatives are SMALL. Impacts from emissions are uncertain but considered SMALL because the plants would comply with health-informed standards in the CAA and other relevant emissions regulations.
Therefore, the NRC staff concludes that the overall human health impact from the second combination alternative would be SMALL.
Socioeconomics The second combination alternative involves the complete shutdown of IP2 and IP3. As detailed in Section 8.2 of this draft SEIS, the socioeconomic impacts of shutting down the plants would be MODERATE because of the loss of PILOT payments to local municipalities. Under this option, those payments would be lost, but because of the gas plant that would be constructed on site, some new tax revenues would replace the PILOT payments. Levitan and Associates (2005) indicated that a smaller gas-fired plant may replace a significant portion of the PILOT payments currently provided by IP2 and IP3. Some IP2 and IP3 jobs would be lost but replaced with decommissioning jobs and jobs associated with the construction and operation of the gas turbine plant. Other jobs would be generated by the construction of the December 2008 8-73 Draft NUREG-1437, Supplement 38
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Socioeconomics (Transportation)
The aspects of this alternative will create modest transportation effects during construction.
Given that the wood-waste facility and wind farm are likely not be located in the same place, construction-stage impacts are less intense than if they were part of one collocated facility.
Similarly, impacts associated with constructing the transmission line will be spread over a large area, and are not likely to be intense in any location. Also, construction of the gas turbine facility will require fewer workers than the gas-fired alternative considered in Section 8.3.2 of thisdraftSEIS.
During operation, only the wood-waste facility is likely to create noticeable transportation impacts (in gathering wood wastes), and these may not affect any important aspects of local transportation. The gas-fired unit may create noticeable impacts on gas transmission, but upgrades to the pipeline system should compensate for these effects. Because winter heating customers take priority over utility generation customer, the plant is unlikely to have noticeable effects for others, though it may need to burn fuel oil during peak demand periods.
Transportation impacts for this alternative would be minimal because the construction and operation workforce would be spread over multiple locations. No single project would have a significant long-term impact. Overall, the NRC staff concludes that the impact would be SMALL.
Aesthetics As described in Section 8.3.5 of this draft SEIS, new transmission lines would be 305 km (190 mi) long or longer. Transmission lines have a significant impact on visual aesthetics.
Aesthetic impacts would occur during operation of the wind farm installation and would depend on its distance from the shore and on its orientation in regard to shoreline communities. The NRC staff estimates that the construction and operational impacts of the facility could be managed, though some may consider the impact to be LARGE, depending on the location of the turbines. An onshore wind facility would also have the potential to create LARGE effects.
The aesthetic impacts from new wood-fired generating plants could also be MODERATE, depending on the plants' locations.
Therefore, the NRC staff concludes that the overall aesthetic impacts from the second combination alternative would be MODERATE to LARGE, depending on the locations of transmission lines and the wind farm.
Historic and Archeological Resources Onsite impacts to historical and cultural resources from the construction of a single gas turbine plant are expected to be SMALL. The offsite impacts from the construction of wood-fired units, a wind farm, and new transmission lines are also expected to be SMALL given the opportunity to evaluate and select the sites in accordance with applicable regulations and the ability to minimize impacts before construction. Therefore, the NRC staff concludes that the overall impacts on historic and archeological resources from the second combination alternative would Draft NUREG-1437, Supplement 38 8-74 December 2008
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Environmental Justice No impacts are anticipated in the IP2 and IP3 area that could disproportionately affect minority or low-income communities. Impacts from offsite activities would depend on the location of the activity. Many conservation measures, especially those involving weatherization or efficiency improvements to low-income households, can have disproportionately positive effects for low-income families. Overall, though, environmental justice impacts from the second combination alternative would depend substantially on the location of the installations and the characteristics of the surrounding populations. Impacts could range from SMALL to LARGE.
December 2008 8-75 Draft NUREG-1437, Supplement 38
1 Environmental Impacts of License Renewal Table 8*5. Summary of Environmental Impacts of Combination Alternatives Impact Combination 1 Combination 2 Category Impact Comments Impact Comments Land Use SMALL to Impacts would depend MODERATE to Impacts would depend on MODERATE on location of wind farm LARGE the site selection for the and the site selection wood-fired plants, and the for the wood-fired placement of new plants. as well as land-transmission lines and the disposal if a cooling wind farm.
tower is constructed at the remaining IP unit.
Ecology SMALL to Impacts would depend SMALL to Impacts would depend on MODERATE on location of wind farm MODERATE site selection for the and the site selection wood-fired plants, the for the wood-fired wind farm. and plants.
transmission line.
Water Use and SMALL Minor impacts occur if SMALL SMALL impacts at the IP2 Quality the wind farm is located and IP3 site because of offshore.
less onsite power production; minor impacts at offshore wind farms.
and locations of wood-fired plants and transmission lines.
Air Quality SMALL Air emissions of the small wood-fired plants SMALL to MODERATE Emissions estimated in Table 8-4 reduced about and gas-fired unit would 80 percent because only be minor considering one gas-fired unit would their size and possible operate at the IP2 and IP3 multiple locations. A site. Air emissions of the wind farm would not small wood-fired plants impact air quality. A would be minor cooling tower could considering their size and have a minor effect on possible multiple air quality.
locations. A wind farm would not impact air Draft NUREG-1437. Supplement 38 8-76 December 2008
1 Environmental Impacts of License Renewal Table 8-5 (continued)
Impact Combination 1 Combination 2 Category Impact Comments Impact Comments Waste SMALL to There would be SMALL to There would be far less LARGE construction waste from MODERATE construction waste from the IP2 and IP3 site if a the IP2 and IP3 site. The cooling tower is other alternatives would constructed:
not generate significant construction of other waste volumes except alternatives would during construction.
increase waste volumes. Operational wastes are SMALL.
