L-11-289, License Renewal Application Amendment No. 16, Supplemental Information for the Review of the License Renewal Application Environmental Report

License Renewal Application Amendment No. 16, Supplemental Information for the Review of the License Renewal Application Environmental Report

ML11266A062
Person / Time
Site:	Davis Besse
Issue date:	09/19/2011
From:	Byrd K FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-289, TAC ME4613
Download: ML11266A062 (176)

Text

{{#Wiki_filter:FENOC Davis-Besse Nuclear Power Station S5501 N. State Route 2 FirstEnergyNuclear Operating Company Oak Harbor,Ohio 43449 September 19, 2011 L-1 1-289 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 License Renewal Application Amendment No. 16, Supplemental Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application Environmental Report (TAC No. ME4613) By letter dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS). Amendment 16 to the DBNPS License Renewal Application, which provides updated information for the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application, Appendix E, "Applicant's Environmental Report, Operating License Renewal Stage," Chapters 7 and 8, is provided as Enclosure A. Enclosure B provides a copy of the Amendment that shows the changes in redline (or tracked-changes) format to facilitate NRC review. There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

Davis-Besse Nuclear Power Station, Unit No. 1 L-1 1-289 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on September __, 2011. Sincerely, Kendall W. B Director, Site Performance Improvement Enclosure-: A. Amendment No. 16 to the DBNPS License Renewal Application B. FENOC Annotation of Amendment No. 16 to the DBNPS License Renewal Application to Facilitate NRC Review cc: NRC DLR Project Manager NRC DLR Environmental Project Manager NRC Region III Administrator cc: w/o Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Enclosure A Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) Letter L-11-289 Amendment No. 16 to the DBNPS License Renewal Application 86 Pages (not including this cover page) License Renewal Application Sections Affected Appendix E, Chapter 7 Appendix E, Chapter 8 This Enclosure provides updated information for the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application, Appendix E, "Applicant's Environmental Report, Operating License Renewal Stage," Chapters 7 and 8, that are to be replaced, in their entirety, with the attached.

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.0 ALTERNATIVES TO THE PROPOSED ACTION Regulatory Requirement: 10 CFR 51.45(b)(3) The environmental report shall discuss "Alternatives to the proposed action." [adopted by reference at 10 CFR 51.53(c)(2)]. 7.0.1 OVERVIEW This chapter assesses alternatives to the proposed renewal of the Davis-Besse operating license. It includes discussions of the no-action alternative and alternatives that meet system generating needs. Descriptions are provided in sufficient detail to facilitate comparison of the impacts of the alternatives to those of the proposed action. In considering the level of detail and analysis that it should provide for each category, FENOC relied on the NRC decision-making standard for license renewal:

   ... the NRC staff, adjudicatory officers, and Commission shall determine whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decision makers would be unreasonable.

[10 CFR 51.95(c)(4)] As noted in 10 CFR 51.53(c)(2), a discussion is not required of need for power or economic costs and benefits of the proposed action or of alternatives to the proposed action except insofar as such costs and benefits are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation. Section 7.1 addresses the "no-action" alternative in terms of the potential environmental impacts of not renewing the Davis-Besse operating license, independent of any actions taken to replace or compensate for the loss of generating capacity. Section 7.2 describes feasible alternative actions that could be taken, which FENOC also considers to be elements of the no-action alternative, and presents other alternatives that FENOC does not consider to be reasonable. Section 7.3 presents the environmental impacts for the reasonable alternatives. The environmental impact evaluations of alternatives presented are intended to provide enough information to support NRC decision-making by demonstrating whether an alternative would have a smaller, comparable, or greater enyironmental impact than the proposed action. Additional detail or analysis was not considered useful or necessary if it would identify only additional adverse impacts of license renewal alternatives; i.e., information beyond that necessary for a decision. This approach is consistent with the CEQ regulations, which provide that the consideration of alternatives (including the Alternatives to the Proposed Action Page 7.0-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report proposed action) be adequately addressed so reviewers may evaluate their comparative merits (40 CFR 1502.14(b)). The characterization of environmental impacts in this chapter applies the same definitions of "SMALL," "MODERATE," and "LARGE" used in Chapter 4 of this ER and by the NRC in the GElS (NRC 1996). Chapter 8 presents a summary comparison of environmental impacts of the proposed action and alternatives. 7.0.2 REGION OF INTEREST NRC environmental guidance for siting new reactors defines the "Region of interest" (ROI) as "the geographic area considered in searching for candidate sites." NUREG-1555, at 9.3-1 (1999). That definition is not directly applicable to this license renewal action because Davis-Besse is already sited as an operating reactor in Ohio. The application here is for license renewal, and not for initial plant siting, construction, or operation. However, that same environmental guidance explains that "the basis for an ROI is the State in which the proposed site is located or the relevant service area for the proposed plant." NUREG-1555, at 9.3-2. This explanation, or basis for selecting the ROI for siting new reactors, is applicable for defining the ROI for purposes of license renewal. Accordingly, FENOC is adopting an ROI for this Environmental Report as the State in which Davis-Besse is located: Ohio. The second portion of the explanation in NUREG-1555-"the relevant service area for the proposed plant"-is not applicable to Davis-Besse, because the electricity that Davis-Besse generates is sold on the wholesale power market. Accordingly, there is no "relevant service area" for the plant. September 2011 Page 7.0-2 Alternatives to the Alternatives to Proposed Action the Proposed Action Page 7.0-2 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.1 NO-ACTION ALTERNATIVE FENOC considers the no-action alternative is not to renew the Davis-Besse operating license. With this alternative, FENOC expects Davis-Besse would continue to operate until the expiration of the existing operating license in 2017, at which time plant operations would cease, decommissioning would begin, and FirstEnergy or others would take the appropriate actions to meet system-generating needs created by discontinued operation of the plant. Section 7.1.1 addresses the impacts of terminating operations and decommissioning, whereas Section 7.1.2 discusses the actions to replace power from Davis-Besse. 7.1.1 TERMINATING OPERATIONS AND DECOMMISSIONING In the event the NRC does not renew the Davis-Besse operating license, FENOC assumes for this ER that it would operate the plant until the current license expires, then terminate operations and initiate decommissioning activities in accordance with NRC requirements. For purposes of this discussion, terminating operations includes those actions directly associated with permanent cessation of operations, which may result in more or less immediate environmental impacts (e.g., socioeconomic impacts from reduction in employment and tax revenues). Decommissioning, as defined in the GELS, is the safe removal of a nuclear facility from service and the reduction of residual radioactivity to a level that permits release of the property for unrestricted use and termination of the license (NRC 1996, Section 7.1). The two decommissioning options typically selected for United States reactors are rapid decontamination and dismantlement (DECON), and safe storage of the stabilized and de-fueled facility (SAFSTOR), followed by final decontamination and dismantlement (NRC 1996, Section 7.2.2). Under the DECON option, radioactively contaminated portions of the facility and site are decontaminated or removed promptly after cessation of operations to a level that permits termination of the license; these activities require several years for large light-water reactors like Davis-Besse (NRC 1996, Table 7.8). The SAFSTOR option involves safe storage of the stabilized and defueled facility for a period of time followed by decontamination to levels that permit license termination. Regardless of the option selected, decommissioning typically must be completed within 60 years after operations cease in accordance with NRC requirements at 10 CFR 50.82 (NRC 1996, Section 7.2.2). FENOC has not selected a decommissioning method for Davis-Besse. The decommissioning method for Davis-Besse would be described in post-shutdown decommissioning plans for the plant, which must be submitted to NRC within two years following cessation of operations. For purposes of the present analysis, FENOC assumes that the DECON option would be employed upon license termination. No-action Alternative Page 7.1-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report The NRC presents in Chapter 7 and Section 8.4 of the GElS a summary of generic environmental impacts of the decommissioning process and an evaluation of potential changes in impact that could result from deferring the decommissioning process for up to 20 years (NRC 1996). For a pressurized water reactor decommissioning, NRC used a 1,175 MWe reference reactor. Although larger than Davis-Besse (910 MWe), FENOC considers the reference reactor to be representative of Davis-Besse. As a result, FENOC believes the decommissioning activities described in the GElS to be representative of activities FENOC would perform for decommissioning at Davis-Besse. The NRC concluded from its evaluation that decommissioning impacts would not be significantly greater as a result of the proposed action, assumed to result in 20 additional years of operation (NRC 1996, Sections 7.3 and 8.4). The NRC conclusions also indicate that the impacts of the decommissioning process itself, addressed in this ER as part of the no-action alternative, would have SMALL impacts with respect to radiation dose, waste management, air quality, water quality, and ecological resources (see 10 CFR Part 51, Subpart A, Appendix B, Table B-i). FENOC considers this generic evaluation and associated conclusions applicable to Davis-Besse as well. The NRC has provided additional analysis of the environmental impacts associated with decommissioning in the Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (NRC 2002). Except for issues that require site-specific evaluation, environmental impacts, including radiological releases and doses from decommissioning activities, were assessed to be SMALL (NRC 2002, Sections 4.3 and 6.1). Regardless of the NRC decision on license renewal, FENOC will have to decommission Davis-Besse; license renewal would only postpone decommissioning for an additional 20 years. In the GELS, the NRC concludes that there should be little difference between the environmental impacts from decommissioning at the end of 40 years of operation versus those associated with decommissioning after an additional 20 years of operation under a renewed license (NRC 1996, Section 7.4). By reference, FENOC adopts the NRC findings regarding environmental impacts of decommissioning in the license renewal GElS (NRC 1996) and in the decommissioning GElS (NRC 2002), and concludes that environmental impacts under the no-action alternative would be similar to those that occur following license renewal. Further, FENOC believes that decommissioning activities would not involve significant land-use disturbance offsite or significant activities beyond current operational areas that would offer potential for impacts on land use, ecological resources, or cultural resources. Decommissioning impacts would be temporary and occur at the same time as those associated with the operation of replacement generating sources. No-action Alternative Page 7.1-2 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.1.2 REPLACEMENT CAPACITY Davis-Besse is a base-load generator of electric power, with a net generating capability of 908 MWe (Section 3.1.2). In 2008, Davis-Besse generated approximately 8.3% of FirstEnergy's total base-load electricity generation (FirstEnergy 2008a, Page 7; USDOE 2010). The power produced by Davis-Besse, which represents a significant portion of the electricity FirstEnergy supplies to 2.1 million customers in its service territories located in Ohio (FirstEnergy 2009a, Page 81), would be unavailable in the event the Davis-Besse operating license is not renewed. As provided in 10 CFR 51.53(c)(2), FENOC does not consider the need for power from Davis-Besse in this analysis, but does consider the potential impact of alternatives for replacing this power. Replacement options considered include building new base-load generating capacity, purchasing power, delaying retirement of non-nuclear assets, and reducing power requirements through demand reduction, as discussed in Section 7.2. September 2011 Alternative Page 7.1-3 Page 7.1-3 September 2011 No-action Alternative

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report [This page intentionally blank] No-action Alternative Page 7.1-4 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.2 ALTERNATIVES THAT MEET SYSTEM GENERATING NEEDS Ifthe Davis-Besse operating license is not renewed, then the State of Ohio, FirstEnergy Corp. and its subsidiary companies, and other participants in the wholesale power market would lose approximately 910 MWe* of base-load capacity. Renewal would preserve the option of relying on Davis-Besse to meet future electric power needs through the period of extended operation. While many methods are available to generate electricity, the GElS indicates that a "reasonable set of alternatives should be limited to analysis of single, discrete electric generation sources and only electric generation sources that are technically feasible and commercially viable" (NRC 1996, Section 8.1). Considering that Davis-Besse serves as a large base-load generator, FENOC considers reasonable alternatives to be those that would also be able to generate base-load power. FENOC believes that any alternative would be unreasonable if it did not consider replacement of the energy resource. 7.2.1 ALTERNATIVES CONSIDERED AS REASONABLE Fossil-Fuel Alternatives Summary FENOC believes that coal-fired and gas-fired generation capacity are feasible alternatives to nuclear power generating capacity, based on current (and expected) technological and cost factors, as compared to the other alternatives listed in the GElS (NRC 1996, Section 8.1). FENOC considers the coal-fired and gas-fired technologies reasonable alternatives for purposes of this analysis to replace Davis-Besse generating capacity in the event its operating license is not renewed. The GElS further notes that natural gas combined-cycle plants are particularly efficient and are used as base-load facilities (NRC 1996, Section 8.3.10). The specific coal-generating technologies that would represent viable alternatives are less certain, particularly in view of potentially higher air emissions compared to natural gas firing. For example, large-capacity integrated gasification combined-cycle (IGCC) and fluidized-bed-combustion (FBC) technologies (atmospheric and pressurized) are at or near commercial viability and could prove to be appropriate replacements. However, modern pulverized coal plants with advanced, clean-coal technology air emission controls represent currently proven technology and are economically competitive and commercially available in large-capacity unit sizes that could effectively replace Davis-Besse. Therefore, FENOC uses a representative plant of this type for purposes of impact evaluation, noting that air emission impacts of IGCC and FBC options may be lower than modern pulverized coal, but would be higher than the gas-fired combined-cycle alternative (USDOE 1999, Pages 5-7). "910 MWe is used for calculation convenience instead of 908 Mwe, as noted in Section 3.1.2. Alternatives that Meet System Page 7.2-1 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Renewable Energy Alternatives Summary On April 26, 2011, an NRC Atomic Safety and Licensing Board (Board) presiding over the license renewal proceeding for Davis-Besse issued a Memorandum and Order (LBP-1 1-13) admitting a contention alleging that the FENOC analysis of renewable energy alternatives in the Environmental Report was not adequate. As admitted by the Board, the contention states: [FENOC's ER] fails to adequately evaluate the full potential for renewable energy sources, specifically wind power in the form of interconnected wind farms and/or solar photovoltaic power, in combination with compressed air energy storage, to offset the loss of energy production from Davis-Besse, and to make the requested license renewal action unnecessary. The FENOC Environmental Report (Section 7.2) treats all of the alternatives to license renewal except for natural gas and coal plants as unreasonable and does not provide a substantial analysis of the potential for significant alternatives in the Region of Interest. The Board's phrasing of the contention, as admitted, arguably includes the following renewable energy alternatives: 1) wind power in the form of interconnected wind farms;

2) wind power in the form of interconnected wind farms with compressed air energy storage (CAES); 3) solar (photovoltaic) power combined with CAES; or 4) a combination of interconnected wind farms and solar (photovoltaic) power with CAES.

FENOC does not believe that any of these are "reasonable" alternatives under NEPA. However, in order to resolve the issues raised in the admitted contention, FENOC has revised this ER to evaluate the renewable energy alternatives listed above as an alternative to replace the rated electrical output of Davis-Besse by 2017. FENOC considers the other technologies listed in the GElS as not reasonable alternatives for the reasons discussed in Section 7.2.2. Disclaimer Throughout Chapters 7 & 8, FENOC presents information about renewable energy resources compiled by others. FENOC has not independently confirmed the accuracy of these statements, nor does FENOC agree with them. Additionally, FENOC does not agree that the renewable energy alternatives listed above can provide base-load generation or that the existing and any interstate transmission system available by 2017 could accommodate such renewable energy. Finally, even if such a group of renewable resources were built, there is no way to assure that the power generated by those resources would be available to the CAES facility to create the alternative that Joint Petitioners envision. There are a number of Alternatives that Meet System Page 7.2-2 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report considerations for the development of a solar or wind resource including the availability of sufficient sun or wind, the availability of land, grid access, cost of interconnection (which may be economically prohibitive in some cases), and sufficient transmission resources to assure the CAES's ability to interact with the resource. The NRC has noted that, while there are many methods available for generating electricity and many combinations of alternative power generation sources that could provide base-load capacity, such an expansive consideration of alternatives would be too unwieldy (NRC 1996, Section 8.1). 7.2.1.1 Coal-Fired Generation For purposes of this analysis, FENOC assumed development of a modern pulverized coal-fired power plant with state-of-the-art emission controls similar to that described in its license renewal application, Appendix E (Environmental Report), for the Beaver Valley Power Station (FENOC 2007, Section 7.2.2.2). In defining the Davis-Besse coal-fired alternative, FENOC has used site-specific input as appropriate. The representative plant would consist of commercially available standard-sized units, with a nominal net output of approximately 910 MWe, and would be designed to meet applicable standards with respect to control of air and wastewater emissions. As a minimum, FENOC assumed that the plant would feature low nitrogen oxide burners with overfire air to minimize formation of nitrogen oxides, and selective catalytic reduction for post-combustion nitrogen oxide control. Emissions of particulate matter and mercury would be limited by use of a fabric filter (baghouse), and sulfur oxide emissions would be controlled using a wet scrubber using limestone as the reagent. Table 7.2-1 lists the basic specifications for the representative plant. The Davis-Besse site would not be a viable location for the representative plant as a result of space limitations (see Section 7.3.1, Land Use). Land area requirements for a coal-fired plant of similar capacity to Davis-Besse would be approximately 1.7 acres per MWe (NRC 1996, Section 8.3.9), or 1,547 acres for a 910 MWe plant. The needed land area, therefore, far exceeds the 954-acre Davis-Besse site, most of which is occupied by marshland that is leased to the U.S. Government as a national wildlife refuge (Section 2.1). Therefore, FENOC assumed for the analysis that the representative coal-fired plant would be located elsewhere at a greenfield or (preferably) brownfield site close to a commercially, navigable waterway or existing railway. A navigable waterway location would be highly desirable from a technical and economic perspective, considering the relative abundance of cooling water and low fuel cost afforded by barge transportation of coal and limestone. FENOC further assumed for the analysis that the representative coal-fired plant would use closed-cycle cooling with a natural draft cooling tower. Alternatives that Meet System Page 7.2-3 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Lastly, FENOC assumed for the analysis that the environmental impacts associated with siting, design, and operation of the plant would be subject to comprehensive review under Ohio Power Siting Board (OPSB) rules or a comparable process. 7.2.1.2 Gas-Fired Generation For purposes of this analysis, FENOC assumed development of a modern natural gas-fired combined-cycle plant based on a commercially available design similar to that described in its license renewal application, Appendix E (Environmental Report), for the Beaver Valley Power Station (FENOC 2007, Section 7.2.2.1). In defining the Davis-Besse gas-fired alternative, FENOC has used site-specific input as appropriate. The representative plant would consist of commercially available standard-sized units, with a nominal net output of approximately 910 MWe, and would be designed to meet applicable standards with respect to control of air and wastewater emissions. As a minimum, FENOC assumed that the plant would use natural gas as its only fuel and feature dry low-NOx burners to minimize formation of nitrogen oxides during combustion and selective catalytic reduction for post-combustion nitrogen oxide control. Emissions of particulate matter and carbon monoxide would be limited through proper combustion controls. Table 7.2-2 lists the basic specifications for the representative plant. The Davis-Besse site is uncertain as a viable location for the representative plant due to space limitations. Land area requirements for a gas-fired plant of similar capacity to Davis-Besse, for example, would be approximately 0.11 acres per MWe (NRC 1996, Table 8.1), or 100 for a 910 MWe plant. Of the 954 acres of land occupied by the Davis-Besse site, 733 acres is occupied by marshland that is leased to the U.S. Government as a national wildlife refuge (Section 2.1). The remaining 221 acres is mostly occupied by Davis-Besse structures. Therefore, FENOC assumed for the analysis that the representative gas-fired plant would be located elsewhere at a greenfield or (preferably) brownfield site, but has not identified a specific site. However, primary considerations for a cost-competitive site include close proximity to adequate natural gas supply, transmission infrastructure, cooling water, and sufficient land suitable for development. For this analysis, FENOC assumed, based on FirstEnergy experience in gas-fired plant siting, that northwestern Ohio would be a realistic general area to locate the new plant (FENOC 2007, Section 7.2.2.1). FENOC further assumed for the analysis that the representative gas-fired plant would use closed-cycle cooling with mechanical draft cooling towers. Lastly, FENOC assumed for the analysis that the environmental impacts associated with siting, design, and operation of the plant would be subject to comprehensive review under Ohio Power Siting Board (OPSB) rules or a comparable process. Alternatives that Meet System Page 7.2-4 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.2.1.3 Renewable Energy Generation As explained above in Section 7.2.1, and subject to the disclaimers in that Section, FENOC is evaluating for the sole purpose of this NEPA analysis certain renewable energy alternatives. These alternatives are discussed in more detail below. Other renewable energy alternatives were rejected for the reasons explained below in Section 7.2.2. Interconnected Wind Farms Wind energy facilities use wind turbines to harness the kinetic energy of wind and transform it into electrical power. Output depends on a turbine's size and the wind's speed through the rotor as well as the availability of wind itself. Wind turbines manufactured today range from 250 watts (AWEA 2002) to 10 megawatts (MW) (SWAY 2010), and wind farms can range in capacity from a few megawatts to the 781+ megawatt Roscoe Wind Complex in Texas. (CBS 2010) Wind availability, speed and turbine height are critical factors for wind farm generating capacity. The stronger and more consistent the wind, and the taller the turbines, the higher potential capacity exists. Multiple land uses are often possible on wind farms. For example, a wind farm may generate electricity while cattle graze or corn grows on the land surrounding the turbines. (AWEA 2002) Neither a single wind turbine nor interconnected wind farms currently provide baseload power anywhere in the United States. However, the theory that multiple wind farms located throughout a region and interconnected via the grid could provide for more consistent power generation due to the reduced likelihood that all sites would experience the same wind patterns at any given time, has been studied. In one study, the benefits of interconnecting wind farms were evaluated for 19 sites located in the midwestern United States with annual average wind speeds greater than 6.9 meters per second (m/s) (class 3 or greater) at 80 m above ground, the hub height of modern wind turbines. The study reported that, on average, only 33% and a maximum of 47% of yearly-averaged wind power from interconnected wind farms could theoretically be relied upon to produce electricity. And there were days when no electricity was produced from these wind farms. (JACM 2007) Additionally, delays in the implementation of interconnected wind technology can be due to transmission line construction difficulties, as the North American Electric Reliability Corporation (NERC) explains in its 2009 Long-Term Reliability Assessment. The NERC points out that siting of new bulk power transmission lines brings with it unique challenges due to the high visibility, their span through multiple states/provinces and, potentially, the amount of coordination/cooperation required among multiple regulating agencies and authorities. Lack of consistent and agreed-upon cost allocation Alternatives that Meet System Page 7.2-5 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report approaches, coupled with public opposition due to land-use and property valuation concerns, have, at times, resulted in long delays in transmission line construction. New transmission, including transmission in the DOE's designated "National Interest Electric Transmission Corridors" can be delayed or halted by individual states, increasing the difficulty to site bulk transmission, including those projects focused on unlocking location-constrained renewable generation. These siting issues create a potential congestion issue and challenge the economic viability of new generation projects. (NERC 2009) In the specific case of wind power, a wind project must be located where it would produce economical generation, and that location may be far removed from the nearest possible connection to the transmission system. A location far removed from the power transmission grid might not be economical, as new transmission lines would be required to connect the wind farm to the distribution system, and the question of who pays for the transmission upgrade would be at issue. Existing transmission infrastructure may need to be upgraded to handle the additional supply. Soil conditions and the terrain must be suitable for the construction of the towers' foundations. Finally, the choice of a location may be limited by land use regulations and the ability to obtain the required permits from local, regional, and national authorities. Jacobs and Archer completed a study of interconnected wind farms with consisting of up to 19 wind farm sites, and concluded that maximum capacity factors of approximately 45% could theoretically be obtained (JACM 2007). Davis-Besse's recent capacity factor has been in excess of 90%, which would generate approximately 7,158,672 MWh over a full year. To achieve a similar annual average at a 45% capacity factor, interconnected wind farms with a minimum of 1210 GE 1.5 MW turbines would be required, and would not be guaranteed due to the uncontrollability of the wind availability. It must be noted, however, that the studies by Jacobs and Archer were based on areas with higher annual average wind speeds (over 8 m/s). Thus, in Ohio, it would be expected that the GE 1.5-MW turbines might not operate as efficiently and thus the number of turbines required for replacement power generation would be higher. And there would still be times when reserve capacity from traditional generation or energy storage would be required. Using larger turbines could be used if wind speeds supported their economical use, especially in offshore locations (discussed below), which would reduce land use. Since 1998-99, average turbine nameplate capacity has increased by 151%, but growth in this metric has slowed in recent years due to the dominance of GE's 1.5 MW turbine and as a result of the logistical challenges associated with transporting larger turbines to project sites. (USDOE 2011) There are several land based wind farms under construction or planned in Ohio. These wind farms will utilize wind turbines ranging from 1.8 MW (Timber Ridge Wind Farm) to 2.0 MW (Blue Creek Wind Farm). (WAG 2011 and TBM 2011) Alternatives that Meet System Page 7.2-6 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC reviewed several recent documents describing studies conducted by the National Renewable Energy Laboratory (NREL) related to wind integration and transmission studies for both land-based and offshore wind generating facilities (NREL 2011, NREL 2010, NREL 2010a). Based on the findings in these documents, a land-based interconnected transmission system in the central and eastern United States is likely to be completed by 2024. For the sole purpose of this NEPA analysis, however, FENOC evaluates renewable energy alternatives as if an interconnected grid system would be available by 2017. FENOC also evaluated the potential for offshore wind generation and integrating that power into the transmission system. Although both Lake Erie and Lake Michigan have significant wind resources, no offshore wind turbines have been sited in freshwater, particularly a potable water source such as the Great Lakes. (USDOE 2011) Offshore wind power project and policy developments continued in 2010; however, to date no offshore projects have been installed in the United States and the emergence of an offshore wind power market still faces many challenges. Nonetheless, interest exists in developing offshore wind energy in several parts of the country, with nine projects totaling 2322 MW of unstated capacity factors primarily located in the Northeast and Mid-Atlantic, though proposed projects also exist in the Great Lakes and Gulf of Mexico. (USDOE 2011) Many of these projects have advanced significantly in the permitting and development process, including three that have signed power purchase agreements with terms and details that have been made public. Notably, the Cape Wind project was granted approval by the Department of Interior in 2010; several significant strides relating to offshore wind energy have been made recently in the federal arena; and a variety of other recent project and state policy announcements demonstrate continued activity in the offshore wind energy sector. (USDOE 2011) In August 2009, Lake Erie Energy Development Corporation (LEEDCo) was created by the Great Lakes Energy Development Task Force (GLEDTF), then developed and launched by NorTech Energy Enterprise, the Cleveland Foundation, City of Cleveland, Cuyahoga and Lorain Counties (Ohio). It was founded as a private, non-profit regional corporation to initially build wind turbines in Lake Erie, and eventually help stimulate an entire offshore freshwater wind industry. Initially LEEDCo plans to build and install a 20-30 megawatt (MW) wind energy pilot project seven miles offshore of downtown Cleveland which would be the first offshore freshwater wind energy project in North America. LEEDco then plans to use the initial project as a road map to develop the permitting process and catalyze future offshore wind projects by commissioning the first 20-to-30 MW, five-to-seven turbines by 2013, with a long-term vision of generating 1000 MW of wind energy by 2020. (LEEDCo 2011) Despite the unlikely development of sufficient offshore wind generation as outlined above, FENOC evaluates-for the sole purpose of this NEPA analysis-wind energy Alternatives that Meet System Page 7.2-7 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report from interconnected wind farms as if such energy was available by 2017. Therefore, FENOC evaluated the potential environmental impacts for offshore wind generation and integrating that power into the transmission system as a replacement for Davis-Besse's rated electrical output. Solar Farms Electric power generation from photovoltaic (PV) cells has been commercially demonstrated. However, because the sun only shines during the day, solar PV arrays cannot by themselves consistently produce electricity. There is currently only one operational solar energy facility in Ohio greater than 10 MW-the 12-MWe Wyandot Solar Farm in Upper Sandusky, OH (PSEG 2010). The 49.9 MWe Turning Point Solar project near Cumberland, OH, is projected to be completed in 2015 (AEP 2011). FENOC is not aware of other planned solar energy facilities greater than 10 MW in Ohio that would be operational by 2017, and whose output is not already dedicated to an existing commercial or industrial facility. A solar project would have to be located where the project would produce economical generation, and that location may be far removed from the nearest possible connection to the transmission system. A location far removed from the power transmission grid might require construction of new transmission lines to connect the solar farm to the distribution system, and the question of who pays for the transmission upgrade would be at issue. Existing transmission infrastructure may need to be upgraded to handle the additional supply. Soil conditions and the terrain must be suitable for the construction of the solar farms. Finally, the choice of a location may be limited by land use regulations and the ability to obtain the required permits from local, regional, and national authorities. Although solar resources are limited in Ohio, FENOC evaluates-for the sole purpose of this NEPA analysis-solar energy combined with CAES, and combined with interconnected wind farms and CAES, as alternatives to replace the rated electrical output of Davis-Besse by 2017. Compressed Air Energy Storage FENOC is presenting the following information about CAES technology as background for the discussion that follows about CAES combined with interconnected wind farms or solar energy facilities. CAES can be linked with renewable energy by offering one way to supplement and back-up the electricity produced by intermittent resources such as wind and solar. This energy storage method enhances the ability of these resources to provide the electricity that customer's need, when they need it. Alternatives that Meet System Page 7.2-8 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report However, CAES facilities are generally operated as peaking plants with energy placed into storage during the less expensive, non-peak demand hours and generated from the storage units during the higher-priced, peak demand hours. CAES involves using compressors powered by the generation source to pump air into a storage facility, such as an underground cavern. During peak demand hours, the compressed air is used in combination with a heat source, such as natural gas, to drive turbines and generate electricity. To generate electricity from CAES, natural gas usage is between one-third and one-half that needed to generate the same amount of electricity at a natural gas generating plant (USDOE 2009). Due to the cost differential between peak and non-peak hours and the reduction in the volume of natural gas used to generate a specific amount of power, a CAES facility can be an economically and environmentally attractive method of producing peaking power (RES 2005; PEI 2008). These economic benefits evaporate if the energy source used to pump air into the storage facility is solar power, or wind power available during the day. Since solar is a resource mostly available during the onpeak daytime hours, storage offers little economic benefit when evaluating solar (or daytime wind power) with CAES. FENOC is not aware of any existing CAES facilities that are combined solely with wind or solar power. The Iowa Stored Energy Park (ISEP) was proposed to be a 270 MW CAES facility integrated with a wind farm in Iowa. However, testing and analysis of the site geology concluded that the ability to store the air underground at the ISEP site near Dallas Center, Iowa was unfeasible. (ISEP 2011) Two CAES facilities combined with natural gas power plants, a 110-MW facility in Alabama and a 290-MW plant in Germany, have been built and are in operation (PEI 2008). A CAES facility powered with energy from generation facilities already on the power grid is proposed for Norton, Ohio. This facility, which is still in the project development stage, is planned to eventually-i.e., after 2017-provide 2700 MW of peaking power generation (PEI 2008). The Norton CAES project is somewhat different from the other CAES projects in that a pre-existing mine on a brownfield site would be utilized. The size and the mining engineered construction of the pre-existing mine allows a much greater planned capacity for the Norton facility as compared to other existing or proposed CAES projects. Norton Energy Storage In 2009, FirstEnergy Generation Corp., a subsidiary of FirstEnergy Corp., purchased the rights to develop the Norton Energy Storage (NES) facility. The facility is located on a 92-acre site in Norton, Ohio. The compressed air would be stored in a 600-acre underground cavern, formerly operated as a limestone mine, which is ideal for energy storage technology. The facility would generate electricity during on-peak and intermediate periods, which would enable the more efficient operation of large, base-Alternatives that Meet System Page 7.2-9 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report load power plants. FirstEnergy is currently developing the NES facility and it would be constructed in phases. The initial phase is designed to produce 268 MW of generation, 220 MW of compression, and 373 hours of storage using two 134 MW generators. FirstEnergy estimates that up to four units or 536 MW of generation could be online by 2017. The existing air permit for the NES facility authorizes FirstEnergy Generation Corp to expand the facility to a capacity of 804 MW (see Table 7.2-3). (NES 2010) This project has two major components: the above-ground equipment and the subsurface abandoned limestone mine used to store compressed air. The size of the cavern could eventually allow the project to provide up to 2700 MW of generation if the current air permit could be modified. The NES facility would include two power generation units designed specifically for the CAES application. Each unit would consist of an air compressor, a motor, an expander, an associated combustor and a generator. The facility would be designed to operate on natural gas only; no fuel oil would be combusted in the turbines or in-line burners. The major ancillary support equipment would consist of an emergency generator, a backup diesel fire pump, and wet cooling towers to cool compressor air to be injected into storage and provide other equipment cooling. Other support equipment would include cooling water treatment systems, acid/caustic or neutralization tanks, instrument air compressors, electric driven fuel compressors, sumps, and oil/water separators. Available Alternatives for Renewable Energy Generation in Combination with Energy Storage The potential for using renewable power sources as an alternative to license renewal can be enhanced if the generation source is combined with an energy storage technology, thus increasing the availability, reliability, and predictability of the delivery of power. The two renewable power generation sources evaluated in this ER are interconnected wind farms and photovoltaic solar facilities. The theory behind the combination of renewable power generation with energy storage is that when the generation capacity is available, the amount of power produced could, at times, exceed the demand for power at that time. Excess energy could be stored and returned later to the electrical grid when the renewable power generation resource is either not available or is available at a diminished level that is insufficient to satisfy the demand for power. Therefore, in order for this combination of technologies to function, the renewable energy source would have to be sized larger than the base-load power level in this case for Davis-Besse, 910 MW. The need to have generation capacity greater than base-load requirements in order to place energy into storage would cause greater environmental impacts than a generation source rated at the base-load value alone. For example, a solar or wind generation source assumed to be available for 12 hours Alternatives that Meet System Page 7.2-10 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report every day, and a CAES facility assumed to be available to generate electricity the remaining 12 hours in the day, would require that generation source to be rated at, and consistently produce 1820 MW in order to provide 24-hours of continuous electricity (i.e., 12 hours to provide 910 MW of generation onto the grid, and the same 12 hours to provide 910 MW to recharge the CAES facility, so that the CAES facility could feed the grid the remainder of the day). As explained in Section 7.2.1, FENOC evaluates-for the sole purpose of this NEPA analysis-renewable energy sources combined with energy storage as an alternative to replace the rated electrical output of Davis-Besse. Wind Energy Generation Combined with CAES As of 2011, there is currently 11 MWe of wind generation in Ohio with another 406 MWe under construction. (AWEA 2011) However, Ohio has a potential wind generation capacity of nearly 55,000 MW according to the NREL (AWEA 2011 and NREL 2011a), which at a 30% capacity factor would be more than sufficient to provide power to operate a CAES facility. The 30% capacity factor is derived from PJM Interconnection (a regional transmission organization) and the U.S. Department of Energy (USDOE) (PJM 2011 and USDOE 2011. The environmental impacts of developing this type of generation alternative are evaluated in Section 7.3.3. For this combination, FENOC evaluated wind energy generating electricity for both 910 MW to replace Davis-Besse's rated output and 910 MW of storage capacity, for a total of 1820 MWe. Sufficient energy must be put into storage when the wind resources are available to account for the lack of power generation capabilities for the periods of time when adequate wind resources are unavailable. Under this alternative, natural gas would be needed to recover the energy captured in the CAES process, but would not be used as a source of supplemental power generation if wind generation or generation from the storage facility is not available for extended periods of time. Photovoltaic Power Combined with CAES As stated previously, there is currently only one operational solar energy facility in Ohio greater than 10 MW: the 12-MWe Wyandot Solar Farm in Upper Sandusky, OH. (PSEG 2010) The 49.9-MWe Turning Point Solar project near Cumberland, OH, is projected to be completed in 2015. (AEP 2011) FENOC is not aware of other planned solar energy facilities greater than 10 MW in Ohio that would be operational by 2017, and whose output is not already dedicated to an existing commercial or industrial facility. As with wind, FENOC evaluated solar farms as if they were interconnected with CAES to provide electricity to the grid. Alternatives that Meet System Page 7.2-11 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Combinations of Wind and Solar with CAES As referenced above, approximately 1820 MWe of base-load power would be required from renewable energy generation plus storage to account for the lack of power generation capabilities for the periods of time when adequate wind and solar resources are unavailable. FENOC evaluates-for the sole purpose of this NEPA analysis-the following a combined alternative to replace the rated electrical output of Davis-Besse by 2017: sufficient interconnected wind farms and solar (PV) facilities available with high reliability, and connected to an operating CAES facility; an operating CAES facility expanded to a capacity similar to Davis-Besse; and an interconnected grid system. The potential environmental impacts related to this scenario are presented in Section 7.3.3.3. 7.2.2 ALTERNATIVES CONSIDERED AS NOT REASONABLE The following alternatives were considered as not reasonable replacement base-load power generation for one or more reasons as listed in Section 7.2.2.1 and Section 7.2.2.2. Although several of the alternatives could be considered in combination for replacement power generation at multiple sites, they do not generally provide base-load generation, and would entail greater environmental impacts. 7.2.2.1 Alternatives Not Requiring New Generating Capacity This section discusses the economic and technical feasibility of supplying replacement energy without constructing new base-load generating capacity. Specific alternatives include:

