Text

E-mail from D. Beissel W/Attachment, NRR to I. King on Salem Hope Chapter 8 (Bob Dover'S Hydro Sections)
	ML11263A136
Person / Time
Site:	Salem, Hope Creek
Issue date:	04/04/2011
From:	Beissel D; Division of License Renewal
To:	King I; Division of License Renewal
References
	FOIA/PA-2011-0113
	Download: ML11263A136 (48)
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King, Ikeda From: Beissel, Dennis Sent: Monday, April 04, 2011 1:58 PM To: King, Ikeda

Subject:

FW: Salem/Hope Chapter 8 (Bob Dovers Hydro sections)

Attachments: Chapter 8 v 2.docx -

Print this up for Leslie??

From: Eccleston, Charles Sent: Monday, July 19, 2010 10:56 AM To: Beissel, Dennis Cc: Eccleston, Charles

Subject:

Salem/Hope Chapter 8 (Bob Dovers Hydro sections)

Dennis, Here is Chapter 8. Just need you to review the hydro sections.

Ch4r/ q'". Ecdtro4 Charles H. Eccleston Nuclear Reactor Regulation Licensing Renewal, Project Manager 301.415.8537 charles.eccleston wnrc.gov 1

1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 2 The National Environmental Policy Act (NEPA) mandates that each environmental impact 3 statement (EIS) consider alternatives to any proposed major Federal action significantly 4 affecting the quality of the human environment. U.S. Nuclear Regulatory Commission (NRC) 5 regulations implementing NEPA for license renewal require that a supplemental environmental 6 impact statement (SEIS) consider and weigh "the environmental effects of the proposed action 7 (license renewal); the environmental impacts of alternatives to the proposed action; and 8 alternatives available for reducing or avoiding adverse environmental impacts," (Title 10 of the 9 Code of Federal Regulations (CFR) 51.71 d).

10 This SEIS considers the proposed Federal action of issuing a renewed license for the Salem 11 Nuclear Generating Stations, Units 1 and 2 (Salem) and Hope Creek Generating Station 12 (HCGS), which would allow the plants to operate for 20 years beyond the current license 13 expiration dates. In this chapter, the NRC staff (Staff) examines the potential environmental 14 impacts of alternatives to issuing a renewed operating license for Salem and HCGS, as well as 15 alternatives that may reduce or avoid adverse environmental impacts from license renewal, 16 when and where these alternatives are applicable.

17 While the Generic Environmental Impact Statement (GELS) for License Renewal of Nuclear 18 Plants, NUREG-1437 (NRC, 1996; NRC, 1999), reached generic conclusions regarding many 19 environmental issues associated with license renewal, it did not determine which alternatives 20 are reasonable or reach conclusions about site-specific environmental impact levels. As such, 21 the Staff must evaluate environmental impacts of alternatives on a site-specific basis.

22 Alternatives to the proposed action of issuing renewed Salem and HCGS operating licenses 23 must meet the purpose and need for issuing a renewed license; they must 24 provide an option that allows for power generation capability beyond the term of 25 a current nuclear power plant operating license to meet future system generating 26 needs, as such needs may be determined by State, utility, and, where 27 authorized, Federal (other than NRC) decision makers.

28 The Staff ultimately makes no decision as to which alternative (or the proposed action) to 29 implement, since that decision falls to utility, State, or other Federal officials to decide.

30 Comparing the environmental effects of these alternatives will assist the Staff in deciding 31 whether the environmental impacts of license renewal are so great that preserving the option of 32 license renewal for energy-planning decision-makers would be unreasonable (10 CFR 33 51.95[c][4]). If the NRC acts to issue renewed licenses, all of the alternatives, including the 34 proposed action, will be available to energy-planning decision-makers. If NRC decides not to 35 renew the licenses (or takes no action at all), then energy-planning decision-makers may no 36 longer elect to continue operating Salem and HCGS and will have to resort to another 37 alternative-which may or may not be one of the alternatives considered in this section-to 38 meet their energy needs.

39 In evaluating alternatives to license renewal, the Staff first selects energy technologies or 40 options currently in commercial operation, as well as some technologies not currently in 41 commercial operation but likely to be commercially available by the time the current Salem and April 2010 8-1 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 HCGS operating licenses expire. The current Salem operating licenses will expire on August 13, 2 2016 for Unit 1 and April 18, 2020 for Unit 2. The current HCGS operating license will expire on 3 April 11, 2026. An alternative must be available (constructed, permitted, and connected to the 4 grid) by the time the current Salem and HCGS 5 licenses expire.

6 Second, the Staff screens the alternatives to remove In-Depth 7 those that cannot meet future system needs, and then Alternatives:I 8 screens the remaining options to remove those whose 9 costs or benefits do not justify inclusion in the range

Coal-fired 10 of reasonable alternatives. Any alternatives supercritical 11 remaining, then, constitute alternatives to the 0 Natural gas-fired 12 proposed action that the Staff evaluates in detail combined-cycle 13 throughout this section. In Section 8.2, the SEIS

Combination 14 briefly addresses each alternative that the Staff 15 removed during screening and explains why each Other Alternatives 16 alternative was removed. Considered:

Offsite Coal-Fired and 17 The Staff initially considered 17 discrete potential Natural Gas 18 alternatives to the proposed action, and then 0 New nuclear 19 narrowed the list to two discrete alternatives and a

Conservationl 20 combination of alternatives considered in section 8.1. Efficiency

Purchased power 21 Once the Staff identifies alternatives for in-depth 0 Solar power 22 review, the Staff refers to generic environmental 0 Wood-fired 23 impact evaluations in the GELS. The GElS provides combustion 24 overviews of some energy technologies available at

Wind 25 the time of its publishing in 1996, though it does not (onshore/offshore) 26 reach any conclusions regarding which alternatives 0 Hydroelectric power 27 are most appropriate, nor does it precisely categorize

Wave and ocean 28 impacts for each site. In addition, since 1996, many energy 29 energy technologies have evolved significantly in energy 30 capability and cost, while regulatory structures have 0 Geotheral powe 31 changed to either promote or impede development of 0 Municipal solid waste 32 particular alternatives.

9 Oil-fired Biofuels power 33 As a result, the Staff's analysis starts with the GElS

Fuel cells 34 and then includes updated information from sources

Delayed retirement 35 like the Energy Information Administration (EIA), other 36 organizations within the Department of Energy (DOE),

37 the Environmental Protection Agency (EPA), industry sources and publications, and information 38 submitted in the PSEG Nuclear, LLC (PSEG, the applicant) environmental report (ER).

39 For each in-depth analysis, the Staff analyzes environmental impacts across seven impact 40 categories: (1) air quality, (2) groundwater use and quality, (3) surface water use and quality, (4) 41 aquatic and terrestrial ecology, (5) human health, (6) socioeconomics, and (7) waste 42 management. As in earlier chapters of this draft SEIS, the Staff uses the NRC's three-level Draft NUREG-1437, Supplement 42 8-2 April 2010

Environmental Impacts of Alternatives 1 standard of significance-SMALL, MODERATE, or LARGE-to indicate the degree of the 2 environmental effect on each of the seven aforementioned categories that have been evaluated.

3 The in-depth alternatives that the Staff 4 considered include a supercritical coal- Energy Outlook: Each year the Energy 5 fired plant in section 8.1.1, a natural gas- Information Administration (EIA), part of the 6 fired combined-cycle power plant in U.S. Department of Energy (DOE), issues 7 8.1.2, and a combination of alternatives its updated Annual Energy Outlook (AEO).

8 in 8.1.3 that includes natural gas-fired AEO 2009 indicates that natural gas, coal, 9 generation, energy conservation, and a and renewable are likely to fuel most new 10 wind power component. In section 8.2, electrical capacity through 2030, with some 11 the Staff explains why it dismissed many growth in nuclear capacity (EIA, 2009a),

12 other alternatives from in-depth though all projections are subject to future 13 consideration. In section 8.3, the Staff developments in fuel price or electricity 14 considers the environmental effects that demand:

15 may occur if NRC takes no action and 16 does not issue renewed licenses for "Natural-gas-fired plants account for 53 17 Salem and HCGS. Finally, in section 8.4, percent of capacity additions in the 18 the impacts of all alternatives are reference case, as compared with 22 19 summarized. percent for renewable, 18 percent for coal-fired plants, and 5 percent for nuclear.

20 8.1 ALTERNATIVE ENERGY Capacity expansion decisions consider 21 SOURCES capital, operating, and transmission costs.

Typically, coal-fired, nuclear, and renewable 22 8.1.1 Supercritical Coal-Fired plants are capital-intensive, whereas 23 Generation operating (fuel) expenditures account for most of the costs associated with natural-24 The GElS indicates that a 3656 gas-fired capacity."

25 megawatt-electric (MWe) supercritical 26 coal-fired power plant (a plant equivalent in capacity to each individual Salem Unit 1, Salem Unit 27 2, and HCGS plants) could require 6,233 acres (2,523 hectares) of available land area, and thus 28 would not fit on the existing 1,480 acres owned by PSEG at the Salem and HCGS sites; 29 however, the Staff notes that many coal-fired power plants with larger capacities have been 30 located on smaller sites. In the ERs, PSEG assumed that a coal-fired alternative would be 31 developed on the existing Salem and HCGS sites. The Staff believes this to be reasonable and, 32 as such, will consider a coal-fired alternative located on the current Salem and HCGS sites.

33 Coal-fired generation accounts for 48.2 percent, a greater share of U.S. electrical power 34 generation than any other fuel (EIA, 201 Oa). Furthermore, the EIA projects that coal-fired power 35 plants will account for the greatest share of added capacity through 2030-more than natural 36 gas, nuclear or renewable generation options (EIA, 2009a). While coal-fired power plants are 37 widely used and likely to remain widely used, the Staff notes that future coal capacity additions 38 may be affected by perceived or actual efforts to limit greenhouse gas (GHG) emissions. For 39 now, the Staff considers a coal-fired alternative to be a feasible, commercially available option 40 that could provide electrical generating capacity after the Salem and HCGS current licenses 41 expire.

February 2010 8-3 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 Supercritical technologies are increasingly common in new coal-fired plants. Supercritical plants 2 operate at higher temperatures and pressures than most existing coal-fired plants (beyond 3 water's "critical point", where boiling no longer occurs and no clear phase change occurs 4 between steam and liquid water). Operating at higher temperatures and pressures allows this 5 coal-fired alternative to function at a higher thermal efficiency than many existing coal-fired 6 power plants do. While supercritical facilities are more expensive to construct, they consume 7 less fuel for a given output, reducing environmental impacts. Based on technology forecasts 8 from EIA, the Staff expects that a new, supercritical coal-fired plant beginning operation in 2014 9 would operate at a heat rate of 9069 British thermal units/kilowatt hour (Btu/kWh), or 10 approximately 38 percent thermal efficiency (EIA, 2009a).

11 In a supercritical coal-fired power plant, burning coal heats pressurized water. As the 12 supercritical steam/water mixture moves through plant pipes to a turbine generator, the 13 pressure drops and the mixture flashes to steam. The heated steam expands across the turbine 14 stages, which then spin and turn the generator to produce electricity. After passing through the 15 turbine, any remaining steam is condensed back to water in the plant's condenser.

16 In most modern U.S. facilities, condenser cooling water circulates through cooling towers or a 17 cooling pond system (either of which are closed-cycle cooling systems). Older plants often 18 withdraw cooling water directly from existing rivers or lakes and discharge heated water directly 19 to the same body of water (called open-cycle cooling). Salem operates open-cycle cooling water 20 using once-through cooling at both of their units, while HCGS operates a closed-cycle cooling 21 system with a natural draft cooling tower. Although nuclear plants require more cooling capacity 22 than an equivalently sized coal-fired plant, the existing cooling tower at HCGS, by itself, is not 23 expected to be adequate to support a coal-fired alternative that would have the capacity to 24 replace both Salem and HCGS. Therefore, implementation of a coal-fired alternative would 25 require the construction of additional cooling towers to provide the necessary cooling capacity to 26 support the replacement of both Salem and HCGS. Under the coal-fired alternative, the facility 27 would withdraw makeup water from and discharge blowdown (water containing concentrated 28 dissolved solids and biocides) from cooling towers back to the Delaware River, similar to the 29 manner in which the current HCGS cooling tower operates. However, additional cooling towers 30 would be required, so the volume of water managed in cooling towers would increase. At the 31 same time, the once-through cooling system associated with the Salem Units 1 and 2 would 32 cease operation.

33 In order to replace the 3656 net MWe that Salem and HCGS currently supply, the coal-fired 34 alternative would need to produce roughly 3889 gross MWe, using about 6 percent of power 35 output for onsite power usage (PSEG, 2009a), (PSEG, 2009b). Onsite electricity demands 36 include scrubbers, cooling towers, coal-handling equipment, lights, communication, and other 37 onsite needs. A supercritical coal-fired plant equivalent in capacity to Salem and HCGS would 38 require less cooling water than Salem and HCGS because the alternative operates at a higher 39 thermal efficiency. The 3889 gross MWe would be achieved using standard-sized units, which 40 are assumed to be approximately equivalent to six units of 630 MWe each.

41 The 3656 net MWe power plants would consume approximately 12.2 million tons of coal 42 annually (EPA, 2006). EIA reports that most coal consumed in New Jersey originates in West 43 Virginia or Pennsylvania (EIA, 2010b). Given current coal mining operations in this area, the Draft NUREG-1437, Supplement 42 8-4 April 2010

Environmental Impacts of Alternatives 1 coal used in this alternative would likely be mined by a combination of strip (mountaintop-2 removal) mining and underground mining. The coal would be mechanically processed and 3 washed, and transported by barge to the Salem and HCGS facility. Limestone for scrubbers 4 would also likely be delivered by barge. This coal-fired alternative would produce roughly 5 753,960 tons of ash annually (EIA, 201 Ob), and roughly 245,300 tons of scrubber sludge 6 annually (PSEG, 2009a), (PSEG, 2009b). Much of the coal ash and scrubbed sludge could be 7 reused depending on local recycling and reuse markets.

8 The coal-fired alternative would also include construction impacts such as clearing the plant site 9 of vegetation, excavation, and preparing the site surface before other crews begin actual 10 construction of the plant and any associated infrastructure. Because this alternative would be 11 constructed at the Salem and HCGS site, it is unlikely that new transmission lines would be 12 necessary. Because coal would be supplied by barge no construction of a new rail line would 13 be necessary.

14 Table 8-1. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative 15 Compared to Continued Operation of Salem and HCGS Supercritical Coal-Fired Continued Salem and HOGS Generation Operation Air Quality MODERATE SMALL Groundwater SMALL SMALL Surface Water SMALL SMALL Aquatic and Terrestrial Resources SMALL to MODERATE SMALL Human Health MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Waste Management MODERATE Not Applicable 16 8.1.1.1 Air Quality 17 Air quality impacts from coal-fired generation can be substantial increased because they emit 18 significant quantities of sulfur oxides (SOx), nitrogen oxides (NOx), particulates, carbon 19 monoxide (CO), and hazardous air pollutants such as mercury. However, many of these 20 pollutants can be substantially reduced using various pollution control technologies.