Human Health SMALL Emissions and SMALL Emissions and occupational risks occupational risks would would be managed in be managed in accordance with accordance with applicable regulations.
applicable regulations.
Socioeconomics SMALL Some PILOT payments SMALL to IP2 and IP3 jobs and and jobs may be lost.
MODERATE PILOT payments lost; some new jobs and taxes; minimum impacts from other power alternatives.
Socioeconomics MODERATE Minor impacts from SMALL Minor impacts from (T ransportation) commuting plant commuting plant personnel. More personnel. Short-tem significant short-tem impacts from offsite impacts from offsite transportation of transportation of construction waste.
construction waste.
including large volumes of soil and rock.
Aesthetics SMALL to Visual impacts from MODERATE to Visual impacts from new LARGE new wind turbines.
LARGE wind turbines and visual depending on the impacts of new location. Limited transmission lines. depend impact from wood-fired on the location chosen.
and gas plants.
Limited impact from wood-fired and gas plants.
Historic and SMALL Cultural resources SMALL Cultural resources Archeological inventories would be inventories would be Resources needed to identify.
needed to identify, evaluate, and mitigate evaluate. and mitigate potential impacts from potential impacts from construction.
construction.
December 2008 8-77 Draft NUREG-1437, Supplement 38
1 Environmental Impacts of License Renewal Table 8*5 (continued)
Impact Combination 1 Combination 2 Category Impact Comments Impact Comments Environmental SMALL to Impacts would depend SMALL to Impacts would depend on Justice LARGE on plant locations.
LARGE plant and transmission line locations.
2 8.4 Summary of Alternatives Considered 3
In this draft SEIS, the NRC staff has considered alternative actions to license renewal of IP2 4
and IP3 including the no-action alternative (discussed in Section 8.2), new generation or energy 5
conservation alternatives (supercritical coal-fired generation, natural gas, nuclear, and 6
conservation alternatives discussed in Sections 8.3.1 through 8.3.4), purchased electrical power 7
(discussed in Section 8.3.5), alternative power-generating technologies (discussed in 8
Section 8.3.6), and two combinations of alternatives (discussed in Section 8.3.7).
9 As established in the GElS, the need for power from IP2 and IP3 is assumed by the NRC in the 10 license renewal process. Should the NRC not renew the IP2 and/or IP3 operating licenses, 11 their generating capacity or load reduction (e.g., by conservation) would have to come from an 12 alternative to license renewal.
13 Furthermore, even if the NRC renews the operating licenses, Entergy could elect not to operate 14 either IP2 or IP3 for the full terms of the renewed licenses. Decisions about which alternative to 15 implement. regardless of whether or not the NRC renews the IP2 and IP3 operating licenses, 16 are outside the NRC's authority and are subject to consideration by Entergy, other power 17 producers, and State-level decisionmakers (or non-NRC Federal-level decisionmakers where 18 applicable).
19 The environmental impact levels of the alternatives considered by the NRC staff in this draft 20 SEIS are similar to the impact levels of continued IP2 and IP3 operation under a renewed 21 license with or without modifications to the existing once-through cooling system combined with 22 aquatic ecology restoration activities designed to comply with the site's draft SPDES permit, 23 though impacts differ significantly across resource areas.
24 Impacts from combinations of alternatives including conservation and generation technologies 25 (e.g., coal, gas, wind) are also likely to be similar to the impacts of renewing the IP2 and IP3 26 operating licenses and implementing modifications to the open-cycle cooling system and 27 participating in and/or funding aquatic resource restoration activities.
28 8.5 References 29 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 30 Production and Utilization Facilities."
31 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 32 Protection Regulations for Domestic Licensing and Related Regulatory Functions."
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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 Environmental Impacts of License Renewal 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, "National Primary and Secondary Ambient Air Quality Standards,"
40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, "Requirements for Preparation, Adoption, and Submittal of Implementation Plans."
40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, "Standards of Performance for New Stationary Sources."
40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, "Designation of Areas for Air Quality Planning Purposes;"
40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122, "EPA Administered Permit Programs: National Pollutant Discharge Elimination System."
40 CFR Part 125. Code of Federal Regulations, Title 40, Protection of Environment, Part 125, "Criteria and Standards for the National Pollutant Discharge Elimination System."
63 FR 49453. Environmental Protection Agency. "Revision of Standards of Performance for Nitrogen Oxide Emissions from New Fossil-Fuel Fired Steam Generating Units; Revisions to Reporting Requirements for Standards of Performance for New Fossil-Fuel Fired Steam Generating Units." Final rule. September 16, 1998.
64 FR 35714. Environmental Protection Agency. "Regional Haze Regulations." Final rule.
July1,1999.
6 NYCRR Part 231. Compilation of the Rules and Regulations of the State of New York, Title 6, Environmental Conservation, Part 231. "New Source Review in Nonattainment Areas and Ozone Transport Regions."
American Coal Ash Association (ACAA). 2007. "ACAA Releases 2006 CCP Production and Use Survey." August 24,2007. Available at URL: http://www.acaa-usa.org/associations/8003/files/2006_CCP _Survey (Final-8-24-07).pdf. Accessed April 15, 2008.
American Council for an Energy-Efficient Economy (ACEEE). 2006. "The State Energy Efficiency Scorecard for 2006." Report Number E075. June 2006.
Blake, Michael E. 2008. "U.S. capacity factors: Another small gain, another new peak."
Nuclear News. Volume 51, Number 6. Page 21. May 2008.
Cape Wind Associates, LLC. 2007. Cape Wind Energy Project Final Environmental Impact Statement. February 15, 2007. Available at URL: http://www.capewind.org/article137.htm.