• Conservation measures (including implementing demand side management (DSM) actions);

" Delayed retirement of existing non-nuclear plants; and " Purchased power from other utilities equivalent to the output of Davis-Besse (i.e., eliminating the need for license renewal). Conservation Programs There is a variety of conservation technologies (e.g., DSM) that could be considered as potential alternatives to generating electricity at Davis-Besse. Examples include:

• Conservation Programs-homeowner agreements to limit energy consumption; educational programs that encourage the wise use of electricity.

Alternatives that Meet System Page 7.2-12 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report " Energy Efficiency Programs- discounted residential rates for homes that meet specific energy efficiency standards; programs providing residential energy audits and encouraging efficiency upgrades; incentive programs used to encourage customers to replace older inefficient appliances or equipment with newer versions that are more efficient.

• Load Management Programs - programs that encourage customers to switch load to customer-owned standby generators during periods of peak demand; programs that encourage customers to allow a portion of their load to be interrupted during periods of peak demand.

On a national basis, DSM has shown great potential in reducing peak demand (maximum power requirement of a system at a given time). In 2008, a peak load reduction of 32,741 MWe was achieved nationally, which is an increase of 8.2% from 2007; however, since these DSM costs increased by 47.4%. DSM costs can vary significantly from year to year because of business cycle fluctuations and regulatory changes. Since costs are reported as they occur, while program effects may appear in future years, DSM costs and effects may not always show a direct relationship. Since 2003, nominal DSM expenditures have increased at 22.9% average annual growth rate. During the same period, actual peak load reductions have grown at a 6.2% average annual rate from, 22,904 MW to 32,741 MW (EIA 2010, Page 9). In Ohio, as part of Senate Bill 221, utilities must implement energy efficiency programs that, beginning in 2009, achieve energy savings of at least 0.3% of the utility's three-year average annual kilowatt-hour (kWh) sales, with energy savings increasing to 22.5% by the end of 2025. Peak demand reductions of 1% in 2009 and increasing to 7.75% by the end of 2018 are also required. (FirstEnergy 2009a, Page 100) However, since these DSM-induced load reductions typically are considered in load forecasts, the reductions do not offset the projected power demands that are expected to be supplied with the power generated by Davis-Besse. Although FENOC believes that energy generation savings can increase from DSM practices, it would be unrealistic to increase those energy savings to completely and consistently replace the Davis-Besse generating capability. The variability in associated costs also makes DSM a less desirable option. Consequently, FENOC does not see DSM as a practicable offset for the base-load capacity of Davis-Besse. Delayed Retirement Extending the lives of existing non-nuclear generating plants beyond the time they were originally scheduled to be retired, as described in the GElS (NRC 1996, Section 8.3.13), does not represent a realistic option with respect to FirstEnergy's generating assets. Alternatives that Meet System Page 7.2-13 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Approximately 56% of FirstEnergy's generating capacity consists of coal-fired plants which, due to a lower cost of generation, are used at capacity factors higher than other fossil-fuel generating units (FirstEnergy 2008b). Virtually all of FirstEnergy's non-nuclear base-load generating capability is from coal firing. These coal-fired plants were developed in the 1980s or earlier and represent the only plants in FirstEnergy's portfolio that would have any potential for continued operation to replace the base-load generation represented by Davis-Besse. However, older plants that do become candidates for retirement generally represent less efficient generation and pollution control technologies than are available in more modern plants, and continued operation typically would require substantial upgrades to be economically competitive and meet applicable environmental standards. In many cases, it is unlikely that such upgrades would be economically viable. FENOC believes that the environmental impacts of implementing such upgrades and operating the upgraded plants are bounded by the assessments presented in Section 7.3 for the gas-fired and coal-fired alternatives. For these reasons, the delayed retirement of non-nuclear generating units is not considered by FENOC as a reasonable alternative to the renewal of Davis-Besse's license. Purchased Power Each of the states (Ohio, Pennsylvania, and New Jersey) in which FirstEnergy serves load have undertaken electric industry restructuring initiatives that promote competition in retail energy markets by allowing participation of non-utility suppliers. Retail customers historically served by the regulated operating subsidiaries of FirstEnergy now have the option to choose between FirstEnergy-affiliated suppliers and other state-qualified energy suppliers. (FENOC 2007, Section 7.2.3.2) In theory, purchased power is a feasible alternative to Davis-Besse license renewal. There is no assurance, however, that sufficient capacity or energy would be available during the entire license renewal time frame to replace the approximately 910 MWe of base-load generation. In addition, even if power to replace Davis-Besse capacity were to be purchased, FENOC assumes that the generating technology used to produce the purchased power would be one of those described in the GELS. Thus, the environmental impacts of purchased power would still occur, but would be located elsewhere within the region. As a result, FENOC has determined that purchased power would not be a reasonable alternative to replace power lost in the event the Davis-Besse operating license is not renewed. Alternatives that Meet System Page 7.2-14 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.2.2.2 Alternatives Requiring New Generating Capacity The following conventional power plant types are evaluated in this section as potential alternatives to license renewal:

• New Nuclear Reactor
• Petroleum Liquids (Oil)

In addition, with the passage of Ohio's Senate Bill 221 in 2008, at least 25% of electricity supply for retail customers must come from renewable and advanced energy resources by 2025 OHPUCO 2009, Pages 3 and 4). Accordingly, the following alternative energy sources are evaluated. " Hydropower " Solar

• Geothermal
• Biomass (Wood Waste)
• Municipal Solid Waste
• Other Biomass-Derived Fuels (Energy Crops)
• Fuel Cells Criteria used to determine if the potential energy alternatives represent a reasonable alternative include whether the alternative is developed and proven, can provide generation of approximately 910 MWe of electricity as a base-load supply, is economically feasible, and does not impact the environment more than Davis-Besse.

New Nuclear Reactor Increased interest in the development of advanced reactor technology has been expressed by members of both industry and government. With energy demands forecasted to increase and public opposition to new carbon-fueled power plants, some companies are pursuing permits and licenses to build and operate new nuclear reactors to meet the country's future energy needs. As of June 2010, for example, 18 applications, for 28 units, for combined licenses have been submitted to the NRC for review (NRC 2010). Nonetheless, there is ongoing uncertainty with respect to future electric demand due to the potential impacts of policy changes that could be enacted to limit or reduce greenhouse gas emissions. The downturn in the world economy also has had a significant impact on energy demand as well. The recovery of the world's financial markets is especially important for the energy supply outlook, because the capital-intensive nature of most large energy projects makes access to financing a critical necessity. (EIA 2010, Pages 5). Moreover, the economics of new nuclear plants Alternatives that Meet System Page 7.2-15 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report remain uncertain with escalating fuel and construction costs emerging as forces which could affect this option. In consideration of the extended schedule for construction of a new nuclear reactor, access to capital, and the schedule for the new reactor licensing process, construction of a new nuclear reactor at the Davis-Besse site or at an alternative site is not feasible prior to the period of extended operation for Davis-Besse, i.e., in this case, 2017. Therefore, a new nuclear reactor is not considered a reasonable alternative to renewal of Davis-Besse's operating license.. Petroleum Liquids (Oil) Oil-fired generation has experienced a significant decline since the early 1970s. Increases in world oil prices have forced utilities to use less expensive fuels (NRC 1996, Section 8.3.11). From 2002 to 2008, for example, the average cost of petroleum for power generation increased by more than a factor of three (EIA 2010, Table 3.5). This high cost of oil has prompted a steady decline in its use for electricity generation. Within Ohio, for example, oil-fired units produce only 0.2% of power generation (NEI 2008). Increasing domestic concerns over oil security also will intensify the move away from oil-fired electricity generation. Therefore, FENOC does not consider oil-fired generation a viable alternative to renewal of Davis-Besse's operating license. Hydropower Considering the FirstEnergy transmission and distribution territory, Ohio and Pennsylvania have a combined potential for 1,758 MWe of additional undeveloped hydroelectric capacity, with Ohio contributing 57 MWe (INEEL 1998, Table 4). Thus, hydropower is a feasible alternative to Davis-Besse license renewal in theory. However, as noted in the GElS, hydropower's percentage of United States generating capacity is expected to decline because the facilities have become difficult to site as a result of public concern about flooding, destruction of natural habitat, and alteration of natural river courses (NRC 1996, Section 8.3.4). For example, the GElS estimated that land requirements for hydroelectric power are approximately 1 million acres per 1,000 MWe. Replacement of the Davis-Besse generating capacity would therefore require flooding a substantial amount of land (910,000 acres). Consequently, even if the capacity for development were available in Ohio-Pennsylvania, there would be large land-use and related environmental and ecological resource impacts associated with siting hydroelectric facilities large enough to replace Davis-Besse. Alternatives that Meet System Page 7.2-16 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report As a result, developing a hydropower base-load capacity of approximately 910 MWe is not considered by FENOC to be a reasonable alternative to renewal of Davis-Besse's operating license. Solar Power Solar power technologies, both thermal and photovoltaic (PV), have been commercially demonstrated. However, because the sun only shines during the day, solar arrays cannot, by themselves, provide consistent electrical output. Therefore, solar arrays alone are not considered in this ER as a reasonable alternative to the license renewal of Davis-Besse. Solar energy in combination with interconnected wind farms and CAES is discussed in Section 7.2.1.3. Geothermal Energqy Geothermal energy has an average capacity factor of 90 percent and can be used for base-load power where available (NRC 2009b Section 8.2.5.5). However, geothermal electric generation is limited by the geographical availability of geothermal resources. As illustrated by Figure 8.4 in the GELS, no feasible eastern location for geothermal capacity exists to serve as an alternative to Davis-Besse (NRC 1996, Section 8.3.5). As a result, FENOC does not consider geothermal energy to be a reasonable alternative to renewal of the Davis-Besse operating license. Biomass Energy Biomass is any organic material made from plants or animals. Agricultural and wood wastes such as forestry residues, particularly paper mill residues, are the most common biomass resources used for generating electricity. Regionally, eastern Ohio and most of Pennsylvania provide the largest biomass resources (EERE 2009a, b). The costs of these fuels, however, are highly variable and very site specific (NRC 1996, Section 8.3.6). Most biomass plants use direct-fired systems by burning biomass feedstocks to produce steam directly for conventional steam turbine conversion technology. Although the technology is relatively simple to operate, it is expensive and inefficient. Conversion efficiencies of wood-fired power plants are typically 20-25%, with capacity factors of around 70-80%. As a result, biomass plants at modest scales (550 MWe) make economic sense if there is a readily available supply of low-cost wood wastes and residues nearby so that feedstock delivery costs are minimal. (NRC 1996, Section 8.3.6) The construction impacts of a wood-fired plant would be similar to those for a coal-fired plant, although most facilities using wood waste for fuel would be built on smaller scales. Like coal-fired plants, biomass and wood-waste plants require large areas for Alternatives that Meet System Page 7.2-17 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report fuel storage and processing. They also create impacts to land and water resources, primarily associated with soil disturbance and runoff, in addition to air emissions which must be managed. However, unlike coal-fired plants, biomass and wood-waste plants have very low levels of sulfur oxide emissions. (NRC 1996, Section 8.3.6) Due to the relatively small scale of potential projects and uncertainties in securing long-term fuel supplies, biomass is not considered by FENOC to be a reasonable alternative to replace Davis-Besse's base-load power generation. Municipal Solid Waste Municipal solid waste (MSW) facilities that convert waste to energy use technology comparable to steam-turbine technology for wood waste plants, although the capital costs are greater due to the need for specialized separation and handling equipment (NRC 1996, Section 8.3.7). The decision to burn MSW for energy is typically made due to insufficient landfill space, rather than energy considerations. There are 89 operational MSW energy conversion plants in the United States (USEPA 2009a), none of which were located in Ohio as of 2007 (WTE 2007). These plants generate approximately 2,500 MWe, or about 0.3% of total national power generation (USEPA 2009a). At an average capacity of about 28 MWe, numerous MSW-fired power plants would be needed to replace the base-load capacity of Davis-Besse. Construction impacts for a waste-to-energy plant are estimated to be similar to those for a coal-fired plant. Air emissions are potentially harmful. Increased construction costs for new plants and economic factors (i.e., strict regulations and public opposition) may limit the growth of MSW energy generation (NRC 1996, Section 8.3.7; USEPA 2009a). For reasons stated, MSW is not considered by FENOC to be a reasonable alternative to renewal of Davis-Besse's operating license. Other Biomass-Derived Fuels In addition to biomass energy such as wood and municipal solid-waste fuels, there are other concepts for biomass-fired electric generators, including direct burning of energy crops, conversion to liquid biofuels, and biomass gasification. The GElS indicated that none of these technologies had progressed to the point of being competitive on a large scale or of being reliable enough to replace a base-load plant (NRC 1996, Section 8.3.8). After recently re-evaluating current technologies, the NRC staff believes other biomass-fired alternatives are still unable to reliably replace base-load capacity (NRC 2009b, Section 8.2.5.8). For this reason, FENOC does not consider biomass-derived fuels to be a reasonable alternative to renewal of Davis-Besse's operating license. Alternatives that Meet System Page 7.2-18 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Fuel Cells Fuel cells are electrochemical devices that generate electricity without combustion and without water and air pollution. Fuel cells began supplying electric power for the space program in the 1960s. Today, they are being developed for more commercial applications. The U.S. Department of Energy (USDOE) is currently partnering with several fuel cell manufacturers to develop more practical and affordable designs for the stationary power generation sector. If successful, fuel cell power generation should prove to be efficient, reliable, and virtually pollution free. At present, progress has been slow and costs are high. The most widely marketed fuel cell is currently about $4,500 per kilowatt (kW) compared to $800 to $1,500 per kW for a diesel generator and about $400 per kW or less for a natural gas turbine. By the end of this decade, the USDOE goal is to reduce costs to as low as $400 per kW. (USDOE 2009b) However, fuel cells presently are not economically or technologically competitive with other alternatives for base-load capacity. Therefore, FENOC does not consider fuel cells to be a reasonable alternative to renewal of Davis-Besse's operating license. Alternatives that Meet System Page 7.2-19 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.2-1 Coal-Fired Alternative Emission Control Characteristics Characteristic Basis Net capacity = 910 MW Equivalent to Davis-Besse. Capacity factor = 80% From FENOC 2007, Table 7.2-2 Firing mode: subcritical, tangential, dry-bottom Widely demonstrated, reliable, economical; pulverized coal tangential firing minimizes NOx emissions (FENOC 2007, Table 7.2-2) Fuel type = bituminous coal Type used in FirstEnergy Ohio River plants (FENOC 2007, Table 7.2-2) Fuel heating value = 12,285 Btu/lb FirstEnergy Bruce Mansfield Plant average (FENOC 2007, Table 7.2-2) Heat rate = 9,800 Btu/kWh at full load FirstEnergy experience (FENOC 2007, Table 7.2-2) Fuel sulfur content = 3.52 wt% ; 2.86 lb/MMBtu FirstEnergy Bruce Mansfield Plant average (FENOC 2007, Table 7.2-2) Fuel ash content = 11.88 wt% FirstEnergy Bruce Mansfield Plant average (FENOC 2007, Table 7.2-2) Uncontrolled SOx emissions = 130 lb/ton coal USEPA estimate calculated as 38 x wt% sulfur in coal (FENOC 2007, Table 7.2-2) Uncontrolled NOx emissions = 10 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2) Uncontrolled CO emission = 0.5 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2) Uncontrolled PM emission = 120 lb/ton coal USEPA estimate calculated as 10 x wt% ash in coal (FENOC 2007, Table 7.2-2) Uncontrolled PM10 emission = 27 lb/ton coal USEPA estimate calculated as 2.3 x wt% of ash in coal (FENOC 2007, Table 7.2-2) CO 2 emissions = 6,000 lb/ton Approximate average for bituminous coal combustion (FENOC 2007, Table 7.2-2) SOx control = wet limestone flue gas Best available technology for minimizing SOx desulphurization (95% removal) emissions (FENOC 2007, Table 7.2-2) NOX control = low NOX burners, overfire air, Best available technology for minimizing NOx selective catalytic reduction (95% reduction) emissions (FENOC 2007, Table 7.2-2) Particulate control = fabric filters Best available technology for minimizing particulate (99.9% removal) emissions (FENOC 2007, Table 7.2-2) Btu = British thermal unit MW = megawatt CO = carbon monoxide NOx = nitrogen oxides CO 2 = carbon dioxide PM = particulate matter ft 3 = cubic feet PM10 = PM with diameter less than 10 microns kWh = kilowatt-hour SOx = sulfur oxides lb = pound USEPA = U.S. Environmental Protection Agency MMBtu = million Btu wt% = percent by weight Alternatives that Meet System Page 7.2-20 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.2-2: Gas-Fired Alternative Emission Control Characteristics Characteristic Basis Net capacity = 910 MW Equivalent to Davis-Besse. Capacity factor = 80% From FENOC 2007, Table 7.2-1 Fuel type = natural gas Assumed Heat rate = 6,500 Btu/kWh FENOC Estimate (FENOC 2007, Table 7.2-1) Fuel heating value = 1,025 Btu/ft3 From FENOC 2007, Table 7.2-1 Fuel sulfur content = 0.2 grains/100 scf From FENOC 2007, Table 7.2-1 (0.00068 wt%) SO 2 emissions = 0.00064 lb/MMBtu USEPA estimate for natural gas-fired turbines (0.94 x wt% sulfur in fuel) (FENOC 2007, Table 7.2-1) NOx emissions (assuming dry low-NOx USEPA estimate for best available NOx combustion combustors) = 0.099 lb/MMBtu control (FENOC 2007, Table 7.2-1) NOx post-combustion control: selective USEPA estimate for best available NOx post-catalytic reduction (90% reduction) combustion control (FENOC 2007, Table 7.2-1) CO emissions (assuming dry low-NOx USEPA estimate (FENOC 2007, Table 7.2-1) combustors) = 0.015 lb/MMBtu PM emissions (all PM10 ) = 0.0019 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1) CO 2 emissions = 110 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1) Btu = British thermal unit MW = megawatt CO = carbon monoxide NOx = nitrogen oxides CO, = carbon dioxide PM = particulate matter ft = cubic feet PM10 = PM with diameter less than 10 microns kWh = kilowatt-hour scf = standard cubic feet lb = pound SOx = sulfur oxides MMBtu = million Btu USEPA = U.S. Environmental Protection Agency wt% = percent by weight Alternatives that Meet System Page 7.2-21 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.2-3: CAES Alternative Emission Control Characteristics Characteristic Basis Six trains at 134 MW per train Net capacity = 804 MW (maximum authorized under existing air permit, although only 536 MW could be online by 2017) Within typical range of base-load plant; results in Capacity factor = 80% approximate annual output near that of Davis-Besse. Fuel type = natural gas Assumed Heat rate (HHV) = 4,395 Btu/kWh From OEPA Air Permit P0106714; Norton CAES Fuel heating value = 1,025 Btu/ft 3 From FENOC 2007, Table 7.2-1 Fuel sulfur content = 2 grains/100 scf From QEPA Air Permit P0106714; Norton CAES (0.0066 wt%) SO 2 emissions = 0.006 lb/MMBtu From OEPA Air Permit P0106714; Norton CAES NOx emissions (assuming water injection & selective catalytic reduction) = 3.0 ppmvd @ From OEPA Air Permit P0106714; Norton CAES 15% oxygen and 43.08 lbs/hr (6 units at 7.18 lbs/hr each) CO emissions (assuming dry low-NOx combustors & CO catalytic oxidation) = From OEPA Air Permit P0106714; Norton CAES 5 ppmvd @ 15% oxygen and 43.68 lbs/hr (6 units at 7.28 lbs/hr each) PM emissionsPM (all PM eissons(al PM0) 0.0066 Ib/MMBtu