21 Salem and HCGS are located in Salem County, New Jersey. Salem County is designated as in 22 attainment/unclassified with respect to the NAAQSs for PM2.5, S02, NOx, CO, and lead. The 23 county, along with all of southern New Jersey, is a nonattainment area with respect to the 1-February 2010 8-5 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> primary ozone standard and the 8-hour ozone standard. For the 1-hour ozone standard, 2 Salem County is located within the multi-state Philadelphia-Wilmington-Trenton non-attainment 3 area, and for the 8-hour ozone standard, it is located in the Philadelphia-Wilmington-Atlantic 4 City (PA-NJ-DE-MD) non attainment area.

5 A new coal-fired generating plant would qualify as a new major-emitting industrial facility and 6 would be subject to Prevention of Significant Deterioration of Air Quality Review under 7 requirements of Clean Air Act (CAA), adopted by the New Jersey Department of Environmental 8 Protection (NJDEP) Bureau of Air Quality Permitting. A new coal-fired generating plant would 9 need to comply with the new source performance standards for coal-fired plants set forth in 40 10 CFR 60 Subpart Da. The standards establish limits for particulate matter and opacity (40 CFR 11 60.42(a)), sulfur dioxide (SO 2 ) (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)). Regulations 12 issued by NJDEP adopt the EPA's CAA rules (with modifications) to limit power plant emissions 13 of SOx, NOx, particulate matter, and hazardous air pollutants. The new coal-fired generating 14 plant would qualify as a major facility as defined in Section 7:27-22.1 of the New Jersey 15 Administrative Code, and would be required to obtain a major source permit from NJDEP.

16 Section 169A of the CAA (42 United States Code (U.S.C.) 7401) establishes a national goal of 17 preventing future and remedying existing impairment of visibility in mandatory Class I Federal 18 areas when impairment results from man-made air pollution. The EPA issued a new regional 19 haze rule in 1999 (64 FederalRegister (FR) 35714). The rule specifies that for each mandatory 20 Class I Federal area located within a state, the State must establish goals that provide for 21 reasonable progress towards achieving natural visibility conditions. The reasonable progress 22 goals must provide an improvement in visibility for the most-impaired days over the period of 23 implementation plan and ensure no degradation in visibility for the least-impaired days over the 24 same period (40 CFR 51.308(d)(1)). Five regional planning organizations (RPO) collaborate on 25 the visibility impairment issue, developing the technical basis for these plans. The State of New 26 Jersey is among eleven member states (Maryland, Delaware, New Jersey, Pennsylvania, New 27 York, Connecticut, Rhode Island, Massachusetts, Vermont, New Hampshire, and Maine) of the 28 Mid-Atlantic/Northeast Visibility Union (MANE-VU), along with tribes, Federal agencies, and 29 other interested parties that identifies regional haze and visibility issues and develops strategies 30 to address them (NJDEP, 2009a). The visibility protection regulatory requirements, contained in 31 40 CFR Part 51, Subpart P, include the review of the new sources that would be constructed in 32 the attainment or unclassified areas and may affect visibility in any Federal Class I area (40 33 CFR Part 51, Subpart P, §51.307). If a coal-fired plant were located close to a mandatory Class 34 I area, additional air pollution control requirements would be imposed. There is one mandatory 35 Class I Federal areas in the State of New Jersey, which is the Brigantine National Wildlife 36 Refuge (40 CFR 81.420), located approximately 58 miles (93 km) southeast of the Salem and 37 HCGS facilities. There are no Class I Federal areas in Delaware, and no other areas located 38 within 100 miles (161 km) of the facilities (40 CFR 81.400). New Jersey is also subject to the 39 Clean Air Interstate Rule (CAIR), which has outlined emissions reduction goals for both SO 2 and 40 NOx for the year 2015. CAIR will aid New Jersey sources in reducing SO 2 emissions by 25,000 41 tons (or 49 percent), and NOx emissions by 11,000 tons (or 48 percent) (EPA, 2010).

42 The Staff projects that the coal-fired alternative at the Salem and HCGS site would have the 43 following emissions for criteria and other significant emissions based on published EIA data, Draft NUREG-1437, Supplement 42 8-6 April 2010

Environmental Impacts of Alternatives 1 EPA emission factors and on performance characteristics for this alternative and likely emission 2 controls:

3 0 Sulfur oxides (SOx) - 12,566 tons (11,423 MT) per year 4 0 Nitrogen oxides (NOx) - 3050 tons (2773 MT) per year 5 0 Particulate matter (PM) PM1 o - 85.4 tons (77.6 MT) per year 6 ° Particulate matter (PM) PM2.5 - 22.6 tons (20.5 MT) per year 7 ° Carbon monoxide (CO) - 3050 tons (2773 MT) per year 8 Sulfur Oxides 9 The coal-fired alternative at the Salem and HCGS site would likely use wet, limestone-based 10 scrubbers to remove SOx. The EPA indicates that this technology can remove more than 95 11 percent of SOx from flue gases. The Staff projects total SOx emissions after scrubbing would be 12 12,566 tons (11,423 MT) per year. SOx emissions from a new coal-fired power plant would be 13 subject to the requirements of Title IV of the CAA. Title IV was enacted to reduce emissions of 14 SO 2 and NOx, the two principal precursors of acid rain, by restricting emissions of these 15 pollutants from power plants. Title IV caps aggregate annual power plant SO 2 emissions and 16 imposes controls on SO 2 emissions through a system of marketable allowances. The EPA 17 issues one allowance for each ton of SO 2 that a unit is allowed to emit. New units do not receive 18 allowances, but are required to have allowances to cover their S02 emissions. Owners of new 19 units must therefore purchase allowances from owners of other power plants or reduce SO 2 20 emissions at other power plants they own. Allowances can be banked for use in future years.

21 Thus, provided a new coal-fired power plant is able to purchase sufficient allowances to 22 operate, it would not add to net regional SO 2 emissions, although it might do so locally.

23 Nitrogen Oxides 24 A coal-fired alternative at the Salem and HCGS site would most likely employ various available 25 NOx-control technologies, which can be grouped into two main categories: combustion 26 modifications and post-combustion processes. Combustion modifications include low-NOx 27 burners, over fire air, and operational modifications. Post-combustion processes include 28 selective catalytic reduction and selective non-catalytic reduction. An effective combination of 29 the combustion modifications and post-combustion processes allow the reduction of NOx 30 emissions by up to 95 percent (EPA, 1998). PSEG indicated in its ER that the technology would 31 use low NOx burners, overfire air, and selective catalytic reduction to reduce NOx emissions by 32 approximately 95 percent from uncontrolled emissions. As a result, the NOx emissions 33 associated with a coal-fired alternative at the Salem and HCGS site would be approximately 34 3,050 tons (2,773 MT) per year.

35 Section 407 of the CAA establishes technology-based emission limitations for NOx emissions. A 36 new coal-fired power plant would be subject to the new source performance standards for such 37 plants as indicated in 40 CFR 60.44a(d)(1). This regulation, issued on September 16, 1998 February 2010 8-7 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 (63 FR 49453), limits the discharge of any gases that contain nitrogen oxides (NO2 ) to 200 2 nanograms (ng) of NOx per joule (J) of gross energy output (equivalent to 1.6 lb/MWh), based 3 on a 30-day rolling average. Based on the projected emissions, the proposed alternative would 4 easily meet this regulation.

5 Particulates 6 The new coal-fired power plant would use baghouse-based fabric filters to remove particulates 7 from flue gases. PSEG indicated that this technology would remove 99.9 percent of particulate 8 matter. The EPA notes that filters are capable of removing in excess of 99 percent of 9 particulate matter, and that SO 2 scrubbers further reduce particulate matter emissions (EPA, 10 2008a). Based on EPA emission factors, the new supercritical coal-fired plant would emit 85.4 11 tons (77.6 MT) per year of particulate matter having an aerodynamic diameter less than or equal 12 to 10 microns (PM10 ) annually (EPA, 1998), (EIA, 2010b). In addition, coal burning would also 13 result in approximately 22.6 tons (20.5 MT) per year of particulate emissions with an 14 aerodynamic diameter of 2.5 microns or less (PM2.5). Coal-handling equipment would introduce 15 fugitive dust emissions when fuel is being transferred to onsite storage and then reclaimed from 16 storage for use in the plant. During the construction of a coal-fired plant, onsite activities would 17 also generate fugitive dust. Vehicles and motorized equipment would create exhaust emissions 18 during the construction process. These impacts would be intermittent and short-lived, however, 19 and to minimize dust generation construction crews would use applicable dust-control 20 measures.

21 Carbon Monoxide 22 Based on EPA emission factors and assumed plant characteristics, the Staff computed that the 23 total CO emissions would be approximately 3,050 tons (2,773 MT) per year (EPA, 1998).

24 HazardousAir Pollutants 25 Consistent with the D.C. Circuit Court's February 8, 2008 ruling that vacated its Clean Air 26 Mercury Rule (CAMR), the EPA is in the process of developing mercury emissions standards for 27 power plants under the CAA (Section 112) (EPA, 2009a). Before CAMR, the EPA determined 28 that coal-and oil-fired electric utility steam-generating units are significant emitters of hazardous 29 air pollutants (HAPs) (EPA, 2000a). The EPA determined that coal plants emit arsenic, 30 beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, 31 and mercury (EPA, 2000a). The EPA concluded that mercury is the HAP of greatest concern; it 32 further concluded that:

33 (1) a link exists between coal combustion and mercury emissions 34 (2) electric utility steam-generating units are the largest domestic source of mercury 35 emissions, and 36 (3) certain segments of the U.S. population (e.g., the developing fetus and subsistence fish-37 eating populations) are believed to be at potential risk of adverse health effects resulting 38 from mercury exposures caused by the consumption of contaminated fish (EPA, 2000a).

Draft NUREG-1437, Supplement 42 8-8 April 2010

Environmental Impacts of Alternatives 1 On February 6, 2009, the Supreme Court dismissed the EPA's request to review the 2008 2 Circuit Court's decision, and also denied a similar request by the Utility Air Regulatory Group 3 later that month (EPA, 2009a).

4 Carbon Dioxide 5 A coal-fired plant would also have unregulated carbon dioxide (CO 2 ) emissions during 6 operations as well as during mining, processing, and transportation, which the GElS indicates 7 could contribute to global warming. The coal-fired plant would emit approximately 33,611,000 8 tons (30,455,500 MT) per year of CO 2.

9 Summary of Air Quality 10 While the GElS analysis mentions global warming from unregulated CO 2 emissions and acid 11 rain from SOx and NOx emissions as potential impacts, it does not quantify emissions from 12 coal-fired power plants. However, the GElS analysis does imply that air impacts would be 13 substantial (NRC, 1996). The above analysis shows that emissions of air pollutants, including 14 SOx, NOx, CO, and particulates, exceed those produced by the existing nuclear power plant, as 15 well as those of the other alternatives considered in this section. Operational emissions of CO 2 16 are also much greater under the coal-fired alternative, as reviewed by the Staff in Section 6.2 17 and in the previous paragraph. Adverse human health effects such as cancer and emphysema 18 have also been associated with air emissions from coal combustion, and are discussed further 19 in Section 8.1.1.5.

20 The NRC analysis for a coal-fired alternative at the Salem and HCGS site indicates that impacts 21 from the coal-fired alternative would have clearly noticeable effects, but given existing regulatory 22 regimes, permit requirements, and emissions controls, the coal-fired alternative would not 23 destabilize air quality. Therefore, the appropriate characterization of air impacts from coal-fired 24 plant located at Salem and HCGS site would be MODERATE. Existing air quality would result in 25 varying needs for pollution control equipment to meet applicable local requirements, or varying 26 degrees of participation in emissions trading schemes.

27 8.1.1.2 Groundwater Use and Quality 28 If the onsite coal-fired alternative continued to use groundwater for drinking water and service 29 water, the need for groundwater at the plant would be minor. Total usage would likely be less 30 than Salem and HCGS because many fewer workers would be onsite, and because the coal-31 fired unit would have fewer auxiliary systems requiring service water. No effect on groundwater 32 quality would be apparent.

33 Construction of a coal-fired plant could have a localized effect on groundwater due to temporary 34 dewatering and run-off control measures. Because of the temporary nature of construction and 35 the likelihood of reduced groundwater usage during operation, the impact of the coal-fired 36 alternative would be SMALL.

February 2010 8-9 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 8.1.1.3 Surface Water Use and Quality 2 The alternative would require a consumptive use of water from the Delaware River for cooling 3 purposes. Because this consumptive loss would be from an estuary, the NRC concludes the 4 impact of surface water use would be SMALL. A new coal-fired plant would be required to 5 obtain a National Pollutant Discharge and Elimination System (NPDES) permit from the NJDEP 6 for regulation of industrial wastewater, storm water, and other discharges. Assuming the plant 7 operates within the limits of this permit, the impact from any cooling tower blowdown, site runoff, 8 and other effluent discharges on surface water quality would be SMALL.

9 8.1.1.4 Aquatic and Terrestrial Ecology 10 Aquatic Ecology 11 Impacts to aquatic ecology resources from a coal-fired alternative at the Salem and HCGS site 12 could result from effects on waterbodies both adjacent to and distant from the site. Temporary 13 effects on some aquatic organisms likely would result from construction that could occur in the 14 water near the shoreline at the facility. Longer-term, more extensive effects on aquatic 15 organisms likely would occur during the period of operation of the facility, due to the intake of 16 cooling water and discharge of effluents to the estuary. The numbers of fish and other aquatic 17 organisms affected by impingement, entrainment, and thermal impacts would be substantially 18 smaller than those associated with license renewal. Water consumption from and discharge of 19 blowdown to the Delaware Estuary would be lower due to the higher thermal efficiency of the 20 coal-fired facility and its use of only closed-cycle cooling. In addition, the intake and discharge 21 would be monitored and regulated by the NJDEP under the facility's NPDES permit, including 22 requirements under Clean Water Act (CWA) Section 316(a) and 316(b) for thermal discharges 23 and cooling water intakes, respectively. Assuming the use of closed-cycle cooling and 24 adherence to regulatory requirements, the impact on ecological resources of the Delaware 25 Estuary from operation of the intake and discharge facilities would be minimal for this 26 alternative.

27 Aquatic resources distant from the site also have the potential to be affected by a coal-fired 28 alternative. Disposal of waste by landfilling offsite could affect the aquatic ecology of 29 waterbodies downgradient from the disposal site; however, regulatory requirements for such 30 facilities are expected to minimize or prevent such effects. Aquatic ecology in offsite coal 31 mining areas also could be affected, such as by acid mine drainage, although waterbodies in 32 the mining areas are likely to be disturbed already due to ongoing mining operations, and 33 regulatory requirements are expected to limit these impacts. Acid rain resulting from NOx and 34 SOx emissions, as well as the deposition of other pollutants, also could affect the aquatic 35 ecology of waterbodies downwind of the site. The emission controls discussed in Section 8.1.1 36 are expected to reduce but not eliminate such effects.