Clean Air Act of 1970, as amended (CAA). 42 USC 7401, et seq.
Clean Water Act of 1977 (CWA). 33 USC 1326 et seq. (common name of the Federal Water Pollution Control Act of 1977).
Coastal Zone Management Act of 1972 (CZMA). 16 USC. 1451-1465.
Department of Energy (DOE). 1986. "Wind Energy Resource Atlas of the United States."
DOE/CH 10093-4, DE86004442. October 1986. Available at URL:
http://rredc.nrel.gov/wind/pubs/atlas/. Accessed March 3, 2008.
Department of Energy (DOE). 2002. Energy Information Administration, "Electric Power Annual December 2008 8-79 Draft NUREG-1437, Supplement 38
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http://tonto.eia.doe.gov/FTPROOT/electricity/0348002.pdf. Accessed November 22, 2005.
Department of Energy (DOE). 2006. "National Electric Transmission Congestion Study."
August.
Department of Energy (DOE). 2008. "U.S. Atlas of Renewable Resources." National Renewable Energy Laboratory. Available at URL:
http://www.nre!.gov/gis/maps.html#resource_atlas. Accessed June 9,2008.
Department of Energy, Energy Information Administration (DOE/EIA). 2001. "Cost and Quality of Fuels for Electric Utility Plants 2000 Tables." DOE/EIA-0191(00). August 2001. Available at URL: http://tonto.eia.doe.gov/FTPROOT/electricity/019100.pdf.
Department of Energy, Energy Information Administration (DOE/EIA). 2006 "Assumptions to the Annual Energy Outlook 2006 with Projections to 2030." DOE/EIA-0554(2006). Washington, DC. Available at URL: http://tonto.eia.doe.gov/FTPROOT/forecasting/0554(2006).pdf.
Department of Energy, Energy Information Administration (DOE/EIA). 2007a. "Annual Energy Outlook 2007 with Projections to 2030." Energy Information Administration, Office of Integrated Analysis and Forecasting, U.S. Department of Energy, Washington, DC. DOE/EIA-0383(2007).
February.
Department of Energy, Energy Information Administration (DOE/EIA). 2007b. "Assumptions to the Annual Energy Outlook 2007, Electricity Market Module." DOE/EIA-0554(2007). April 2007.
Department of Energy, Energy Information Administration (DOE/EIA). 2008. "New York Renewable Electricity Profile: 2006 Edition." Release date: May 2008b. Available at URL:
www.eia.doe.gov/cneaf/solar.renewables/page/stateprofiles/newyork.htm!. Accessed June 13, 2008.
Department of Energy, Energy Information Administration (DOE/EIA). 2008a. "Voluntary Reporting of Greenhouse Gases Program (Emission Coefficients)." Available at URL:
http://www.eia.doe.gov/oiafl1650/factors.html. Accessed March 26, 2008.
Department of Energy, Energy Information Administration (DOE/EIA). 2008b. "Short-Term Energy Outlook." December 9,2008. Available at URL:
http://www.eia.doe.gov/emeu/steo/pub/contents.html. Accessed December 9, 2008.
Enercon Services, Inc. (Enercon). 2003. "Economic and Environmental Impacts Associated with Conversion of Indian Point Units 2 and 3 to a Closed-Loop Condenser Cooling Water Configuration."
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Environmental Report References." November 14, 2007. ADAMS Accession No. ML073330590 Entergy Nuclear Operations, Inc. (Entergy) 2007. "Applicant's Environment Report, Operating License Renewal Stage." (Appendix E to Indian Point. Units 2 and 3, License Renewal Application). April 23, 2007. Agencywide Documents Access and Management System (ADAMS) Accession No. ML071210530.
Environmental Protection Agency (EPA). 1998. "Compilation of Air Pollutant Emission Factors," Volume 1, "Stationary Point and Area Sources: AP 42," Fifth Edition. Section 1.1, Draft NUREG-1437, Supplement 38 8-80 December 2008
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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 Environmental Impacts of License Renewal "Bituminous and Subbituminous Coal Combustion: Final Section, Supplement E." Available at URL: http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s01.pdf.
Environmental Protection Agency (EPA). 2000a. "Regulatory Finding on the Emissions of Hazardous Air Pollutants from Electric Utility Steam Generating Units." Federal Register.
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Environmental Protection Agency (EPA). 2007. "National Pollutant Discharge Elimination System-Suspension of Regulations Establishing Requirements for Cooling Water Intake Structures at Phase II Existing Facilities." Federal Register, Volume 72, Number 130, pp.37107-37109. Washington, DC. July 9,2007.
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New York State Department of Environmental Conservation (NYSDEC). 2003b. Entergy Nuclear Indian Point 2 and 3-Ruling. In the Matter of a Renewal and Modification of a State Pollutant Discharge Elimination System (SPDES) Discharge Permit Pursuant to Environmental Conservation Law (ECL) Article 17 and Title 6 of the Official Compilation of Codes, Rules, and Regulations of the State of New York (6 NYCRR) Parts 704 and 750 et seq. by Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3. LLC, Permittees. February 3,2003.
Draft NUREG-1437, Supplement 38 December 2008
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"New York State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with Modification, IP2 and IP3 Electric Generating Station, Buchanan, NY." November 2003.
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New York State Department of Environmental Conservation (NYSDEC). 2003d. "Final Environmental Impact Statement Concerning the Applications to Renew New York State Pollutant Discharge Elimination System (SPDES) Permits for the Roseton 1 and 2, Bowline 1 and 2, and Indian Point 2 and 3 Steam Electric Generating Stations, Orange, Rockland and Westchester Counties. Hudson River Power Plants FEIS," June 25, 2003.
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NUREG-1437, Volume 1, Addendum 1, Washington, DC.