10) ==0.066 b/M~tu From OEPA Air Permit P0106714; Norton CAES and 23.34 lbs/hr (6 units at 3.89 lbs/hr each)

CO 2 emissions = 110 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1) VOC = 13.2 lbs/hr (6 unitemissions at sions lbs/hr eaFrom 3.2 OEPA Air Permit P0106714; Norton CAES (6 units at 2.2 Ibs/hr each) Btu = British thermal unit MW = megawatt CO = carbon monoxide NOx = nitrogen oxides CO 2 = carbon dioxide OEPA = Ohio Environmental Protection Agency CAES = compressed air energy storage PM = particulate matter ft 3 = cubic feet PM 10 = PM with diameter less than 10 microns HHV = higher heating value ppmvd = parts per million volumetric dry kWh = kilowatt-hour scf = standard cubic feet lb = pound SOx = sulfur oxides lbs/hr = pounds per hour USEPA = U.S. Environmental Protection Agency MMBtu = million Btu wt% = percent by weight VOC = volatile organic compound Alternatives that Meet System Page 7.2-22 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.3 ENVIRONMENTAL IMPACTS OF ALTERNATIVES Environmental impacts are evaluated in this section for the coal- and gas-fired generation alternatives determined by FENOC to be reasonable in Section 7.2.1 compared to renewal of Davis-Besse's operating license. The impacts are characterized as being SMALL, MODERATE, or LARGE. The definitions of these impact descriptions are the same as presented in the introduction to Chapter 4, which in turn are consistent with the criteria established in 10 CFR Part 51, Appendix B to Subpart A, Table B-i, Footnote 3. FENOC believes the environmental impacts associated with the construction and operation of new generating capacity at a greenfield site would exceed those for the same type plants located at Davis-Besse or at another existing disturbed site, i.e., brownfield site. The new generating plants addressed in Section 7.2.1 would not be constructed only to operate for the period of extended operation of Davis-Besse. Therefore, FENOC assumes for this analysis a typical design life of 40 years for the coal-fired plant, 30 years for the combined-cycle natural gas-fired plant, and considers impacts associated with operation for the entire design life of the units in this analysis. The life span of a wind turbine is 20 years (REN 2005); however, turbines can be replaced and the tower would likely be in service for at least 40 years. The life span of a solar plant is estimated to be at least 30 years (TEP 2005). Chapter 8 presents a summary comparison of the environmental impacts of license renewal and the alternatives discussed in this section. 7.3.1 COAL-FIRED GENERATION This section presents the impact evaluation for the representative coal-fired generation alternative. As discussed in Section 7.2.1.1, FENOC assumed for purposes of this analysis that the representative plant would be located at a greenfield or (preferably) brownfield site along commercially navigable waterway or existing rail way. This assumption is a result of the space limitation at the Davis-Besse site. Land Use Land area requirements for a coal-fired plant of similar capacity to Davis-Besse, for example, would be approximately 1.7 acres per MWe (NRC 1996, Table 8.1), or 1,547 acres for a 910 MWe plant. This amount of land use will include plant structures and associated infrastructure. Additional acres would be needed offsite for transmission lines and possibly rail lines, depending on the location of the site relative to the nearest inter-tie connection or rail spur. This acreage could amount to a considerable loss of natural habitat or agricultural land for the plant site alone dependent upon whether a Environmental Impacts of Alternatives Page 7.3-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report greenfield or brownfield site was used, excluding that required for mining and other fuel-cycle impacts. Some portion of the impacts could be mitigated by constructing new transmission line in existing rights-of-way (ROW) to as great an extent as possible. Land-use changes also would occur offsite in an undetermined coal-mining area to supply coal for the plant. For example, the GElS estimated that approximately 22 acres of land per MWe would be affected for mining the coal and disposing of the waste to support a coal-fired plant during its operational life (NRC 1996, Section 8.3.9). Therefore, for the 910 MWe plant used in this analysis, approximately 20,020 acres of land would be needed. Partially offsetting this offsite land use would be the elimination of the need for uranium mining and processing to supply fuel for Davis-Besse. The GElS estimated that approximately one acre per MWe would be affected for mining and processing the uranium during the operating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for Davis-Besse uranium mining and processing, approximately 910 acres of land would be required, resulting in offsite mining net land use of 19,110 acres for the representative coal-fired generation alternative. In consideration of the above, FENOC considers that land use impacts associated with a coal-fired plant at an alternate site would depend on the location of the plant and be MODERATE to LARGE. Water Use and Quality - Surface Water Construction-phase impacts on water quality of greatest potential concern include erosion and sedimentation associated with land clearing and grading operations at the plant site and waste disposal site, and suspension of bottom sediments during construction of cooling water intake and discharge structures and facilities for barge delivery of coal and limestone. However, land clearing and grading activities would be subject to stormwater protections in accordance with the NPDES program, and work in waterways would be regulated by the USACE under the CWA Section 404 and Section 10 of the Rivers and Harbors Act. These activities would also be subject to corresponding state and local regulatory controls, as applicable. In addition, these adverse effects would be localized and temporary. As a result, FENOC considers that impacts on surface water quality associated with construction of the representative plant at an alternative site would be SMALL. FENOC expects that potential impacts on water quality and use associated with operation of the representative plant would be similar to impacts associated with Davis-Besse operation. Cooling water and other wastewater discharges would be regulated by an NPDES permit, regardless of location. Cooling water intake, evaporative losses, and discharge flows for the representative coal-fired plant, assumed to use a closed-cycle cooling system, would be similar to or lower than those resulting from Davis-Besse operation (see Chapter 4). As a result, FENOC considers that Environmental Impacts of Alternatives Page 7.3-2 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report impacts on surface water quality associated with operation of the representative plant at an alternative site would be SMALL. In view of the environmental review afforded under OPSB rules or a similar program, FENOC considers the impacts of surface water use and quality from construction and operation of the representative plant at an alternative site would be SMALL. Water Use and Quality - Ground Water Impacts will depend on whether the plant will use ground water for any purposes, as well as the characteristics of local aquifers. Effects to ground water quality can also depend on waste-management and coal-storage practices, although proper disposal and material handling should reduce the likelihood of an effect, as would recycling a greater percentage of waste products. Regardless of location, FENOC believes it highly unlikely that a coal-fired power plant at an alternate site will rely on ground water for plant cooling, and that ground water and waste-management regulations will limit impacts to SMALL. Air Quality Air quality impacts of coal-fired generation differ considerably from those of nuclear generation. A coal-fired plant emits sulfur oxides (SO,), nitrogen oxides (NO.), particulate matter (PM), and carbon monoxide (CO), all of which are regulated pollutants. Additionally, there are substantial emissions of carbon dioxide (CO2), a greenhouse gas, although future developments such as carbon capture and storage and co-firing with biomass have the potential to reduce the carbon footprint of coal-fired electricity generation (POST 2006). Coal also contains other constituents (e.g., mercury, beryllium) that are potentially emitted as hazardous air pollutants, which are also of concern from a human health standpoint. (NRC 1996, Section 8.3.9) As noted in Section 7.2.1.1, FENOC has assumed a plant design that includes controls to minimize emissions of regulated air pollutants effectively. Based on emission factors, estimated efficiencies for emission controls, and assumed design parameters listed in Table 7.2-1, operation of the plant would result in the following annual air emissions for criteria pollutants:

• Sulfur dioxide = 8,267 tons
• Nitrogen oxides = 5,087 tons

" Carbon monoxide = 636 tons

• Total filterable particulates = 153 tons
• PM 10 = 34.3 tons.

The annual emissions of carbon dioxide, which is currently unregulated, would be approximately 7.63 million tons. See Table 7.3-1 for details. Environmental Impacts of Alternatives Page 7.3-3 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC expects that these emissions would result in a decrease in local air quality compared to operation of a nuclear plant. However, FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions will be subject to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add to regional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions, at least during the ozone season (FENOC 2007, Section 7.3.2, Air Quality). The representative plant would add to regional concentrations of other pollutants, including the criteria pollutants carbon monoxide and particulates; hazardous air pollutants; and carbon dioxide, which is a greenhouse gas. Subject to regulatory controls, FENOC anticipates that the overall air quality would be noticeable, but not destabilizing. As a result, FENOC considers that the impacts to air quality from operation of the representative plant at an alternative site would be MODERATE. Ecological Resources Onsite and offsite land disturbances form the basis for impacts to terrestrial ecology. Constructing a coal-fired plant at an alternate site could alter onsite ecological resources because of the need to convert about 1,547 acres of land at the site to industrial use for the plant, coal storage, and ash and scrubber sludge disposal (see the Land Use subsection above). Coal-mining operations will also affect terrestrial ecology in offsite mining areas, although some of this land is likely already disturbed by mining operations. Impacts could include wildlife habitat loss, reduced productivity, habitat fragmentation, and a local reduction in biological diversity. Impacts, however, will vary based on the degree to which the proposed plant site is already disturbed. On a previous industrial site, impacts to terrestrial ecology will be minor, unless substantial transmission line ROWs, a lengthy rail spur, or additional roads need to be constructed through undisturbed or less-disturbed areas. Any onsite or offsite waste disposal by landfilling will also affect terrestrial ecology at least through the time period when the disposal area is reclaimed. During construction, impacts to aquatic ecology are likely. Regardless of where the plant is constructed, site disturbance will likely increase erosion and sedimentation runoff into nearby waterways, increasing turbidity. While site procedures and management practices may limit this effect, the impact will likely be noticeable. This is particularly true when intake and outfall structures are constructed alongside or in the body of water, as well as when any ROWs, roads, or rail lines require in-stream structures to support stream crossings. Noise and disturbance from construction, in addition to increased turbidity, may have a noticeable effect. Required regulatory permits, however, will help to mitigate these impacts. Environmental Impacts of Alternatives Page 7.3-4 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report During operations, the cooling water system would have a potential impact to aquatic communities. However, this system would be designed and operated in compliance with the CWA, including NPDES limitations to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. The cooling water intake and discharge flows would be comparable to or less than for Davis-Besse, the impact from which is considered to be SMALL (see Chapter 4). Therefore, associated impacts at a comparable site on commercially navigable waterway would also be expected to be SMALL. Management of runoff from coal piles will also be necessary. However, subject to regulatory oversight, as afforded under OPSB rules or a similar program, FENOC considers the impacts to ecological resources from construction and operation of the representative plant at an alternative site may be noticeable, but not destabilizing. On this basis, FENOC considers that the overall impact to ecological resources of constructing a coal-fired plant with a closed-cycle cooling system at an alternate site would be MODERATE. Human Health Coal-fired power generation introduces worker risk from coal and limestone mining, worker and public risk from coal and lime/limestone transportation, worker and public risk from disposal of coal combustion wastes, and public risk from inhalation of stack emissions. For example, the GElS noted that there could be human health impacts (cancer and emphysema) from inhalation of toxins and particulates from a coal-fired plant, but the GElS does not identify the significance of these impacts (NRC 1996, Section 8.3.9). In addition, the coal-fired alternative also introduces the risk of coal pile fires and attendant inhalation risks, though these types of events are relatively rare. (NRC 2009b, Section 8.2.1, Human Health) Regulatory agencies, including the USEPA, USOSHA, and state agencies, set air emission standards requirements for workers and the public based on human health impacts. These agencies also impose site-specific emission limits as needed to protect human health. Given these extensive health-based regulatory controls, FENOC considers that operating the representative coal-fired plant at an alternate site would be SMALL. Socioeconomics The peak workforce during construction of the coal-fired plant alternative is estimated to range between 1.2 to 2.5 workers per MWe and the workforce required during operation is estimated to be 0.25 workers per MWe (NRC 1996, Section 8.3.9, Table 8.1 and Environmental impacts of Alternatives Page 7.3-5 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.2). For a plant with a capacity of 910 MWe, workforces of approximately 1,092 to 2,275 construction workers and 228 permanent employees would be required. Potential impacts from construction of the coal-fired alternative would be highly location dependent. As noted in the GElS, socioeconomic impacts are expected to be larger at a rural site than at an urban site, because more of the peak construction work force would need to move to the area to work (NRC 1996, Section 8.3.9). Not considering impacts of terminating Davis-Besse operations, socioeconomic impacts at a remote rural site could be LARGE, while impacts at a site in the vicinity of a more populated metropolitan area (e.g., Toledo) could be SMALL to MODERATE. FENOC assumed that the OPSB or comparable review process, including application of appropriate mitigation found to be needed as a result, would ensure that these construction impacts would not be destabilizing to local communities. At most alternate sites, coal and lime would be delivered by barge, although delivery is feasible for a location near a railway. Transportation impacts would depend upon the site location. Socioeconomic impacts associated with rail transportation would be MODERATE to LARGE. Barge delivery of coal and lime/limestone would have SMALL socioeconomic impacts. As noted in Section 4.17, communities in Ottawa County, particularly those within the tax jurisdiction of Carroll Township and the Carroll-Benton-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse closure, assuming the plant is constructed outside the area. Based on the above, FENOC considers that the overall socioeconomic impacts of construction and operation of the representative coal-fired plant at an alternate site would be MODERATE. Waste Management The representative coal-fired plant would produce substantial solid waste, especially fly ash and scrubber sludge. Based on emission factors and controls scaled from Beaver Valley (FENOC 2007, Section 7.3.2 and Table 7.2-2)*, the plant annual waste generation amounts would be approximately 300,000 tons/year of ash and 470,100 tons of flue gas desulphurization waste (dry basis), consisting primarily of hydrated calcium sulfate (gypsum) and excess limestone reactant. Although these wastes represent potentially usable products, FENOC assumed the total waste generated would be disposed of at an offsite landfill. Based on a fill depth of 30 feet and scaling from Beaver Valley (FENOC 2007, Section 7.3.2), approximately 644 acres would be required for the landfill over an assumed plant operating life of 40 years. .The scale factor for coal is the ratio of total electric capability, 910 MWe/1 980 Mwe, or 0.460. Environmental Impacts of Alternatives Page 7.3-6 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Disposal of the waste could noticeably affect land use and ground water quality. In addition, the December 2008 failure of the dike used to contain fly ash at the Tennessee Valley Authority Kingston Fossil Plant in Roane County, Tennessee, and subsequent cleanup, highlight other waste management issues (USEPA 2009b). However, environmental impacts related to the location, design, and operational aspects of waste disposal for the plant would be subject to regulatory review under OPSB rules or similar programs. As a result, FENOC believes that with proper disposal siting, coupled with current waste management and monitoring practices, waste disposal would not destabilize any resources. On this basis, FENOC considers that waste management impacts from operation of the representative coal-fired plant at an alternate site would be MODERATE. Aesthetics Potential aesthetic impacts of construction and operation of the representative coal-fired plant include visual impairment resulting from the presence of a large industrial facility, including 500-foot-high stacks, and cooling towers up to approximately 500 feet high with associated condensate plumes. The stacks and condensate plumes from the cooling towers could be visible some distance from the plant. There would also be an aesthetic impact if construction of a new transmission line or rail spur were needed. Similarly, noise impacts associated with rail delivery of coal and lime/limestone if used would be most significant for residents living in the vicinity of the facility and along the rail route. These impacts, however, are highly site-specific. Site locations could reduce the aesthetic impact of a coal-fired generation, for example, if siting were in an area that was already industrialized versus locating at largely undeveloped sites. In view of the environmental review afforded under OPSB rules or a similar program, FENOC considers that the impacts to aesthetics from construction and operation of the representative plant at an alternative site would depend on location and be SMALL to MODERATE. Cultural Resources FENOC assumed that the representative coal-fired plant, associated infrastructure (e.g., roads, transmission corridors, rail lines, or other rights-of-way), and associated waste disposal site would be located with consideration of cultural resources afforded under OPSB or comparable rules. FENOC further assumed that appropriate measures would be taken to recover or provide other mitigation for loss of any resources discovered during onsite or offsite construction. Environmental Impacts of Alternatives Page 7.3-7 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report On this basis, FENOC considers that the potential impact on cultural resources from construction and operation of the representative plant at an alternative site would be SMALL. 7.3.2 GAS-FIRED GENERATION This section presents the impact evaluation for the representative gas-fired generation alternative. As discussed in Section 7.2.1.2, FENOC assumed for purposes of this analysis that the representative plant would be located at a greenfield or (preferably) brownfield site in northwestern Ohio. This assumption is a result of the space limitation at the Davis-Besse site. Land Use Land-use requirements for gas-fired plants are relatively small, at about 100 acres for a 910 MWe plant (Section 7.2.1.2). An estimated 240 - 270 additional acres would be needed offsite at a greenfield location for new gas and electric transmission lines (FENOC 2007, Section 7.3.1, Land Use) and increased land-related impacts, which in turn would be location-specific. Land use in northwestern Ohio is predominantly rural agricultural cropland with scattered rural residences and woodlots. Located in a rural area, the change in land use would be locally apparent and could include displacement of cropland, which is highly productive for corn, wheat, and soybeans relative to other areas of the state; however, substantial buffer with respect to highly incompatible land uses (e.g., residential use) could be provided and destabilization of overall land use would not be expected. Ifthe plant were located in an area designated for industrial use, associated land-use impacts would not be significant. Agricultural practices could continue along most of the area occupied by offsite rights-of-way. (FENOC 2007, Section 7.3.1, Land Use) Regardless of where the natural gas-fired plant is built, additional land would be required for natural gas wells and collection stations. Partially offsetting these offsite land requirements would be the elimination of the need for uranium mining to supply fuel for Davis-Besse. The GElS estimated that approximately one acre per MWe would be affected for mining and processing the uranium during the operating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for Davis-Besse uranium mining and processing, approximately 910 acres of land would be required, resulting in a net gain in reclaimed land for the representative natural gas-fired generation alternative. In view of the environmental review afforded under OPSB rules or a similar program, FENOC considers that the overall impacts of land use from construction and operation of the representative plant at an alternative site would depend on plant location and be SMALL to MODERATE. Environmental Impacts of Alternatives Page 7.3-8 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Water Use and Quality - Surface Water Cooling water intake, evaporative losses, and discharge flows for the plant would be less than that of Davis-Besse, primarily because less power would be derived from a steam cycle (FENOC 2007, Section 7.2.2.1). During operation, cooling water and wastewater discharges would be regulated under the federal CWA and corresponding state programs by an NPDES permit. Construction activities would be similarly regulated to ensure protection of water resources. In addition, impacts on water use and quality would be subject to scrutiny in the planning stage under OPSB or similar governing authority rules. Overall, FENOC considers that the impacts from construction and operation of the representative plant at an alternative site on surface water use and quality would be SMALL. Water Use and Quality - Ground Water Impacts will depend on whether the plant will use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumes that a gas-fired power plant at an alternate site will not rely on ground water for plant cooling, and that regulations for ground water use for potable water will limit impacts to SMALL. Air Quality Natural gas is a relatively clean-burning fuel with nitrogen oxides being the primary focus of combustion emission controls. As noted in the GELS, air quality impacts for all natural gas technologies are generally less than for fossil technologies of equal capacity because fewer pollutants are emitted (NRC 1996, Section 8.3.10). As noted in Section 7.2.1.2, FENOC has assumed a plant design that includes controls to minimize emissions of regulated air pollutants effectively. Based on emission factors, estimated efficiencies for emission controls, and assumed design parameters listed in Table 7.2-2, operation of the plant would result in the following annual air emissions for criteria pollutants: " Sulfur dioxide = 13.3 tons