37 Thus, impacts to aquatic ecology may occur as a result of the effects of facility operations on the 38 adjacent Delaware Estuary as well as more distant effects from waste disposal, coal mining, 39 and air emissions. The coal-fired alternative potentially would have noticeable effects on 40 aquatic resources in multiple areas. Given existing regulatory regimes, permit requirements, 41 and emissions controls, these effects would be limited and unlikely to destabilize aquatic 42 communities. Therefore, the impacts to aquatic resources from a coal-fired plant located at the Draft NUREG-1437, Supplement 42 8-10 April 2010

Environmental Impacts of Alternatives 1 Salem and HCGS site would be SMALL for the Delaware Estuary but could range from SMALL 2 to MODERATE depending on the extent to which other aquatic resources may be affected.

3 TerrestrialEcology 4 Constructing the coal-fired alternative onsite would require approximately 204 ha (505 ac) of 5 land for construction of the power block with an additional 78-56 ha (193-386 ac) for waste 6 disposal, which PSEG indicated could be accommodated on the existing site (see Section 7 8.1.1.6) (PSEG, 2009a; PSEG, 2009b). Terrestrial ecology in offsite coal mining areas also 8 could be affected, although some of the land is likely to already be disturbed as a result of 9 ongoing mining operations. Thus, impacts to terrestrial ecology may occur as a result of 10 construction and operational activities both onsite and offsite.

11 Onsite impacts to terrestrial ecology would be minor because the site is on an artificial island 12 and most of the site has been previously disturbed. If additional roads would need to be 13 constructed through less disturbed areas, impacts would be greater as these construction 14 activities may fragment or destroy local ecological communities. Land disturbances could affect 15 habitats of native wildlife; however, these impacts are not expected to be extensive. Cooling 16 tower operation would produce drift that could result in some deposition of dissolved solids on 17 surrounding vegetation and soils onsite and offsite. Overall, impacts to terrestrial resources at 18 the site would be minimal and limited mostly to the period of construction.

19 Onsite or offsite waste disposal by landfilling also would affect terrestrial ecology at least until 20 the time when the disposal area is reclaimed. Deposition of acid rain resulting from NOx and 21 SOx emissions, as well as the deposition of other pollutants, also could affect terrestrial 22 ecology. Air deposition impacts may be noticeable but, given the emission controls discussed in 23 Section 8.1.1, are unlikely to be destabilizing. Thus, the impacts to terrestrial resources from a 24 coal-fired plant located at the Salem and HCGS site would be SMALL for the area of the site but 25 could range from SMALL to MODERATE depending on the extent to which terrestrial resources 26 at other locations may be affected.

27 8.1.1.5 Human Health 28 Coal-fired power plants introduce worker risks from new plant construction, coal and limestone 29 mining, from coal and limestone transportation, and from disposal of coal combustion and 30 scrubber wastes. In addition, there are public risks from inhalation of stack emissions (as 31 addressed in Section 8.1.1.1) and the secondary effects of eating foods grown in areas subject 32 to deposition from plant stacks.

33 Human health risks of coal-fired power plants are described, in general, in Table 8-2 of the 34 GElS (NRC, 1996). Cancer and emphysema as a result of the inhalation of toxins and 35 particulates are identified as potential health risks to occupational workers and members of the 36 public (NRC, 1996). The human health risks of coal-fired power plants, both to occupational 37 workers and to members of the public, are greater than those of the current Salem and HCGS 38 facilities due to exposures to chemicals such as mercury; SOx; NOx; radioactive elements such 39 as uranium and thorium contained in coal and coal ash; and polycyclic aromatic hydrocarbon 40 (PAH) compounds, including benzo(a)pyrene.

February 2010 8-11 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 During construction activities there would be also risk to workers from typical industrial incidents 2 and accidents. Accidental injuries are not uncommon in the construction industry and accidents 3 resulting in fatalities do occur. However, the occurrence of such events is mitigated by the use 4 of proper industrial hygiene practices, worker safety requirements, and training. Occupational 5 and public health impacts during construction are expected to be controlled by continued 6 application of accepted industrial hygiene and occupational health and safety practices.

7 Regulations restricting emissions-enforced by EPA or State agencies-have acted to 8 significantly reduce potential health effects but have not entirely eliminated them. These 9 agencies also impose site-specific emission limits as needed to protect human health. Even if 10 the coal-fired alternative were located in a nonattainment area, emission controls and trading or 11 offset mechanisms could prevent further regional degradation; however, local effects could be 12 visible. Many of the byproducts of coal combustion responsible for health effects are largely 13 controlled, captured, or converted in modern power plants (as described in Section 8.1.1.1),

14 although some level of health effects may remain.

15 Aside from emission impacts, the coal-fired alternative introduces the risk of coal pile fires and 16 for those plants that use coal combustion liquid and sludge waste impoundments, the release of 17 the waste due to a failure of the impoundment. Although there have been several instances of 18 this occurring in recent years, these types of events are still relatively rare.

19 Based on the cumulative potential impacts of construction activities, emissions, and materials 20 management on human health, the NRC staff considers the overall impact of constructing and 21 operating a new coal-fired facility to be MODERATE.

22 8.1.1.6 Socloeconomics 23 Land Use 24 The GElS generically evaluates the impacts of nuclear power plant operations on land use both 25 on and off each power plant site. The analysis of land use impacts focuses on the amount of 26 land area that would be affected by the construction and operation of a new supercritical coal-27 fired power plant on the Salem and HCGS site.

28 The GElS indicates that an estimated 1,700 acres (700 ha) would be required for constructing a 29 1,000-MW(e) coal plant. Scaling from the GElS estimate, approximately 6,233 acres (2,523 ha) 30 would be required to replace the 3,660 MW(e) provided by Salem and HCGS. PSEG indicated 31 that approximately 505 acres (204 ha) of land would be needed to support the power block for a 32 coal-fired alternative capable of replacing the Salem and HCGS facilities (PSEG, 2009a),

33 (PSEG, 2009b). The Staff notes than many coal-fired power plants with larger capacities have 34 been located on smaller sites, and believes that the PSEG estimate is reasonable. PSEG 35 indicated that an additional 193 acres (78 ha) of land area may be needed for waste disposal 36 over the 20-year license renewal term, or 386 acres (156 ha) over the 40-year operational life of 37 a coal-fired alternative, which PSEG indicated could be accommodated onsite (PSEG, 2009a),

38 (PSEG, 2009b).

Draft NUREG-1437, Supplement 42 8-12 April 2010

Environmental Impacts of Alternatives 1 Offsite land use impacts would occur from coal mining, in addition to land use impacts from the 2 construction and operation of the new power plant. In the GELS, the Staff estimated that 3 supplying coal to a 1,000-MW(e) plant would disturb approximately 22,000 acres (8,900 ha) of 4 land for mining the coal and disposing of the wastes during the 40-year operational life. Scaling 5 from GElS estimates, approximately 80,500 acres (32,570 ha) of land would be required for a 6 coal-fired alternative to replace Salem and HCGS. However, most of the land in existing coal-7 mining areas has already experienced some level of disturbance. The elimination of the need 8 for uranium mining to supply fuel for the Salem and HCGS facilities would partially offset this 9 offsite land use impact. In the GELS, the Staff estimated that approximately 3,660 acres 10 (1,480 ha) of land would be affected by the mining and processing of uranium over the 11 operating life of a plant with the capacity of Salem and HCGS.

12 Based on this information, land use impacts would be MODERATE.

13 Socioeconomics 14 Socioeconomic impacts are defined in terms of changes to the demographic and economic 15 characteristics and social conditions of a region. For example, the number of jobs created by 16 the construction and operation of a new coal-fired power plant could affect regional 17 employment, income, and expenditures. Two types of job creation result from this alternative:

18 (1) construction-related jobs, and (2) operation-related jobs in support of power plant operations, 19 which have the greater potential for permanent, long-term socioeconomic impacts. The Staff 20 estimated workforce requirements during power plant construction and operation for the coal-21 fired alternative in order to measure their possible effect on current socioeconomic conditions.

22 The GElS projects a peak construction workforce of 1,200 to 2,500 for a 1,000 MW(e) plant 23 (when extrapolated, a lower-end workforce of approximately 4,400 for a 3,660-MW(e) plant).

24 PSEG projected a peak workforce of about 5,660 required to construct the coal-fired alternative 25 at the Salem and HCGS site (PSEG 2009a), (PSEG, 2009b). During the construction period, 26 the communities surrounding the plant site would experience increased demand for rental 27 housing and public services. The relative economic contributions of these relocated workers to 28 local business and tax revenues would vary over time.

29 After construction, local communities could be temporarily affected by the loss of construction 30 jobs and associated loss in demand for business services. In addition, the rental housing 31 market could experience increased vacancies and decreased prices. As noted in the GELS, the 32 socioeconomic impacts at a rural construction site could be larger than at an urban site, 33 because the workforce would need to relocate closer to the construction site. Although the ER 34 indicates that Salem and HCGS is a rural site (PSEG, 2009a), (PSEG, 2009b), it is located near 35 the Philadelphia and Wilmington metropolitan areas. Therefore, these effects may be 36 somewhat lessened because workers are likely to commute to the site from these areas instead 37 of relocating closer to the construction site. Based on the site's proximity to these metropolitan 38 areas, construction impacts would be SMALL.

February 2010 8-13 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 PSEG estimated an operational workforce of approximately 500 workers for the 3,660 MWe 2 alternative (PSEG, 2009a), (PSEG 2009b). The area would experience a loss of approximately 3 1,100 permanent, relatively high-paying jobs (based on a current Salem and HCGS workforce of 4 1,614), with a corresponding reduction in purchasing activity and tax contributions to the 5 regional economy. The impact of the job loss is, however, expected to be SMALL given the 6 relatively large area from which Salem and HCGS personnel are currently drawn and the 7 extensive timeframe over which construction of a new plant and decommissioning of the 8 existing facility would occur. The coal-fired alternative would provide a new tax base in Lower 9 Alloways Creek Township and Salem County to offset the loss of taxes that would occur 10 assuming Salem and HCGS are decommissioned. While it is difficult to estimate the impact of 11 this scenario on Lower Alloways Creek Township and Salem County resources, it would not be 12 unreasonable to assume that, on balance, the township's and county's tax base would not be 13 significantly altered and that resulting impacts could be best characterized as SMALL to 14 MODERATE.

15 Transportation 16 During construction, up to 5,660 workers would be commuting to the site, as well as the current 17 1,614 workers already at Salem and HCGS. In addition to commuting workers, trucks would 18 transport construction materials and equipment to the worksite increasing the amount of traffic 19 on local roads. The increase in vehicular traffic on roads would peak during shift changes 20 resulting in temporary level of service impacts and delays at intersections. Barges would likely 21 be used to deliver large components to the Salem and HCGS site. Transportation impacts are 22 likely to be MODERATE during construction.

23 Transportation impacts would be greatly reduced after construction, but would not disappear 24 during plant operations. The maximum number of plant operating personnel commuting to the 25 Salem and HCGS site would be approximately 500 workers. Deliveries of coal and limestone 26 would be by barge. The coal-fired alternative would likely create SMALL transportation impacts 27 during plant operations.

28 Aesthetics 29 The aesthetics impact analysis focuses on the degree of contrast between the coal-fired 30 alternative and the surrounding landscape and the visibility of the coal plant.

31 The coal-fired alternative would have boiler houses up to 200 feet (61 m) tall with exhaust 32 stacks up to 500 feet (152 m) and would be visible offsite in daylight hours. The coal-fired plant 33 would be similar in height to the current Salem and HCGS reactor containment buildings (190 to 34 200 feet, or 58 to 61 m, tall) and the HCGS cooling tower, which stands at 514 feet (157 m).

35 The coal-fired alternative would require the use of multiple cooling towers instead of the current 36 one tower, thus increasing the size of the condensate plume. Lighting on plant structures would 37 be visible offsite at night. Overall, aesthetic impacts associated with the coal-fired alternative 38 would likely be SMALL to MODERATE.

39 Coal-fired generation would introduce mechanical sources of noise that would be audible offsite, 40 although given the low population near the plant's periphery, nuisance impacts are not Draft NUREG-1437, Supplement 42 8-14 April 2010

Environmental Impacts of Alternatives 1 expected. Sources contributing to total noise produced by plant operation would be classified 2 as continuous or intermittent. Continuous sources include the mechanical equipment 3 associated with normal plant operations. Intermittent sources include the equipment related to 4 coal handling, solid-waste disposal, use of outside loudspeakers, and the commuting of plant 5 employees. The nuisance impacts of plant noise emissions are expected to be SMALL due to 6 the large area encompassed by the Salem and HCGS site and the fact that sensitive land uses 7 do not occur in the immediate plant vicinity.

8 Historic and ArchaeologicalResources 9 Before construction at the Salem and HCGS site studies would likely be needed to identify 10 evaluate, and address mitigation of potential impacts of new plant construction on cultural 11 resources. Studies would be needed for all areas of potential disturbance at the proposed plant 12 site and along associated corridors where construction would occur (e.g., roads, transmission 13 corridors, rail lines, or other ROWs). Areas with the greatest sensitivity should be avoided.

14 As noted in Section 4.9.6, there is little potential for historic and archaeological resources to be 15 present on most of the Salem and HCGS site, therefore, the impact for a coal-fired alternative at 16 the Salem and HCGS site would likely be SMALL.

17 EnvironmentalJustice 18 The environmental justice impact analysis evaluates the potential for disproportionately high and 19 adverse human health and environmental effects on minority and low-income populations that 20 could result from the construction and operation of a new coal-fired power plant. Adverse health 21 effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human 22 health. Disproportionately high and adverse human health effects occur when the risk or rate of 23 exposure to an environmental hazard for a minority or low-income population is significant and 24 exceeds the risk or exposure rate for the general population or for another appropriate 25 comparison group. For socioeconomic data regarding the analysis of environmental justice 26 issues, the reader is referred to Section 4.9.7, Environmental Justice.

27 No environmental or human health impacts were identified that would result in 28 disproportionately high and adverse environmental impacts on minority and low-income 29 populations if a replacement coal-fired plant were built at the Salem and HCGS site. Some 30 impacts on rental and other temporary housing availability and lease prices during construction 31 might occur, and this could disproportionately affect low-income populations. Although the site 32 is located in a rural area, it is near the Philadelphia and Wilmington metropolitan areas.

33 Therefore, the demand for rental housing would be mitigated because workers would be likely to 34 commute to the site from these areas instead of relocating closer to the construction site. Thus, 35 the impact on minority and low-income populations would be SMALL.

February 2010 8-15 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 8.1.1.7 Waste Management 2 Coal combustion generates several waste streams including ash (a dry solid) and sludge (a 3 semi-solid byproduct of emission control system operation). The Staff estimates that an 4 approximately 3,656 MWe power plant comprised of six units of approximately 630 MWe each 5 would generate annually a total of approximately 753,960 tons of ash (EIA, 201 Ob), and 245,300 6 tons of scrubber sludge (PSEG, 2009a) (PSEG, 2009b) About 340,00 tons or 45 percent of the 7 ash waste and 194,000 tons or 79 percent of scrubber sludge would be recycled, based on 8 industry-average.recycling rates (ACAA, 2007). Therefore, approximately 413,900 tons of ash 9 and 51,300 tons of scrubber sludge would remain annually for disposal. Disposal of the 10 remaining waste could noticeably affect land use and groundwater quality, but would require 11 proper citing in accordance with the describe local ordinance and the implementation of the 12 required monitoring and management practices in order to minimize these impacts (state 13 reference). After closure of the waste site and revegetation, the land could be available for other 14 uses.