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Draft NUREG-1437. Supplement 38 8-84 December 2008
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9.0
SUMMARY
AND CONCLUSIONS 2
Entergy Nuclear Operations, Inc. (Entergy), Entergy Nuclear Indian Point 2 (IP2), LLC, and 3
Entergy Nuclear Indian Point 3 (IP3), LLC, are joint applicants for the renewal of the IP2 and IP3 4
operating licenses Goint applicants will be referred to as Entergy). On April 30, 2007, Entergy submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the IP2 6
and IP3 operating licenses for an additional 20 years each under Title 10, Part 54, 7
"Requirements for Renewal of Operating Licenses for Nuclear Power Plants," of the Code of 8
Federal Regulations (10 CFR Part 54) (Entergy 2007a). If the operating licenses are renewed, 9
State and Federal (other than NRC) regulatory agencies and Entergy would ultimately decide whether the plant will continue to operate based on factors such as the need for power, power 11 availability from other sources, regulatory mandates, or other matters within the agencies' 12 jurisdictions or the purview of the owners. If the NRC decides not to renew the operating 13 licenses, then the units must be shut down upon the expiration of the current operating licenses, 14 subject to the conclusion of the license renewal process. If the license renewal review is ongoing at the time of license expiration, the units will be allowed to continue operating until the 16 NRC makes a determination. The IP2 operating license will expire on September 28, 2013; the 17 IP3 operating license will expire on December 12, 2015.
18 Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA), requires an 19 environmental impact statement (EIS) for major Federal actions that significantly affect the quality of the human environment. The NRC has implemented Section 102 of NEPA in 21 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related 22 Regulatory Functions." As identified in 10 CFR Part 51, certain licensing and regulatory actions 23 require an EIS. In 10 CFR 51.20(b)(2), the NRC requires preparation of an EIS or a supplement 24 to an EIS for renewal of a reactor operating license. Furthermore, 10 CFR 51.95(c) states that the EIS prepared at the operating license renewal stage will be a supplement to NUREG-1437, 26 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 27 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999).(1) 28 Upon acceptance of the license renewal application, the NRC began the environmental review 29 process described in 10 CFR Part 51 by publishing, on August 10, 2007, a Notice of Intent to prepare an EIS and conduct scoping (Volume 72, page 45075, of the Federal Register 31 (72 FR 45075)). The NRC staff held two public scoping meetings on September 19, 2007, and 32 visited the IP2 and IP3 site to conduct site audits on September 10-14, 2007, and 33 September 24-27, 2007. The NRC staff reviewed the Entergy environmental report (ER) 34 (Entergy 2007b) and compared it to the GElS, consulted with other agencies, and conducted an independent review of the issues following the guidance set forth in NUREG-1555, 36 Supplement 1, "Standard Review Plans for Environmental Reviews for Nuclear Power Plants, 37 Supplement 1: Operating License Renewal" (NRC 2000). The NRC staff also considered the 38 public comments received during the scoping process for preparation of this draft supplemental 39 environmental impact statement (SEIS) for IP2 and IP3. Public comments and NRC staff responses are available in the Scoping Summary Report prepared by the NRC staff (ADAMS (1)
The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the GElS include the GElS and its Addendum 1.
December 2008 9-1 Draft NUREG-1437, Supplement 38
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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 Summary and Conclusions Accession Number ML083360115).
The NRC staff plans to hold public meetings in Cortlandt Manor, New York, in February of 2009 to present the preliminary results of the NRC environmental review, answer questions from the public, and receive comments on this draft SEIS. When the comment period ends, the NRC staff will consider and address all of the comments received. These comments will be addressed in Part 2 of Appendix A to the final SEIS.
This draft SEIS includes the NRC staff's preliminary analysis that considers and weighs the environmental effects of the proposed action (including cumUlative impacts), the environmental impacts of alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse effects. This draft SEIS also includes the NRC staff's preliminary recommendation regarding the proposed action.
The NRC has adopted the following statement of purpose and need for license renewal from the GElS:
The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by State, utility, and, where authorized, Federal (other than NRC) decisionmakers.
The evaluation criterion for the NRC staff's environmental review, as defined in 10 CFR 51.95(c){4) and the GElS, is to determine the following:
whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable.
Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that there are factors, in addition to license renewal, that would contribute to the NRC's ultimate determination of whether an existing nuclear power plant continues to operate beyond the period of the current operating licenses.
NRC regulations (10 CFR 51.95(c)(2)) contain the following statement regarding the content of SEISs prepared at the license renewal stage:
The supplemental environmental impact statement for license renewal is not required to include discussion of need for power or the economic costs and economic benefits of the proposed action or of alternatives to the proposed action except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation. In addition, the supplemental environmental impact statement prepared at the license renewal stage need not discuss other issues not related to the environmental effects of the proposed action and the alternatives, or any aspect of the storage of spent fuel for the facility within the scope of the generic determination in 10 CFR 51.23(a) and in accordance with Draft NUREG-1437, Supplement 38 9-2 December 2008
Summary and Conclusions 1
10 CFR 51.23(b).(2) 2 3
The GElS contains the results of a systematic evaluation of the consequences of renewing an 4
operating license and operating a nuclear power plant for an additional 20 years. It evaluates 5
92 environmental issues using the NRC's three-level standard of significance-SMALL, 6
MODERATE, or LARGE-developed on the basis of the Council on Environmental Quality 7
guidelines. The following definitions of the three significance levels are set forth in the footnotes 8
to Table B-1 of Appendix B to Subpart A, "Environmental Effect of Renewing the Operating 9
License of a Nuclear Power Plant," of 10 CFR Part 51:
10 SMALL-Environmental effects are not detectable or are so minor that they will 11 neither destabilize nor noticeably alter any important attribute of the resource.