• Nitrogen oxides = 205 tons

" Carbon monoxide = 311 tons " Total filterable particulates = 39.4 tons The annual emissions of carbon dioxide, which is currently unregulated, would be approximately 2.28 million tons. See Table 7.3-2 for details. Environmental Impacts of Alternatives Page 7.3-9 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC expects that these emissions may result in a noticeable reduction in local air quality. However, FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions will be subject to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add to regional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions, at least during the ozone season (FENOC 2007, Section 7.3.1, Air Quality). The representative plant would add to regional concentrations of other pollutants, including the criteria pollutants carbon monoxide and particulates; hazardous air pollutants such as mercury; and carbon dioxide, which is presently unregulated. Subject to regulatory controls, FENOC anticipates that the overall air quality would be noticeable, but not destabilizing. As a result, FENOC considers that the impacts to air quality from operation of the representative plant at an alternative site would be MODERATE, but smaller than those of coal-fired generation. Ecological Resources As noted in the Land Use subsection above, development of the representative combined-cycle natural gas-fired plant may require approximately 100 acres for the plant site and approximately 240 - 270 additional acres for offsite infrastructure. Although the GElS noted that land-dependent ecological impacts from construction from gas-fired plants would be smaller than for other fossil fuel technologies of equal capacity (NRC 1996, Section 8.3.10), the type and quality of terrestrial habitat that would be displaced is location-specific. However, FENOC considers it likely that most of the area required for construction would consist of agricultural cropland with relatively low habitat value. Stream crossings and wetland disturbance, if any, would be subject to provisions of a USACE permit (CWA Section 404) and relevant state and local requirements. (FENOC 2007, Section 7.3.1, Ecology) The most significant potential impacts to aquatic communities relate to operation of the cooling water system. However, the cooling system for the plant would be designed and operated in compliance with the CWA, including NPDES limitations for physical and chemical parameters of potential concern and provisions of CWA Sections 316(a) and 316(b), which are respectively established to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. Also, the siting, design, and operation of the plant would be subject to the environmental protections under OPSB rules. Overall, FENOC expects that development of the representative natural gas-fired plant would likely have little noticeable impact on ecological resources of the area. As a result, FENOC considers that the overall impacts to ecology resources from Environmental Impacts of Alternatives Page 7.3-10 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report construction and operation of the representative plant at an alternative site would depend on plant location and be SMALL to MODERATE. Human Health The GElS cites risk of accidents to workers and public health risks (e.g., cancer, or emphysema) from the inhalation of toxics and particulates associated with air emissions as potential risks to human health associated with the gas-fired generation alternative (NRC 1996, Table 8.2). However, regulatory requirements imposed on facility design, construction, and operations under the authority of the Occupational Safety and Health Act, Clean Air Act, and related statutes are designed to provide an appropriate level of protection to workers and the public. Additionally, regulatory agencies, including the USEPA, USOSHA, and state agencies, set air emission standards requirements for workers and the public based on human health impacts. Given the extensive health-based regulatory control, FENOC considers that operating the representative gas-fired plant at an alternate site, regardless of plant location, would be SMALL. Socioeconomics Major sources of potential socioeconomic impacts from the representative gas-fired generation alternative include temporary increases in jobs, economic activity, and demand for housing and public services in communities surrounding the site during the construction period. Countering these increases are losses in permanent jobs, tax revenues, and economic activity attributable to gas-fired plant operation and termination of operations of Davis-Besse. The estimated number of peak construction workers expected to build a gas-fired plant with a capacity of 910 MWe is 1,092 -2,275 (NRC 1996, Tables 8.1). To operate the plant would require 137 workers (NRC 1996, Tables 8.2). Although northwestern Ohio is predominantly rural, most areas are within commuting distance of the metropolitan areas like Toledo and Cleveland, Ohio. Considering the proximity of these sources of labor and services, FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. Communities in Ottawa County, however, particularly those within the taxing jurisdiction of Carroll Township and the Benton-Carroll-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse closure that could constitute MODERATE impact (see Section 4.17). FENOC believes that these impacts, although noticeable, would not be destabilizing. As a result, FENOC considers that the overall socioeconomic impact of construction Environmental Impacts of Alternatives Page 7.3-11 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report and operation of the representative gas-fired at an alternative site would be MODERATE. Waste Management Gas-fired generation would result in minimal waste generation, producing minor (if any) impacts (NRC 1996, Section 8.3.10). As a result, FENOC considers waste management impacts from the operation of the representative plant at an alternative site would be SMALL. Aesthetics Potential aesthetic impacts of construction and operation of a gas-fired plant include visual impairment resulting from the presence of a large industrial facility, including multiple exhaust stacks at least 150 feet high, and mechanical-draft cooling towers with associated condensate plumes. Considering the flat topography in northwestern Ohio, the stacks and condensate plumes would likely be visible for several miles from the site; new transmission lines constructed to connect the plant to the grid would also be relatively visible for the same reason, though would not be out of character for the rural northwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics) FENOC expects that the plant likely would be located in a rural area, and assumed that adequate buffer and vegetation screens would be provided at the plant site as needed to moderate visual and noise impacts. In view of the environmental review afforded under OPSB rules, FENOC considers that the impacts to aesthetics from construction and operation of the representative plant at an alternative site would depend on location and be SMALL to MODERATE. Cultural Resources FENOC assumed that the representative gas-fired plant and associated gas-supply pipeline and transmission line would be located with consideration of cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of the representative plant at an alternative site, regardless of location, would be SMALL. Page 7.3-12 September 2011 Environmental of Alternatives Impacts of Environmental Impacts Alternatives Page 7.3-12 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.3.3 RENEWABLE ENERGY This section presents the impact evaluation for wind power in the form of interconnected wind farms and/or solar photovoltaic power, in combination with CAES. To be specific, FENOC evaluated for purposes of this NEPA analysis electricity generation coming from: wind power in the form of interconnected wind farms; or wind power in the form of interconnected wind farms with CAES; or solar (photovoltaic) power with CAES; or a combination of interconnected wind farms and solar power with CAES, as described in Sections 7.2.1 and 7.2.1.3. Wind and solar energy are renewable energy sources that produce electricity without releasing air or water pollutants; however, these advantages are offset by environmental impacts such as large land requirements (both wind and solar), potential harm to birds and bats (wind), aesthetic concerns (wind and solar), noise concerns (wind); radar interference (wind), and generation of hazardous waste streams (solar). In addition, there would be environmental impacts associated with the construction and operation of new transmission lines associated with new renewable energy sources. These impacts are not evaluated as part of this analysis because the scope of new transmission would not be determined until the energy sources were sited. The environmental impacts related to interconnected wind farms are discussed in Section 7.3.3.1. The environmental impacts of interconnected wind farms with CAES are discussed in Section 7.3.3.2. The environmental impacts of solar PV power with CAES are discussed in Section 7.3.3.3. Finally, a summary of the combined environmental impacts of wind farms, solar PV power, and CAES are provided in Section 7.3.3.4. 7.3.3.1 Interconnected Wind Energy Using the assumptions and disclaimers in Section 7.2.1, development of a series of wind farms would be required to provide replacement power for Davis-Besse. Transmission impacts associated with an interconnected grid that would serve renewable energy sources would have to be evaluated once the renewable energy sources have been sited. Development of large-scale, land-based wind power facilities could have MODERATE to LARGE impacts on aesthetics, land use, and terrestrial ecology. The environmental impacts of a large-scale wind farm are described in the GElS (NRC 1996, Section 8.3.1). In summary, the construction of roads and turbine tower supports would result in short-term impacts, such as increases in noise, erosion, and sedimentation, and decreases in air quality from fugitive dust and equipment emissions. Construction in undeveloped areas would have the potential to disturb and impact cultural resources or habitat for sensitive species. During operation, some land near wind turbines could be Environmental Impacts of Alternatives Page 7.3-13 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report available for compatible uses such as agriculture. There is some continuing noise from wind turbine operation, light flicker caused by reflection of the sun, and aesthetic impacts, although whether a wind farm improves the landscape is in the eye of the beholder. Wind farms generate very little waste and pose limited human health risk other than from occupational injuries. There is a potential for bird and bat collisions with turbine blades, which is discussed in this subsection. Although most environmental impacts associated with a single wind farm are SMALL or can be mitigated, the cumulative impacts from the many wind farms that would be needed to support an interconnected grid system, such as impacts to sensitive habitats and endangered species, could be LARGE, depending on the locations. The incorporation of offshore wind resources from Lake Erie could reduce the amount of land use impacts; however, a new set of impacts related to offshore wind would be created. Placing wind farms offshore eliminates some of the obstacles encountered when siting wind farms on shore and limits conflicts with other planning interests. However, other impacts are created, including influence on birds, marine life, hydrography, and marine traffic. (IEAWIND 2002) A detailed discussion of impacts is presented below. Land Use The land use requirement for interconnected wind farms in open and flat terrain is about 50 acres per megawatt (MW) of installed capacity. Approximately 5% (2.5 acres) of this area is occupied by turbines, access roads, and other equipment. The remaining land area can be used for compatible activities such as farming or ranching (AWEA 2002), except if the wind farms are located offshore. The Roscoe Wind Farm near Roscoe, Texas has the capacity of 209 MW and is spread-out across 30,000 acres (RWC 2010), or 143 acres per MW. When complete, the entire Roscoe Wind Complex project is expect to have the capacity of 781 MW on approximately 100,000 acres (CBS 2010) or 128 acres per MW. Assuming the use of interconnected wind as the only renewable source to generate the equivalent of Davis-Besse's net output of 910 MWe base-load power plus 910 MWe of energy storage to be used when wind power is not available, a series of wind farms with 2.0-MWe turbines with an average capacity factor of 30% as specified by PJM and USDOE (PJM 2011 and USDOE 2011) would require approximately 3030 turbines to produce 1820 MWe. At 50 acres per MW, the land use potential would be as much as 91,000 acres (142 square miles), with about 4550 acres (7.1 square miles) occupied by turbines and support facilities. Land use in Ohio, where additional wind generation would likely be developed, is predominantly rural agricultural cropland with scattered rural residences and woodlots. Environmental Impacts of Alternatives Page 7.3-14 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report In such a location, the change in land use would be locally apparent and could include some initial displacement of highly productive cropland for corn, wheat, and soybeans. However, a substantial buffer with respect to highly incompatible land uses (e.g., residential use) could be provided, and destabilization of overall land use would not be expected. Agricultural practices could continue along most of the area occupied by offsite rights-of-way. (FENOC 2007, Section 7.3.1, Land Use) Offshore impacts have been extensively studied in Europe. An environmental impact report has been prepared by the Cape Wind Project (CWP) and a feasibility study was conducted by the Great Lakes Wind Energy Center (GLWEC) for an offshore area in Lake Erie near Cleveland, Ohio (GLWEC 2009). Based on the findings in the CWP Environmental Impact Report (EIR) (CWP 2007) and the study completed by GLWEC, land use impacts associated with offshore wind generation would be SMALL. Regardless of where the wind generation facilities are built, additional land would be required for an interconnected grid system as described in Section 7.2.2.3. Partially offsetting these offsite land requirements would be the elimination of the need for uranium mining to supply fuel for Davis-Besse. The GElS estimates that approximately one acre per MWe would be affected for mining and processing the uranium during the operating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for the uranium mining and processing associated with fuel for Davis-Besse, approximately 910 acres of land would be required, resulting in a net avoidance of potentially disturbing 3640 (4550-910) acres of land when compared to wind generation land use. Based on these data, FENOC considers that the overall impacts of land use from construction and operation of interconnected wind farms would depend on their locations, and be MODERATE to LARGE. Water Use and Quality - Surface Water Wind generation does not require cooling water or intake structures. Therefore, there would be no impact on water use and the only potential impact on local water quality would be erosion or sedimentation issues during construction. These impacts would be minimized by using best management practices during construction activities and are considered SMALL. Water Use and Quality - Ground Water A limited amount of ground water may be used during construction activities if other potable water supplies are limited. Minor amounts of water may be needed for operating wind generation facilities if surface water resources were not available. The potential impact to ground water is SMALL. Environmental Impacts of Alternatives Page 7.3-15 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Air Quality There are no air quality impacts associated with the operation of onshore or offshore interconnected wind farms. The construction of roads and turbine tower supports would result in short-term impacts in air quality from fugitive dust and equipment emissions and the overall impacts would be SMALL. Ecological Resources As noted in the Land Use subsection above, development of onshore interconnected wind farms would have a MODERATE to LARGE impact on land resources which could have a LARGE impact on the ecological resources, especially during construction. Migratory bird, eagle and raptor, and bat mortality are potential impacts related to wind turbines. The deaths of birds and bats at wind farm sites have raised concerns by fish and wildlife agencies and conservation groups. United States Fish and Wildlife Service (USFWS) estimates indicate that wind turbine rotors kill 33,000 birds annually (USFWS 2002). Concerns of the potential impacts of wind power deployment have led the USFWS to release draft guidance that provides agency employees, developers, federal agencies, and state organizations information for reviewing and selecting sites for interconnected and community-scale wind energy facilities to avoid and minimize negative impacts to fish, wildlife, plants and their habitats (USDOI 2011). Direct effects include blade strikes, barotrauma, loss of habitat, and "displacement". Indirect effects occur later in time and include introduction of invasive vegetation that result in alteration of fire cycles; increase in predators or predation pressure; decreased survival or reproduction of the species; and decreased use of the habitat that may result from effects of the project or resulting "habitat fragmentation." (USFWS 2011) Although wind turbine/bird collision studies seem to indicate that wind generating facilities in some locations of the United States have a minor impact on birds compared to other sources of collision mortality, one cannot assume that similar impacts would occur among birds using wind-generating sites built in Ohio or offshore in Lake Erie. Based on a feasibility study conducted by Great Lakes Wind Energy Center (GLWEC) the avian morality rate of this proposed offshore project is expected to be minimal. (GLWEC 2009) FENOC assumed that construction best management practices and awareness of critical habitat during operations would minimize impacts to ecological resources. Therefore, impacts to migrating species would depend on the location of the wind farms and could be SMALL to MODERATE. Human Health The only major health risk for the construction and operation of a series of wind farms (onshore or offshore) would be accidents. FENOC assumed that all Occupational Environmental Impacts of Alternatives Page 7.3-16 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Safety and Health Act requirements would be complied with during construction and operation of these facilities and the impacts should be SMALL. Socioeconomics Major sources of potential socioeconomic impacts from interconnected wind farms include temporary increases in jobs, economic activity, and demand for housing and public services in communities surrounding the sites during the construction period. These impacts would be spread throughout the region. Countering these increases are losses in permanent jobs, tax revenues, and economic activity attributable to the termination of operations of Davis-Besse. Typically, renewable energy sources are not subject to the tax rate of conventional energy-generating facilities, so the loss of permanent jobs and tax revenue could be significant to the communities near Davis-Besse and thus have a SMALL to MODERATE impact. Communities in Ottawa County, however, particularly those within the taxing jurisdiction of Carroll Township and the Benton-Carroll-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse closure that could constitute MODERATE impacts. The number of peak construction workers expected to build the wind farms is unknown at this time; however, it is likely similar to a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Tables 8.1). To operate and maintain the wind farms would require approximately 150 to 200 workers. FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. Waste Management Construction of wind farms could result in generation of large amounts of vegetation from land clearing activities. If this material is managed correctly (e.g., recycled or composted) the impacts should be SMALL. Minor amounts of waste may be generated during the operations and maintenance of the wind turbines (onshore or offshore) which, if waste streams are managed correctly, the impacts would likely be SMALL. Aesthetics Most wind farms are located in remote areas and may generate large aesthetic concerns, particularly if sited on highlands or in recreational areas and could have some effect on the local aesthetic quality. The aesthetic impacts from wind farms located in flat-lying rural areas would likely be SMALL. Offshore wind turbines would likely have a lesser aesthetic impact than onshore wind turbines and be limited to those individuals who reside close to the shoreline or Environmental Impacts of Alternatives Page 7.3-17 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report participate in recreational activities close to the wind facilities. There have been concerns related to the related to aesthetic impacts. (CA 2011) The overall aesthetic impacts from wind turbines would be SMALL to MODERATE. Cultural Resources Due to the large amount of land needed to construct the necessary wind farms, the potential for impacting cultural resources could be LARGE. To minimize these impacts, FENOC assumed construction activities would consider cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures for both onshore and offshore construction activities would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of the wind farms, regardless of location, would be SMALL. 7.3.3.2 Wind with Compressed Air Energy Storage Environmental impacts associated with wind farms are discussed above in Section 7.3.3.1, and are not repeated here in detail. Impacts associated with the compressed air energy storage (CAES) facility are discussed below. By combining CAES with interconnected wind farms, the anticipated environmental impacts would be greater than the impacts from interconnected wind farms alone. Therefore, wind farms with CAES generating 1820 MW of power are expected to have greater environmental impacts than Davis-Besse during the proposed 20 year license extension. Land Use The overall land use impact for wind generation in this energy alternative, as discussed in Section 7.3.3.1, is MODERATE to LARGE. Land use associated with the NES facility would be limited to the facility's 92 surface acres. There would be some land impacted during construction, but this site has been previously disturbed so the impact should be SMALL. However, if another site is Wind generation source is assumed to be available for 12 hours every day, and a CAES facility assumed to be 100% efficient (i.e., 910 MWe of energy input from wind and/or solar to the CAES facility results in 910 MWe of generation from the CAES facility), would require that generation source to be rated at 1820 MW in order to provide 24-hours of baseload electricity when integrated with a 910 MW CAES facility (i.e., 12 hours to provide 910 MW of base-load generation onto the grid, and the same 12 hours to provide 910 MW to recharge the CAES facility, so that the CAES facility could feed the grid the remainder of the day). Environmental Impacts of Alternatives Page 7.3-18 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report chosen for the CAES or an additional CAES facility is needed to meet base-load power requirements then there could be a MODERATE to LARGE land use impact. Water Use and Quality - Surface Water CAES facilities have cooling towers associated with the use of gas turbines to produce electricity and compressors to recharge the storage structure. These cooling towers are much smaller than those typically used for coal and gas generation plants. Cooling makeup water evaporative losses, and discharge flows for the plant would be considerably less than that of Davis-Besse, primarily because less power would be derived from a steam cycle. (FENOC 2007, Section 7.2.2.1) During CAES operation, cooling water and wastewater discharges would be regulated under the federal CWA and corresponding state programs by an NPDES permit. Construction activities would be similarly regulated to ensure protection of water resources. In addition, impacts on water use and quality would be subject to scrutiny in the planning stage under OPSB or similar governing authority rules. Overall, FENOC considers that the impacts from construction and operation of interconnected wind farms (onshore and offshore) combined with a CAES facility on surface water use and quality would be SMALL. Water Use and Quality - Ground Water Impacts would depend on whether the plant would use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumed that the NES plant or a CAES plant at an alternate site would not rely on ground water for plant cooling, and that regulations for ground water use for potable water would limit impacts to SMALL. Air Quality CAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogen oxides being the primary focus of combustion emission controls. As noted in the GELS, air quality impacts for all natural gas technologies are generally less than for fossil technologies of equal capacity because fewer pollutants are emitted (NRC 1996, Section 8.3.10). FirstEnergy Generation Corp. has applied for and received an Air Pollution Permit to Install and Operate (PTIO) proposed emission units for the Norton CAES facility (Facility ID 1677105001) (see Table 7.2-3). The permit (Number P0106714) was issued on September 7, 2010 by the Ohio EPA. The permit establishes emission limitations, air emission controls, monitoring, reporting, and recordkeeping requirements. The proposed emission units established in the PTIO are based on the original design of the Environmental Impacts of Alternatives Page 7.3-19 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report facility and include six combustion trains and one cooling tower. Each combustion train includes a 589 mmBtu/hr (134 MWe) combustion turbine and a 1 mmBtu/hr in-line heater to remove moisture from the compressed air. (NES 2010) The combustion turbines and in-line heaters would fire only pipeline-quality natural gas. The only other sources associated with this facility are an emergency generator and a back-up firewater pump; both of these units would be diesel-fired. The permitted annual air emission limits from this facility with six combustion trains (i.e., 804 Mwe) are as follows:

• Sulfur dioxide (SO 2 ) = 42.41 tons
• Nitrogen oxides (NOx) = 93.67 tons
• Carbon monoxide = 90.36 tons
• PM10 = 46.65 tons

    " Volatile Organic Compounds (VOCs) = 26.40 tons The annual emissions of carbon dioxide from all sources would be approximately 681,100 tons. These emissions are based on the current air permit for NES and could change if different equipment is used during plants operations. A list of air emissions for the six combustion trains is presented in Table 7.3-4.

FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions would be subject to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add to regional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions, at least during the ozone season (FENOC 2007, Section 7.3.1, Air Quality). The plant would add to regional concentrations of other pollutants, including the criteria pollutants carbon monoxide and particulates; hazardous air pollutants such as mercury; and carbon dioxide, which is presently unregulated. Subject to regulatory controls, FENOC anticipates that the impacts to air quality from operation of the CAES plant at an alternative site would be MODERATE. Ecological Resources As noted in Section 7.3.3.1, development of the interconnected wind farms would have a MODERATE to LARGE impact on land resources which could have a LARGE impact on ecological resources, especially during construction. Since the NES has an existing underground storage space and only has 92 acres of land use at the surface, the potential impact to ecological resources is SMALL. However, if another CAES site with compressed air storage on the land surface is chosen or needed to provide additional stored energy capacity the ecological impacts could be MODERATE to LARGE. Environmental Impacts of Alternatives Page 7.3-20 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report For an alternative CAES site, FENOC considers it likely that most of the area required for construction would consist of agricultural cropland with relatively low habitat value. Stream crossings and wetland disturbance, if any, would be subject to provisions of a USACE permit (CWA Section 404) and relevant state and local requirements. (FENOC 2007, Section 7.3.1, Ecology) The most significant potential impacts to aquatic communities relate to operation of the cooling water system. However, the NES site (or alternative site) cooling system for the plant would be designed and operated in compliance with the CWA, including NPDES limitations for physical and chemical parameters of potential concern and provisions of CWA Sections 316(a) and 316(b), which are respectively established to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. Also, the siting, design, and operation of the plant would be subject to the environmental protections under OPSB or other state agency's rules. Overall, FENOC expects that development of the CAES plant would likely have little noticeable impact on ecological resources of the area. As a result, FENOC considers that the overall impacts to ecology resources from construction and operation of the representative plant at an alternative site would depend on plant location and be SMALL to LARGE. Human Health The only major health risk for the construction and operation of a series of wind farms (onshore or offshore) would be accidents. FENOC assumed that all Occupational Safety and Health Act requirements would be complied with during construction and operation of these facilities and the impacts should be SMALL. The NES or an alternative CAES facility would use natural gas in its power generation mode. The GElS cites risk of accidents to workers and public health risks (e.g., cancer, or emphysema) from the inhalation of toxics and particulates associated with air emissions as potential risks to human health associated with the gas-fired generation alternative (NRC 1996, Table 8.2). However, regulatory requirements imposed on facility design, construction, and operations under the authority of the Occupational Safety and Health Act, Clean Air Act, and related statutes are designed to provide an appropriate level of protection to workers and the public. Additionally, regulatory agencies, including the USEPA, USOSHA, and state agencies, set air emission standards requirements for workers and the public based on human health impacts. Given the extensive health-based regulatory control, FENOC considers that human health impacts from operating a CAES plant at NES or an alternate site, regardless of plant location, would be SMALL. Environmental Impacts of Alternatives Page 7.3-21 September2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Socioeconomics Major sources of potential socioeconomic impacts from interconnected wind farms with CAES would be similar to those discussed in Section 7.3.3.1. The number of peak construction workers expected to build the NES facility is unknown at this time; however, it is likely not to exceed the number for a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Table 8.1). FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. To operate and maintain the NES plant would require approximately 50 to 100 workers. FENOC believes that the construction impacts, although noticeable, would be spread throughout the State and should not impact any one local community over another. The financial impacts from closing Davis-Besse, however, could be significant to the areas surrounding the station. The addition of an operational workforce for the CAES facility and new tax revenue for the local community near the CAES facility would be a beneficial impact in that local community. As a result, FENOC considers that the overall socioeconomic impact of construction and operation of the NES or an alternative CAES site would be SMALL to MODERATE. Waste Management Construction of interconnected wind farms could result in generation of large amounts of vegetation from land clearing activities. Ifthis material is managed correctly (e.g. recycled or composted) then the impacts should be SMALL. Like gas-fired generation, NES or an alternative CAES site would result in minimal waste generation, producing minor (if any) impacts (NRC 1996, Section 8.3.10). As a result, FENOC considers waste management impacts from the operation of a CAES plant at an alternative site would be SMALL. Aesthetics Most wind farms are located in remote areas and may generate large aesthetic concerns, particularly if sited on highlands or in recreational areas and could have some effect on the aesthetic quality. In general, impact on aesthetic quality for wind farms located in flat-lying rural areas would be SMALL Potential aesthetic impacts of construction and operation of NES or an alternative CAES plant may include visual impairment resulting from the presence of a large industrial facility, including multiple exhaust stacks and mechanical-draft cooling towers with associated condensate plumes. Considering the flat topography in northwestern Ohio and other areas where an alternative CAES may be placed, the stacks and condensate plumes would likely be visible for several miles from the site; new transmission lines constructed to connect the plant to the grid would also be relatively visible for the same Environmental Impacts of Alternatives Page 7.3-22 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report reason, though would not be out of character for most rural areas including the northwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics) The NES site is on a brownfield area located just south of Norton, Ohio. The construction of the facility would cause a minor change in the appearance of the area, but aesthetic impacts would be SMALL. FENOC expects that an alternative CAES plant likely would be located in a rural area, and assumed that adequate buffer and vegetation screens would be provided at the plant site as needed to moderate visual and noise impacts. In view of the environmental review afforded under OPSB rules, FENOC considers that the impacts to aesthetics from construction and operation of interconnected wind farms and NES or an alternative CAES site would depend on location and be SMALL to MODERATE. Cultural Resources As discussed in Section 7.3.3.1, FENOC concludes that the potential adverse impact on cultural resources of the interconnected wind farms, regardless of location, would be SMALL. FENOC assumed that the NES facility or alternative CAES plant and associated gas-supply pipeline and transmission lines would be located with consideration of cultural resources under OPSB or comparable program rules, and the impact would be SMALL. 7.3.3.3 Photovoltaic Power Combined with CAES Environmental impacts of solar power systems can vary based on site-specific conditions. Land use and aesthetics are the primary environmental impacts of solar power. Land requirements for PV facilities are large, compared to the land currently used by Davis-Besse. During operation, however, PV technologies produce no air pollution, little or no noise, and require no transportable fuels. Land Use As stated in the GELS, land requirements are high: 35,000 ac (14,000 ha) [i.e., 54.7 square miles] per 1,000 MWe for PV cells (NRC, 1996). An NREL study (for the western United States) has indicated the amount of land required depends on the available solar insolation and ranges from about 3.8 to 7.6 acres per MW for photovoltaic systems with a capacity factor ranging from 20 to 25%. (NREL 2002) Assuming an average capacity factor of 24% from NREL 2002, and 5 acres per MW, plus an additional 910 MWe needed for energy storage, and the estimated required land would be approximately 37,900 acres (59.2 square miles). Environmental Impacts of Alternatives Page 7.3-23 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Unlike wind power generation, all the land used to construct the solar generation facilities would be permanently disturbed and could not be used for other purposes. To reduce the amount of land use, the solar facilities could be placed in the same locations as the wind generation facilities, or brownfield locations assuming these are flat areas with sufficient sunlight. PV arrays are placed on the rooftops of businesses and residential dwellings to generate electricity or to heat water. These units are usually small and are designed to provide energy directly to the facility or residence to which they are attached. Only in a few cases are these PV arrays large enough to provide excess energy to the grid. Based on these data, FENOC considers that the overall impacts of land use from construction and operation of the representative solar power facilities alone would be LARGE. Land use associated with the NES facility would be limited to the facilities' 92 surface acres. There would be some land impacted during construction but this site has been previously disturbed so the impact should be SMALL. However, if another site is chosen for the CAES or an additional CAES facility is needed to meet base-load power requirements then the potential impacts to land resources could be MODERATE to LARGE. Water Use and Quality - Surface Water Solar generation using PV technology does not require cooling water or intake structures. Therefore, there would be no impact on water use and the only potential impact on local water quality would be erosion or sedimentation issues during construction. These impacts would be minimized by using best management practices during construction activities. Significant amounts of water could be used to keep the solar panels clean so they remain effective in collecting the maximum amount of sunlight possible. Since the areas where these solar facilities would be located are not in a desert or semi-arid environment, the demands on water resources should be reduced. Overall, the impacts on water use and quality should be SMALL to MODERATE. Surface water impacts associated with the CAES cooling systems are discussed in detail in Section 7.3.3.2, and are SMALL. Overall, FENOC considers that the impacts from construction and operation of solar generation facilities and a CAES plant at alternative sites on surface water use and quality would be SMALL to MODERATE. Page 7.3-24 September 2011 of Alternatives Impacts of Environmental Impacts Alternatives Page 7.3-24 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Water Use and Quality - Ground Water Impacts would depend on whether the plant would use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumed that the NES plant or a CAES plant at an alternate site would not rely on ground water for plant cooling, and that regulations for ground water use for potable water would limit impacts to SMALL. Air Quality There are no air quality impacts associated with the operation of solar generation facilities. Potential emissions from NES are discussed in Section 7.3.3.2 and Table 7.3-3. FENOC considers that the impacts to air quality from operation of a CAES facility at an alternative site would be MODERATE. Ecological Resources As noted in the Land Use subsection above, development of solar generation facilities would have a major impact on land resources, which could have a significant impact on the ecological resources during construction and operation of these facilities. As stated in the Land Use subsection, approximately 37,900 acres would be permanently disturbed, and with the possible loss of important habitat. Although FENOC assumed that construction best management practices and awareness to critical habitat during operations would minimize effects to ecological resources, the potential for significant impacts would be MODERATE to LARGE. As discussed in Section 7.3.3.2, since the NES is a former underground limestone mine and only has 92 acres of land use at the surface, the potential impact to ecological resources is SMALL. However, if another CAES site with compressed air storage on the land surface is chosen or needed to provide additional stored energy capacity, then the ecological impacts could be MODERATE to LARGE. Human Health The health risks for the construction and operation of a series of solar generation facilities would be accidents and potential exposure to hazardous materials. FENOC assumed that all Occupational Safety and Health Act requirements would be complied with during construction and operation of these facilities and the impacts should be SMALL. Page 7.3-25 September 2011 Environmental Impacts Environmental of Alternatives Impacts of Alternatives Page 7.3-25 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report As discussed in Section 7.3.3.2, given the extensive health-based regulatory control, FENOC considers that operating the CAES plant at NES or an alternate site, regardless of plant location, would be SMALL. Socioeconomics Major sources of potential socioeconomic impacts from the solar power with associated NES or CAES facility alternative include temporary increases in jobs, economic activity, and demand for housing and public services in communities surrounding the sites during the construction period. These impacts would be spread throughout the state and should not impact any one local community over another. Countering these increases are losses in permanent jobs, tax revenues, and economic activity attributable to operation of the alternative generation facilities and termination of operations of Davis-Besse. Typically, renewable energy sources are not subject to the tax rate of conventional energy generating facilities, so the loss of permanent jobs and tax revenue could be significant to the communities near Davis-Besse and thus the impacts could be SMALL to MODERATE. Communities in Ottawa County, however, particularly those within the taxing jurisdiction of Carroll Township and the Benton-Carroll-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse's closure that could constitute MODERATE impacts. The number of peak construction workers expected to build the solar power facilities and the NES facility is unknown at this time. However, it is likely not to exceed that of a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Table 8.1). To operate and maintain the solar facilities and NES plant would require approximately 150 to 200 workers. FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. In summary, FENOC considers that the overall socioeconomic impact of construction and operation of the representative solar generation combined with CAES generation facility would be SMALL to MODERATE. Waste Management PV technology creates environmental impacts related to manufacture and disposal. Chemicals used in the manufacture of PV cells include cadmium and lead. Potential human health risks also arise from the manufacture and deployment of PV systems because there is a risk of exposure to heavy metals such as selenium and cadmium. The cumulative and long-range impacts from transporting and disposing of hazardous waste could be SMALL to MODERATE. Environmental Impacts of Alternatives Page 7.3-26 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Aesthetics Most solar facilities are located in remote areas and would likely not generate large aesthetic concerns and would likely meet minor public resistance. Overall, the impacts from the construction and operation of solar power facilities would be SMALL. Cultural Resources Due to the large land use to construct the necessary solar generation facilities and for the CAES facility, the potential for impacting cultural resources could be LARGE. To minimize these impacts, FENOC assumed construction activities would consider cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of the solar generating facilities, regardless of location, would be SMALL. FENOC assumed that the NES facility or alternative CAES plant and associated gas-supply pipeline and transmission line would be located considering cultural resources under OPSB or comparable program rules and, therefore, any impacts would be SMALL. 7.3.3.4 Combinations of Wind and Solar with CAES As discussed in Sections 7.2.1 and 7.2.1.3, FENOC evaluated a combination of wind and solar generation along with CAES as an alternative to replace the rated electrical output of Davis-Besse. The environmental impact results for interconnected wind farms and PV solar and CAES facilities are discussed in detail in Sections 7.3.3.1 through 7.3.3.3. A summary of these results is described below and listed in Table 8.0-1. Land Use The amount of territory required for the construction and operation of a series of wind farms and solar PV facilities would result in LARGE land use impacts. Most of this land would be in greenfield or agricultural areas. Although some land used to develop wind farms could be used to generate solar power, there could be several issues including agriculture needs, transmission capacity and sunlight duration that may limit the multiuse of this land. Land use associated with the NES facility would be limited to the facility's 92 surface acres. There would be some land impacted during construction, but this site has been Environmental Impacts of Alternatives Page 7.3-27 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report previously disturbed so the impact should be SMALL. However, if another site is chosen for the CAES or an additional CAES facility is needed to meet base-load power requirements, then the land use impact could be MODERATE to LARGE. Water Use and Quality - Surface Water Wind farms and solar generation using PV technology do not require cooling water or intake structures. Therefore, there would be no impact on water use and the only potential impact on local water quality would be erosion or sedimentation issues during construction. These impacts would be minimized by using best management practices during construction activities. Significant amounts of water could be used to keep the solar panels clean so they remain effective in collecting the maximum amount of sunlight as possible. Since the areas where these solar facilities would be located are not in a desert or semi-arid environment, the demands on water resources should be reduced. Overall, the impacts on water use and quality should be SMALL to MODERATE. CAES have cooling towers associated with the use of gas turbines to produce electricity and compressors to recharge the storage structure. These cooling towers are much smaller than those typically used for coal and gas generation plants. Cooling makeup water evaporative losses and discharge flows for the plant would be considerably less than that of Davis-Besse, primarily because less power would be derived from a steam cycle. (FENOC 2007, Section 7.2.2.1) During CAES operation, cooling water and wastewater discharges would be regulated under the federal CWA and corresponding state programs by an NPDES permit. Construction activities would be similarly regulated to ensure protection of water resources. In addition, impacts on water use and quality would be subject to scrutiny in the planning stage under OPSB or similar governing authority rules. Overall, FENOC considers that the impacts from construction and operation of this combined energy alternative on surface water use and quality to be SMALL to MODERATE. Water Use and Quality - Ground Water Impacts would depend on whether the combined energy alternative facilities would use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumed that the NES plant or a CAES plant at an alternate site would not rely on ground water for plant cooling, and that regulations for ground water use for potable water would limit impacts to SMALL. FENOC also assumed that construction of the facilities would employ best management practices to keep the impact to groundwater quality SMALL. Environmental Impacts of Alternatives Page 7.3-28 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Air Quality The construction of roads and turbine tower supports would result in short-term impacts in air quality from fugitive dust and equipment emissions. There are no air quality impacts associated with the operation of wind farms and solar PV facilities, therefore the overall impacts would be SMALL. CAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogen oxides being the primary focus of combustion emission controls. The NES facility has been issued an air permit by the Ohio EPA, and emission details are discussed in Section 7.3.3.2 and Table 7.3-3. FENOC assumed that best management practices would be utilized during construction activities to minimize impacts to air quality. In addition, FENOC assumed that the NES or alternate CAES facility would comply with its air permit, thus impacts to air quality should be MODERATE. Ecological Resources As noted in the Land Use subsection above, development of wind farms and solar PV facilities and CAES would have a MODERATE to LARGE impact on land resources which could have a MODERATE to LARGE impact on the ecological resources during construction and operation of these facilities. FENOC assumed that construction best management practices and awareness to critical habitat during operations would minimize impacts to ecological resources. Human Health The only major health risk for the construction and operation of a series of wind farms and solar PV facilities, and a CAES plant would be accidents. There may be minor health impacts from reduced air quality during construction and the operation of the CAES facility and from handling potential hazardous substances or waste materials. FENOC assumed that all air permits and Occupational Health and Safety Act requirements would be complied with during construction and operation of these facilities, and the impacts should be SMALL. Socioeconomics Major sources of potential socioeconomic impacts from wind farms and solar PV systems with an associated NES or CAES facility include temporary increases in jobs, economic activity, and demand for housing and public services in communities surrounding the sites during the construction period. Socioeconomic impacts are similar to those discussed in Sections 7.3.3.1 to 7.3.3.3 and would be SMALL to MODERATE. Page 7.3-29 September 2011 Environmental Impacts Environmental of Alternatives Impacts of Alternatives Page 7.3-29 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Waste Management PV technology creates environmental impacts related to manufacture and disposal. Chemicals used in the manufacture of PV cells include cadmium and lead. Potential human health risks also arise from the manufacture and deployment of PV systems because there is a risk of exposure to heavy metals such as selenium and cadmium. The cumulative and long range impacts from transporting and disposing of hazardous waste could be a MODERATE to LARGE impact. Minimal waste streams should be generated from the construction and operations of the wind power and CAES facilities. Therefore, the impacts should be SMALL. Aesthetics Most wind farms are located in remote areas and may generate large aesthetic concerns, particularly if sited on highlands or in recreational areas. Solar PV generation requires relatively flat land, which limits the view to the public. However, presence of overhead transmission lines may cause some moderate public resistance. To minimize these impacts, the renewable generation facilities would likely be located in rural areas as much as possible. The proposed NES facility is located in a brownfield area and should not change the aesthetic view of the area. Overall, the aesthetic impacts from these facilities should be SMALL. Cultural Resources Due to the large amount of land needed to construct the necessary wind farms and solar PV facilities, and for the CAES facility, the potential for impacting cultural resources could be LARGE. To minimize these impacts, FENOC assumed construction activities would consider cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of this combined energy alternative regardless of location would be SMALL. 7.3.3.5 Conclusions of Combining New Generation Power Sources with Storage The use of wind power in the form of interconnected wind farms and/or solar photovoltaic power, in combination with CAES to provide power to replace Davis-Besse's output by 2017 has been evaluated and discussed in the subsections above. The environmental impacts associated with renewable sources and CAES were evaluated in Subsections 7.3.3.1, 7.3.3.2, 7.3.3.3 and 7.3.3.4. The overall conclusion from this impact analysis is that the combination of these energy source alternatives has SMALL to LARGE impacts. These impacts are compared in Section 8.0 to the impacts from renewal of the Davis-Besse license for another 20 years as well as those for the alternative coal and natural gas fired plants. Environmental Impacts of Alternatives Page 7.3-30 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.3-1: Air Emissions from Coal-Fired Alternative Parameter(1 ) Calculation Result Heat Rate Total Gross Capability x x Conversion Factors x Capacity Factor tons/year Annual Coal Heat Value Consumption 910MW x 9,800 Btu lb 1,000 kW 8,760 hr ton xO.80 2,543,644 x *x ~x - x