15 In May 2000, the EPA issued a "Notice of Regulatory Determination on Wastes from the 16 Combustion of Fossil Fuels" (EPA, 2000b) stating that it would issue regulations for disposal of 17 coal combustion waste under Subtitle D of the Resource Conservation and Recovery Act. The 18 EPA has not yet issued these regulations.

19 The impacts from waste generated during operation of this coal-fired alternative would be 20 clearly visible, but would not destabilize any important resource.

21 The amount of the construction waste would be small compared to the amount of waste 22 generated during operational stage and much of it could be recycled. Overall, the impacts from 23 waste generated during construction stage would be minor.

24 Therefore, the Staff concludes that the overall impacts from construction and operation of this 25 alternative would be MODERATE.

26 27 8.1.2 Natural Gas Combined-Cycle Generation 28 In this section, the Staff evaluates the environmental impacts of a natural gas-fired combined-29 cycle generation plant at the Salem and HCGS site.

30 Natural gas fueled 21.4 percent of electric generation in the US in 2008 (the most recent year 31 for which data are available); this accounted for the second greatest share of electrical power 32 after coal (EIA, 201 Oa). Like coal-fired power plants, natural gas-fired plants may be affected by 33 perceived or actual actions to limit GHG emissions; they produce markedly lower GHG 34 emissions per unit of electrical output than coal-fired plants. Natural gas-fired power plants are 35 feasible and provide commercially available options for providing electrical generating capacity 36 beyond Salem and HCGS's current license expiration dates.

Draft NUREG-1437, Supplement 42 8-16 April 2010

Environmental Impacts of Alternatives 1 Combined-cycle power plants differ significantly from coal-fired and existing nuclear power 2 plants. They derive the majority of their electrical output from a gas-turbine cycle, and then 3 generate additional power-without burning any additional fuel-through a second, steam-4 turbine cycle. The first, gas turbine stage (similar to a large jet engine) burns natural gas that 5 turns a driveshaft that powers an electric generator. The exhaust gas from the gas turbine is still 6 hot enough, however, to boil water into steam. Ducts carry the hot exhaust to a heat recovery 7 steam generator, which produces steam to drive a steam turbine and produce additional 8 electrical power. The combined-cycle approach is significantly more efficient than any one cycle 9 on its own; thermal efficiency can exceed 60 percent. Since the natural gas-fired alternative 10 derives much of its power from a gas turbine cycle, and because it wastes less heat than either 11 the coal-fired alternative or the existing Salem and HCGS, it requires significantly less cooling.

12 In order to replace the 3,656 MWe that Salem and HCGS currently supply, the Staff selected a 13 gas-fired alternative that uses nine GE STAG 107H combined-cycle generating units. While any 14 number of commercially available combined-cycle units could be installed in a variety of 15 combinations to replace the power currently produced by Salem and HCGS, the STAG 107H is 16 a highly efficient model that would help minimize environmental impacts (GE, 2001). Other 17 manufacturers, like Siemens, offer similarly high efficiency models. This gas-fired alternative 18 produces a net 400 MWe per unit. Nine units would produce a total of 3600 MWe, or nearly the 19 same output as the existing Salem and HCGS plants.

20 The combined-cycle alternative operates at a heat rate of 5,687 btu/kWh, or about 60 percent 21 thermal efficiency (GE, 2001). Allowing for onsite power usage, including cooling towers and 22 site lighting, the gross output of these units would be roughly 3,744 MWe. As noted above, this 23 gas-fired alternative would require much less cooling water than Salem and HCGS because it 24 operates at a higher thermal efficiency and because it requires much less water for steam cycle 25 condenser cooling. This alternative would likely make use of the site's existing natural draft 26 cooling tower, but may require the construction of an additional tower.

27 In addition to the already existing natural draft cooling tower, other visible structures onsite 28 would include the turbine buildings, two exhaust stacks, an electrical switchyard, and, possibly, 29 equipment associated with a natural gas pipeline, like a compressor station. The GElS 30 estimates indicate that this 3,600 MWe plant would require 409 acres (1,023 ha), which would 31 be feasible on the 1,480 acre PSEG site.

32 This 3600 MWe power plant would consume 161.65 billion cubic feet (ft3) (4,587 cubic meters 33 [M3 ]) of natural gas annually assuming an average heat content of 1,029 btu/ft3 (EIA, 2009b).

34 Natural gas would be extracted from the ground through wells, then treated to remove impurities 35 (like hydrogen sulfide), and blended to meet pipeline gas standards, before being piped through 36 the interstate pipeline system to the power plant site. This gas-fired alternative would produce 37 relatively little waste, primarily in the form of spent catalysts used for emissions controls.

38 Environmental impacts from the gas-fired alternative would be greatest during construction. The 39 closest natural gas pipeline that could serve as a source of natural gas for the plant is located in 40 Logan Township, approximately 25 miles from the Salem and HCGS facilities (PSEG, 2010).

41 Site crews would clear vegetation from the site, prepare the site surface, and begin excavation 42 before other crews begin actual construction on the plant and any associated infrastructure, February 2010 8-17 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 including the 25-mile pipeline spur to serve the plant and electricity transmission infrastructure 2 connecting the plant to existing transmission lines. Constructing the gas-fired alternative on the 3 Salem and HCGS site would allow the gas-fired alternative to make use of the existing electric 4 transmission system.

5 Table 8-2. Summary of Environmental Impacts of the Natural Gas Combined-Cycle 6 Generation Alternative Compared to Continued Operation of Salem and HCGS Natural Gas Combined-Cycle Continued Salem and HCGS Generation Operation Air Quality SMALL to MODERATE SMALL Groundwater SMALL SMALL to MODERATE Surface Water SMALL SMALL Aquatic and Terrestrial Resources SMALL SMALL Human Health SMALL SMALL Socioeconomics SMALL to MODERATE SMALL Waste Management SMALL Not Applicable 7 8.1.2.1 Air Quality 8 Salem and HCGS are located in Salem County, New Jersey. Salem County is designated as in 9 attainment/unclassified with respect to the NAAQSs for PM2.5, S02, NOx, CO, and lead. The 10 county, along with all of southern New Jersey, is a nonattainment area with respect to the 1-11 hour primary ozone standard and the 8-hour ozone standard. For the 1-hour ozone standard, 12 Salem County is located within the multi-state Philadelphia-Wilmington-Trenton non-attainment 13 area, and for the 8-hour ozone standard, it is located in the Philadelphia-Wilmington-Atlantic 14 City (PA-NJ-DE-MD) non attainment area.

15 A new gas-fired generating plant would qualify as a new major-emitting industrial facility and 16 would be subject to Prevention of Significant Deterioration of Air Quality Review under 17 requirements of CAA, adopted by the NJDEP Bureau of Air Quality Permitting. The natural gas-18 fired plant would need to comply with the standards of performance for stationary gas turbines 19 set forth in 40 CFR Part 60 Subpart GG. Regulations issued by NJDEP adopt the EPA's CAA 20 rules (with modifications) to limit power plant emissions of SOx, NOx, particulate matter, and 21 hazardous air pollutants. The new gas-fired generating plant would qualify as a major facility as 22 defined in Section 7:27-22.1 of the New Jersey Administrative Code, and would be required to 23 obtain a major source permit from NJDEP.

24 Section 169A of the CAA (42 United States Code (U.S.C.) 7401) establishes a national goal of 25 preventing future and remedying existing impairment of visibility in mandatory Class I Federal 26 areas when impairment results from man-made air pollution. The EPA issued a new regional 27 haze rule in 1999 (64 FederalRegister (FR) 35714). The rule specifies that for each mandatory 28 Class I Federal area located within a state, the State must establish goals that provide for 29 reasonable progress towards achieving natural visibility conditions. The reasonable progress 30 goals must provide an improvement in visibility for the most-impaired days over the period of Draft NUREG-1437, Supplement 42 8-18 April 2010

Environmental Impacts of Alternatives 1 implementation plan and ensure no degradation in visibility for the least-impaired days over the 2 same period (40 CFR 51.308(d)(1)). Five RPO collaborate on the visibility impairment issue, 3 developing the technical-basis for these plans. The State of New Jersey is among eleven 4 member states (Maryland, Delaware, New Jersey, Pennsylvania, New York, Connecticut, 5 Rhode Island, Massachusetts, Vermont, New Hampshire, and Maine) of the MANE-VU, along 6 with tribes, Federal agencies, and other interested parties that identifies regional haze and 7 visibility issues and develops strategies to address them (NJDEP, 2009a). The visibility 8 protection regulatory requirements, contained in 40 CFR Part 51, Subpart P, include the review 9 of the new sources that would be constructed in the attainment or unclassified areas and may 10 affect visibility in any Federal Class I area (40 CFR Part 51, Subpart P, §51.307). If a gas-fired 11 plant were located close to a mandatory Class I area, additional air pollution control 12 requirements would be imposed. There is one mandatory Class I Federal areas in the State of 13 New Jersey, which is the Brigantine National Wildlife Refuge (40 CFR 81.420), located 14 approximately 58 miles (93 km) southeast of the Salem and HCGS facilities. There are no 15 Class I Federal areas in Delaware, and no other areas located within 100 miles (161 km) of the 16 facilities (40 CFR 81.400). New Jersey is also subject to the CAIR, which has outlined 17 emissions reduction goals for both SO 2 and NOx for the year 2015. CAIR will aid New Jersey 18 sources in reducing SO 2 emissions by 25,000 tons (or 49 percent), and NOx emissions by 19 11,000 tons (or 48 percent) (EPA 2010).

20 The Staff projects the following emissions for a gas-fired alternative based on data published by 21 the EIA, the EPA, and on performance characteristics for this alternative and its emissions 22 controls:

23 0 Sulfur oxides (SOx) - 53 tons (48.2 MT) per year 24 0 Nitrogen oxides (NOx) - 932 tons (847 MT) per year 25 0 Carbon monoxide (CO) - 193 tons (175 MT) per year 26 0 Total suspended particles (TSP) - 162 tons (147 MT) per year 27 0 Particulate matter (PM) PM 10 - 162 tons (147 MT) per year 28 0 Carbon dioxide (C0 2) - 9,400,000 tons (8,500,000 MT) per year 29 Sulfur and Nitrogen Oxides 30 As stated above, the new natural gas-fired alternative would produce 53 tons (48.2 MT) per year 31 of SOx (assumed to be all SO 2) (EPA, 2000c), (INGAA, 2000) and 932 tons (847 MT) per year 32 of NOx based on the use of the dry low NOx combustion technology and use of the selective 33 catalytic reduction (SCR) in order to significantly reduce NOx emissions (INGAA, 2000). The 34 new plant would be subjected to the continuous monitoring requirements of SO 2 , NO, and CO 2 35 specified in 40 CFR Part 75. A new natural gas-fired plant would have to comply with Title IV of 36 the CAA reduction requirements for SO 2 and NOx, which are the main precursors of acid rain 37 and the major cause of reduced visibility. Title IV establishes maximum SO 2 and NOx emission February 2010 8-19 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 rate from the existing plants and a system of the SO 2 emission allowances that can be used, 2 sold or saved for future use by new plants.

3 Particulates 4 Based on EPA emission factors (EPA, 2000c), the new natural gas-fired alternative would 5 produce 162 tons (147 MT) per year of TSP, all of which would be emitted as PM1 o.

6 Carbon Monoxide 7 Based on EPA emission factors (EPA, 2000c), Staff estimates that the total CO emissions 8 would be approximately 193 tons (175 MT) per year.

9 HazardousAir Pollutants 10 The EPA issued in December 2000 regulatory findings (EPA, 2000a) on emissions of hazardous 11 air pollutants from electric utility steam-generating units, which identified that natural gas-fired 12 plants emit hazardous air pollutants such as arsenic, formaldehyde and nickel and stated that 13 ... the impacts due to HAP emissions from natural gas-fired electric utility steam 14 generating units were negligible based on the results of the study. The 15 Administrator finds that regulation of HAP emissions from natural gas-fired 16 electric utility steam generating units is not appropriate or necessary.

17 Carbon Dioxide 18 The new plant would be subjected to the continuous monitoring requirements of SO 2 , NO. and 19 CO 2 specified in 40 CFR Part 75. The Staff computed that the natural gas-fired plant would emit 20 approximately 9.4 million tons (8.5 million MT) per year of unregulated CO 2 emissions. In 21 response to the Consolidated Appropriations Act of 2008, the EPA has proposed a rule that 22 requires mandatory reporting of GHG emissions from large sources that would allow collection 23 of accurate and comprehensive emissions data to inform future policy decisions (EPA, 2009b).

24 The EPA proposes that suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles 25 and engines, and facilities that emit 25,000 MT or more per year of GHG emissions submit 26 annual reports to the EPA. The gases covered by the proposed rule are carbon dioxide (C0 2),

27 methane (CH 4 ), nitrous oxide (N2 0), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur 28 hexafluoride (SF 6 ), and other fluorinated gases including nitrogen trifluoride (NF3) and 29 hydrofluorinated ethers (HFE).

30 Construction Impacts 31 Activities associated with the construction of the new natural gas-fired plant at the Salem and 32 HCGS site would cause some additional air effects as a result of equipment emissions and 33 fugitive dust from operation of the earth-moving and material handling equipment. Workers' 34 vehicles and motorized construction equipment would generate temporary exhaust emissions.

35 The construction crews would employ dust-control practices in order to control and reduce 36 fugitive dust, which would be temporary in nature. The Staff concludes that the impact of vehicle Draft NUREG-1437, Supplement 42 8-20 April 2010

Environmental Impacts of Alternatives 1 exhaust emissions and fugitive dust from operation of earth-moving and material handling 2 equipment would be SMALL.

3 The overall air-quality impacts of a new natural gas-fired plant located at the Salem and HCGS 4 site would be SMALL to MODERATE.

5 8.1.2.2 Groundwater Use and Quality 6 The use of groundwater for a natural gas-fired combined-cycle plant would likely be limited to 7 supply wells for drinking water and possibly filtered service water for system cleaning purposes.

8 Total usage would likely be much less than Salem and HCGS because many fewer workers 9 would be onsite, and because the gas-fired alternative would have fewer auxiliary systems 10 requiring service water.

11 No effects on groundwater quality would be apparent except during the construction phase due 12 to temporary dewatering and run-off control measures. Because of the temporary nature of 13 construction and the likelihood of reduced groundwater usage during operation, the impact of 14 the natural gas-fired alternative would be SMALL.

15 8.1.2.3 Surface Water Use and Quality 16 The alternative would require a consumptive use of water from the Delaware River for cooling 17 purposes. Because this consumptive loss would be from an estuary, the NRC concludes the 18 impact of surface water use would be SMALL. A new natural gas-fired plant would be required 19 to obtain a National Pollutant Discharge and Elimination System (NPDES) permit from the 20 NJDEP for regulation of industrial wastewater, storm water, and other discharges. Assuming the 21 plant operates within the limits of this permit, the impact from any cooling tower blowdown, site 22 runoff, and other effluent discharges on surface water quality would be SMALL.