12 MODERATE-Environmental effects are sufficient to alter noticeably, but not to 13 destabilize, important attributes of the resource.
14 LARGE-Environmental effects are clearly noticeable and are sufficient to 15 destabilize important attributes of the resource.
16 For 69 of the 92 environmental issues considered in the GElS, the NRC staff analysis in the 17 GElS shows the following:
18 (1)
The environmental impacts associated with the issue have been determined to apply 19 either to all plants or, for some issues, to plants having a specific type of cooling system 20 or other specified plant or site characteristics.
21 (2)
A single significance level (Le., SMALL, MODERATE, or LARGE) has been assigned to 22 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 23 high-level waste and spent fuel disposal).
24 (3)
Mitigation of adverse impacts associated with the issue has been considered in the 25 analysis, and it has been determined that additional plant-specific mitigation measures 26 are likely not to be sufficiently beneficial to warrant implementation.
(2)
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."
December 2008 9-3 Draft NUREG-1437, Supplement 38
5 10 15 20 25 30 35 40 Summary and Conclusions 1
These 69 issues were identified in the GElS as Category 1 issues. In the absence of new and 2
significant information, the NRC staff relied on conclusions as amplified by supporting 3
information in the GElS for issues designated as Category 1 in 10 CFR Part 51, Subpart A, 4
Appendix B, Table B-1.
Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 6
issues requiring analysis in a plant-specific SEIS. The remaining two issues, environmental 7
justice and chronic effects of electromagnetic fields, were not categorized.
8 This draft SEIS documents the NRC staff's consideration of all 92 environmental issues 9
identified in the GElS. The NRC staff considered the environmental impacts associated with alternatives to license renewal and compared the environmental impacts of license renewal and 11 the alternatives. The alternatives to license renewal that were considered include the no-action 12 alternative (not renewing the operating licenses for IP2 and IP3), alternative methods of power 13 generation, and conservation. When possible, these alternatives were evaluated assuming that 14 the replacement power generation plant, if any, could be located at either the IP2 and IP3 site or some other unspecified location.
16 9.1 Environmental Impacts of the Proposed Action-License Renewal 17 The NRC staff has established an independent process for identifying and evaluating the 18 significance of any new information on the environmental impacts of license renewal. The NRC 19 staff has not identified any information that is both new and significant related to Category 1 issues that would call into question the conclusions in the GElS. In the IP2 and IP3 ER, Entergy 21 identified leakage from onsite spent fuel pools as potentially new and significant information 22 (Entergy 2007a). The NRC staff has reviewed Entergy's analysis of the leakage and has 23 conducted an extensive onsite inspection of leakage to ground water, as identified in Section 24 2.2.7 of this draft SEIS. Based on the NRC staffs review of Entergy's analysis, the NRC staffs adoption of the NRC inspection report findings in this SEIS, and Entergy's subsequent 26 statements (all discussed in Section 2.2.7), the NRC staff concludes that the abnormal liquid 27 releases discussed by Entergy in its ER, while new information, are within the NRC's radiation 28 safety standards contained in 10 CFR Part 20 and are not considered to have a significant 29 impact on plant workers, the public, or the environment (I.e., while the information related to spent fuel pool leakage is new, it is not significant). Therefore, the NRC staff relied upon the 31 conclusions of the GElS for all Category 1 issues that are applicable to IP2 and IP3.
32 Entergy's license renewal application contains an analysis of the Category 2 issues that are 33 applicable to IP2 and IP3, plus environmental justice and chronic effects from electromagnetic 34 fields for 23 total issues. The NRC staff has reviewed the Entergy analysis and has conducted an independent review of each issue. Six of the Category 2 issues are not applicable because 36 they are related to cooling systems, water use conflicts, and ground water use not found at IP2 37 and IP3.
38 As discussed in Chapter 3, scoping comments revealed-and Entergy indicated-that Entergy 39 may replace reactor vessel heads and control rod drive mechanisms in both units. As a result, the NRC staff addressed the impacts of these replacement activities in Chapter 3. This includes 41 three Category 2 issues that apply only to refurbishment, six Category 2 issues that apply to Draft NUREG-1437, Supplement 38 9-4 December 2008
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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 Summary and Conclusions refurbishment and continued operation, and one uncategorized issue, environmental justice, that applies to both refurbishment and continued operations. The NRC staff determined that all effects from refurbishment are of SMALL significance.
The NRC staff addresses twelve Category 2 issues related to impacts from continued operations and postulated accidents during the renewal term, as well as environmental justice and chronic effects of electromagnetic fields. Research is continuing in the area of chronic effects on electromagnetic fields, and a scientific consensus has not been reached. Therefore, no further evaluation of this issue is required. The NRC staff concludes that the potential environmental effects for 8 of the 12 categorized issues are of SMALL significance in the context of the standards set forth in the GElS. The NRC staff concludes that the combined impacts from impingement and entrainment (each a separate issue) range from SMALL to LARGE, depending on fish species affected. Impacts from heat shock could range from SMALL to MODERATE. Finally, given a lack of current impingement monitoring data, impacts to the endangered shortnose sturgeon could range from SMALL to LARGE (see Chapter 4 of this draft SEIS).
For severe accident mitigation alternatives (SAMAs), the NRC staff concludes that a reasonable, comprehensive effort was made by Entergy to identify and evaluate SAMAs.
Based on its review of the SAMAs for IP2 and IP3, and the plant improvements already made, the NRC staff concludes that several candidate SAMAs may be cost-beneficial. However, these SAMAs do not relate to adequately managing the effects of aging during the period of extended operation. Therefore, they need not be implemented as part of license renewal pursuant to 10 CFR Part 54.