• x08 ,4,4 kW x hr 12,285 Btu MW year year 2,000 lb Emissions Coal Consumption x Uncontrolled Emissions x Conversion Factors x [100 - removal efficiency (%)](2) tons/year 2,543,644 tons 130 Ib ton 100 -95 8,267 S xx x -- x8,6 year ton 2,000 Ib 100 NOX 2,543,644 tons 10 lb ton 100-60 5,087 year ton 2,000 lb 100 CO 2,543,644 tons 0.5 lb ton 636 year ton 2,000 lb PM 2,543,644 tons 120 lb ton 100 - 99.9152.6 PMx x x156 year ton 2,000 Ib 100 PM10 2,543,644 tons 27 lb ton 100-99.9 3434 year ton 2,000 Ib 100 CO 2 2,543,644 tons 6,000 lb ton year year x ton ton x 2,630, 2,000 lb Btu = British thermal units CO = carbon monoxide CO 2 = carbon dioxide hr = hour kW = kilowatt lb = pound MW = megawatt NOx = nitrogen oxides PM = total filterable particulate matter PM 10 = PM having a diameter less than 10 microns Sox = sulfur oxides Notes:

(1) Source: Table 7.2-1 (2) There are no emission controls for CO and CO 2. Page 7.3-31 September 2011 Environmental Impacts of Environmental Impacts of Alternatives Alternatives Page 7.3-31 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.3-2: Air Emissions from Gas-Fired Alternative ParameterO') Calculation Result Gross Capability xHeat Rate x Conversion Factors x Capacity Factor MMBtu/year Annual Gas Heat Input 910 MW x 6,500 Btu 1,000 kW 8,760 hr 0.80 41,452,320 kW - hr MW year Emissions Annual Gas Heat Input x Uncontrolled Emissions x Conversion Factors x [100 - removal efficiency (%)] (2) tons/year 41,452,320 0.00064 lb ton year MMBtu 2,000 lb 41,452,320 0.099 lb ton 100 -90 year MMBtu 2,000 lb 100 CO 41,452,320 x 0.015 - lb x ton -- 311 year MMBtu 2,000 lb PM (al 0 41,452,320

                      -          XX0.019 lb       ton
                                                    --                                            39.4 PM (all PMlo)          year       MMBtu 2,000 lb 41,452,320     110 lb        ton year       MMBtu      2,000 lb Btu = British thermal units CO = carbon monoxide CO 2   = carbon dioxide hr   = hour kW    = kilowatt Ib/MMBtu     = pounds per million British thermal units MW     = megawatt NOx    = nitrogen oxides PM    = particulate matter PM1 o   = PM having a diameter less than 10 microns SOx    = sulfur oxides (mainly SO 2)

Notes: (1) Source: Table 7.2-2 (2) There are no emission controls for SO 2, CO, PM, and CO 2. Page 7.3-32 September 2011 Environmental Impacts of Environmental Impacts of Alternatives Alternatives Page 7.3-32 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.3-3 Permitted Air Emissions from the Proposed Norton Energy Storage Project Parameter Quantity Volume S02 42.41 tons/year* NOx 93.67 tons/year* CO 90.36 tons/year* PM (all PM10) 46.65 tons/year* Volatile Organic 26.40 tons/year* Compounds CO 2 681,100 tons/year* CO = carbon monoxide CO 2 = carbon dioxide NOx = nitrogen oxides PM = particulate matter PM10 = PM having a diameter less than 10 microns SO 2 = sulfur dioxide

• Based on rolling, 12-month permits Emissions are listed based on Permit information, and are from units P001 - P006, combined (including startups/shutdowns), which equates to 804 MW (134 MW x 6 units).

Equipment

Description:

Each Combustion Train - 589MMBtu/hr Dresser Rand natural gas fired combustion turbine (134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, water injection, and selective catalytic reduction. As explained in Section 7.2.1.3, FirstEnergy estimates that only up to four units (i.e., 536 MW) could be online by 2017. Source: NES 2010 Page 7.3-33 September 2011 Environmental of Alternatives Impacts of Environmental Impacts Alternatives Page 7.3-33 September 2011

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Davis-Besse Nuclear Power Station License Renewal Application Environmental Report

7.4 REFERENCES

Note to reader: This list of references identifies web pages and associated URLs where reference data were obtained. Some of these web pages may likely no longer be available or their URL addresses may have changed. FENOC has maintained hard copies of the information and data obtained from the referenced web pages. AEP 2011. AEP Ohio to Partner with Turning Point Solar on the Development of the Turning Point Solar Generating Facility in MNoble County, Website: http://www.prnewswire.com/ ..partner-with-tturning-point-on-the-development-of-the-turning-point-solar-generation-facility-in-noble-county-125021444.html, accessed September 6, 2011. AWEA 2002. Most Frequently Asked Questions About Wind Energy, American Wind Energy Association, May 2002. AWEA 2011. Wind Energy Facts: Ohio, American Wind Energy Association, July 2011. CA 2011. Machines of the Ocean: The Aesthetics od Wind Farms, Contemporary Aesthetics. Website: http://www.contempaesthetics.org/newvoIume/pages/article. php?articlel D=24 7, accessed September 7, 2011. CBS 2010. World's Largest Wind Farm Churns in Texas, CBS News, Website: cbsnews.com/stories/2009/10/02/tech/livinggreen/main5358287.shtm, accessed September 1, 2011. CWP 2007. Cape wind Energy Project Final Environmental Impact report/Development of Regional Impact, Cape wind Project, February 2007. EERE 2009a. Ohio Wind Resource Map, U.S. Department of Energy, Energy Efficiency and Renewable Energy, available at http://www.windpoweringamerica.gov/astate_template.asp?stateab=oh, accessed June 30, 2009. EERE 2009b. Pennsylvania Wind Resource Map, U.S. Department of Energy, Energy Efficiency and Renewable Energy, available at http://www.windpoweringamerica.gov/astatetemplate.asp?stateab=pa, accessed June 30, 2009. EIA 2010. Electric Power Annual 2008, DOE/EIA-0348(2008), U.S. Department of Energy, Energy Information Administration, January 2010. References Page 7.4-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC 2007. FirstEnergy Nuclear Operating Company, Beaver Valley Power Station Unit Nos. 1 and 2, License Renewal Application, Appendix E, Applicant's Environmental Report - Operating License Renewal Stage, Facility Operating License No. DPR-66 and NPF-73, Akron, OH, ADAMS Accession No. ML072470523. FirstEnergy 2008a. 2008 Annual Report, FirstEnergy Corp., Akron, Ohio, Website: http://www.firstenergycorp.com/financialreports/index.html, accessed January 12, 2010. FirstEnergy 2008b. FirstEnergy Generation System, 6/25/08, Website: http://www.firstenergycorp.com/corporate/Corporate-Profile/FirstEnergyGeneration-Sy stem.html, accessed July 13, 2009. FirstEnergy 2009a. FirstEnergy Boston Investor Meetings, June 11, 2009, Website: http://investors.firstenergycorp.com/phoenix.zhtml?c=1 02230&p=irol-presentations, accessed June 21, 2009. FirstEnergy 2009b. FirstEnergy to Repower R.E. Burger Plant With Biomass, News Release, FirstEnergy Corp., Akron, Ohio, April 1, 2009. GLWEC 2009. Final Feasibility Report, Great Lakes Wind Energy Center, April 2009. IEAWIND 2002. Summary of lEA R&D Wind - Topical Expert Meeting #40, Environmental issues of Offshore Wind Farms, September 2002. INEEL 1998. U.S. Hydropower Resource Assessment Final Report, Document DOE/ID-10430.2, Idaho National Engineering and Environmental Laboratory, December 1998. NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008. ISEP 2011. Iowa Stored Energy Park Project Terminated, Press Release, July 28, 2011. JACM2007. Supplying Baseload Power and Reducing Transmission Requirements by Interconnected Wind Farms, Journal of Applied Meteorology and Climatotology, November 2007. LEEDco 2011. About LEEDco Lake Erie Energy Development Corporation, Website. www.leedco.org/about-us/about-leedco, accessed August 10, 2011. NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008. NERC 2009. 2009 Long Tem Reliability Assessment, North American Electric Reliability Corporation, October 2009. References Page 7.4-2 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report NES 2010. Norton Energy Storage, LLC, Final Air Permit-To-Install and Operate, Ohio EPA, September 2010. NRC 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, May 1996. NRC 2002. Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, NUREG-0586 Supplement 1, Volume 1, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, November 2002. NRC 2009a. Combined License Applications for New Reactors, Website: http://www.nrc.gov/reactors/new-reactors/col.html, accessed July 13, 2009. NRC 2009b. Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GELS), NUREG-1437, Supplement 36, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, May 2009. NRC 2010. Combined License Applications for New Reactors, Website: http://www.nrc.gov/reactors/new-reactors/col.html, accessed June 18, 2010. NREL 2002. Fuel from the Sky - Solar Power's Potential for Western Energy Supply, National Renewable Energy Laboratory, July 2002. NREL 2010. Large-Scale Offshore Wind Power in the United States, National Renewable Energy Laboratory, June 2010. NREL 2010a. Assessment of Offshore Wind Energy for the United States, National Renewable Energy Laboratory, September 2010. NREL 2011. Eastern Wind Integration and Transmission Study, National Renewable Energy Laboratory, February 2011. NREL 2011 a. Estimates of Windy Land Areas and Wind Energy Potential by State, National Renewable Energy Laboratory, Updated April 13, 2011. OHPUCO 2009. Alternative Energy Portfolio Standard, Chapter 4901: 1-40, Ohio Public Utilities Commission, December 2009. PEI 2008. Compressed Air Energy Storage,: Theory, Resources, and Applications for Wind Power Energy Systems Analysis group, Princeton Environmental institute, Princeton University, April 2008. PMJ 2011. State of the Market report for PJM, Monitoring Analytics, LLC, August 2011. References Page 7.4-3 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report POST 2006. Carbon Footprint of Electricity Generation, Parliamentary Office of Science and Technology, October 2006, available at http://www.parliament.uk/documents/upload/postpn268.pdf, accessed July 8, 2009. PSEG 2010. Governor Strickland Helps Dedicate Ohio's Largest Solar Farm, Media Release from Public Service Enterprise Group, August 19, 2010. REN 2005. Assessing the Life Cycle of Wind turbine Production, Renewable Energy World, Website. www.renewableenergyworld.com/rea/news/article/2005/04/assessing - the-life-cycle-of-wind-turbine-production-25113, accessed August 6, 2011. RES 2005. The Economic Impact of CAES on Wind in TX, OK, and NM, Ridge Energy Storage & Grid Services, L.P., June 2005. RWC 2010. Roscoe Wind Council, Website: http://www.roscoewind.org/roscoewind-farm/php,_ accessed September 11, 2011. SWAY 2010. Norway to Build the World's Largest Wind Turbine, Website. http://inhabitat.com/norway-to-build-the-worlds-largest-wind-tu rbine, accessed September 1,2011. TBM 2011. lberdrola Sells Energy from Blue Creek Wind Farm project, Times Bulletin Media, February 9, 2011, Website: http://www.timesbuiletin.com/main.asp?SectionlD=2&SubsectionlD=4&ArticlelD=1 6433 9. TEP2006. Photovoltaic Power Experience at Tucson Electric Power, Sandia National Laboratories and Tucson Electric Power Company, April 2006. USDOE 1999. Executive Summary, Clean Coal Technology Evaluation Guide - Final Report, December 1999, available at http://www.netl.doe.gov/technologies/coalpower/cctc/ccpi/bibliography/program/bibp-ev. html, accessed June 26, 2009. USDOE 2009a. Installed U.S. Wind Capacity and Wind Project Locations, Website: http://www.windpoweringamerica.gov/windinstalledcapacity.asp, accessed July 9, 2009. USDOE 2011. A national Offshore Wimd Strategy: Creating an Offshore Wind Energy Industry in the United States, U.S. Department of Energy, February 2011. USDO 2011. News Release - Salazar Announces Additional Steps Towards Smarter Development of Renewable Energy on U.S. Public Land, United States Department of Interior, February 8, 2011. References Page 7.4-4 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report USDOE 2009b. Future Fuel Cells R&D, U.S. Department of Energy, Office of Science and Technology, Website: http://www.fossil.energy.gov/programs/powersystems/fuelcells/, accessed June 30, 2009. USDOE 2010. Monthly Nuclear Generation by State and Reactor, 2008, U.S. Department of Energy, Energy Information Administration, Website: http://www.eia.doe.gov/cneaf/nuclear/page/nucgeneration/gensum.html, accessed January 12, 2010. USEPA 2009a. Electricity from Municipal Solid Waste, U.S. Environmental Protection Agency, Website: http://www.epa.gov/cleanenergy/energy-and-you/affect/municipal-sw.html, accessed June 30, 2009. USEPA 2009b. EPA's Response to the TVA Kingston Fossil Fly Ash Release, U.S. Environmental Protection Agency, Region 4, May 11, 2009. USFWS 2002. Migratory Bird Mortality, United States Fish and Wildlife Service, January 2002. USFWS 2011. United States Fish and Wildlife Service - Draft Land-Based Wind Energy Guidelines, February 2011. WGA 2011. Timber Road Wind Farm in Ohio, Wind Action Group, Website. http://wagengin eering. blog spot. com/2011 /05/tim ber-road-wind-fa rm-in-ohio. html, accessed September 1, 2011. WTE 2007. 2007 Directory of Waste-to-Energy Plants in the United States, Waste-to-Energy Resources, Energy Recovery Council, Website: http://www.wte.org/waste-energy-resources-a2985, accessed June 30, 2009. September 2011 Page 7.4-5 References References Page 7.4-5 September 2011

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Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 8.0 COMPARISON OF ENVIRONMENTAL IMPACT OF LICENSE RENEWAL WITH THE ALTERNATIVES Regulatory Requirement: 10 CFR 51.45(b)(3)

       "To the extent practicable, the environmental impacts of the proposal and the alternatives should be presented in comparative form." as adopted by 10 CFR 51.53(c)(2)."

FENOC presents its evaluations of the environmental impacts of Davis-Besse license renewal in Chapter 4 and reasonable alternatives in Chapter 7. In this chapter, FENOC provides a comparative summary of these impacts. Table 8.0-1 summarizes environmental impacts of the proposed action (license renewal) and the alternatives, for comparison purposes. The environmental impacts compared in Table 8.0-2 are those that are either Category 2 issues for the proposed action or are issues that the GElS (NRC 1996) identified as major considerations in an alternatives analysis. For example, although the NRC concluded that air quality impacts from the proposed action would be small (Category 1), the GElS identified major human health concerns associated with air emissions from alternatives (Section 7.2.2). Therefore, Table 8.0-1 compares air quality impacts from the proposed action to the alternatives. Table 8.0-2 is a more detailed comparison of the alternatives. As shown in Table 8.0-1 and Table 8.0-2, environmental impacts of the proposed action (Davis-Besse license renewal) are expected to be SMALL for all impact categories evaluated. In contrast, FENOC expects that environmental impacts in some impact categories would be MODERATE or MODERATE to LARGE for the no-action alternative (NRC decision not to renew Davis-Besse operating license), considered with or without development of replacement generation facilities. As codified in the NRC regulations at 10 C.F.R. § 51.95(c)(4), "the NRC staff, adjudicatory officers, and Commission shall determine whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decision makers would be unreasonable." The Commission explained this standard as follows: Given the uncertaintiesinvolved and the lack of control that the NRC has in the choice of energy alternativesin the future, the Commission believes that it is reasonableto exercise its NEPA authority to reject license renewal applicationsonly when it has determined that the impacts of Comparison of Environmental Impact of Page 8.0-1 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report license renewal sufficiently exceed the impacts of all or almost all of the alternativesthat preserving the option of license renewal for future decision makers would be unreasonable. Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, 61 Fed. Reg. 28,467, 28,473 (June 5, 1996). FENOC concludes that the environmental impacts of the continued operation of Davis-Besse, providing approximately 910 MWe of base-load power generation through 2037, when compared to alternatives discussed in Section 7.0 of this Environmental Report, demonstrate that preserving license renewal as an option is not unreasonable. Comparison of Environmental Impact of Page 8.0-2 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-1: Impacts Comparison Summary 1 No-Action Alternatives( ) Proposed Impact(') Action Base With With (License (Decommissioning) With Coal-Fired With Gas-Fired Interconnected Renewable & Renewal) Generation Generation Wind CAES Generation MODERATE to SMALL to MODERATE to Land Use SMALL SMALL LARGE MODERATE MDRT LARGE LARGE AG AG Water Quality SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE Air Quality SMALL SMALL MODERATE MODERATE(3 ) SMALL MODERATE Ecological SMALL SMALL MODERATE MALL to S MALL to LARGE MODERATE to Resources MODERATE LARGE Human Health SMALL SMALL SMALL SMALL SMALL SMALL Socioeconomics SMALL SMALL MODERATE MODERATE SMALL to SMALL to MODERATE MODERATE Waste Magee SMALL SMALL MODERATE SMALL SMALL SMALL Management SMALL to SMALL to SMALL to Aesthetics SMALL SMALL MODERATE MODERATE MODERATE SMALL Cultural Resources SMALL SMALL SMALL SMALL SMALL SMALL Comparison of Environmental Impact of Page 8.0-3 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Notes: (1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at a greenfield site would exceed those for a coal-fired or gas-fired plant located at a brownfield, i.e., existing disturbed site. (2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-i, Footnote 3:

    - SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.
    - MODERATE - Environmental effects are sufficient to alter noticeably, but not destabilize, any important attribute of the resource.
    - LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

(3) Moderate, but less than with coal-fired generation. Comparison of Environmental Impact of Page 8.0-4 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail No-Action Alternativest 1 )' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Generattion Wind Generation GCato Alternative Descriptions Davis-Besse license Decommissioning New construction at New construction at New construction at New construction renewal for 20 years, following expiration of greenfield (but greenfield (but greenfield locations, at greenfield (wind, followed by current Davis-Besse preferably brownfield) preferably brownfield) and solar) CAES at decommissioning license. Adopting by site. site. brownfield site. reference, as bounding Pulverized coal units, Combined-cycle units, Wind generation Assume CAES with Davis-Besse decommissioning, GElS 910-MW (equivalent 910-MW (equivalent units, 910-MW natural gas units at description (NRC 1996, to Davis-Besse); to Davis-Besse); (equivalent to electrical output of Section 7.1). capacity factor 0.80. capacity factor 0.80. Davis-Besse); 804 MW (6 trains). capacity factor 0.80. Closed-cycle cooling Closed-cycle cooling No cooling required. Closed-cycle with 500-foot-tall with mechanical-draft cooling with natural-draft cooling cooling towers. mechanical-draft towers. cooling towers for CAES. Coal and limestone Delivery of natural gas No fuel delivery Delivery of natural delivery via waterway via a new 10-mile- system required. gas via a new or rail. long pipeline. 10-mile-long pipeline for CAES. Comparison of Environmental Impact of Page 8.0-5 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(1 )' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation GenertionGeneration Wind Generation &CaES Air emission controls: Air emission controls: No air emission Air emission Particulates: fabric Nitrogen oxides: dry controls required. controls: Nitrogen filter (99.9% removal) low-NOx burners; oxides: dry low-Sulfur oxide: wet selective catalytic NOx burners; limestone scrubber reduction (90% selective catalytic (95% removal) removal). Particulate reduction (90% Nitrogen oxide: matter and carbon removal). low-NOx burners, monoxide emissions Particulate matter overfire air, selective limited through proper and carbon catalytic reduction combustion controls. monoxide (95% removal), emissions limited through proper combustion controls for CAES. Emissions dispersed Exhaust dispersed via No emissions or Exhaust dispersed via 500-foot-tall 150-foot-tall stacks. heat plume exhaust. via 150-foot-tall (or stacks. less) stacks. 825 permanent and Estimated workforce: Estimated workforce: Estimated Estimated 60 contract workers Construction: 1,092 - Construction: 1,092 - workforce: workforce: (Section 3.4) 2,275; Operation: 228 2,275; Operation: 137 Construction: 1,200 Construction: 1,200

                                                                                              - 1,500; Operation:      - 1,500; Operation:

150. 150. Comparison of Environmental Impact of Page 8.0-6 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternativestt 1 (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAES Generation Generation Wind Generation Generation Land Use Impacts SMALL - Adopting by SMALL - Adopting by MODERATE to SMALL to MODERATE to LARGE - up to reference Category 1 reference applicable LARGE - 1,547 acres MODERATE - 100 LARGE - Would be 91,000 acres issue findings NRC impact conclusions required for the acres for facility and dependent on how required for wind (Table A-i, Issues 52, in the GElS Section 8.4 powerblock and 240 to 270 additional many wind farms and 37,900 acres 53). and Supplement 1 to associated facilities; acres for gas pipeline onshore verses for solar generation NUREG-0586. assumed 10 miles of and electric offshore and associated 345-kV transmission transmission lines (Section 7.3.3). facilities; line on a 150-foot (Section 7.3.2). (Section 7.3.3). right-of-way; 22 acres/MW for mining and disposal (Section 7.3.1). Comparison of Environmental Impact of Page 8.0-7 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(11 ' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation GenertionGeneration Wind Generation &CaES Water Quality Impacts SMALL - Adopting by SMALL - Adopting by SMALL - SMALL - SMALL - SMALL to reference Category 1 reference Category 1 Construction impacts Construction impacts Construction MODERATE - issue findings (Table issue finding (Table A-i, minimized by minimized by impacts minimized Construction A-i, Issues 1-3, 6-11, Issue 89) in the GElS regulatory controls; regulatory controls; by regulatory impacts minimized and 31). Five Chapter 7 and operation-phase cooling water and controls by regulatory Category 2 water Section 8.4, and in impacts similar to wastewater (Section 7.3.3). controls; cooling quality issues do not Supplement 1 to those of Davis-Besse; discharges subject to water and apply: Section 4.1, NUREG-0586. cooling water and regulatory controls wastewater Issue 13; Section 4.6, wastewater (Section 7.3.2). discharges subject Issue 34, Section 4.5, discharges subject to to regulatory Issue 33; Section 4.7, regulatory controls controls Issue 35; and (Section 7.3.1). (Section7.3.3). Section 4.8 Issue 39. Comparison of Environmental Impact of Page 8.0-8 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(')' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation GenertionGeneration Wind Generation Gnato Air Quality Impacts SMALL - Adopting by SMALL- Adopting by MODERATE - MODERATE - SMALL - MODERATE - reference Category 1 reference Category 1 8,267 tons SOx/year 13.3 tons S0 2/year Construction 42.41 tons issue finding issue findings 5,087 tons NOx/year 205 tons NOx/year impacts minimized S0 2/year (Table A-i, Issue 51). (Table A-i, Issue 88) in 636 tons CO/year 311 tons CO/year by regulatory 93.67 tons One Category 2 issue the GElS Chapter 7 and 153 tons PM/year 39.4 tons PM/year controls NOx/year does not apply: Section 8.4, and in 34.3 tons PM 10/year 2.28x10 6 tons (Section 7.3.3). 90.36 tons CO/year Section 4.11, Supplement 1 to 7.63x10 6 tons C0 2/year 46.65 tons PE/year Issue 50. NUREG-0586. C0 2/year (Section 7.3.2). 26.40 tons (Section 7.3.1). VOCs/year 681.1 x10 3 tons of C0 2/year (Section 7.3.3). Comparison of Environmental Impact of Page 8.0-9 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(')' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAES Generation Generation Wind Generation Generation Ecological Resource Impacts SMALL - Adopting by SMALL - Adopting by MODERATE - SMALL to SMALL to MODERATE to reference Category 1 reference Category 1 Potential loss or MODERATE - MODERATE - LARGE- Potential issue findings issue finding alteration of more Approximately 100 Habitat and loss or alteration of (Table A-i, Issues (Table A-i, Issue 90) in than 1,500 acres of acres onsite and 240 migratory impacts more than 90,000 14-24, 28-30, 41-43, the GElS Chapter 7 and habitat (e.g., to 270 acres offsite of would be greater for acres of habitat and 45-48). Three Section 8.4, and in transmission, waste largely agricultural land based wind (e.g., wind and Category 2 issues do Supplement 1 to disposal landfill); land would be farms then offshore solar facilities, not apply: NUREG-0586. facilities siting would converted to industrial wind farms (e.g., transmission); Section 4.2, Issue 25; be subject to use for plant site and wind facilities, facilities siting Section 4.3, Issue 26; regulatory controls offsite infrastructure, transmission); would be subject to and Section 4.4, limiting impacts to respectively; facilities facilities siting would regulatory controls Issue 27. ecological resources, siting would be be subject to limiting impacts to including wetlands subject to regulatory regulatory controls ecological and threatened or controls limiting limiting impacts to resources, endangered species. impacts to ecological ecological including wetlands Impact on aquatic resources, including resources, including and threatened or habitats and biota wetlands and wetlands and endangered from dredging (e.g., threatened or threatened or species for intake and endangered species. endangered species (Section 7.3.3). discharge structures Potential for impacts (Section 7.3.3). and, if applicable, to aquatic resources barge terminal), from construction and cooling water operation (e.g., withdrawal, and cooling water discharge would be withdrawal and Comparison of Environmental Impact of Page 8.0-10 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(')' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAES Generation Generation Wind Generation Generation subject to regulatory discharge) reduced by controls best management (Section 7.3.1). practices and regulatory controls (Section 7.3.2). Threatened or Endangered Species Impacts SMALL - Federally SMALL - Not an impact SMALL - Federal and SMALL - Federal and SMALL - Federal SMALL - Federal and state threatened evaluated by the GEIS. state laws prohibit state laws prohibit and state laws and state laws or endangered destroying or destroying or prohibit destroying prohibit destroying species are protected adversely affecting adversely affecting or adversely or adversely through company and protected species and protected species and affecting protected affecting protected plant procedures. their habitats. their habitats. species and their species and their (Section 4.10, habitats. habitats. Issue 49) 1 Comparison of Environmental Impact of Page 8.0-11 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(')' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAES Generation Generation Wind Generation Generation Human Health Impacts SMALL - Adopting by SMALL- Adopting by SMALL - Some risk of SMALL - Similar to SMALL SMALL - Similar to reference Category 1 reference Category 1 cancer and the coal-fired (Section 7.3.3). the gas-fired issues (Table A-i, issue finding (Table A-i, emphysema from air alternative alternative (CAES Issues 54-56, 58, 61, Issue 86) in the GElS emissions and risk of (Section 7.3.2). plant) 62). One Category 2 Chapter 7 and accidents to workers, (Section 7.3.3). issue does not apply: Section 8.4, and in as the NRC notes in Section 4.12, Supplement 1 to the GELS. Issue 57. Risk due to NUREG-0586. Assumed that transmission-line regulatory controls induced currents would reduce risks to minimal due to acceptable levels conformance with (Section 7.3.1). consensus code (Section 4.13, Issue 59). __1___1_1 Comparison of Environmental Impact of Page 8.0-12 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(1 )' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAES Generation Generation Wind Generation Generation Socioeconomic Impacts SMALL - Adopting by SMALL - Adopting by MODERATE to MODERATE - MODERATE - MODERATE - reference Category 1 reference Category 1 Reduction in Reduction in Reduction in Reduction in issue findings issue finding (Table A-i, permanent work force permanent work force permanent work permanent work (Table A-i, Issues 64, Issue 91) in the GElS and tax base at and tax base at force and tax base force and tax base 67). Two Category 2 Chapter 7 and Davis-Besse would Davis-Besse would at Davis-Besse at Davis-Besse issues do not apply: Section 8.4, and in adversely affect adversely affect would adversely would adversely Section 4.16, Issue 66 Supplement 1 to surrounding surrounding affect surrounding affect surrounding and Section 4.17.1, NUREG-0586. communities. communities. communities. communities. Issue 68. Location in Construction and Impacts from Impacts from Impacts from high population area operational impacts construction would be construction would construction would with no growth would depend upon mitigated by siting be mitigated by be mitigated by controls minimizes the site location. plant within siting renewable siting renewable potential for housing Regulatory controls commuting distance facilities within facilities within impacts (Section 4.14, and appropriate of large metropolitan commuting distance commuting Issue 63). mitigation would areas (Section 7.3.2). of metropolitan distance of Capacity of public ensure that impacts areas when possible metropolitan areas water supply as well are not destabilizing (Section 7.3.3). when possible as education and (Section 7.3.1). (Section 7.3.3). transportation infrastructures minimizes potential for related impacts (Section 4.15, Issue 65; Section 4.16, Issue 66; and Section Comparison of Environmental Impact of Page 8.0-13 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(')' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation GenertionGeneration Wind Generation &CaES 4.18, Issue 70). Plant tax payments range from <10% to nearly 20% of local jurisdictions tax revenues (Section 4.17.2, Issue 69). 1 1 1 1 Waste Management Impacts SMALL - Adopting by SMALL - Adopting by MODERATE - Annual SMALL - Solid waste SMALL - Solid SMALL - Solid reference Category 1 reference Category 1 waste of is minimal (Section waste is minimal waste is minimal issue findings issue finding Table A-i, approximately 7.3.2). (Section 7.3.3). (Section 7.3.3). (Table A-i, Issue 87) in the GElS 300,000 tons ash and Issues 77-85). Chapter 7 and 470,000 tons flue gas Section 8.4, and in desulphurization Supplement 1 to waste, requiring NUREG-0586. disposal offsite in a 644-acre landfill over an assumed 40-year plant life (Section 7.3.1). Comparison of Environmental Impact of Page 8.0-14 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(1 )' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAES Generation Generation Wind Generation Generation Aesthetic Impacts SMALL - Adopting by SMALL - Adopting by SMALL to SMALL to SMALL to SMALL - Aesthetic reference Category 1 reference conclusions in MODERATE - Highly MODERATE - Highly MODERATE - impacts are issue findings (Table the GElS Section 8.4 dependent on dependent on Highly dependent on minimal A-i, Issues 73, 74). and Supplement 1 to location. Stacks, location. Stacks, location of wind (Section 7.3.3). NUREG-0586. cooling tower plumes cooling tower plumes farms likely would be visible would be visible (Section 7.3.3). for several miles. offsite (Section 7.3.2). Operation of waste disposal site would have adverse impact potential (Section 7.3.1). Cultural Resource Impacts SMALL -License SMALL - Adopting by SMALL - Siting of SMALL - Same as SMALL - Cultural SMALL - Cultural renewal does not reference conclusions in plant and offsite the coal-fired resource impacts resource impacts require additional land the GElS Section 8.4 infrastructure (e.g., alternative (Section are minimal are minimal disturbance (Section and Supplement 1 to transmission line, 7.3.2). (Section 7.3.2). (Section 7.3.2). 4.19, Issue 71). NUREG-0586. natural gas pipeline) would be subject to regulatory review, and mitigation measures would be implemented (Section 7.3.1). Comparison of Environmental Impact of Page 8.0-15 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Btu = British thermal unit CO = carbon monoxide CO 2 = carbon dioxide ft 3 = cubic foot GElS = Generic Environmental Impact Statement (NRC 1996) kWh = kilowatt hour lb = pound MM = million MW = megawatt NOx = nitrogen oxides PM = particulate matter PM 10 = particulates having diameter less than 10 microns Notes: (1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at a greenfield site would exceed those described in the table for a coal-fired or gas-fired plant located at a brownfield, i.e., existing disturbed site. (2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-I, Footnote 3:

      - SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.
      - MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize, any important attribute of the resource.
      - LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

Comparison of Environmental Impact of Page 8.0-16 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report

8.1 REFERENCES

NES 2010. Norton Energy Storage, LLC, Final Air Permit-To-Install and Operate, Ohio EPA, September 2010. NRC 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, May 1996. References Page 8. 1-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report [This page intentionally blank] Page 8.1-2 September 2011 References References Page 8.1-2 September 2011

Enclosure B Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) Letter L-11-289 FENOC Annotation of Amendment No. 16 to the DBNPS License Renewal Application to Facilitate NRC Review 86 Pages (not including this cover page) License Renewal Application Sections Affected Appendix E, Chapter 7 Appendix E, Chapter 8 This Enclosure provides a copy of the Amendment provided in Enclosure A (Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application, Appendix E, "Applicant's Environmental Report, Operating License Renewal Stage," Chapters 7 and 8) that shows the changes in redline (or tracked-changes) format to facilitate NRC review.

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.0 ALTERNATIVES TO THE PROPOSED ACTION Regulatory Requirement: 10 CFR 51.45(b)(3) The environmental report shall discuss "Alternatives to the proposed action." [adopted by reference at 10 CFR 51.53(c)(2)]. 7.0.1 OVERVIEW This chapter assesses alternatives to the proposed renewal of the Davis-Besse operating license. It includes discussions of the no-action alternative and alternatives that meet system generating needs. Descriptions are provided in sufficient detail to facilitate comparison of the impacts of the alternatives to those of the proposed action. In considering the level of detail and analysis that it should provide for each category, FENOC relied on the NRC decision-making standard for license renewal:

    ... the NRC staff, adjudicatory officers, and Commission shall determine whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decision makers would be unreasonable.

[10 CFR 51.95(c)(4)] As noted in 10 CFR 51.53(c)(2), a discussion is not required of need for power or economic costs and benefits of the proposed action or of alternatives to the proposed action except insofar as such costs and benefits are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation. Section 7.1 addresses the "no-action" alternative in terms of the potential environmental impacts of not renewing the Davis-Besse operating license, independent of any actions taken to replace or compensate for the loss of generating capacity. Section 7.2 describes feasible alternative actions that could be taken, which FENOC also considers to be elements of the no-action alternative, and presents other alternatives that FENOC does not consider to be reasonable. Section 7.3 presents the environmental impacts for the reasonable alternatives. The environmental impact evaluations of alternatives presented are intended to provide enough information to support NRC decision-making by demonstrating whether an alternative would have a smaller, comparable, or greater environmental impact than the proposed action. Additional detail or analysis was not considered useful or necessary if it would identify only additional adverse impacts of license renewal alternatives; i.e., information beyond that necessary for a decision. This approach is consistent with the CEQ regulations, which provide that the consideration of alternatives (including the Alternatives to the Proposed Action Page 7.0-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report proposed action) be adequately addressed so reviewers may evaluate their comparative merits (40 CFR 1502.14(b)). The characterization of environmental impacts in this chapter applies the same definitions of "SMALL," "MODERATE," and "LARGE" used in Chapter 4 of this ER and by the NRC in the GElS (NRC 1996). Chapter 8 presents a summary comparison of environmental impacts of the proposed action and alternatives. 7.0.2 REGION OF INTEREST NRC environmental guidance for siting new reactors defines the "Region of interest" (ROI) as "the geographic area considered in searching for candidate sites." NUREG-1 555, at 9.3-1 (1999). That definition is not directly applicable to this license renewal action because Davis-Besse is already sited as an operating reactor in Ohio. The application here is for license renewal, and not for initial plant siting, construction. or operation. However, that same environmental guidance explains that "the basis for an ROI is the State in which the proposed site is located or the relevant service area for the Proposed plant." NUREG-1555, at 9.3-2. This explanation, or basis for selecting the ROI for siting new reactors, is applicable for defining the ROI for purposes of license renewal, Accordingly, FENOC is adopting an ROI for this Environmental Report as the State in which Davis-Besse is located: Ohio. The second portion of the explanation in NUREG-1 555--the relevant service area for the proposed plant"-is not applicable to Davis-Besse, because the electricity that Davis-Besse generates is sold on the wholesale power market. Accordingly, there is no "relevant service area" for the plant. Page 7.0-2 September 2011 I Alternatives to the Proposed Action

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.1 NO-ACTION ALTERNATIVE FENOC considers the no-action alternative is not to renew the Davis-Besse operating license. With this alternative, FENOC expects Davis-Besse would continue to operate until the expiration of the existing operating license in 2017, at which time plant operations would cease, decommissioning would begin, and FirstEnergy or others would take the appropriate actions to meet system-generating needs created by discontinued operation of the plant. Section 7.1.1 addresses the impacts of terminating operations and decommissioning, whereas Section 7.1.2 discusses the actions to replace power from Davis-Besse. 7.1.1 TERMINATING OPERATIONS AND DECOMMISSIONING In the event the NRC does not renew the Davis-Besse operating license, FENOC assumes for this ER that itwould operate the plant until the current license expires, then terminate operations and initiate decommissioning activities in accordance with NRC requirements. For purposes of this discussion, terminating operations includes those actions directly associated with permanent cessation of operations, which may result in more or less immediate environmental impacts (e.g., socioeconomic impacts from reduction in employment and tax revenues). Decommissioning, as defined in the GELS, is the safe removal of a nuclear facility from service and the reduction of residual radioactivity to a level that permits release of the property for unrestricted use and termination of the license (NRC 1996, Section 7.1). The two decommissioning options typically selected for United States reactors are rapid decontamination and dismantlement (DECON), and safe storage of the stabilized and de-fueled facility (SAFSTOR), followed by final decontamination and dismantlement (NRC 1996, Section 7.2.2). Under the DECON option, radioactively contaminated portions of the facility and site are decontaminated or removed promptly after cessation of operations to a level that permits termination of the license; these activities require several years for large light-water reactors like Davis-Besse (NRC 1996, Table 7.8). The SAFSTOR option involves safe storage of the stabilized and defueled facility for a period of time followed by decontamination to levels that permit license termination. Regardless of the option selected, decommissioning typically must be completed within 60 years after operations cease in accordance with NRC requirements at 10 CFR 50.82 (NRC 1996, Section 7.2.2). FENOC has not selected a decommissioning method for Davis-Besse. The decommissioning method for Davis-Besse would be described in post-shutdown decommissioning plans for the plant, which must be submitted to NRC within two years following cessation of operations. For purposes of the present analysis, FENOC assumes that the DECON option would be employed upon license termination. I No-action Alternative Page 7.1-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report The NRC presents in Chapter 7 and Section 8.4 of the GElS a summary of generic environmental impacts of the decommissioning process and an evaluation of potential changes in impact that could result from deferring the decommissioning process for up to 20 years (NRC 1996). For a pressurized water reactor decommissioning, NRC used a 1,175 MWe reference reactor. Although larger than Davis-Besse (910 MWe), FENOC considers the reference reactor to be representative of Davis-Besse. As a result, FENOC believes the decommissioning activities described in the GElS to be representative of activities FENOC would perform for decommissioning at Davis-Besse. The NRC concluded from its evaluation that decommissioning impacts would not be significantly greater as a result of the proposed action, assumed to result in 20 additional years of operation (NRC 1996, Sections 7.3 and 8.4). The NRC conclusions also indicate that the impacts of the decommissioning process itself, addressed in this ER as part of the no-action alternative, would have SMALL impacts with respect to radiation dose, waste management, air quality, water quality, and ecological resources (see 10 CFR Part 51, Subpart A, Appendix B, Table B-1). FENOC considers this generic evaluation and associated conclusions applicable to Davis-Besse as well. The NRC has provided additional analysis of the environmental impacts associated with decommissioning in the Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (NRC 2002). Except for issues that require site-specific evaluation, environmental impacts, including radiological releases and doses from decommissioning activities, were assessed to be SMALL (NRC 2002, Sections 4.3 and 6.1). Regardless of the NRC decision on license renewal, FENOC will have to decommission Davis-Besse; license renewal would only postpone decommissioning for an additional 20 years. In the GELS, the NRC concludes that there should be little difference between the environmental impacts from decommissioning at the end of 40 years of operation versus those associated with decommissioning after an additional 20 years of operation under a renewed license (NRC 1996, Section 7.4). By reference, FENOC adopts the NRC findings regarding environmental impacts of decommissioning in the license renewal GElS (NRC 1996) and in the decommissioning GElS (NRC 2002), and concludes that environmental impacts under the no-action alternative would be similar to those that occur following license renewal. Further, FENOC believes that decommissioning activities would not involve significant land-use disturbance offsite or significant activities beyond current operational areas that would offer potential for impacts on land use, ecological resources, or cultural resources. Decommissioning impacts would be temporary and occur at the same time as those associated with the operation of replacement generating sources. I No-action Alternative Page 7.1-2 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.1.2 REPLACEMENT CAPACITY Davis-Besse is a base-load generator of electric power, with a net generating capability of 908 MWe (Section 3.1.2). In 2008, Davis-Besse generated approximately 8.3% of FirstEnergy's total base-load electricity generation (FirstEnergy 2008a, Page 7; USDOE 2010). The power produced by Davis-Besse, which represents a significant portion of the electricity FirstEnergy supplies to 2.1 million customers in its service territories located in Ohio (FirstEnergy 2009a, Page 81), would be unavailable in the event the Davis-Besse operating license is not renewed. As provided in 10 CFR 51.53(c)(2), FENOC does not consider the need for power from Davis-Besse in this analysis, but does consider the potential impact of alternatives for replacing this power. Replacement options considered include building new base-load generating capacity, purchasing power, delaying retirement of non-nuclear assets, and reducing power requirements through demand reduction, as discussed in Section 7.2. I No-action Alternative Page 7.1-3 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report [This page intentionally blank] I No-action Alternative Page 7.1-4 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.2 ALTERNATIVES THAT MEET SYSTEM GENERATING NEEDS Ifthe Davis-Besse operating license is not renewed, then the State of Ohio, FirstEnergy Corp. and its subsidiary companies, and other participants in the wholesale power market would lose approximately 910 MWe of base-load capacity. Renewal would preserve the option of relying on Davis-Besse to meet future electric power needs through the period of extended operation. While many methods are available to generate electricity, the GElS indicates that a "reasonable set of alternatives should be limited to analysis of single, discrete electric generation sources and only electric generation sources that are technically feasible and commercially viable" (NRC 1996, Section 8.1). Considering that Davis-Besse serves as a large base-load generator, FENOC considers reasonable alternatives to be those that would also be able to generate base-load power. FENOC believes that any alternative would be unreasonable if it did not consider replacement of the energy resource. 7.2.1 ALTERNATIVES CONSIDERED AS REASONABLE Fossil-Fuel Alternatives Summary FENOC believes that coal-fired and gas-fired generation capacity are feasible alternatives to nuclear power generating capacity, based on current (and expected) technological and cost factors, as compared to the other alternatives listed in the GElS (NRC 1996, Section 8.1). FENOC considers the coal-fired and gas-fired technologies reasonable alternatives for purposes of this analysis to replace Davis-Besse generating capacity in the event its operating license is not renewed. The GEIS further notes that - - Deleted: FENOC considers the other technologies listed in the GElS as not natural gas combined-cycle plants are particularly efficient and are used as base-load reasonable alternatives for the facilities (NRC 1996, Section 8.3.10). The specific coal-generating technologies that reasons discussed in Section 7.2.2.¶, would represent viable alternatives are less certain, particularly in view of potentially higher air emissions compared to natural gas firing. For example, large-capacity integrated gasification combined-cycle (IGCC) and fluidized-bed-combustion (FBC) technologies (atmospheric and pressurized) are at or near commercial viability and could prove to be appropriate replacements. However, modern pulverized coal plants with advanced, clean-coal technology air emission controls represent currently proven technology and are economically competitive and commercially available in large-capacity unit sizes that could effectively replace Davis-Besse. Therefore, FENOC uses a representative plant of this type for purposes of impact evaluation, noting that air emission impacts of IGCC and FBC options may be lower than modern pulverized coal, but would be higher than the gas-fired combined-cycle alternative (USDOE 1999, Pages 5-7). "910 MWe is used for calculation convenience instead of 908 Mwe, as noted in Section 3.1.2. Alternatives that Meet System Page 7.2-1 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Renewable Energy Alternatives Summary On April 26, 2011, an NRC Atomic Safety and Licensing Board (Board) presiding over the license renewal proceeding for Davis-Besse issued a Memorandum and Order (LBP-1 1-13) admitting a contention alleging that the FENOC analysis of renewable energy alternatives in the Environmental Report was not adequate. As admitted by the Board, the contention states: [FENOC's ER] fails to adequately evaluate the full potential for renewable energy sources, specifically wind power in the form of interconnected wind farms and/or solar photovoltaic power, in combination with compressed air energy storage, to offset the loss of energy production from Davis-Besse. and to make the requested license renewal action unnecessary. The FENOC Environmental Report (Section 7.2) treats all of the alternatives to license renewal except for natural gas and coal plants as unreasonable and does not provide a substantial analysis of the potential for significant alternatives in the Region of Interest. The Board's phrasing of the contention, as admitted, arguably includes the followinq renewable energy alternatives: 1) wind power in the form of interconnected wind farms:

2) wind power in the form of interconnected wind farms with compressed air energy storage (CAES): 3) solar (photovoltaic) power combined with CAES: or 4) a combination of interconnected wind farms and solar (photovoltaic) power with CAES.

FENOC does not believe that any of these are "reasonable" alternatives under NEPA. However, in order to resolve the issues raised in the admitted contention, FENOC has revised this ER to evaluate the renewable energy alternatives listed above as an alternative to replace the rated electrical output of Davis-Besse by 2017. FENOC considers the other technologies listed in the GElS as not reasonable alternatives for the reasons discussed in Section 7.2.2. Disclaimer Throughout Chapters 7 & 8. FENOC presents information about renewable energy resources compiled by others. FENOC has not independently confirmed the accuracy of these statements, nor does FENOC agree with them. Additionally, FENOC does not agree that the renewable energy alternatives listed above can provide base-load generation or that the existing and any interstate transmission system available by 2017 could accommodate such renewable enerqy. Finally, even if such a group of renewable resources were built, there is no way to assure that the power generated by those resources would be available to the CAES facility to create the alternative that Joint Petitioners envision. There are a number of Alternatives that Meet System Page 7.2-2 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report considerations for the development of a solar or wind resource including the availability of sufficient sun or wind, the availability of land, grid access, cost of interconnection (which may be economically prohibitive in some cases), and sufficient transmission resources to assure the CAES's ability to interact with the resource. The NRC has noted that, while there are many methods available for generating electricity and many combinations of alternative power generation sources that could provide base-load capacity, such an expansive consideration of alternatives would be too unwieldy (NRC 1996, Section 8.1).

                                                                                                 -{ Deleted: Representative 7.2.1.1      Coal-Fired Generation For purposes of this analysis, FENOC assumed development of a modern pulverized coal-fired power plant with state-of-the-art emission controls similar to that described in its license renewal application, Appendix E (Environmental Report), for the Beaver Valley Power Station (FENOC 2007, Section 7.2.2.2). In defining the Davis-Besse coal-fired alternative, FENOC has used site-specific input as appropriate.

The representative plant would consist of commercially available standard-sized units, with a nominal net output of approximately 910 MWe, and would be designed to meet applicable standards with respect to control of air and wastewater emissions. As a minimum, FENOC assumed that the plant would feature low nitrogen oxide burners with overfire air to minimize formation of nitrogen oxides, and selective catalytic reduction for post-combustion nitrogen oxide control. Emissions of particulate matter and mercury would be limited by use of a fabric filter (baghouse), and sulfur oxide emissions would be controlled using a wet scrubber using limestone as the reagent. Table 7.2-1 lists the basic specifications for the representative plant. The Davis-Besse site would not be a viable location for the representative plant as a result of space limitations (see Section 7.3.1, Land Use). Land area requirements for a coal-fired plant of similar capacity to Davis-Besse would be approximately 1.7 acres per MWe (NRC 1996, Section 8.3.9), or 1,547 acres for a 910 MWe plant. The needed land area, therefore, far exceeds the 954-acre Davis-Besse site, most of which is occupied by marshland that is leased to the U.S. Government as a national wildlife refuge (Section 2.1). Therefore, FENOC assumed for the analysis that the representative coal-fired plant would be located elsewhere at a greenfield or (preferably) brownfield site close to a commercially, navigable waterway or existing railway. A navigable waterway location would be highly desirable from a technical and economic perspective, considering the relative abundance of cooling water and low fuel cost afforded by barge transportation of coal and limestone. FENOC further assumed for the analysis that the representative coal-fired plant would use closed-cycle cooling with a natural draft cooling tower. Alternatives that Meet System Page 7.2-3 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Lastly, FENOC assumed for the analysis that the environmental impacts associated with siting, design, and operation of the plant would be subject to comprehensive review under Ohio Power Siting Board (OPSB) rules or a comparable process.