23 8.1.2.4 Aquatic and Terrestrial Ecology 24 Aquatic Ecology 25 Compared to the existing Salem and HCGS facilities, impacts on aquatic ecology from the 26 onsite, gas-fired alternative would be substantially smaller because the combined-cycle plant 27 would inject significantly less heat to the environment and require less water. The numbers of 28 fish and other aquatic organisms affected by impingement, entrainment, and thermal impacts 29 would be smaller than those associated with license renewal because water consumption and 30 blowdown discharged to the Delaware Estuary would be substantially lower. Some temporary 31 impacts on aquatic organisms may occur due to construction. Longer-term effects could result 32 from effluents discharged to the river. However, NRC assumes that the appropriate agencies 33 would monitor and regulate such activities. The number of organisms affected by impingement, 34 entrainment, and thermal effects of this alternative would be substantially less than for license 35 renewal, so NRC expects that the levels of impact for the natural gas alternative would be 36 SMALL.

37 February 2010 8-21 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 TerrestrialEcology 2 Constructing the natural gas alternative would require approximately 52 ha (128 ac) of land 3 according to PSEG estimates (PSEG, 2009a; PSEG, 2009b). Scaling from the GElS estimate, 4 approximately 162 ha (396 ac) would be required to replace the 3,600 MW(e) provided by 5 Salem and HCGS. These land disturbances are the principal means by which this alternative 6 would affect terrestrial ecology.

7 Onsite impacts to terrestrial ecology would be minor because the site is on an artificial island 8 and most of the site has been previously disturbed. If additional roads would need to be 9 constructed through less disturbed areas, impacts would be greater as these construction 10 activities may fragment or destroy local ecological communities. Land disturbances could affect 11 habitats of native wildlife; however, these impacts are not expected to be extensive. Gas 12 extraction and collection would also affect terrestrial ecology in offsite gas fields, although much 13 of this land is likely already disturbed by gas extraction, and the incremental effects of this 14 alternative on gas field terrestrial ecology are difficult to gauge.

15 Construction of the nine natural-gas-fired units could entail some loss of native wildlife habitats; 16 however, these impacts are not expected to be extensive. If new roads were required to be 17 constructed through less disturbed areas, this activity could fragment or destroy local ecological 18 communities, thereby increasing impacts. Operation of the cooling tower would cause some 19 deposition of dissolved solids on surrounding vegetation (including wetlands) and soils from 20 cooling tower drift. Overall, impacts to terrestrial resources at the site would be minimal and 21 limited mostly to the construction period. Construction of the 25-mi gas pipeline (to the nearest 22 assumed tie-in) could lead to further disturbance to undeveloped areas. However, PSEG 23 indicated that the pipeline would be routed along existing, previously disturbed rights-of-way and 24 would not be expected to impact terrestrial species. Because of the relatively small potential for 25 undisturbed land to be affected, impacts from construction of the pipeline are expected to be 26 minimal.

27 Based on this information, impacts to terrestrial resources from the onsite, gas-fired alternative 28 would be SMALL.

29 8.1.2.5 Human Health 30 Like the coal-fired alternative discussed above, a gas-fired plant would emit criteria air 31 pollutants, but in smaller quantities (except NOx, which requires additional controls to reduce 32 emissions). Human health effects of gas-fired generation are generally low, although in Table 8-33 2 of the GElS (NRC, 1996), the Staff identified cancer and emphysema as potential health risks 34 from gas-fired plants. NOx emissions contribute to ozone formation, which in turn contributes to 35 human health risks. Emission controls on this gas-fired alternative maintain NOx emissions well 36 below air quality standards established for the purposes of protecting human health, and 37 emissions trading or offset requirements mean that overall NOx in the region would not 38 increase. Health risks to workers may also result from handling spent catalysts that may contain 39 heavy metals.

40 During construction activities there would be a risk to workers from typical industrial incidents 41 and accidents. Accidental injuries are not uncommon in the construction industry, and Draft NUREG-1437, Supplement 42 8-22 April 2010

Environmental Impacts of Alternatives 1 accidents resulting in fatalities do occur. However, the occurrence of such events is mitigated 2 by the use of proper industrial hygiene practices, worker safety requirements, and training.

3 Occupational and public health impacts during construction are expected to be controlled by 4 continued application of accepted industrial hygiene and occupational health and safety 5 practices. Fewer workers would be on site for a shorter period of time to construct a gas-fired 6 plant that other new power generation alternatives, and so exposure to occupational risks tends 7 to be lower than other alternatives.

8 Overall, human health risks to occupational workers and to members of the public from gas-fired 9 power plant emissions sited at the Salem and HCGS site would be less than the risks described 10 for coal-fired alternative and therefore, would likely be SMALL.

11 8.1.2.6 Socioeconomics 12 Land Use 13 As discussed in Section 8.1.1.6, the GElS generically evaluates the impacts of nuclear power 14 plant operations on land use both on and off each power plant site. The analysis of land use 15 impacts focuses on the amount of land area that would be affected by the construction and 16 operation of a nine-unit natural gas-fired combined-cycle power plant at the Salem and HCGS 17 site.

18 Based on GElS estimates, PSEG indicated that approximately 128 acres (52 ha) of land would 19 be needed to support a natural gas-fired alternative to replace Salem and HCGS (PSEG 20 2009a), (PSEG 2009b). Scaling from the GElS estimate, approximately 396 acres (162 ha) 21 would be required to replace the 3600 MW(e) provided by Salem and HCGS. This amount of 22 onsite land use would include other plant structures and associated infrastructure. Onsite land 23 use impacts from construction would be SMALL.

24 In addition to onsite land requirements, land would be required offsite for natural gas wells and 25 collection stations. Scaling from GElS estimates, approximately 12,960 acres (5,400 ha) would 26 be required for wells, collection stations, and a 25-mile pipeline spur to bring the gas to the 27 plant. Most of this land requirement would occur on land where gas extraction already occurs.

28 In addition, some natural gas could come from outside of the United States and be delivered as 29 liquefied gas.

30 The elimination of uranium fuel for the Salem and HCGS facilities could partially offset offsite 31 land requirements. Scaling from GElS estimates, the Staff estimated that approximately 3,660 32 acres (1,480 ha) would not be needed for mining and processing uranium during the 40-year 33 operating life of the plant. Overall land use impacts from a gas-fired power plant would be 34 SMALL to MODERATE.

35 Socioeconomics 36 Socioeconomic impacts are defined in terms of changes to the demographic and economic 37 characteristics and social conditions of a region. For example, the number of jobs created by 38 the construction and operation of a new natural gas-fired power plant could affect regional February 2010 8-23 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 employment, income, and expenditures. Two types of job creation would result: (1) 2 construction-related jobs, which are transient, short in duration, and less likely to have a long-3 term socioeconomic impact; and (2) operation-related jobs in support of power plant operations, 4 which have the greater potential for permanent, long-term socioeconomic impacts. Staff 5 evaluated workforce requirements for construction and operation of the natural gas-fired power 6 plant alternative in order to measure their possible effect on current socioeconomic conditions.

7 While the GElS estimates a peak construction workforce of 4,320, PSEG projected a maximum 8 construction workforce of 2,920 (PSEG 2009a), (PSEG, 2009b). During construction, the 9 communities surrounding the power plant site would experience increased demand for rental 10 housing and public services. The relative economic effect of construction workers on local 11 economy and tax base would vary over time.

12 After construction, local communities could be temporarily affected by the loss of construction 13 jobs and associated loss in demand for business services, and the rental housing market could 14 experience increased vacancies and decreased prices. As noted in the GELS, the 15 socioeconomic impacts at a rural construction site could be larger than at an urban site, 16 because the workforce would have to move to be closer to the construction site. Although the 17 ER identifies the Salem and HCGS site as a primarily rural site (PSEG, 2009a), (PSEG, 2009b),

18 it is located near the Philadelphia and Wilmington metropolitan areas. Therefore, these effects 19 would likely be lessened because workers are likely to commute to the site from these areas 20 instead of relocating closer to the construction site. Because of the site's proximity to these 21 highly populated areas, the impact of construction on socioeconomic conditions would be 22 SMALL.

23 PSEG estimated a power plant operations workforce of approximately 132 (PSEG, 2009a),

24 (PSEG, 2009b). Scaling from GElS estimates of an operational workforce of 150 employees for 25 a 1,000-MW(e) gas-fired plant, 540 workers would be required to replace the 3600 MW(e) 26 provided by Salem and HCGS. The PSEG estimate appears reasonable and is consistent with 27 trends toward lowering labor costs by reducing the size of power plant operations workforces.

28 The area would experience a loss of approximately 1,070 to 1,480 permanent, relatively high-29 paying jobs (based on a current Salem and HCGS workforce of 1,614), with a corresponding 30 reduction in purchasing activity and tax contributions to the regional economy. The impact of 31 the job loss is, however, expected to be SMALL given the relatively large area from which 32 Salem and HCGS personnel are currently drawn and the extensive timeframe over which 33 construction of a new plant and decommissioning of the existing facility would occur. The gas-34 fired alternative would provide a new tax base in Lower Alloways Creek Township and Salem 35 County to offset the loss of taxes that would occur assuming Salem and HCGS are 36 decommissioned. While it is difficult to estimate the impact of this scenario on Lower Alloways 37 Creek Township and Salem County resources, it would not be unreasonable to assume that, on 38 balance, the township's and county's tax base would not be significantly altered and that 39 resulting impacts could be best characterized as SMALL to MODERATE.

40 Transportation 41 Transportation impacts associated with construction and operation of a nine-unit gas-fired 42 power plant would consist of commuting workers and truck deliveries of construction materials Draft NUREG-1437, Supplement 42 8-24 April 2010

Environmental Impacts of Alternatives 1 to the Salem and HCGS site. During construction, a peak workforce of between 2,900 and 2 4,300 workers would be commuting to the site, as well as the current 1,614 workers already at 3 Salem and HCGS. In addition to commuting workers, trucks would transport construction 4 materials and equipment to the worksite increasing the amount of traffic on local roads. The 5 increase in vehicular traffic would peak during shift changes resulting in temporary level of 6 service impacts and delays at intersections. Some large plant components would likely be 7 delivered by barge. Pipeline construction and modification to existing natural gas pipeline 8 systems could also have an impact on local traffic. Transportation impacts are likely to be 9 MODERATE during construction.

10 During plant operations, transportation impacts would be greatly reduced. According to PSEG, 11 approximately 132 workers would commute to the Salem and HCGS site to operate the gas-12 fired power plant. Fuel for the plant would be transported by pipeline. The transportation 13 infrastructure would experience little to no increased use from plant operations. The gas-fired 14 alternative would have a SMALL impact on transportation conditions in the region around the 15 Salem and HCGS site during plant operations.

16 Aesthetics 17 The aesthetics impact analysis focuses on the degree of contrast between the natural gas-fired 18 alternative and the surrounding landscape and the visibility of the gas-fired plant.

19 The nine gas-fired units would be approximately 100 foot (30 m) tall, with an exhaust stack up to 20 200 feet (60 m) and may be visible offsite in daylight hours. However, the gas-fired plant would 21 be shorter than the existing HCGS cooling tower, which stands at 514 feet (157 m). This 22 alternative would likely make use of the site's existing natural draft cooling tower. The 23 mechanical draft tower would generate a condensate plume, which would be no more 24 noticeable than the existing HCGS plume. Noise and light from plant operations, as well as 25 lighting on plant structures, would be detectable offsite. Pipelines delivering natural gas fuel 26 could be audible offsite near gas compressors.

27 In general, aesthetic impacts associated with the gas-fired alternative would likely be SMALL to 28 MODERATE and noise impacts would likely be SMALL.

29 Historic and ArchaeologicalResources 30 Before construction at the Salem and HCGS site studies would likely be needed to identify 31 evaluate, and address mitigation of potential impacts of new plant construction on cultural 32 resources. Studies would be needed for all areas of potential disturbance at the proposed plant 33 site and along associated corridors where construction would occur (e.g., roads, transmission 34 corridors, rail lines, or other ROWs). Areas with the greatest sensitivity should be avoided.

35 As noted in Section 4.9.6, there is little potential for historic and archaeological resources to be 36 present on most of the Salem and HCGS site, therefore, the impact for a natural gas-fired 37 alternative at the Salem and HCGS site would likely be SMALL.

38 EnvironmentalJustice February 2010 8-25 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 The environmental justice impact analysis evaluates the potential for disproportionately high and 2 adverse human health and environmental effects on minority and low-income populations that 3 could result from the construction and operation of a new natural gas-fired power plant.

4 Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 5 impacts on human health. Disproportionately high and adverse human health effects occur 6 when the risk or rate of exposure to an environmental hazard for a minority or low-income 7 population is significant and exceeds the risk or exposure rate for the general population or for 8 another appropriate comparison group. For socioeconomic data regarding the analysis of 9 environmental justice issues, the reader is referred to Section 4.9.7, Environmental Justice.

10 No environmental or human health impacts were identified that would result in 11 disproportionately high and adverse environmental impacts on minority and low-income 12 populations if a replacement gas-fired plant were built at the Salem and HCGS site. Some 13 impacts on rental and other temporary housing availability and lease prices during construction 14 might occur, and this could disproportionately affect low-income populations. Although the site 15 is located in a rural area, it is near the Philadelphia and Wilmington metropolitan areas.

16 Therefore, the demand for rental housing would be mitigated because workers would be likely to 17 commute to the site from these areas instead of relocating closer to the construction site. Thus, 18 the impact on minority and low-income populations would be SMALL.

19 8.1.2.7 Waste Management 20 During the construction phase of this alternative, land clearing and other construction activities 21 would generate waste that can be recycled, disposed onsite or shipped to an offsite waste 22 disposal facility. Because the alternative would be constructed on the previously disturbed 23 Salem and HCGS site, the amounts of wastes produced during land clearing would be reduced.

24 During the operational stage, spent SCR catalysts used to control NOx emissions from the 25 natural gas-fired plants, would make up the majority of the waste generated by this alternative.

26 This waste would be disposed of according to applicable Federal and state regulations.

27 The Staff concluded in the GElS (NRC, 1996), that a natural gas-fired plant would generate 28 minimal waste and the waste impacts would be SMALL for a natural gas-fired alternative 29 located at the Salem and HCGS site.

30 8.1.3 Combination Alternative 31 Even though individual alternatives to license renewal might not be sufficient on their own to 32 replace the 3656 MWe total capacity of Salem and HCGS because of the lack of resource 33 availability, technical maturity, or regulatory barriers, it is conceivable that a combination of 34 alternatives might be sufficient.

35 There are many possible combinations of alternatives that could be considered to replace the 36 power generated by Salem and HCGS. In the GELS, NRC staff indicated that consideration of 37 alternatives would be limited to single, discrete generating options, given the virtually unlimited 38 number of combinations available. In this section, the NRC staff examines a possible 39 combination of alternatives. Under this alternative, both Salem and HCGS would be retired and Draft NUREG-1437, Supplement 42 8-26 April 2010

Environmental Impacts of Alternatives 1 a combination of other alternatives would be considered, as follows:

2 0 Denying the re-license application for Salem and HCGS 3 0 Constructing seven 400 MWe combined-cycle natural gas plants at Salem 4 0 Obtaining 400 MWe from renewable energy sources (primarily offshore wind) 5 0 Implementing 400 MWe of efficiency and conservation programs, from among the 3,300 6 MW of energy efficiency and conservation goals identified by the Northeast Energy 7 Efficiency Partnerships (NEEP, 2009).