Mitigation measures were considered for each Category 2 issue. For all issues of SMALL significance, current measures to mitigate the environmental impacts of plant operation were found to be adequate. For issues of MODERATE or LARGE significance (Le., issues related to aquatic ecology), mitigation measures are addressed both in Chapter 4 and in Chapter 8 as alternatives based on determinations in the draft New York State Department of Environmental Conservation (NYSDEC) State Pollutant Discharge Elimination System (SPDES) permit. These alternatives included plant operation with a new closed-cycle cooling system (Section 8.1.1) and operation of the existing once-through cooling system with enhanced controls and restoration efforts (Section 8.1.2).
Cumulative impacts of past, present, and reasonably foreseeable future actions were considered, regardless of what agency (Federal or non-Federal) or person undertakes such other actions. The NRC staff concludes that the cumulative impacts to the environment around IP2 and IP3 license renewal would be LARGE for some affected resources, given historical environmental impacts, current actions, and likely future actions. With the exception of aquatic resources, the contribution of IP2 and IP3 to cumulative impacts is SMALL.
The following sections discuss unavoidable adverse impacts, irreversible or irretrievable commitments of resources, and the relationship between local short-term use of the environment and long-term productivity.
December 2008 9-5 Draft NUREG-1437, Supplement 38
5 10 15 20 25 30 35 Summary and Conclusions 1
9.1. 1 Unavoidable Adverse Impacts 2
An environmental review conducted at the license renewal stage differs from the review 3
conducted in support of a construction permit because the plant is in existence at the license 4
renewal stage and has operated for a number of years. As a result, adverse impacts associated with the initial construction have already occurred, have been mitigated, or have been avoided.
6 The environmental impacts to be evaluated for license renewal are those associated with 7
refurbishment and continued operation during the renewal term.
8 Unavoidable adverse impacts of continued operation from heat shock and the combined effects 9
of entrainment and impingement of fish and shellfish are considered SMALL to MODERATE and SMALL to LARGE, respectively. Unavoidable adverse impacts from license renewal may 11 be SMALL to LARGE for the endangered shortnose sturgeon as a result of limited data. Other 12 unavoidable adverse impacts are considered to be of SMALL significance.
13 Unavoidable adverse impacts of likely alternatives to the operation of IP2 and IP3 vary greatly.
14 All have smaller impacts to aquatic resources than the current IP2 and IP3, though all also have larger impacts than the current IP2 and IP3 in at least one other resource area.
16 9.1.2 Irreversible or Irretrievable Resource Commitments 17 The commitment of resources related to construction and operation of IP2 and IP3 during the 18 current license period was made when the plant was built. The resource commitments to be 19 considered in this draft SEIS are associated with continued operation of the plant for an additional 20 years. These resources include materials and equipment required for plant 21 maintenance, operation, and refurbishment; the nuclear fuel used by the reactors; and 22 ultimately, permanent offsite storage space for the spent fuel assemblies.
23 Entergy may be required to commit additional resources should the final NYSDEC SPDES 24 permit require closed-cycle cooling (as the draft SPDES permit does in its current form) and Entergy decides to (1) build and operate a closed-cycle cooling system to meet the permit's 26 required reductions in impacts to aquatic ecology, or (2) to invest in cooling water intake 27 modifications and restoration activities. However, regardless of the future status of the SPDES 28 permit, significant resource commitments will be required during the renewal term for additional 29 fuel and the permanent spent fuel storage space. IP2 and IP3 replace a portion of their fuel assemblies during every refueling outage, which typically occurs on a 24-month cycle (Entergy 31 2007a). Additional resources may also be committed to constructing and installing new reactor 32 vessel heads and control rod drive mechanisms.
33 The likely energy alternatives would also require a commitment of resources for construction of 34 the replacement facilities, implementation of conservation measures, and in some cases, fuel to run plants. Significant resource commitments would also be required for development of 36 transmission capacity. These resource commitments, however, would not necessarily come 37 from Entergy because Entergy currently has no obligation to support power production in the 38 New York area should IP2 a~d IP3 shut down.
Draft NUREG-1437, Supplement 38 9-6 December 2008
5 10 15 20 25 30 35 40 Summary and Conclusions 9.1.3 Short-Term Use Versus Long-Term Productivity 2
An initial balance between local short-term uses of the environment and maintenance and 3
enhancement of long-term productivity at IP2 and IP3 was set when the plant was approved and 4
construction began. Renewal of the operating licenses for IP2 and IP3 and continued operation of the plant would not alter the existing balance, but may postpone the availability of the site for 6
other uses. Denial of the application to renew the operating licenses would lead to a shutdown 7
of the plant that will alter the balance in a manner that depends on subsequent uses of the site.
8 Furthermore, new replacement energy sources or conservation options will establish new 9
balances at their respective locations.
9.2 Relative Significance of the Environmental Impacts of License 11 Renewal and Alternatives 12 The proposed action is renewal of the operating licenses for IP2 and I P3. Chapter 2 describes 13 the site, power plant, and interactions of the plant with the environment. Chapters 3 through 7 14 discuss environmental issues associated with renewal of the operating licenses. Environmental issues associated with the no-action alternative and alternatives such as new power generation, 16 purchased power, conservation, and cooling system modifications are discussed in Chapter 8.
17 The significance of the environmental impacts from the proposed action (approval of the 18 application for renewal of the operating licenses), the no-action alternative (denial of the 19 application), alternatives involving altering plant operations to comply with the NYSDEC draft SPDES discharge permit, construction of coal-or gas-fired generating capacity at alternate 21 sites, gas-fired generation of power at IP2 and IP3, and two combinations of alternatives are 22 compared in Table 9-1. All new fossil-fueled alternatives presented in Table 9-1 are assumed to 23 use closed-cycle cooling systems given current regulations for new power plants.