                                                                                                    -{ Deleted: Representative
                                                                          ---......................                      aiv 7.2.1.2      Glas-Fired G eneration _---- --- -- -- --- -- ---

For purposes of this analysis, FENOC assumed development of a modern natural gas-fired combined-cycle plant based on a commercially available design similar to that described in its license renewal application, Appendix E (Environmental Report), for the Beaver Valley Power Station (FENOC 2007, Section 7.2.2.1). In defining the Davis-Besse gas-fired alternative, FENOC has used site-specific input as appropriate. The representative plant would consist of commercially available standard-sized units, with a nominal net output of approximately 910 MWe, and would be designed to meet applicable standards with respect to control of air and wastewater emissions. As a minimum, FENOC assumed that the plant would use natural gas as its only fuel and feature dry low-NOx burners to minimize formation of nitrogen oxides during combustion and selective catalytic reduction for post-combustion nitrogen oxide control. Emissions of particulate matter and carbon monoxide would be limited through proper combustion controls. Table 7.2-2 lists the basic specifications for the representative plant. The Davis-Besse site is uncertain as a viable location for the representative plant due to space limitations. Land area requirements for a gas-fired plant of similar capacity to Davis-Besse, for example, would be approximately 0.11 acres per MWe (NRC 1996, Table 8.1), or 100 for a 910 MWe plant. Of the 954 acres of land occupied by the Davis-Besse site, 733 acres is occupied by marshland that is leased to the U.S. Government as a national wildlife refuge (Section 2.1). The remaining 221 acres is mostly occupied by Davis-Besse structures. Therefore, FENOC assumed for the analysis that the representative gas-fired plant would be located elsewhere at a greenfield or (preferably) brownfield site, but has not identified a specific site. However, primary considerations for a cost-competitive site include close proximity to adequate natural gas supply, transmission infrastructure, cooling water, and sufficient land suitable for development. For this analysis, FENOC assumed, based on FirstEnergy experience in gas-fired plant siting, that northwestern Ohio would be a realistic general area to locate the new plant (FENOC 2007, Section 7.2.2.1). FENOC further assumed for the analysis that the representative gas-fired plant would use closed-cycle cooling with mechanical draft cooling towers. Lastly, FENOC assumed for the analysis that the environmental impacts associated with siting, design, and operation of the plant would be subject to comprehensive review under Ohio Power Siting Board (OPSB) rules or a comparable process. Alternatives that Meet System Page 7.2-4 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.2.1.3 Renewable Energy Generation As explained above in Section 7.2.1. and subject to the disclaimers in that Section, FENOC is evaluating for the sole purpose of this NEPA analysis certain renewable energy alternatives. These alternatives are discussed in more detail below. Other renewable energy alternatives were rejected for the reasons explained below in Section 7.2.2. Interconnected Wind Farms Wind enerqy facilities use wind turbines to harness the kinetic energy of wind and transform it into electrical power. Output depends on a turbine's size and the wind's speed through the rotor as well as the availability of wind itself. Wind turbines manufactured today range from 250 watts (AWEA 2002) to 10 megawatts (MW) (SWAY 2010), and wind farms can range in capacity from a few megawatts to the 781+ megawatt Roscoe Wind Complex in Texas. (CBS 2010) Wind availability, speed and turbine height are critical factors for wind farm generating capacity. The stronger and more consistent the wind, and the taller the turbines, the higher potential capacity exists. Multiple land uses are often possible on wind farms. For example, a wind farm may generate electricity while cattle graze or corn grows on the land surrounding the turbines. (AWEA 2002) Neither a single wind turbine nor interconnected wind farms currently provide baseload power anywhere in the United States. However, the theory that multiple wind farms located throughout a region and interconnected via the grid could provide for more consistent power generation due to the reduced likelihood that all sites would experience the same wind patterns at any given time, has been studied. In one study, the benefits of interconnecting wind farms were evaluated for 19 sites located in the midwestern United States with annual average wind speeds greater than 6.9 meters per second (mWs) (class 3 or greater) at 80 m above ground, the hub height of modern wind turbines. The study reported that, on average, only 33% and a maximum of 47% of yearly-averaged wind power from interconnected wind farms could theoretically be relied upon to produce electricity. And there were days when no electricity was produced from these wind farms. (JACM 2007) Additionally, delays in the implementation of interconnected wind technology can be due to transmission line construction difficulties, as the North American Electric Reliability Corporation (NERC) explains in its 2009 Long-Term Reliability Assessment. The NERC points out that siting of new bulk power transmission lines brings with it unique challenges due to the high visibility, their span through multiple states/provinces and. potentially, the amount of coordination/cooperation required among multiple regulating agencies and authorities. Lack of consistent and agreed-upon cost allocation I Alternatives that Meet System Page 7.2-5 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report approaches, coupled with public opposition due to land-use and property valuation concerns, have, at times, resulted in long delays in transmission line construction. New transmission, including transmission in the DOE's designated "National Interest Electric Transmission Corridors" can be delayed or halted by individual states, increasing the difficulty to site bulk transmission, including those projects focused on unlocking location-constrained renewable generation. These siting issues create a potential congestion issue and challenge the economic viability of new generation proiects. (NERC 2009) In the specific case of wind power, a wind proiect must be located where it would produce economical generation, and that location may be far removed from the nearest possible connection to the transmission system. A location far removed from the power transmission grid might not be economical, as new transmission lines would be required to connect the wind farm to the distribution system, and the question of who pays for the transmission upgrade would be at issue. Existing transmission infrastructure may need to be upgraded to handle the additional supply. Soil conditions and the terrain must be suitable for the construction of the towers' foundations. Finally, the choice of a location may be limited by land use regulations and the ability to obtain the required permits from local, regional, and national authorities. Jacobs and Archer completed a study of interconnected wind farms with consisting of up to 19 wind farm sites, and concluded that maximum capacity factors of approximately 45% could theoretically be obtained (JACM 2007). Davis-Besse's recent capacity factor has been in excess of 90%, which would generate approximately 7,158,672 MWh over a full year. To achieve a similar annual average at a 45% capacity factor, interconnected wind farms with a minimum of 1210 GE 1.5 MW turbines would be required, and would not be guaranteed due to the uncontrollability of the wind availability. It must be noted, however, that the studies by Jacobs and Archer were based on areas with higher annual average wind speeds (over 8 m/s). Thus, in Ohio, it would be expected that the GE 1.5-MW turbines might not operate as efficiently and thus the number of turbines required for replacement power generation would be higher. And there would still be times when reserve capacity from traditional generation or energy storage would be required. Using larger turbines could be used if wind speeds supported their economical use, especially in offshore locations (discussed below). which would reduce land use. Since 1998-99, average turbine nameplate capacity has increased by 151%, but growth in this metric has slowed in recent years due to the dominance of GE's 1.5 MW turbine and as a result of the logistical challenges associated with transporting larger turbines to proiect sites. (USDOE 2011) There are several land based wind farms under construction or planned in Ohio. These wind farms will utilize wind turbines ranging from 1.8 MW (Timber Ridge Wind Farm) to 2.0 MW (Blue Creek Wind Farm). (WAG 2011 and TBM 2011) Alternatives that Meet System Page 7.2-6 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC reviewed several recent documents describing studies conducted by the National Renewable Energy Laboratory (NREL) related to wind integration and transmission studies for both land-based and offshore wind generating facilities (NREL 2011. NREL 2010. NREL 2010a). Based on the findings in these documents, a land-based interconnected transmission system in the central and eastern United States is likely to be completed by 2024. For the sole purpose of this NEPA analysis, however, FENOC evaluates renewable energy alternatives as if an interconnected grid system would be available by 2017. FENOC also evaluated the potential for offshore wind generation and integrating that power into the transmission system. Although both Lake Erie and Lake Michigan have significant wind resources, no offshore wind turbines have been sited in freshwater, particularly a potable water source such as the Great Lakes. (USDOE 2011) Offshore wind power project and policy developments continued in 2010: however, to date no offshore projects have been installed in the United States and the emergence of an offshore wind power market still faces many challenges. Nonetheless, interest exists in developing offshore wind energy in several parts of the country, with nine projects totaling 2322 MW of unstated capacity factors primarily located in the Northeast and Mid-Atlantic, though proposed projects also exist in the Great Lakes and Gulf of Mexico. (USDOE 2011) Many of these projects have advanced significantly in the permitting and development process, including three that have signed power purchase agreements with terms and details that have been made public. Notably, the Cape Wind project was granted approval by the Department of Interior in 2010; several significant strides relating to offshore wind energy have been made recently in the federal arena: and a variety of other recent project and state policy announcements demonstrate continued activity in the offshore wind energy sector. (USDOE 2011) In August 2009, Lake Erie Energy Development Corporation (LEEDCo) was created by the Great Lakes Energy Development Task Force (GLEDTF), then developed and launched by NorTech Energy Enterprise, the Cleveland Foundation, City of Cleveland, Cuyahoga and Lorain Counties (Ohio). It was founded as a private, non-profit regional corporation to initially build wind turbines in Lake Erie, and eventually help stimulate an entire offshore freshwater wind industry. Initially LEEDCo plans to build and install a 20-30 megawatt (MW) wind energy pilot project seven miles offshore of downtown Cleveland which would be the first offshore freshwater wind energy project in North America. LEEDco then plans to use the initial project as a road map to develop the permitting process and catalyze future offshore wind projects by commissioning the first 20-to-30 MW, five-to-seven turbines by 2013, with a long-term vision of generating 1000 MW of wind energy by 2020. (LEEDCo 2011) Despite the unlikely development of sufficient offshore wind generation as outlined above, FENOC evaluates-for the sole purpose of this NEPA analysis-wind energy I Alternatives that Meet System Page 7.2-7 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report from interconnected wind farms as if such energy was available by 2017. Therefore, FENOC evaluated the potential environmental impacts for offshore wind generation and integrating that power into the transmission system as a replacement for Davis-Besse's rated electrical output. Solar Farms Electric power generation from photovoltaic (PV) cells has been commercially demonstrated. However, because the sun only shines during the day, solar PV arrays cannot by themselves consistently Produce electricity. There is currently only one operational solar energy facility in Ohio greater than 10 MW-the 12-MWe Wyandot Solar Farm in Upper Sandusky, OH (PSEG 2010). The 49.9 MWe Turning Point Solar project near Cumberland, OH, is proiected to be completed in 2015 (AEP 2011). FENOC is not aware of other planned solar energy facilities greater than 10 MW in Ohio that would be operational by 2017, and whose output is not already dedicated to an existing commercial or industrial facility. A solar Proiect would have to be located where the proiect would produce economical generation, and that location may be far removed from the nearest possible connection to the transmission system. A location far removed from the power transmission grid might require construction of new transmission lines to connect the solar farm to the distribution system, and the question of who pays for the transmission upgrade would be at issue. Existing transmission infrastructure may need to be upgraded to handle the additional supply. Soil conditions and the terrain must be suitable for the construction of the solar farms. Finally, the choice of a location may be limited by land use requlations and the ability to obtain the required permits from local, regional, and national authorities. Although solar resources are limited in Ohio, FENOC evaluates-for the sole purpose of this NEPA analysis-solar energy combined with CAES, and combined with interconnected wind farms and CAES, as alternatives to replace the rated electrical output of Davis-Besse by 2017. Compressed Air Energy Storage FENOC is presenting the following information about CAES technology as background for the discussion that follows about CAES combined with interconnected wind farms or solar enerqy facilities. CAES can be linked with renewable energy by offering one way to supplement and back-up the electricity produced by intermittent resources such as wind and solar. This energy storage method enhances the ability of these resources to provide the electricity that customer's need, when they need it. I Alternatives that Meet System Page 7.2-8 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report However, CAES facilities are generally operated as peaking plants with energy placed into storage during the less expensive, non-peak demand hours and generated from the storage units during the higher-priced, peak demand hours. CAES involves using compressors powered by the generation source to pump air into a storage facility, such as an underground cavern. During peak demand hours, the compressed air is used in combination with a heat source, such as natural gas, to drive turbines and generate electricity. To generate electricity from CAES, natural gas usage is between one-third and one-half that needed to generate the same amount of electricity at a natural gas generating plant (USDOE 2009). Due to the cost differential between peak and non-peak hours and the reduction in the volume of natural gas used to generate a specific amount of power, a CAES facility can be an economically and environmentally attractive method of producing peaking power (RES 2005; PEI 2008). These economic benefits evaporate ifthe energy source used to pump air into the storage facility is solar power, or wind power available during the day. Since solar is a resource mostly available during the onpeak daytime hours, storage offers little economic benefit when evaluating solar (or daytime wind power) with CAES. FENOC is not aware of any existing CAES facilities that are combined solely with wind or solar power. The Iowa Stored Energy Park (ISEP) was proposed to be a 270 MW CAES facility integrated with a wind farm in Iowa. However, testing and analysis of the site geology concluded that the ability to store the air underground at the ISEP site near Dallas Center, Iowa was unfeasible. (ISEP 2011) Two CAES facilities combined with natural gas power plants, a 110-MW facility in Alabama and a 290-MW plant in Germany, have been built and are in operation (PEI 2008). A CAES facility powered with energy from generation facilities already on the power grid is proposed for Norton, Ohio. This facility, which is still in the project development stage, is planned to eventually-i.e., after 2017-provide 2700 MW of peaking power generation (PEI 2008). The Norton CAES project is somewhat different from the other CAES proiects in that a pre-existing mine on a brownfield site would be utilized. The size and the mining engineered construction of the pre-existing mine allows a much greater Planned capacity for the Norton facility as compared to other existing or proposed CAES proiects. Norton Energy Storage In 2009, FirstEnergy Generation Corp., a subsidiary of FirstEnergy Corp., purchased the rights to develop the Norton Energy Storage (NES) facility. The facility is located on a 92-acre site in Norton, Ohio. The compressed air would be stored in a 600-acre underground cavern, formerly operated as a limestone mine, which is ideal for energy storage technology. The facility would generate electricity during on-peak and intermediate periods, which would enable the more efficient operation of large, base-I Alternatives that Meet System Page 7.2-9 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report load power plants. FirstEnergy is currently developing the NES facility and it would be constructed in phases. The initial phase is designed to produce 268 MW of generation, 220 MW of compression, and 373 hours of storage using two 134 MW generators. FirstEnergy estimates that up to four units or 536 MW of generation could be online by 2017. The existing air permit for the NES facility authorizes FirstEnergy Generation Corp to expand the facility to a capacity of 804 MW (see Table 7.2-3). (NES 2010) This Project has two maior components: the above-ground equipment and the subsurface abandoned limestone mine used to store compressed air. The size of the cavern could eventually allow the project to provide up to 2700 MW of generation ifthe current air Permit could be modified. The NES facility would include two power generation units designed specifically for the CAES application. Each unit would consist of an air compressor, a motor, an expander, an associated combustor and a generator. The facility would be designed to operate on natural gas only: no fuel oil would be combusted in the turbines or in-line burners. The maior ancillary support eguipment would consist of an emergency generator, a backup diesel fire pump, and wet cooling towers to cool compressor air to be injected into storage and provide other equipment cooling. Other support equipment would include cooling water treatment systems, acid/caustic or neutralization tanks, instrument air compressors, electric driven fuel compressors, sumps, and oil/water separators. Available Alternatives for Renewable Energy Generation in Combination with Energy Storage The potential for using renewable power sources as an alternative to license renewal can be enhanced if the generation source is combined with an energy storage technoloqy, thus increasing the availability, reliability, and predictability of the delivery of power. The two renewable power generation sources evaluated in this ER are interconnected wind farms and photovoltaic solar facilities. The theory behind the combination of renewable power generation with energy storage is that when the generation capacity is available, the amount of power produced could, at times, exceed the demand for power at that time. Excess energy could be stored and returned later to the electrical grid when the renewable power generation resource is either not available or is available at a diminished level that is insufficient to satisfy the demand for power. Therefore, in order for this combination of technologies to function, the renewable energy source would have to be sized larger than the base-load power level in this case for Davis-Besse, 910 MW. The need to have generation capacity greater than base-load requirements in order to place energy into storage would cause greater environmental impacts than a generation source rated at the base-load value alone. For example, a solar or wind generation source assumed to be available for 12 hours I Alternatives that Meet System Page 7.2-10 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report every day, and a CAES facility assumed to be available to -generate electricity the remaining 12 hours in the day, would require that generation source to be rated at, and consistently produce 1820 MW in order to provide 24-hours of continuous electricity (i.e., 12 hours to provide 910 MW of generation onto the grid, and the same 12 hours to provide 910 MW to recharge the CAES facility, so that the CAES facility could feed the grid the remainder of the day). As explained in Section 7.2.1. FENOC evaluates-for the sole purpose of this NEPA analysis-renewable energy sources combined with energy storage as an alternative to replace the rated electrical output of Davis-Besse. Wind Energy GenerationCombined with CAES As of 2011. there is currently 11 MWe of wind generation in Ohio with another 406 MWe under construction. (AWEA 2011) However, Ohio has a potential wind generation capacity of nearly 55,000 MW according to the NREL (AWEA 2011 and NREL 2011a), which at a 30% capacity factor would be more than sufficient to provide power to operate a CAES facility. The 30% capacity factor is derived from PJM Interconnection (a regional transmission organization) and the U.S. Department of Energy (USDOE) (PJM 2011 and USDOE 2011. The environmental impacts of developing this type of generation alternative are evaluated in Section 7.3.3. For this combination, FENOC evaluated wind energy generating electricity for both 910 MW to replace Davis-Besse's rated output and 910 MW of storage capacity, for a total of 1820 MWe. Sufficient energy must be put into storage when the wind resources are available to account for the lack of power generation capabilities for the periods of time when adequate wind resources are unavailable. Under this alternative, natural gas would be needed to recover the energy captured in the CAES process, but would not be used as a source of supplemental power generation if wind generation or generation from the storage facility is not available for extended periods of time. Photovoltaic Power Combined with CAES As stated previously, there is currently only one operational solar energy facility in Ohio greater than 10 MW: the 12-MWe Wyandot Solar Farm in Upper Sandusky, OH. (PSEG 2010) The 49.9-MWe Turning Point Solar proiect near Cumberland, OHR is proiected to be completed in 2015. (AEP 2011) FENOC is not aware of other planned solar energy facilities greater than 10 MW in Ohio that would be operational by 2017, and whose output is not already dedicated to an existing commercial or industrial facility. As with wind, FENOC evaluated solar farms as if they were interconnected with CAES to provide electricitv to the arid. I Alternatives that Meet System Page 7.2-11 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Combinationsof Wind and Solar with CAES As referenced above, approximately 1820 MWe of base-load power would be required from renewable energy generation plus storage to account for the lack of power generation capabilities for the periods of time when adequate wind and solar resources are unavailable. FENOC evaluates-for the sole purpose of this NEPA analysis-the following a combined alternative to replace the rated electrical output of Davis-Besse by 2017: sufficient interconnected wind farms and solar (PV) facilities available with high reliability, and connected to an operating CAES facility: an operating CAES facility expanded to a capacity similar to Davis-Besse: and an interconnected grid system. The potential environmental impacts related to this scenario are presented in Section 7.3.3.3. 7.2.2 ALTERNATIVES CONSIDERED AS NOT REASONABLE The following alternatives were considered as not reasonable replacement base-load power generation for one or more reasons as listed in Section 7.2.2.1 and Section 7.2.2.2. Although several of the alternatives could be considered in combination for replacement power generation at multiple sites, they do not generally provide base-load generation, and would entail greater environmental impacts. 7.2.2.1 Alternatives Not Requiring New Generating Capacity This section discusses the economic and technical feasibility of supplying replacement energy without constructing new base-load generating capacity. Specific alternatives include:

• Conservation measures (including implementing demand side management (DSM) actions);
• Delayed retirement of existing non-nuclear plants; and
• Purchased power from other utilities equivalent to the output of Davis-Besse (i.e.,

eliminating the need for license renewal). Conservation Programs There is a variety of conservation technologies (e.g., DSM) that could be considered as potential alternatives to generating electricity at Davis-Besse. Examples include:

• Conservation Programs-homeowner agreements to limit energy consumption; educational programs that encourage the wise use of electricity.

I Alternatives that Meet System Page 7.2-12 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report

• Energy Efficiency Programs- discounted residential rates for homes that meet specific energy efficiency standards; programs providing residential energy audits and encouraging efficiency upgrades; incentive programs used to encourage customers to replace older inefficient appliances or equipment with newer versions that are more efficient.
• Load Management Programs - programs that encourage customers to switch load to customer-owned standby generators during periods of peak demand; programs that encourage customers to allow a portion of their load to be interrupted during periods of peak demand.

On a national basis, DSM has shown great potential in reducing peak demand (maximum power requirement of a system at a given time). In 2008, a peak load reduction of 32,741 MWe was achieved nationally, which is an increase of 8.2% from 2007; however, since these DSM costs increased by 47.4%. DSM costs can vary significantly from year to year because of business cycle fluctuations and regulatory changes. Since costs are reported as they occur, while program effects may appear in future years, DSM costs and effects may not always show a direct relationship. Since 2003, nominal DSM expenditures have increased at 22.9% average annual growth rate. During the same period, actual peak load reductions have grown at a 6.2% average annual rate from, 22,904 MW to 32,741 MW (EIA 2010, Page 9). In Ohio, as part of Senate Bill 221, utilities must implement energy efficiency programs that, beginning in 2009, achieve energy savings of at least 0.3% of the utility's three-year average annual kilowatt-hour (kWh) sales, with energy savings increasing to 22.5% by the end of 2025. Peak demand reductions of 1% in 2009 and increasing to 7.75% by the end of 2018 are also required. (FirstEnergy 2009a, Page 100) However, since these DSM-induced load reductions typically are considered in load forecasts, the reductions do not offset the projected power demands that are expected to be supplied with the power generated by Davis-Besse. Although FENOC believes that energy generation savings can increase from DSM practices, it would be unrealistic to increase those energy savings to completely and consistently replace the Davis-Besse generating capability. The variability in associated costs also makes DSM a less desirable option. Consequently, FENOC does not see DSM as a practicable offset for the base-load capacity of Davis-Besse. Deleted: AJso, FENOC is not knowledgeable of retirement plans of Delayed Retirement other regional electric power suppliers. Even without retiring any generating units, FirstEnergy expects Extending the lives of existing non-nuclear generating plants beyond the time they were to require additional capacity in the near future. Therefore, even if a originally scheduled to be retired, as described in the GElS (NRC 1996, Section 8.3.13), substantial portion of its capacity does not represent a realistic option with respect to FirstEnergy's generating assets. ,_ _ were scheduled for retirement and could be delayed, some of the delayed retirement would be needed just to meet load growth. Alternatives that Meet System Page 7.2-13 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Approximately 56% of FirstEnergy's generating capacity consists of coal-fired plants which, due to a lower cost of generation, are used at capacity factors higher than other fossil-fuel generating units (FirstEnergy 2008b). Virtually all of FirstEnergy's non-nuclear base-load generating capability is from coal firing. These coal-fired plants were developed in the 1980s or earlier and represent the only plants in FirstEnergy's portfolio that would have any potential for continued operation to replace the base-load generation represented by Davis-Besse. However, older plants that do become candidates for retirement generally represent less efficient generation and pollution control technologies than are available in more modern plants, and continued operation typically would require substantial upgrades to be economically competitive and meet applicable environmental standards. In many cases, it is unlikely that such upgrades would be economically viable. FENOC believes that the environmental impacts of implementing such upgrades and operating the upgraded plants are bounded by the assessments presented in Section 7.3 for the gas-fired and coal-fired alternatives. For these reasons, the delayed retirement of non-nuclear generating units is not considered by FENOC as a reasonable alternative to the renewal of Davis-Besse's license. Purchased Power Each of the states (Ohio, Pennsylvania, and New Jersey) in which FirstEnergy serves load have undertaken electric industry restructuring initiatives that promote competition in retail energy markets by allowing participation of non-utility suppliers. Retail customers historically served by the regulated operating subsidiaries of FirstEnergy now have the option to choose between FirstEnergy-affiliated suppliers and other state-qualified energy suppliers. (FENOC 2007, Section 7.2.3.2) In theory, purchased power is a feasible alternative to Davis-Besse license renewal. There is no assurance, however, that sufficient capacity or energy would be available during the entire license renewal time frame to replace the approximately 910 MWe of base-load generation. In addition, even if power to replace Davis-Besse capacity were to be purchased, FENOC assumes that the generating technology used to produce the purchased power would be one of those described in the GELS. Thus, the environmental impacts of purchased power would still occur, but would be located elsewhere within the region. As a result, FENOC has determined that purchased power would not be a reasonable alternative to replace power lost in the event the Davis-Besse operating license is not renewed. Alternatives that Meet System Page 7.2-14 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.2.2.2 Alternatives Requiring New Generating Capacity The following conventional power plant types are evaluated in this section as potential alternatives to license renewal:

• New Nuclear Reactor
• Petroleum Liquids (Oil)

In addition, with the passage of Ohio's Senate Bill 221 in 2008, at least 25% of electricity supply for retail customers must come from renewable and advanced energy resources by 2025 OHPUCO 2009, Pages 3 and 4). Accordingly, the following alternative energy sources are evaluated.

• Hydropower S ,S*olaar .- -{ Deleted: <#>Windl
• Geothermal
• Biomass (Wood Waste)
• Municipal Solid Waste
• Other Biomass-Derived Fuels (Energy Crops)
• Fuel Cells Criteria used to determine if the potential energy alternatives represent a reasonable alternative include whether the alternative is developed and proven, can provide generation of approximately 910 MWe of electricity as a base-load supply, is economically feasible, and does not impact the environment more than Davis-Besse.

New Nuclear Reactor Increased interest in the development of advanced reactor technology has been expressed by members of both industry and government. With energy demands forecasted to increase and public opposition to new carbon-fueled power plants, some companies are pursuing permits and licenses to build and operate new nuclear reactors to meet the country's future energy needs. As of June 2010, for example, 18 applications, for 28 units, for combined licenses have been submitted to the NRC for review (NRC 2010). Nonetheless, there is ongoing uncertainty with respect to future electric demand due to the potential impacts of policy changes that could be enacted to limit or reduce greenhouse gas emissions. The downturn in the world economy also has had a significant impact on energy demand as well. The recovery of the world's financial markets is especially important for the energy supply outlook, because the capital-intensive nature of most large energy projects makes access to financing a critical necessity. (EIA 2010, Pages 5). Moreover, the economics of new nuclear plants I Alternatives that Meet System Page 7.2-15 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report remain uncertain with escalating fuel and construction costs emerging as forces which could affect this option. In consideration of the extended schedule for construction of a new nuclear reactor, access to capital, and the schedule for the new reactor licensing process, construction of a new nuclear reactor at the Davis-Besse site or at an alternative site is not feasible prior to the period of extended operation for Davis-Besse, i.e., in this case, 2017. Therefore, a new nuclear reactor is not considered a reasonable alternative to renewal of Davis-Besse's operating license.. Petroleum Liquids (Oil) Oil-fired generation has experienced a significant decline since the early 1970s. Increases in world oil prices have forced utilities to use less expensive fuels (NRC 1996, Section 8.3.11). From 2002 to 2008, for example, the average cost of petroleum for power generation increased by more than a factor of three (EIA 2010, Table 3.5). This high cost of oil has prompted a steady decline in its use for electricity generation. Within Ohio, for example, oil-fired units produce only 0.2% of power generation (NEI 2008). Increasing domestic concerns over oil security also will intensify the move away from oil-fired electricity generation. Therefore, FENOC does not consider oil-fired generation a viable alternative to renewal of Davis-Besse's operating license. Hydropower Considering the FirstEnergy transmission and distribution territory, Ohio and Pennsylvania have a combined potential for 1,758 MWe of additional undeveloped hydroelectric capacity, with Ohio contributing 57 MWe (INEEL 1998, Table 4). Thus, hydropower is a feasible alternative to Davis-Besse license renewal in theory. However, as noted in the GELS, hydropower's percentage of United States generating capacity is expected to decline because the facilities have become difficult to site as a result of public concern about flooding, destruction of natural habitat, and alteration of natural river courses (NRC 1996, Section 8.3.4). For example, the GElS estimated that land requirements for hydroelectric power are approximately 1 million acres per 1,000 MWe. Replacement of the Davis-Besse generating capacity would therefore require flooding a substantial amount of land (910,000 acres). Consequently, even if the capacity for development were available in Ohio-Pennsylvania, there would be large land-use and related environmental and ecological resource impacts associated with siting hydroelectric facilities large enough to replace Davis-Besse. Alternatives that Meet System Page 7.2-16 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Deleted: Wind Power¶J As a result, developing a hydropower base-load capacity of approximately 910 MWe is Areas suitable for wind energy not considered by FENOC to be a reasonable alternative to renewal of Davis-Besse's / applications must be wind-power Class 3 or higher (NREL 1986, operating license. Chapter 1). Coastal regions along Lake Erie in northwestern Ohio have Solar Power ......................................................... an estimated wind power of Class 3, increasing to Class 5 over offshore areas (NREL 1986, Chapter 3) and

,Solar power technologies, both thermal and photovoltaic (PV). have been commercially                      some Class 6 areas mid-lake (USDOE 2009a). The rest of the demonstrated. However, because the sun only shines during the day, solar arrays                           state, however, is devoid of Class 3 cannot, by themselves, provide consistent electrical output. Therefore, solar arrays                      or higher wind-power areas.