8 The following sections analyze the impacts of the alternative outlined above. In some cases, 9 detailed impact analyses for similar actions are described in previous sections of this Chapter.

10 When this occurs, the impacts of the combined alternatives are discussed in a general manner 11 with reference to other sections of this draft SEIS. A summary of the impacts from the 12 combined alternative option is presented in Table 8-3.

13 8.1.3.1 Impacts of Combination Alternative 14 Each component of the combination alternative produces different environmental impacts, 15 though several of the options would have impacts similar to-but smaller than-alternatives 16 already addressed in this SEIS. Constructing a total of 2,800 MWe of gas-fired capacity on the 17 Salem and HCGS sites would create roughly the same impacts as the on-site combined-cycle 18 natural gas alternative described in Section 8.1.2. This alternative would make use of the 19 existing transmission lines at the sites, but would require construction of a 25-mile long natural 20 gas pipeline, the same as would be required under the combined-cycle natural gas alternative 21 evaluated in Section 8.1.2. The amount of air emissions, land use, and water consumption 22 would be reduced due to the smaller number of natural-gas fired units.

23 The NRC staff has not yet addressed in any depth in this SEIS the impacts of wind power or 24 conservation. A wind installation capable of yielding 400 MWe of capacity would likely entail 25 placing wind turbines off of the New Jersey coast. A wind installation capable of delivering 400 26 MWe on average would require approximately 112 turbines with a capacity of 3.6 MW each 27 (MMS, 2010). Because wind power installations do not provide full power all the time, the total 28 installed capacity exceeds the capacity stated here.

29 Impacts from conservation measures are likely to be negligible, as the NRC staff indicated in the 30 GElS (NRC, 1996). The primary concerns NRC staff identified in the GElS related to indoor air 31 quality and waste disposal. In the GELS, NRC staff indicated that air quality appeared to 32 become an issue when weatherization initiatives exacerbated existing problems, and were 33 expected not to present significant effects. The NRC staff also indicated that waste disposal 34 concerns related to energy-saving measures like fluorescent lighting could be addressed by 35 recycling programs. The NRC staff considers the overall impact from conservation to be 36 SMALL in all resource areas, though measures that provide weatherization assistance to low-37 income populations may have positive effects on environmental justice.

February 2010 8-27 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 Air Quality 2 The combination alternative will have some impact on air quality as a result of emissions from 3 the onsite gas turbines. Because of the size of the units, an individual unit's impacts would be 4 SMALL. Section 8.1.2.1 of this draft SEIS describes the impacts on air quality from the 5 construction and operation of natural gas units as SMALL. The construction and operation of 6 the wind farm would have only minor impacts on air quality.

7 Overall, the NRC staff considers that the air quality impacts from the combination alternative 8 would be SMALL.

9 Water Use and Quality 10 The primary water use and quality issues from this alternative would occur from the gas-fired 11 units at Salem and HCGS. While construction impacts could occur from a wind farm, 12 particularly if located offshore, these impacts are likely to short lived. An offshore windfarm is 13 unlikely to located immediately adjacent to any water users, though construction may increase 14 turbidity. An onshore wind farm could create additional erosion during construction, as would a 15 gas-fired unit on the Salem and HCGS sites. In general, site management practices keep these 16 effects to a small level.

17 During operations, only the gas-fired plants would require water for cooling. The natural gas 18 would likely use closed-cycle cooling, however, and this would limit the effects on water 19 resources. As the NRC staff indicated for the coal-fired and gas-fired alternatives, the gas-fired 20 portion of this alternative is likely to rely on surface water for cooling (or, as is the case in some 21 locations, treated sewage effluent).

22 The NRC staff considers impacts on water use and quality to be SMALL for the combination 23 alternative. The onsite impacts at the Salem and HCGS facility would be expected to be similar 24 to the impacts described in Sections 8.1.2.2 and 8.1.2.3 of this draft SEIS.

25 Ecology 26 Impacts on aquatic and terrestrial ecology from the gas-fired power plant component of the 27 combination alternative, which includes seven gas-fired units, would be similar to those 28 described for the gas-fired alternative (based on nine units) in Section 8.1.2.4. Therefore, 29 ecological impacts would similarly be SMALL.

30 The wind farm component of this alternative, if located offshore, could have temporary impacts 31 on aquatic organisms due to construction activities, which would likely increase turbidity in the 32 area of construction. The NRC assumes that the appropriate agencies would monitor and 33 regulate such activities. Overall, the impacts to aquatic resources would be SMALL.

34 Based on data in the GELS, an onshore wind farm component of the combination alternative 35 producing 400 MWe of electricity would require approximately 24,400 ha (60,000 ac) spread 36 over several offsite locations, with less than 10 percent of that land area in actual use for 37 turbines and associated infrastructure. The remainder of the land could remain in use for 38 activities such as agriculture. Additional land would likely be needed for construction of support Draft NUREG-1437, Supplement 42 8-28 April 2010

Environmental Impacts of Alternatives 1 infrastructure to connect to existing transmission lines. During construction, there would be an 2 increased potential for erosion and adverse effects on adjacent water bodies, though 3 stormwater management practices are expected to minimize such impacts.

4 Impacts to terrestrial ecology from construction of the wind farm portion of the combination 5 alternative and any needed transmission lines could include loss of terrestrial habitat, an 6 increase in habitat fragmentation and corresponding increase in edge habitat, and may impact 7 threatened and endangered species. The GElS notes that habitat fragmentation may lead to 8 declines of migrant bird populations. Once operational, birds would be likely to collide with the 9 turbines, and migration routes would need to be considered during site selection. Based on this 10 information, impacts to terrestrial resources would be MODERATE.

11 Human Health 12 The primary health concerns under this option would be occupational health and safety risks 13 during the construction of the new gas turbine and the wind farm. As described previously, if 14 the risks are appropriately managed, the human health impacts from construction and operation 15 of a gas-fired power plant are SMALL. Human health impacts from a wind farm would also be 16 associated primarily with the construction of the facility and would also be minimal. Continued 17 operation of HCGS with the existing closed-cycle cooling system would not change the human 18 health impacts designation of SMALL as discussed in Chapter 4.

19 Therefore, the NRC staff concludes that the overall human health impact from the first 20 combination alternative would be SMALL.

21 Land Use 22 Impacts from this alternative would include the types of impacts discussed for land use in 23 Section 8.1.2.6 of this draft SEIS. Section 8.1.2.6 states that the land use impacts from the 24 construction of nine gas-fired units at the Salem site would be SMALL to MODERATE. The 25 combined alternative includes seven gas-fired units, which would fit on the existing site without 26 purchasing offsite land. In addition to onsite land requirements, land would be required offsite 27 for natural gas wells and collection stations. The elimination of uranium fuel for the Salem and 28 HCGS facilities could partially offset offsite land requirements. The land use impacts of the gas-29 fired component of the combination alternative would be expected to be similar to the impacts 30 described in Sections 8.1.2.6, that is, SMALL to MODERATE.

31 Impacts from the wind power component of this alternative would depend largely on whether the 32 wind facility is located onshore or offshore. Onshore wind facilities would incur greater land use 33 impacts than offshore facilities, simply because all towers and supporting infrastructure would 34 be located on land. NRC observations provided in the GElS indicate that onshore installations 35 could require approximately 60,000 acres (24,400 ha), though turbines and infrastructure would 36 actually occupy only a small percentage (less than 10 percent) of that land area. Land around 37 wind installations could remain in use for activities like agriculture (a practice consistent with 38 wind farm siting throughout the U.S.).

39 Although the offsite wind component of this alternative would require a large amount of land, February 2010 8-29 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 only a small component of that land would be in actual use. Overall, the NRC staff considers 2 that the land use impacts from the combination alternative would be SMALL to MODERATE.

3 Socioeconomics 4 Impacts from this alternative would include the types of impacts discussed for socioeconomics 5 in Section 8.1.2.6 of this draft SEIS. Section 8.1.2.6 states that the socioeconomics impacts 6 from the construction and operation of nine gas-fired units at the Salem site would be SMALL to 7 MODERATE. The combined alternative includes seven gas-fired units. The associated 8 construction workforce and number of operational workers, and the property taxes paid to the 9 local jurisdiction, would be similar to the gas-fired alternative. Accordingly, the socioeconomic 10 impacts from the gas-fired component of the combination alternative would be SMALL to 11 MODERATE.

12 Socioeconomic impacts from the wind component of this alternative were evaluated based on 13 construction and operations workforce requirements. Additional estimated construction 14 workforce requirements for this combination alternative would include 300 workers for the wind 15 farm. The number of additional workers would cause a short-term increase in demand for 16 services and temporary (rental) housing in the region around the construction site(s). Following 17 construction, some local communities may be temporarily affected by the loss of the 18 construction jobs and associated loss in demand for business services. The rental housing 19 market would also experience increased vacancies and decreased prices. Considering the 20 relatively low levels of employment associated with construction of this component of the 21 combination alternative, the impact on socioeconomic conditions would be SMALL. Also, 22 employment effects would likely be spread over a larger area, as the wind farms may be 23 constructed in more than one location.

24 Additional estimated operations workforce requirements for the wind farm component of the 25 combination alternative would include 50 workers. Given the small number of operations 26 workers, socioeconomic impacts associated with operation of the wind farm would be SMALL.

27 Socioeconomics (Transportation) 28 Construction and operation of a natural gas-fired power plant and a wind farm would increase 29 the number of vehicles on roads in the vicinity of these facilities. During construction, cars and 30 trucks would deliver workers, materials, and equipment to the work sites. The increase in 31 vehicular traffic would peak during shift changes resulting in temporary level of service impacts 32 and delays at intersections. Transporting components of wind turbines could have a noticeable 33 impact, but is likely to be spread over a large area. Pipeline construction and modification to 34 existing natural gas pipeline systems could also have an impact. Transportation impacts would 35 be SMALL to MODERATE.

36 During plant operations, transportation impacts would lessen. Given the small numbers of 37 operations workers at these facilities, overall operational impacts on levels of service on local 38 roads from operation of the gas-fired power plant at the Salem and HCGS site as well as the 39 wind farm would be SMALL. Transportation impacts at the wind farm site or sites would also 40 depend on current road capacities and average daily traffic volumes, but are likely to be SMALL Draft NUREG-1437, Supplement 42 8-30 April 2010

Environmental Impacts of Alternatives 1 given the low number of workers employed by that component of the alternative.

2 Aesthetics 3 Aesthetic impacts from the gas-fired power plant component of the combination alternative 4 would be essentially the same as those described for the gas-fired alternative in Section 8.1.2.6.

5 Aesthetic impacts, associated with visibility of the gas-fired units and exhaust stacks, and the' 6 existing HCGS cooling tower, would be SMALL to MODERATE. The impact associated with 7 noise from plant operations, which may be detectable offsite, would be SMALL.

8 The wind farm component would have the greatest aesthetic effect of this combination 9 alternative. Several hundred wind turbines at over 300 feet (100 m) in height and spread over 10 60,000 acres (24,400 ha) may dominate the view and, in the absence of larger topographic 11 features, would be the major focus of viewer attention. The overall impact would depend on the 12 sensitivity of the site. Therefore, overall aesthetic impacts from the construction and operation 13 of a wind farm would be MODERATE, or LARGE if the wind farm is built at a site where 14 aesthetics is an important element of the natural environment.

15 Historic and Archeological Resources 16 Onsite impacts to historical and cultural resources from the construction of a gas turbine plant 17 are expected to be SMALL. The offsite impacts from the construction of a wind farm are also 18 expected to be small given the opportunity to evaluate and select the sites in accordance with 19 applicable regulations and the ability to minimize impacts before construction. Therefore, the 20 NRC staff concludes that the overall impacts on historic and archeological resources from the 21 first combination alternative would be SMALL.

22 EnvironmentalJustice 23 The environmental justice impact analysis evaluates the potential for disproportionately high and 24 adverse human health and environmental effects on minority and low-income populations that 25 could result from the construction and operation of a new natural gas-fired power plant and a 26 new wind farm, and from energy efficiency and conservation programs. No environmental or 27 human health impacts were identified that would result in disproportionately high and adverse 28 environmental impacts on minority and low-income populations if a replacement gas-fired plant 29 were built at the Salem and HCGS site and a wind farm was built in the area. Some impacts on 30 rental and other temporary housing availability and lease prices during construction may occur, 31 and this could disproportionately affect low-income populations. The demand for rental housing 32 would be mitigated because workers would be likely to commute to the construction sites from 33 metropolitan areas in the region instead of relocating closer to the construction sites. Thus, the 34 impact of the gas-fired and wind farm components of the combination alternative on minority 35 and low-income populations would be SMALL.

36 Weatherization programs associated with the conservation component of this alternative could 37 target low-income residents as a cost-effective energy efficiency option since low-income 38 populations tend to spend a larger proportion of their incomes paying utility bills. According to 39 the Office of Management and Budget, low income populations experience energy burdens February 2010 8-31 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 more than four times as large as those of average households (OMB, 2007). Impacts to 2 minority and low-income populations from the energy efficiency and conservation programs 3 component of this alternative, although dependent on program design and enrollment, would be 4 SMALL.

5 Waste 6 The primary source of waste would be associated with the construction of the new gas turbine 7 facility and the wind farm. Waste impacts could be substantial but likely not noticeably alter or 8 destabilizing the resource during construction of the alternatives, depending on how the various 9 sites handle wastes.

10 The waste contribution from the remaining HCGS unit would be roughly one-third of the waste 11 generated by the current facility (Salem and HCGS) described in Sections 2.1.2 and 2.1.3. If 12 the remaining HCGS unit were to continue operation with the existing closed-cycle cooling 13 system, waste impacts would be minor.

14 Therefore, the NRC staff concludes that the overall impact from waste from the first combination 15 alternative would be SMALL.

16 Table 8-3 Summary of Environmental Impacts of Combination Alternative Impact Combination Alternative Category Impact Comments Land Use SMALL to Although the offsite wind farm component requires a IE MODERATE of land, only a small portion would be in actual use.

Ecology SMALL to Impacts would be greatest to terrestrial resources MODERATE from an onshore wind farm.

Water Use and SMALL Minor impacts occur if the wind farm is located Quality offshore.

Air Quality SMALL Air emissions of the gas-fired unit would be minor considering their size. A wind farm would not impact air quality.

Waste SMALL Waste volumes could be substantial during construction. Operational waste volumes would be SMALL Human Health SMALL Occupational health and safety risks would be managed in accordance with applicable regulations.

Draft NUREG-1 437, Supplement 42 8-32 April 2010

Environmental Impacts of Alternatives Impact Combination Alternative Category Impact Comments Socioeconomics SMALL to Most of the socioeconomic impacts are associated MODERATE with the gas-fired component.

Socioeconomics SMALL to Traffic impacts would be greater during construction, (Transportation) MODERATE with minor impacts during operations.

Aesthetics SMALL to The greatest aesthetic effects are associated with LARGE the wind farm component.

Historic and Archeological Resources Environmental SMALL Impacts would be similar to those experienced by the Justice general population in the region.