24 Table 9-1 shows the significance of the plant-specific environmental effects of the proposed action (renewal of IP2 and IP3 operating licenses) as well as environmental effects of 26 alternatives to the proposed action. Impacts from license renewal would be SMALL for all 27 impact categories except aquatic ecology, which includes the impacts of heat shock, 28 entrainment, and impingement. Chapter 4 of this draft SEIS describes the SMALL to LARGE 29 impacts of plant operation on aquatic ecology through impingement and entrainment (impact levels vary by species), and the SMALL to MODERATE impacts from thermal shock. Overall, 31 impacts to aquatic ecology from continued operation of IP2 and IP3 without cooling system 32 modifications or restoration actions is SMALL to LARGE. A single significance level was not 33 assigned for the collective offsite radiological impacts from the fuel cycle and from high-level 34 radioactive waste spent fuel disposal (see Chapter 6).
NRC staff analysis indicates that the no-action alternative has the smallest effect, but it would 36 necessitate additional actions to replace generation capacity (whether with newly-constructed 37 power plants or purchased power) and/or to institute conservation programs. Impacts of the 38 likely consequences of the no-action alternative would be similar to those of the energy 39 alternatives that the NRC staff considered. All other alternative actions have impacts in at least four resource areas that reach SMALL to MODERATE or higher significance. Often, these December 2008 9-7 Draft NLiREG-1437, Supplement 38
Summary and Conclusions impacts are the result of constructing new facilities or infrastructure.
2 9.3 Conclusions and Recommendations 3
Based on (1) the analysis and findings in the GElS, (2) the ER submitted by Entergy, 4
(3) consultation with Federal, State, and local agencies, (4) the NRC staffs consideration of 5
public scoping comments received, and (5) the NRC staffs independent review, the preliminary 6
recommendation of the NRC staff is that the Commission determine that the adverse 7
environmental impacts of license renewal for IP2 and IP3 are not so great that preserving the 8
option of license renewal for energy planning decisionmakers would be unreasonable.
Draft NUREG-1437, Supplement 38 9-8 December 2008
Summary and Conclusions o
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Table 9-1. Summary of Environmental Significance of License Renewal, the No-Action Alternative, and Alternative 3~
Methods of Generation N a a OJ
<0 I
<0 z c Proposed Action No-Action Alternative(b)
License Renewal with Coal-Fired Plant(d)
Impact Category License Renewal Denial of Renewal New Closed Once-Through Cycle Cooling Cooling with Restoration Alternate Site Land Use Ecology-Aquatic SMALL SMALL to LARGE(a)
SMALL SMALL SMALL to SMALL to LARGE MODERATE SMALL to SMALL MODERATE MODERATE to LARGE SMALL Ecology-Terrestrial SMALL SMALL SMALL to SMALL to MODERATE MODERATE MODERATE to LARGE Water Use and Quality SMALL SMALL SMALL SMALL to MODERATE SMALL to MODERATE Air Quality SMALL SMALL SMALL SMALL MODERATE Waste SMALL SMALL SMALL to SMALL LARGE MODERATE Human Health SMALL (e)
SMALL SMALL SMALL SMALL to LARGE Socioeconomics SMALL SMALL to MODERATE SMALL SMALL SMALL to LARGE Transportation Aesthetics SMALL SMALL SMALL SMALL SMALL to SMALL LARGE MODERATE SMALL MODERATE to LARGE SMALL to LARGE Historical and Archeological Resources SMALL SMALL SMALL SMALL to MODERATE SMALL to MODERATE Environmental Justice SMALL SMALL SMALL SMALL SMALL to LARGE 4fg G)
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December 2008 9-9 Draft NUREG-1437, Supplement 38 m
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Indian Point License Renewal Docket No. 50-247-LR 50-286-LR NRC STAFF'S ANSWER TO THE STATE OF NEW YORK'S MOTION FOR LEAVE TO FILE A NEW CONTENTION, AND NEW CONTENTION 37, CONCERNING THE FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT Attachment B
80440 Federal Register/Vol. 73, No. 251/Wednesday, December 31, 200S/Notices for public inspection at the Commission's Public Document Room (PDR), located at One White Flint North, Public File Area 01 F21, 11555 Rockville Pike (first floor), Rockville, Maryland. Publicly available records will be accessible electronically from the Agencywide Documents Access and Management System's (ADAMS) Public Electronic Reading Room on the Internet at the NRC Web site http://www.nrc.gov/
reading-rm.html. Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC PDR Reference staff by telephone at 1-800-397-4209, or 301 415-4737, or bye-mail to pdr.resource@nrc.gov.
Dated at Rockville. Maryland. this 23rd day of December 2008.
For the Nuclear Regulatory Commission.
public inspection.
Mohan C. Thadani, Any interested partih max..£!lEmit 1
Senior Project Manager, Plant Licensing Branch LPLlV, Division ofOperating Reactor licensing, Office ofNuclear Reactor Regulation.
[FR Doc. E8-31163 Filed 12-30-08; 8:45 ami BILLING CODE 7S9O-Q1-P NUCLEAR REGULATORY COMMISSION
[Docket Nos. 50-247 and 50-286]
Indian Point Nuclear Generating Unit Nos. 2 and 3; Notice of Availability of the Draft Supplement 38 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meeting for the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 Notice is hereby given that the U.S.
Nuclear Regulatory Commission (NRC, Commission) has published a draft plant-specific supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GElS), NUREG-1437, regarding the renewal of operating licenses DPR-26 and DPR-64 for an additional 20 years of operation for the Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3). IP2 and IP3 are located in Westchester County in the village of Buchanan, New York, approximately 24 miles north of New York City. Possible alternatives to the proposed action (license renewal) include no action and reasonable alternative energy sources. Draft Supplement 38 to the GElS is publicly available at the NRC Public Document Room (PDRl. located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://
adamswebsearch.nrc.gov/dologin.htm.