1 8.1 ALTERNATIVES CONSIDERED BUT DISMISSED 2 In this section, the Staff presents the alternatives it initially considered for analysis as 3 alternatives to license renewal of Salem and HCGS, but later dismissed due to technical, 4 resource availability, or commercial limitations that currently exist and that the Staff believes are 5 likely to continue to exist when the existing Salem and HCGS licenses expire. Under each of the 6 following technology headings, the Staff indicates why it dismissed each alternative from further 7 consideration.

8 8.2.1 Offsite Coal- and Gas-Fired Capacity 9 While it is possible that coal- and gas-fired alternatives like those considered in 8.1.1 and 8.1.2, 10 respectively, could be constructed at sites other than Salem and HCGS, the Staff determined 11 that they would likely result in greater impacts than alternatives constructed at the Salem and 12 HCGS site. Greater impacts would occur from construction of support infrastructure, like 13 transmission lines, and roads that are already present on the Salem and HCGS site. Further, 14 the community around Salem and HCGS is already familiar with the appearance of a power 15 facility and it is an established part of the region's aesthetic character. Workers skilled in power 16 plant operations would also be available in this area. The availability of these factors are only 17 likely to be available on other recently-industrial sites. In cases where recently-industrial sites 18 exist, other remediation may also be necessary in order to ready the site for redevelopment. In 19 short, an existing power plant site would present the best location for a new power facility.

20 February 2010 8-33 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 8.2.2 New Nuclear 2 In its ER, PSEG indicated that it is unlikely that a nuclear alternative could be sited, constructed 3 and operational by the time the HCGS operating license expires in 2026 (PSEG, 2009b).

4 However, this could not be accomplished in a timeframe necessary to replace the generating 5 output of Salem Unit 1, which has a license expiration date of 2016 (PSEG, 2009a). Given the 6 relatively short time remaining on the current Salem and HCGS licenses, the Staff has not 7 evaluated new nuclear generation as an alternative to license renewal.

8 8.2.3 Energy Conservation/Energy Efficiency 9 Though often used interchangeably, energy conservation and energy efficiency are different 10 concepts. Energy efficiency typically means deriving a similar level of services by using less 11 energy, while energy conservation simply indicates a reduction in energy consumption. Both fall 12 into a larger category known as demand-side management (DSM). DSM measures-unlike the 13 energy supply alternatives discussed in previous sections-address energy end uses. DSM can 14 include measures that shift energy consumption to different times of the day to reduce peak 15 loads, measures that can interrupt certain large customers during periods of high demand or 16 measures than interrupt certain appliances during high demand periods, and measures like 17 replacing older, less efficient appliances, lighting, or control systems. DSM also includes 18 measures that utilities use to boost sales, such as encouraging customers to switch from gas to 19 electricity for water heating.

20 Unlike other alternatives to license renewal, the GElS notes that conservation is not a discrete 21 power generating source; it represents an option that states and utilities may use to reduce their 22 need for power generation capability (NRC, 1996).

23 In October 2008, the State of New Jersey published their Energy Master Plan (New Jersey 24 2008), which established goals and evaluated potential options for meeting the protected 25 increase in electricity demand in the state through 2020. As part of this Master Plan, actions 26 were identified to maximize energy conservation and energy efficiency, including: transitioning 27 the state's current energy efficiency programs to be implemented by the electric and gas 28 utilities; modifying the statewide building code for new buildings to make new buildings as least 29 30 percent more energy efficient; increasing energy efficiency standards for new appliances and 30 other equipment, and developing education and outreach programs for the public. An additional 31 goal is to reduce peak electricity demand, primarily by expanding incentives developing 32 technologies to increase participation in regional demand response programs. A separate goal 33 established in the report (not related to energy conservation) included successful 34 accomplishment of the state's Renewable Energy Portfolio Standard by 2020.

35 The report concluded that the combination of all of these efforts (energy conservation, 36 efficiency, and renewable energy sources) would still not result in meeting the increased 37 demand for electricity in the state, and that additional development of traditional electricity 38 sources would still be required. Therefore, these measures would not be able to replace the 39 output of the Salem and HCGS facilities. Because of this, the Staff has not evaluated energy 40 conservation/efficiency as a discrete alternative to license renewal. It has, however, been 41 considered as a component of the combination alternative.

Draft NUREG-1437, Supplement 42 8-34 April 2010

Environmental Impacts of Alternatives 1 8.2.4 Purchased Power 2 In the Salem and HCGS ERs, PSEG indicated that purchased electrical power is a potentially 3 viable option for replacing the generating capacity of the Salem and HCGS facilities. PSEG 4 anticipated that this power could be purchased from other generation sources within the PJM 5 region, but that the source would likely be from new capacity generated using technologies that 6 are evaluated in the GELS. The technologies that would most likely be used to generate the 7 purchased power would be coal and natural gas, and therefore the impacts associated with the 8 power purchase would be similar to those evaluated in Sections 8.1.1 and 8.1.2. In addition, 9 purchased power would likely require the addition of transmission capacity, which would result 10 in additional land use impacts. Because purchased electrical power would likely be provided by 11 new generation sources evaluated elsewhere in this section, and would also require new 12 transmission capacity, the Staff has not evaluated purchased power as a separate alternative to 13 license renewal.

14 8.2.5 Solar Power 15 Solar technologies use the sun's energy to produce electricity. Currently, the Salem and HCGS 16 area receives approximately 4.5 to 5.5 kilowatt hour (kWh) per square meter per day, for solar 17 collectors oriented at an angle equal to the installation's latitude (NREL, 2010). Since flat-plate 18 photovoltaics tend to be roughly 25 percent efficient, a solar-powered alternative would require 19 more than 140,000 acres (56,000 ha) of collectors to provide an amount of electricity equivalent 20 to that generated by Salem and HCGS. Space between parcels and associated infrastructure 21 increase this land requirement. This amount of land, while large, is consistent with the land 22 required for coal and natural gas fuel cycles. In the GELS, the Staff noted that, by its nature, 23 solar power is intermittent (i.e., it does not work at night and cannot serve baseload when the 24 sun is not shining), and the efficiency of collectors varies greatly with weather conditions. A 25 solar-powered alternative would require energy storage or backup power supply to provide 26 electric power at night. Given the challenges in meeting baseload requirements, the Staff did not 27 evaluate solar power as an alternative to license renewal of Salem and HCGS.

28 8.2.6 Wood Waste 29 The National Renewable Energy Laboratory estimates the amount of biomass fuel resources, 30 including forest, mill, agricultural, and urban residues, available within New Jersey, Delaware, 31 and Pennsylvania to be approximately 5.6 million dry tons per year (NREL, 2005). Based on an 32 estimate of 9.961 million Btu per dry ton and a thermal conversion efficiency of 25%, conversion 33 of this entire resource would generate the equivalent of less than 500 MWe. Of the available 34 biomass in the three states, the vast majority (80 percent) is in Pennsylvania, and assumed to 35 be located primarily in the western portion of the state. Therefore, the volume that would be 36 available for fueling a plant in the local area would be much less, and is not likely to be sufficient 37 to substitute for the capacity provided by Salem and HCGS. As a result, the Staff has not 38 considered a wood-fired alternative to Salem and HCGS license renewal.

39 February 2010 8-35 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 8.2.7 Wind (Onshore/Offshore) 2 The American Wind Energy Association indicates that New Jersey currently ranks 33rd among 3 the states in installed wind power capacity (7.5 MW), and 2 9 th among the state in potential 4 capacity. No projects are currently under construction (AWEA, 2010). No wind capacity is 5 installed in Delaware. Although Pennsylvania ranks 15th among the states in installed capacity, 6 with a total of 748 MW, most of this installed capacity is located in the western portion of the 7 state (AWEA, 2010). The Report of the New Jersey Governor's Blue Ribbon Panel on 8 Development of Wind Turbine Facilities in Coastal Waters (State of New Jersey 2006) 9 concluded that onshore wind speeds in New Jersey are not viable for commercial wind power 10 development, and that the vast majority of the state's wind generation capacity was offshore.

11 The report also concluded that development of the offshore resources is not commercially viable 12 without significant state and/or federal subsidies. Also, preliminary information evaluated in the 13 report indicated that the timing of peak offshore wind speeds did not coincide with the times of 14 peak energy demand, and that offshore wind alone could not significantly reduce reliance on 15 fossil fuel and domestic nuclear capacity (State of New Jersey, 2006). Finally, the results of a 16 study of potential impacts of large-scale wind turbine siting by NJDEP identified large areas 17 along the New Jersey Coast that would likely be considered to be off limits to large scale wind 18 development due to documented bird concentrations, nesting for resident threatened and 19 endangered bird species, and stopover locations for migratory birds (NJDEP, 2009b).

20 Given wind power's intermittency, the lack of easily implementable onshore resources in New 21 Jersey, and restrictions on placement of turbines in areas that would otherwise have high 22 resource potential, NRC staff will not consider wind power as a stand-alone alternative to 23 license renewal. However, given the potential for development of offshore resources, the NRC 24 staff will consider wind power as a portion of a combination alternative.

25 8.2.8 Hydroelectric Power 26 According to researchers at Idaho National Energy and Environmental Laboratory, New Jersey 27 has an estimated 11 MW of technically available, undeveloped hydroelectric resources at 12 28 sites throughout the State (INEEL, 1996). Given that the available hydroelectric potential in the 29 State of New Jersey constitutes only a small fraction of generating capacity of Salem and 30 HCGS, the Staff did not evaluate hydropower as an alternative to license renewal.

31 8.2.9 Wave and Ocean Energy 32 Wave and ocean energy has generated considerable interest in recent years. Ocean waves, 33 currents, and tides are often predictable and reliable. Ocean currents flow consistently, while 34 tides can be predicted months and years in advance with well-known behavior in most coastal 35 areas. Most of these technologies are in relatively early stages of development, and while some 36 results have been promising, they are not likely to be able to replace the capacity of Salem and 37 HCGS by the time their licenses expire. Therefore, the NRC did not consider wave and ocean 38 energy as an alternative to Salem and HCGS license renewal.

39 Draft NUREG-1437, Supplement 42 8-36 April 2010

Environmental Impacts of Alternatives 1 8.2.10 Geothermal Power 2 Geothermal energy has an average capacity factor of 90 percent and can be used for baseload 3 power where available. However, geothermal electric generation is limited by the geographical 4 availability of geothermal resources (NRC, 1996). Although New Jersey has some geothermal 5 potential in a heating capacity, it does not have geothermal electricity potential for electricity 6 generation (GHC, 2008). The Staff concluded that geothermal energy is not a reasonable 7 alternative to license renewal at Salem and HCGS.

8 8.2.11 Municipal Solid Waste 9 Municipal solid waste combustors use three types of technologies-mass burn, modular, and 10 refuse-derived fuel. Mass burning is currently the method used most frequently in the United 11 States and involves no (or little) sorting, shredding, or separation. Consequently, toxic or 12 hazardous components present in the waste stream are combusted, and toxic constituents are 13 exhausted to the air or become part of the resulting solid wastes. Currently, approximately 87 14 waste-to-energy plants operate in the United States. These plants generate approximately 15 2,531 MWe, or an average of 29 MWe per plant (Energy Recovery Council, 2010). This 16 includes five plants in New Jersey generating a total of 173 MWe. More than 124 average-17 sized plants would be necessary to provide the same level of output as the other alternatives to 18 Salem and HCGS license renewal.

19 Estimates in the GElS suggest that the overall level of construction impact from a waste-fired 20 plant would be approximately the same as that for a coal-fired power plant. Additionally, waste-21 fired plants have the same or greater operational impacts than coal-fired technologies (including 22 impacts on the aquatic environment, air, and waste disposal). The initial capital costs for 23 municipal solid-waste plants are greater than for comparable steam-turbine technology at coal-24 fired facilities or at wood-waste facilities because of the need for specialized waste separation 25 and handling equipment (NRC, 1996).

26 The decision to burn municipal waste to generate energy is usually driven by the need for an 27 alternative to landfills rather than energy considerations. The use of landfills as a waste disposal 28 option is likely to increase in the near term as energy prices increase; however, it is possible 29 that municipal waste combustion facilities may become attractive again.

30 Given the small average installed size of municipal solid waste plants and the unfavorable 31 regulatory environment, the Staff does not consider municipal solid waste combustion to be a 32 feasible alternative to Salem and HCGS license renewal.

33 8.2.12 Biofuels 34 In addition to wood and municipal solid waste fuels, there are other concepts for biomass-fired 35 electric generators, including direct burning of energy crops, conversion to liquid biofuels, and 36 biomass gasification. In the GELS, the Staff indicated that none of these technologies had 37 progressed to the point of being competitive on a large scale or of being reliable enough to 38 replace a baseload plant such as Salem and HCGS. After reevaluating current technologies, 39 the Staff finds other biomass-fired alternatives are still unable to reliably replace the Salem and February 2010 8-37 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 HCGS capacity. For this reason, the Staff does not consider other biomass-derived fuels to be 2 feasible alternatives to Salem and HCGS license renewal.

3 8.2.13 Oil-Fired Power 4 EIA projects that oil-fired plants would account for very little of the new generation capacity 5 constructed in the United States during the 2008 to 2030 time period. Further, EIA does not 6 project that oil-fired power would account for any significant additions to capacity (EIA, 2009a).

7 The variable costs of oil-fired generation tend to be greater than those of the nuclear or coal-8 fired operations, and oil-fired generation tends to have greater environmental impacts than 9 natural gas-fired generation. In addition, future increases in oil prices are expected to make oil-10 fired generation increasingly more expensive (EIA, 2009a). The high cost of oil has prompted a 11 steady decline in its use for electricity generation. Thus, the Staff did not consider oil-fired 12 generation as an alternative to Salem and HCGS license renewal.

13 8.2.14 Fuel Cells 14 Fuel cells oxidize fuels without combustion and its environmental side effects. Power is 15 produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) 16 over a cathode and separating the two by an electrolyte. The only byproducts (depending on 17 fuel characteristics) are heat, water, and C02. Hydrogen fuel can come from a variety of 18 hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically 19 used as the source of hydrogen.

20 At the present time, fuel cells are not economically or technologically competitive with other 21 alternatives for electricity generation. In addition, fuel cell units are likely to be small in size.

22 While it may be possible to use a distributed array of fuel cells to provide an alternative to Salem 23 and HCGS, it would be extremely costly to do so and would require many units. Accordingly, the 24 Staff does not consider fuel cells to be an alternative to Salem and HCGS license renewal.

25 8.2.15 Delayed Retirement 26 The power generating merchants within the PJM region have retired a large number of 27 generation sources since 2003, totaling 5,945 MW retired and 2,629 MW pending retirement.

28 Most of these retirements involve older fossil fuel-powered plants which are retired due to 29 challenges in meeting increasingly stringent air quality standards (PJM, 2009). Although these 30 retirements have caused reliability criteria violations, PJM does not have any authority to 31 compel owners to delay retirement (PJM, 2009), and therefore retirements are likely to continue.

32 Therefore, delayed retirement of non-nuclear plants is not considered as a feasible alternative to 33 Salem and HCGS license renewal.