The Accession Numbers for draft Supplement 38 to the GElS are ML083540594 (Volume 1, main report) and ML083540514 (Volume 2, appendices). Persons who do not have access to ADAMS, or who encounter problems in accessing the documents located in ADAMS, should contact the NRC(s PDR reference staff by telephone at 1-800-397-4209 or 301-415-4737, or bye-mail atPDR.Resource@nrc.gov.ln addition, the White Plains Public Library (White Plains, NY), Hendrick Hudson Free Library (Montrose, NY),
and the Field Library (Peekskill, NY),
have agreed to make the draft supplement to the GElS available for comments on the dra supplement to the GElS for consideration by the NRC staff. To be considered, comments on the draft supplement to the GElS and the proposed action must be received by March 18, 2009; the NRC staff is able to ensure consideration only for comments received on or before this date.
Comments received after the due date will be considered only if it is practical to do so. Written comments on the draft supplement to the G ould be sent to: Chief, Rulemaking, Directives an Edttmg Branch, DiviSIOn of Administrative Services, Office of Administration, Mailstop T-5D59, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001.
Comments may be hand-delivered to the NRC at 11545 Rockville Pike, Room T-6D59, Rockville, Maryland 20852, between 7:30 a.m. and 4:15 p.m. on Federal workdays. Electronic comments may be submitted to the NRC bye-mail at IndianPoint.EIS@nrc.gov. All comments received by the Commission, including those made by Federal, State, local agencies, Native American Tribes, or other interested persons, will be made available electronically at the Commission's PDR in Rockville, Maryland, and through ADAMS.
The NRC staff will hold a public meeting to present an overview of the draft plant-specific supplement to the GElS and to accept public comments on the document. The public meeting will be held on February 12, 2009, at the Colonial Terrace, 119 Oregon Road, Cortlandt Manor, New York 10567.
There will be two sessions to accommodate interested parties. The first session will convene at 1:30 p.m.
and will continue until 4:30 p.m., as necessary. The second session will convene at 7 p.m. with a repeat of the overview portions of the meeting and will continue until 10 p.m., as necessary. Both meetings will be transcribed and will include: (1) A presentation of the contents of the draft plant-specific supplement to the GElS, and (2) the opportunity for interested government agencies, organizations, and individuals to provide comments on the draft report. Additionally, the NRC staff will host informal discussions one hour prior to the start of each session at the same location. No comments on the draft supplement to the GElS will be accepted during the informal discussions. To be considered, comments must be provided either at the transcribed public meeting or in writing. Persons may pre-register to present oral comments at the meeting by contacting Mr. Andrew Stuyvenberg, the NRC Environmental Project Manager at 1-800-358-5542, extension 4005, or by e-mail atlndianPoint.EIS@nrc.gov.no later than January 29, 2009. Members of the public may also register to provide oral comments within 15 minutes of the start of each session. Individual, oral comments may be limited by the time available, depending on the number of persons who register. If special equipment or accommodations are needed to attend or present information at the public meeting, the need should be brought to Mr. Stuyvenberg's attention no later than January 25, 2009, to provide the NRC staff adequate notice to determine whether the request can be accommodated.
FOR FURTHER INFORMATION CONTACT: Mr.
Stuyvenberg, Projects Branch 2, Division of License Renewal. Office of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission, Mail Stop 0-11Fl, Washington, DC 20555 0001. Mr. Stuyvenberg may be contacted at the aforementioned telephone number or e-mail address.
Dated at Rockville, Maryland, this 22nd day of December, 2008.
For the Nuclear Regulatory Commission.
David J. Wrona, Branch Chief, Projects Branch 2, Division of License Renewal, Office of Nuclear Reactor Regulation.
[FR Doc. E8-31161 Filed 12-30-08; 8:45 amI BILLING CODE 75~1-P
Indian Point License Renewal Docket No. 50-247 -LR 50-286-LR NRC STAFF'S ANSWER TO THE STATE OF NEW YORK'S MOTION FOR LEAVE TO FILE A NEW CONTENTION, AND NEW CONTENTION 37, CONCERNING THE FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT Attachment C
Land-Use Requirements of Modern Wind Power Plants in the United States Paul Denholm, Maureen Hand, Maddalena Jackson, and Sean Ong Technical Report NREUTP-6A2-45834 August 2009
Buffer Areas I~
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Buffer Area 2 Spring Creek Wind Farm (CPV VVind)
Buffer Area 3 Geneseo. Illinois Figure 11. Possible methodologies for assigning uniform land metrics to total area of wind power plants 6 Conclusions Although there is no uniformly accepted single metric of land use for wind power plants, two primary indices of land use do exist the infrastructure/direct impact area (or land temporarily or permanently disturbed by wind power plant development) and the total area (or overall area of the power plant as a whole).
Based on the collected data, direct impact is mostly caused by road development, as opposed to the turbine pads and electrical support equipment. For 93 projects representing about 14 OW of proposed or installed capacity, the average permanent direct impact value reported was 0.3 +/- 0.3 hectareslMW of capacity. Fewer projects (52 representing 9 OW of capacity) provide temporary direct impact data, with an overall average of0.7 +/- 0.6 hectareslMW of capacity. This implies a total direct impact area (both temporary and permanently disturbed land) ofabout 1 +/- 0.7 hectare/MW, but with a wide variation in this area.
We also found reported total-area data for 161 projects representing about 25 OW of proposed or installed capacity. Excluding several outliers, the average value for the total project area was about 34 +/- 22 hectares/MW, equal to a capacity density of 3.0 +/- 1.7 22