34 8.3 NO-ACTION ALTERNATIVE 35 This section examines environmental effects that would occur if NRC takes no action. No action 36 in this case means that NRC does not issue a renewed operating license for Salem and HCGS 37 and the licenses expire at the end of their current license terms. If NRC takes no action, the Draft NUREG-1437, Supplement 42 8-38 April 2010

Environmental Impacts of Alternatives 1 plants would shutdown at or before the end of the current license. After shutdown, plant 2 operators would initiate decommissioning according to 10 CFR 50.82. Table 8-4 provides a 3 summary of environmental impacts of No Action compared to continued operation of the Salem 4 and HCGS.

5 The Staff notes that the option of no-action is the only alternative considered in-depth that does 6 not satisfy the purpose and need for this SEIS, as it does not provide power generation capacity 7 nor would it meet the needs currently met by Salem and HCGS or that the alternatives 8 evaluated in Section 8.1 would satisfy. Assuming that a need currently exists for the power 9 generated by Salem and HCGS, the no-action alternative would require that the appropriate 10 energy planning decision-makers rely on an alternative to replace the capacity of Salem and 11 HCGS or reduce the need for power.

12 This section addresses only those impacts that arise directly as a result of plant shutdown. The 13 environmental impacts from decommissioning and related activities have already been 14 addressed in several other documents, including the Final Generic Environmental Impact 15 Statement on Decommissioning of NuclearFacilities, NUREG-0586, Supplement 1 (NRC, 16 2002); the license renewal GElS (chapter 7; NRC, 1996); and Chapter 7 of this SEIS. These 17 analyses either directly address or bound the environmental impacts of decommissioning 18 whenever PSEG ceases operating Salem and HCGS.

19 The Staff notes that, even with renewed operating licenses, Salem and HCGS would eventually 20 shut down, and the environmental effects addressed in this section would occur at that time.

21 Since these effects have not otherwise been addressed in this SEIS, the impacts will be 22 addressed in this section. As with decommissioning effects, shutdown effects are expected to 23 be similar whether they occur at the end of the current license or at the end of a renewed 24 license.

25 Table 8-4. Summary of Environmental Impacts of No Action Compared to Continued 26 Operation of Salem and HCGS Continued Salem and HCGS No Action Operation Air Quality SMALL SMALL Groundwater SMALL SMALL Surface Water SMALL SMALL to MODERATE Aquatic and Terrestrial Resources SMALL SMALL Human Health SMALL SMALL Socioeconomics SMALL to LARGE SMALL Waste Management SMALL Not Applicable February 2010 8-39 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 8.3.1 Air Quality 2 When the plant stops operating, there would be a reduction in emissions from activities related 3 to plant operation such as use of diesel generators and employees vehicles. In Chapter 4, the 4 Staff determined that these emissions would have a SMALL impact on air quality during the 5 renewal term. Therefore, if the emissions decrease, the impact to air quality would also 6 decrease and would be SMALL.

7 8.3.2 Groundwater Use and Quality 8 The use of groundwater would diminish as plant personnel are removed from the site and 9 operations cease. Some consumption of groundwater may continue as a small staff remains 10 onsite to maintain facilities prior to decommissioning. Overall impacts would be smaller than 11 during operations, but would remain SMALL.

12 8.3.3 Surface Water Use and Quality 13 The rate of consumptive use of surface water would decrease as the plant is shut down and the 14 reactor cooling system continues to remove the heat of decay. Wastewater discharges would 15 also be reduced considerably. Shutdown would reduce the already SMALL impact on surface 16 water resources and quality.

17 8.3.4 Aquatic and Terrestrial Resources 18 Aquatic Ecology 19 If the plant were to cease operating, impacts to aquatic ecology would decrease, as the plant 20 would withdraw and discharge less water than it does during operations. Shutdown would 21 reduce the already SMALL impacts to aquatic ecology.

22 TerrestrialEcology 23 Shutdown would result in no additional land disturbances onsite or offsite, and terrestrial 24 ecology impacts would be SMALL.

25 8.3.5 Human Health 26 Human health risks would be smaller following plant shutdown. The plant, which is currently 27 operating within regulatory limits, would emit less gaseous and liquid radioactive material to the 28 environment. In addition, following shutdown, the variety of potential accidents at the plant 29 (radiological or industrial) would be reduced to a limited set associated with shutdown events 30 and fuel handling and storage. In Chapter 4 of this draft supplemental EIS, the Staff concluded 31 that the impacts of continued plant operation on human health would be SMALL. In Chapter 5, 32 the Staff concluded that the impacts of accidents during operation were SMALL. Therefore, as 33 radioactive emissions to the environment decrease, and as the likelihood and variety of 34 accidents decrease following shutdown, the Staff concludes that the risks to human health 35 following plant shutdown would be SMALL.

Draft NUREG-1437, Supplement 42 8-40 April 2010

Environmental Impacts of Alternatives 1 8.3.6 Socioeconomics 2 Land Use 3 Plant shutdown would not affect onsite land use. Plant structures and other facilities would likely 4 remain in place until decommissioning. Most transmission lines connected to Salem and HCGS 5 would remain in service after the facilities stop operating. Maintenance of most existing 6 transmission lines would continue as before. The transmission lines could be used to deliver the 7 output of any new capacity additions made on the Salem and HCGS site. Impacts on land use 8 from plant shutdown would be SMALL.

9 Socioeconomics 10 Plant shutdown would have an impact on socioeconomic conditions in the region around Salem 11 and HCGS. Plant shutdown would eliminate approximately 1,614 jobs and would reduce tax 12 revenue in the region. The loss of these contributions, which may not entirely cease until after 13 decommissioning, could have a MODERATE impact within Salem County and a LARGE impact 14 within Lower Alloways Creek Township, which receives approximately 57 percent of its total 15 property tax revenue from Salem and HCGS. See Appendix J to NUREG-0586, Supplement 1 16 (NRC, 2002), for additional discussion of the potential socioeconomic impacts of plant 17 decommissioning.

18 Transportation 19 Traffic volumes on the roads in the vicinity of Salem and HCGS would be reduced after plant 20 shutdown. Most of the reduction in traffic volume would be associated with the loss of jobs at 21 the facilities. Deliveries of materials and equipment to the plant would be reduced until 22 decommissioning. Transportation impacts would be SMALL as a result of plant shutdown.

23 Aesthetics 24 Plant structures and other facilities would likely remain in place until decommissioning. The 25 plume from the cooling tower would cease or greatly decrease after shutdown. Noise caused by 26 plant operation would cease. Aesthetic impacts of plant closure would be SMALL.

27 Historic and Archaeological Resources 28 Impacts from the no-action alternative would be SMALL, since Salem and HCGS would be 29 decommissioned. A separate environmental review would be conducted for decommissioning.

30 That assessment would address the protection of historic and archaeological resources.

31 EnvironmentalJustice 32 Impacts to minority and low-income populations when Salem and HCGS cease operation would 33 depend on the number of jobs and the amount of tax revenues lost by the communities 34 surrounding the facilities. Closure of Salem and HCGS would reduce the overall number of jobs 35 (there are currently 1,614 permanent positions at the facilities) and the tax revenue attributed to February 2010 8-41 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1 plant operations (approximately 57 percent of Lower Alloways Creek Township's tax revenues, 2 and 2.9 percent of Salem County's tax revenues, are from Salem and HCGS). Since the Salem 3 and HCGS tax payments represent such a significant percentage of Lower Alloways Creek 4 Township's total annual property tax revenue, it is likely that economic impacts within the 5 townsip would range from MODERATE to LARGE should Salem and HCGS be shutdown and 6 closed. Therefore, minority and low-income populations in the township could experience a 7 disproportionately high and adverse socioeconomic impact from plant shutdown.

8 8.3.7 Waste Management 9 If the no-action alternative were implemented the generation of high-level waste would stop and 10 generation of low-level and mixed waste would decrease. Impacts from implementation of no-11 action alternative are expected to be SMALL.

12 Wastes associated with plant decommissioning are unavoidable and will be significant whether 13 the plant is decommissioned at the end of the initial license period or at the end of the 14 relicensing period. Therefore, the selection of the no-action alternative has no impact on issues 15 relating to decommissioning waste.

16 8.4 ALTERNATIVES

SUMMARY

17 In this chapter, the Staff considered the following alternatives to Salem and HCGS license 18 renewal: supercritical coal-fired generation; natural gas combined-cycle generation; and a 19 combination of alternatives. No action by the NRC and the effects it would have were also 20 considered. The impacts for all alternatives are summarized in Table 8-5 on the following page.

21 Socioeconomic and groundwater impacts could range from SMALL to MODERATE. The Staff 22 did not determine a single significance level for these impacts, but the Commission determined 23 them to be Category 1 issues nonetheless. The environmental impacts of the proposed action 24 (issuing renewed Salem and HCGS operating licenses) would be SMALL for all other impact 25 categories, except for the Category 1 issue of collective offsite radiological impacts from the fuel 26 cycle, high level waste (HLW), and spent fuel disposal.

27 In the Staff's professional opinion, the coal-fired alternative would have the greatest over all 28 adverse environmental impact. This alternative would result in MODERATE waste 29 management, land use, and air quality impacts. Its impacts upon socioeconomic and biological 30 resources could range from SMALL to MODERATE. This alternative is not an environmentally 31 preferable alternative due to air quality impacts from nitrogen oxides, sulfur oxides, particulate 32 matter, PAHs, carbon monoxide, carbon dioxide, and mercury (and the corresponding human 33 health impacts), as well as construction impacts to aquatic, terrestrial, and potential historic and 34 archaeological resources.

35 With the exception of land use, socioeconomic, and air quality impacts, the gas-fired alternative 36 would result in SMALL impacts. Socioeconomic, land use, and air quality impacts could range 37 from SMALL to MODERATE. This alternative would result in substantially lower air emissions, 38 and waste management than the coal-fired alternative.

Draft NUREG-1437, Supplement 42 8-42 April 2010

Environmental Impacts of Alternatives 1 The combination alternative would have lower air emissions and waste management impacts 2 than both the gas-fired and coal-fired alternatives, however it would have relatively higher 3 construction impacts in terms of land use, aquatic and terrestrial resources, and potential 4 disruption to historic and archaeological resources, mainly as a result of the wind turbine 5 component.

6 Under the no-action alternative, plant shutdown would eliminate approximately 1,614 jobs and 7 would reduce tax revenue in the region. The loss of these contributions, which may not entirely 8 cease until after decommissioning, would have a MODERATE to LARGE impact. However, the 9 no-action alternative does not meet the purpose and need stated in this draft SEIS.

10 Therefore, in the Staff's best professional opinion, the environmentally preferred alternative in 11 this case is the license renewal of Salem and HCGS. All other alternatives capable of meeting 12 the needs currently served by Salem and HCGS entail potentially greater impacts than the 13 proposed action of license renewal of Salem and HCGS.

February 2010 8-43 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives Table 8-5. Summary of Environmental Impacts of Proposed Action and Alternatives Impact Area E E Alternative E0U 0 a c 00-U (U

<Co SMALL to License Renewal SMALL SMALL MODERtE MODERATE SMALL SMALL SMALL SMALL Supercritical Coal-fired MODERATE SMALL SMALL SMALL to MODERATE SMALL to MODERATE Alternative MODERATE MODERATE SMALL to SMALL to Gas-fired Alternative MODERtE MODERATE SMALL SMALL SMALL SMALL MODERtE MODERATE SMALL Combination Alternative SMALL SMALL SMALL SMALL to SMALL to SMALL MODERATE LARGE No Action Alternative SMALL SMALL SMALL SMALL SMALL SMALL to SMALL LARGE 2 (a) For the Salem and HCGS license renewal alternative, waste management was evaluated in Chapter 6. Consistent with the findings in the GELS, these impacts 3 were determined to be SMALL with the exception of collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel 4 disposal.

February 2010 8 -44 Draft NUREG-1437, Supplement 42

Environmental Impacts of Alternatives 1

8.5 REFERENCES

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6 40 CFR Part 51. Code of Federal Regulations, Title 40, Protectionof Environment, Part 51, 7 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

8 40 CFR Part 81. Code of Federal Regulations, Title 40, Protectionof the Environment, Part 81, 9 "Designation of Areas for Air Quality Planning Purposes."

10 63 FR 49453, Revision of Standards of Performance for Nitrogen Oxide Emissions From New 11 Fossil-Fuel Fired Steam Generating Units. September 16, 1998.

12 64 FR 35714, Regional Haze Regulations. July 1, 1999.

13 American Wind Energy Association (AWEA). 2010. U.S. Wind Energy Projects, New Jersey, 14 Delaware, and Pennsylvania. Available URL:

15 http://www.awea.org/promects/Proiects.aspx?s=New+Jersey (Accessed April 16, 2010).

16 Energy Information Administration (EIA). 2009a. Annual Energy Outlook 2009 With Projections 17 to 2030. DOE/EIA 0383(2009). Washington, D.C. Available URL:

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19 EIA. 2009b. Table A4. Approximate Heat Content of Natural Gas, 1949-2008 (Btu per Cubic 20 Foot). Available URL: http://www.eia.doe.qov/emeu/aer/txt/ltb 1304.html (accessed April 15, 21 2010).

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30 Environmental Protection Agency (EPA). 1998. Compilation of Air PollutantEmission Factors, 31 Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition. "Section 1.1: Bituminous 32 and Subbituminous Coal Combustion: Final Section Supplement E." Washington, D.C.

33 EPA. 2000a. "Regulatory Finding on the Emissions of Hazardous Air Pollutants from Electric 34 Utility Steam Generating Units." FederalRegister, Vol. 65, No. 245, pp. 79825-79831.

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38 EPA. 2000c. Emissions Factors & AP 42. Available URL:

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Draft NUREG-1437, Supplement 42 8-45 February 2010

Environmental Impacts of Alternatives 1 EPA. 2006. Final report: Environmental Footprintsand Costs of Coal-Based Integrated 2 GasificationCombined Cycle and Pulverized Coal Technologies. EPA-430/R-06/006. July, 3 2006. Available URL: http://www.epa..ov/air/caaac/coaltech/2007 01 epaiqcc.pdf (Accessed 4 April 15, 2010).

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12 Geo-Heat Center (GHC). 2008. U.S. Geothermal Projects and Resource Areas. Available 13 URL: http://qeoheat.oit.edu/dusys.htm (Accessed April 16, 2010.

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Draft NUREG-1437, Supplement 42 8-46 February 2010

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2 Applicant's Environmental Report - Operating License Renewal Stage, Hope Creek Generating 3 Station. July 2009. ADAMS Accession No. ML092430389.

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6 Available URL: http://www.pim.com/documents/reports/rtep-report.aspx (Accessed April 16, 7 2010).

8 State of New Jersey. 2006. Blue Ribbon Panel on Development of Wind Turbine Facilitiesin 9 Coastal Waters, Final Report. April 2006. Available URL:

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13 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic EnvironmentalImpact Statement.

14 for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2. Washington, D.C.

15 NRC. 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, 16 Main Report, "Section 6.3 - Transportation, Table 9.1, Summary of Findings on NEPA Issues 17 for License Renewal of Nuclear Power Plants, Final Report." NUREG-1437, Vol. 1, Add. 1.

18 Washington, D.C.

19 NRC. 2002. Generic EnvironmentalImpact Statement on Decommissioning of Nuclear 20 Facilities:Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors. NUREG-21 0586, Supplement 1, Vols. 1 and 2. Washington, D.C.

22 February 2010 8-47 Draft NUREG-1437, Supplement 42

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