Pennsylvania is mostly a wind power alone are not considered in this ER as a reasonable alternative to the license renewal of Class 1 region, although some areas, Davis-Besse. Solar energy in combination with interconnected wind farms and CAES is particularly along ridgelines, may provide wind classes ranging from 4 discussed in Section 7.2.1.3. to 6. West Virginia is also mostly a wind power Class 1 region, with Class Geothermal Energy 2 and higher resources along highlands and ridges in the east-central part of the state. The total Geothermal energy has an average capacity factor of 90 percent and can be used for wind generation capacity for the three-state region in 2008 was 698 base-load power where available (NRC 2009b Section 8.2.5.5). However, geothermal MWe. (USDOE 2009a) ¶ electric generation is limited by the geographical availability of geothermal resources. Thus, wind power in coastal Ohio along Lake Erie and along ridgelines As illustrated by Figure 8.4 in the GELS, no feasible eastern location for geothermal in Pennsylvania and West Virginia is capacity exists to serve as an alternative to Davis-Besse (NRC 1996, Section 8.3.5). As a feasible alternative to Davis-Besse license renewal in theory. However, a result, FENOC does not consider geothermal energy to be a reasonable alternative to wind power by itself is not suitable for renewal of the Davis-Besse operating license. large base-load capacity. As discussed in the GELS, wind h* Biomass Energy Deleted: Solar power technologies, bothphotovoltaic (PV) and thermal, depend on the availability and Biomass is any organic material made from plants or animals. Agricultural and wood strength of sunlight. As such, it is an intermittent source of energy, wastes such as forestry residues, particularly paper mill residues, are the most common requiring energy storage or a biomass resources used for generating electricity. Regionally, eastern Ohio and most supplemental power source to provide electric power at night. Solar of Pennsylvania provide the largest biomass resources (EERE 2009a, b). The costs of resource availability in Ohio, western these fuels, however, are highly variable and very site specific (NRC 1996, Pennsylvania, and northern West Virginia is low compared to other Section 8.3.6). parts of the United States. The three-state region, for example, has about Most biomass plants use direct-fired systems by burning biomass feedstocks to produce 3.3 kWh per square meter per day of, solar radiation, which is less than half steam directly for conventional steam turbine conversion technology. Although the of that available in the southwestern United States (NRC 1996, Figure technology is relatively simple to operate, it is expensive and inefficient. Conversion 8.2). ¶ efficiencies of wood-fired power plants are typically 20-25%, with capacity factors of The land requirement for solar around 70-80%. As a result, biomass plants at modest scales (550 MWe) make technology is large. As noted in the GElS, it requires 14 to 35 acres for economic sense if there is a readily available supply of low-cost wood wastes and every 1 MWe generated, depending residues nearby so that feedstock delivery costs are minimal. (NRC 1996, on the solar technology (NRC 1996, Sections 8.3.2 and 8.3.3). At a Section 8.3.6) minimum, it would require approximately 12,740 acres to replace the 910 MWe produced by The construction impacts of a wood-fired plant would be similar to those for a coal-fired Davis-Besse. In addition, although I plant, although most facilities using wood waste for fuel would be built on smaller solar technologies produce no air pollution, little or no noise, and scales. Like coal-fired plants, biomass and wood-waste plants require large areas for require no transportable fuels, Alternatives that Meet System Page 7.2-17 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report fuel storage and processing. They also create impacts to land and water resources, primarily associated with soil disturbance and runoff, in addition to air emissions which must be managed. However, unlike coal-fired plants, biomass and wood-waste plants have very low levels of sulfur oxide emissions. (NRC 1996, Section 8.3.6) ,Que to the relatively small scale of potential projescsts----------- -ecuring------ Deleted: FirstEnergy is retrofitting units 4 and 5 of the R.E. Burger plant long-term fuel supplies, biomass is not considered by FENOC to be a reasonable in Shadyside, Ohio, for biomass alternative to replace Davis-Besse's base-load power generation. capability. When completed, the units will be one of the largest biomass facilities in the United States capable Municipal Solid Waste of producing up to 312 MWe (FirstEnergy 2009b). Nevertheless, due to the relatively small scale of Municipal solid waste (MSW) facilities that convert waste to energy use technology other comparable to steam-turbine technology for wood waste plants, although the capital costs are greater due to the need for specialized separation and handling equipment (NRC 1996, Section 8.3.7). The decision to burn MSW for energy is typically made due to insufficient landfill space, rather than energy considerations. There are 89 operational MSW energy conversion plants in the United States (USEPA 2009a), none of which were located in Ohio as of 2007 (WTE 2007). These plants generate approximately 2,500 MWe, or about 0.3% of total national power generation (USEPA 2009a). At an average capacity of about 28 MWe, numerous MSW-fired power plants would be needed to replace the base-load capacity of Davis-Besse. Construction impacts for a waste-to-energy plant are estimated to be similar to those for a coal-fired plant. Air emissions are potentially harmful. Increased construction costs for new plants and economic factors (i.e., strict regulations and public opposition) may limit the growth of MSW energy generation (NRC 1996, Section 8.3.7; USEPA 2009a). For reasons stated, MSW is not considered by FENOC to be a reasonable alternative to renewal of Davis-Besse's operating license. Other Biomass-Derived Fuels In addition to biomass energy such as wood and municipal solid-waste fuels, there are other concepts for biomass-fired electric generators, including direct burning of energy crops, conversion to liquid biofuels, and biomass gasification. The GElS indicated that none of these technologies had progressed to the point of being competitive on a large scale or of being reliable enough to replace a base-load plant (NRC 1996, Section 8.3.8). After recently re-evaluating current technologies, the NRC staff believes other biomass-fired alternatives are still unable to reliably replace base-load capacity (NRC 2009b, Section 8.2.5.8). For this reason, FENOC does not consider biomass-derived fuels to be a reasonable alternative to renewal of Davis-Besse's operating license. Alternatives that Meet System Page 7.2-18 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Fuel Cells Fuel cells are electrochemical devices that generate electricity without combustion and without water and air pollution. Fuel cells began supplying electric power for the space program in the 1960s. Today, they are being developed for more commercial applications. The U.S. Department of Energy (USDOE) is currently partnering with several fuel cell manufacturers to develop more practical and affordable designs for the stationary power generation sector. If successful, fuel cell power generation should prove to be efficient, reliable, and virtually pollution free. At present, progress has been slow and costs are high. The most widely marketed fuel cell is currently about $4,500 per kilowatt (kW) compared to $800 to $1,500 per kW for a diesel generator and about $400 per kW or less for a natural gas turbine. By the end of this decade, the USDOE goal is to reduce costs to as low as $400 per kW. (USDOE 2009b) However, fuel cells presently are not economically or technologically competitive with other alternatives for base-load capacity. Therefore, FENOC does not consider fuel Deleted: Combination of Alternatives¶ Individual evaluation of renewable cells to be a reasonable alternative to renewal of Davis-Besse's operating license. and advanced energy resources shows that, by themselves, these energy resources are not considered

                         -- -- -- --- ------- ------- - - - - -- - -- - -- - - --  - -- -  -- - -- -  -- -

by FENOC to be reasonable alternatives to renewal of Davis-Besse's operating license. When considered in various combinations with generation equivalent to that of Davis-Besse, these same renewable and advanced energy resources still fail to be reasonable alternatives to renewal of Davis-Besse's operating license.¶ For example, consider a mix of 25 percent of renewable and advanced energy resources, such as wind, hydroelectric, geothermal, solar, and biomass, with 75 percent natural gas generation to replace the baseload 908 MWe of the Davis-Besse plant. This mix of energy resources would result in an increased uncertainty in energy output due to the fluctuation of wind and solar resources. The environmental impacts associated with the large amount of land required for siting the various resources would likely exceed those associated with continued operation of Davis-Besse. And, the air quality impacts of operation of the natural gas plant greatly exceed those associated with continued operation of Davis-Besse. Therefore, FENOC believes that various combinations of renewable and advanced energy resources with generation equivalent to that of Davis-Besse are not reasonable alternatives to renewal of Davis-Besse's operating license.¶ Alternatives that Meet System Page 7.2-19 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.2-1 Coal-Fired Alternative Emission Control Characteristics Characteristic Basis Net capacity = 910 MW Equivalent to Davis-Besse. Capacity factor = 80% From FENOC 2007, Table 7.2-2 Firing mode: subcritical, tangential, dry-bottom Widely demonstrated, reliable, economical; pulverized coal tangential firing minimizes NOx emissions (FENOC 2007, Table 7.2-2) Fuel type = bituminous coal Type used in FirstEnergy Ohio River plants (FENOC 2007, Table 7.2-2) Fuel heating value = 12,285 Btu/Ib FirstEnergy Bruce Mansfield Plant average (FENOC 2007, Table 7.2-2) Heat rate = 9,800 Btu/kWh at full load FirstEnergy experience (FENOC 2007, Table 7.2-2) Fuel sulfur content = 3.52 wt% ; 2.86 lb/MMBtu FirstEnergy Bruce Mansfield Plant average (FENOC 2007, Table 7.2-2) Fuel ash content = 11.88 wt% FirstEnergy Bruce Mansfield Plant average (FENOC 2007, Table 7.2-2) Uncontrolled SOx emissions = 130 lb/ton coal USEPA estimate calculated as 38 x wt% sulfur in coal (FENOC 2007, Table 7.2-2) Uncontrolled NOx emissions = 10 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2) Uncontrolled CO emission = 0.5 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2) Uncontrolled PM emission = 120 lb/ton coal USEPA estimate calculated as 10 x wt% ash in coal (FENOC 2007, Table 7.2-2) Uncontrolled PM1 o emission = 27 lb/ton coal USEPA estimate calculated as 2.3 x wt% of ash in coal (FENOC 2007, Table 7.2-2) C02 emissions = 6,000 lb/ton Approximate average for bituminous coal combustion (FENOC 2007, Table 7.2-2) SOx control = wet limestone flue gas Best available technology for minimizing SOx desulphurization (95% removal) emissions (FENOC 2007, Table 7.2-2) NOX control = low NOX burners, overfire air, Best available technology for minimizing NOx selective catalytic reduction (95% reduction) emissions (FENOC 2007, Table 7.2-2) Particulate control = fabric filters Best available technology for minimizing particulate (99.9% removal) emissions (FENOC 2007, Table 7.2-2) Btu = British thermal unit MW = megawatt CO z carbon monoxide NOx = nitrogen oxides CO, z carbon dioxide PM = particulate matter ft cubic feet PMIo = PM with diameter less than 10 microns kWh kilowatt-hour SOx = sulfur oxides lb = pound USEPA = U.S. Environmental Protection Agency MMBtu million Btu wt% = percent by weight Alternatives that Meet System Page 7.2-20 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.2-2: Gas-Fired Alternative Emission Control Characteristics Characteristic Basis Net capacity = 910 MW Equivalent to Davis-Besse. Capacity factor = 80% From FENOC 2007, Table 7.2-1 Fuel type = natural gas Assumed Heat rate = 6,500 Btu/kWh FENOC Estimate (FENOC 2007, Table 7.2-1) Fuel heating value = 1,025 Btu/ft3 From FENOC 2007, Table 7.2-1 Fuel sulfur content = 0.2 grains/100 scf From FENOC 2007, Table 7.2-1 (0.00068 wt%) SO 2 emissions = 0.00064 lb/MMBtu USEPA estimate for natural gas-fired turbines (0.94 x wt% sulfur in fuel) (FENOC 2007, Table 7.2-1) NOx emissions (assuming dry low-NOx USEPA estimate for best available NOx combustion combustors) = 0.099 lb/MMBtu control (FENOC 2007, Table 7.2-1) NOx post-combustion control: selective USEPA estimate for best available NOx post-catalytic reduction (90% reduction) combustion control (FENOC 2007, Table 7.2-1) CO emissions (assuming dry low-NOx USEPA estimate (FENOC 2007, Table 7.2-1) combustors) = 0.015 lb/MMBtu PM emissions (all PMjo) = 0.0019 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1) C02 emissions = 110 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1) Btu = British thermal unit MW = megawatt CO = carbon monoxide NOx = nitrogen oxides CO, = carbon dioxide PM = particulate matter ft = cubic feet PMIo = PM with diameter less than 10 microns kWh = kilowatt-hour scf = standard cubic feet lb = pound SOx = sulfur oxides MMBtu = million Btu USEPA = U.S. Environmental Protection Agency wt% = percent by weight Alternatives that Meet System Page 7.2-21 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.2-3: CAES Alternative Emission Control Characteristics Characteristic Basis Six trains at 134 MW per train Net capacity = 804 MW (maximum authorized under existing air permit, although only 536 MW could be online by 2017) Capacity factor = 80% Within typical range of base-load plant: results in approximate annual output near that of Davis-Besse. Fuel type = natural gas Assumed Heat rate (HHV) = 4,395 Btu/kWh From OEPA Air Permit P01 06714: Norton CAES 3 Fuel heating value = 1,025 Btu/ft From FENOC 2007, Table 7.2-1 Fuel sulfur content = 2 grains/100 scf From OEPA Air Permit P0106714: Norton CAES (0.0066 wt%)FA SO9 emissions = 0.006 lb/MMBtu From OEPA Air Permit P0106714: Norton CAES NOxemissions (assuming water injection &

,selective catalytic reduction) = 3.0 ppmvd (5     From     EPA Air Permit P01 06714 Norton CAES 15% oxygen and 43.08 lbs/hr (6 units at 7.18 lbs/hr each)

CO emissions (assuming dry low-NOx Combustors & CO catalytic oxidation) =

§ ppmvd 0) 15% oxygen and 43.68 lbs/hr              From OEPA Air Permit P0106714: Norton CAES (6 units at 7.28 lbs/hr each)

PM emissions PM (all PM 10 ) ==0.066 eissons(al PMo) 0.0066 Ib/MMBtu b/M~tu From OEPA Air Permit P01 06714m Norton CAES and 23.34 lbs/hr (6 units at 3.89 lbs/hr each)

.CO emissions = 110 lb/MMBtu                       USEPA estimate (FENOC 2007. Table 7.2-1)

VOC emissions =13.2 lbs/hr From OEPA Air Permit P0106714: Norton CAES (6 units at 2.2 lbs/hr each) Btu = British thermal unit MW = megawatt CO = carbon monoxide NON = nitrogen oxides CO = carbon dioxide OEPA = Ohio Environmental Protection Agency CAES = compressed air energy storage PM = particulate matter ft, = cubic feet PM10 = PM with diameter less than 10 microns HHV = higher heating value ppmvd = parts per million volumetric dry kWh - kilowatt-hour scf = standard cubic feet lb = pound SOx = sulfur oxides lbs/hr = pounds per hour USEPA = U.S. Environmental Protection Agency MMBtu = million Btu wt% = percent by weight VOC = volatile organic compound Alternatives that Meet System Page 7.2-22 September 2011 Generating Needs

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.3 ENVIRONMENTAL IMPACTS OF ALTERNATIVES Environmental impacts are evaluated in this section for the coal- and gas-fired generation alternatives determined by FENOC to be reasonable in Section 7.2.1 compared to renewal of Davis-Besse's operating license. The impacts are characterized as being SMALL, MODERATE, or LARGE. The definitions of these impact descriptions are the same as presented in the introduction to Chapter 4, which in turn are consistent with the criteria established in 10 CFR Part 51, Appendix B to Subpart A, Table B-I, Footnote 3. FENOC believes the environmental impacts associated with the construction and operation of new generating capacity at a greenfield site would exceed those for the same type plants located at Davis-Besse or at another existing disturbed site, i.e., brownfield site. The new generating plants addressed in Section 7.2.1 would not be constructed only to operate for the period of extended operation of Davis-Besse. Therefore, FENOC assumes for this analysis a typical design life of 40 years for the coal-fired plant, 30 years for the combined-cycle natural gas-fired plant, and considers impacts associated with operation for the entire design life of the units in this analysis. The life span of a wind turbine is 20 years (REN 2005): however, turbines can be replaced and the tower would likely be in service for at least 40 years. The life span of a solar plant is estimated to be at least 30 years (TEP 2005). Chapter 8 presents a summary comparison of the environmental impacts of license renewal and the alternatives discussed in this section. 7.3.1 COAL-FIRED GENERATION This section presents the impact evaluation for the representative coal-fired generation alternative. As discussed in Section 7.2.1.1, FENOC assumed for purposes of this analysis that the representative plant would be located at a greenfield or (preferably) brownfield site along commercially navigable waterway or existing rail way. This assumption is a result of the space limitation at the Davis-Besse site. Land Use Land area requirements for a coal-fired plant of similar capacity to Davis-Besse, for example, would be approximately 1.7 acres per MWe (NRC 1996, Table 8.1), or 1,547 acres for a 910 MWe plant. This amount of land use will include plant structures and associated infrastructure. Additional acres would be needed offsite for transmission lines and possibly rail lines, depending on the location of the site relative to the nearest inter-tie connection or rail spur. This acreage could amount to a considerable loss of natural habitat or agricultural land for the plant site alone dependent upon whether a I Environmental Impacts of Alternatives Page 7.3-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report greenfield or brownfield site was used, excluding that required for mining and other fuel-cycle impacts. Some portion of the impacts could be mitigated by constructing new transmission line in existing rights-of-way (ROW) to as great an extent as possible. Land-use changes also would occur offsite in an undetermined coal-mining area to supply coal for the plant. For example, the GElS estimated that approximately 22 acres of land per MWe would be affected for mining the coal and disposing of the waste to support a coal-fired plant during its operational life (NRC 1996, Section 8.3.9). Therefore, for the 910 MWe plant used in this analysis, approximately 20,020 acres of land would be needed. Partially offsetting this offsite land use would be the elimination of the need for uranium mining and processing to supply fuel for Davis-Besse. The GElS estimated that approximately one acre per MWe would be affected for mining and processing the uranium during the operating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for Davis-Besse uranium mining and processing, approximately 910 acres of land would be required, resulting in offsite mining net land use of 19,110 acres for the representative coal-fired generation alternative. In consideration of the above, FENOC considers that land use impacts associated with a coal-fired plant at an alternate site would depend on the location of the plant and be MODERATE to LARGE. Water Use and Quality - Surface Water Construction-phase impacts on water quality of greatest potential concern include erosion and sedimentation associated with land clearing and grading operations at the plant site and waste disposal site, and suspension of bottom sediments during construction of cooling water intake and discharge structures and facilities for barge delivery of coal and limestone. However, land clearing and grading activities would be subject to stormwater protections in accordance with the NPDES program, and work in waterways would be regulated by the USACE under the CWA Section 404 and Section 10 of the Rivers and Harbors Act. These activities would also be subject to corresponding state and local regulatory controls, as applicable. In addition, these adverse effects would be localized and temporary. As a result, FENOC considers that impacts on surface water quality associated with construction of the representative plant at an alternative site would be SMALL. FENOC expects that potential impacts on water quality and use associated with operation of the representative plant would be similar to impacts associated with Davis-Besse operation. Cooling water and other wastewater discharges would be regulated by an NPDES permit, regardless of location. Cooling water intake, evaporative losses, and discharge flows for the representative coal-fired plant, assumed to use a closed-cycle cooling system, would be similar to or lower than those resulting from Davis-Besse operation (see Chapter 4). As a result, FENOC considers that I Environmental Impacts of Alternatives Page 7.3-2 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report impacts on surface water quality associated with operation of the representative plant at an alternative site would be SMALL. In view of the environmental review afforded under OPSB rules or a similar program, FENOC considers the impacts of surface water use and quality from construction and operation of the representative plant at an alternative site would be SMALL. Water Use and Quality - Ground Water Impacts will depend on whether the plant will use ground water for any purposes, as well as the characteristics of local aquifers. Effects to ground water quality can also depend on waste-management and coal-storage practices, although proper disposal and material handling should reduce the likelihood of an effect, as would recycling a greater percentage of waste products. Regardless of location, FENOC believes it highly unlikely that a coal-fired power plant at an alternate site will rely on ground water for plant cooling, and that ground water and waste-management regulations will limit impacts to SMALL. Air Quality Air quality impacts of coal-fired generation differ considerably from those of nuclear generation. A coal-fired plant emits sulfur oxides (SOx), nitrogen oxides (NO,), particulate matter (PM), and carbon monoxide (CO), all of which are regulated pollutants. Additionally, there are substantial emissions of carbon dioxide (CO2 ), a greenhouse gas, although future developments such as carbon capture and storage and co-firing with biomass have the potential to reduce the carbon footprint of coal-fired electricity generation (POST 2006). Coal also contains other constituents (e.g., mercury, beryllium) that are potentially emitted as hazardous air pollutants, which are also of concern from a human health standpoint. (NRC 1996, Section 8.3.9) As noted in Section 7.2.1.1, FENOC has assumed a plant design that includes controls to minimize emissions of regulated air pollutants effectively. Based on emission factors, estimated efficiencies for emission controls, and assumed design parameters listed in Table 7.2-1, operation of the plant would result in the following annual air emissions for criteria pollutants:

 "   Sulfur dioxide = 8,267 tons
 "    Nitrogen oxides = 5,087 tons

• Carbon monoxide = 636 tons

 "   Total filterable particulates = 153 tons
 "    PM10 = 34.3 tons.

The annual emissions of carbon dioxide, which is currently unregulated, would be approximately 7.63 million tons. See Table 7.3-1 for details. I Environmental Impacts of Alternatives Page 7.3-3 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC expects that these emissions would result in a decrease in local air quality compared to operation of a nuclear plant. However, FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions will be subject to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add to regional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions, at least during the ozone season (FENOC 2007, Section 7.3.2, Air Quality). The representative plant would add to regional concentrations of other pollutants, including the criteria pollutants carbon monoxide and particulates; hazardous air pollutants; and carbon dioxide, which is a greenhouse gas. Subject to regulatory controls, FENOC anticipates that the overall air quality would be noticeable, but not destabilizing. As a result, FENOC considers that the impacts to air quality from operation of the representative plant at an alternative site would be MODERATE. Ecological Resources Onsite and offsite land disturbances form the basis for impacts to terrestrial ecology. Constructing a coal-fired plant at an alternate site could alter onsite ecological resources because of the need to convert about 1,547 acres of land at the site to industrial use for the plant, coal storage, and ash and scrubber sludge disposal (see the Land Use subsection above). Coal-mining operations will also affect terrestrial ecology in offsite mining areas, although some of this land is likely already disturbed by mining operations. Impacts could include wildlife habitat loss, reduced productivity, habitat fragmentation, and a local reduction in biological diversity. Impacts, however, will vary based on the degree to which the proposed plant site is already disturbed. On a previous industrial site, impacts to terrestrial ecology will be minor, unless substantial transmission line ROWs, a lengthy rail spur, or additional roads need to be constructed through undisturbed or less-disturbed areas. Any onsite or offsite waste disposal by landfilling will also affect terrestrial ecology at least through the time period when the disposal area is reclaimed. During construction, impacts to aquatic ecology are likely. Regardless of where the plant is constructed, site disturbance will likely increase erosion and sedimentation runoff into nearby waterways, increasing turbidity. While site procedures and management practices may limit this effect, the impact will likely be noticeable. This is particularly true when intake and outfall structures are constructed alongside or in the body of water, as well as when any ROWs, roads, or rail lines require in-stream structures to support stream crossings. Noise and disturbance from construction, in addition to increased turbidity, may have a noticeable effect. Required regulatory permits, however, will help to mitigate these impacts. I Environmental Impacts of Alternatives Page 7.3-4 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report During operations, the cooling water system would have a potential impact to aquatic communities. However, this system would be designed and operated in compliance with the CWA, including NPDES limitations to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. The cooling water intake and discharge flows would be comparable to or less than for Davis-Besse, the impact from which is considered to be SMALL (see Chapter 4). Therefore, associated impacts at a comparable site on commercially navigable waterway would also be expected to be SMALL. Management of runoff from coal piles will also be necessary. However, subject to regulatory oversight, as afforded under OPSB rules or a similar program, FENOC considers the impacts to ecological resources from construction and operation of the representative plant at an alternative site may be noticeable, but not destabilizing. On this basis, FENOC considers that the overall impact to ecological resources of constructing a coal-fired plant with a closed-cycle cooling system at an alternate site would be MODERATE. Human Health Coal-fired power generation introduces worker risk from coal and limestone mining, worker and public risk from coal and lime/limestone transportation, worker and public risk from disposal of coal combustion wastes, and public risk from inhalation of stack emissions. For example, the GElS noted that there could be human health impacts (cancer and emphysema) from inhalation of toxins and particulates from a coal-fired plant, but the GElS does not identify the significance of these impacts (NRC 1996, Section 8.3.9). In addition, the coal-fired alternative also introduces the risk of coal pile fires and attendant inhalation risks, though these types of events are relatively rare. (NRC 2009b, Section 8.2.1, Human Health) Regulatory agencies, including the USEPA, USOSHA, and state agencies, set air emission standards requirements for workers and the public based on human health impacts. These agencies also impose site-specific emission limits as needed to protect human health. Given these extensive health-based regulatory controls, FENOC considers that operating the representative coal-fired plant at an alternate site would be SMALL. Socioeconomics The peak workforce during construction of the coal-fired plant alternative is estimated to range between 1.2 to 2.5 workers per MWe and the workforce required during operation is estimated to be 0.25 workers per MWe (NRC 1996, Section 8.3.9, Table 8.1 and I Environmental Impacts of Alternatives Page 7.3-5 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.2). For a plant with a capacity of 910 MWe, workforces of approximately 1,092 to 2,275 construction workers and 228 permanent employees would be required. Potential impacts from construction of the coal-fired alternative would be highly location dependent. As noted in the GELS, socioeconomic impacts are expected to be larger at a rural site than at an urban site, because more of the peak construction work force would need to move to the area to work (NRC 1996, Section 8.3.9). Not considering impacts of terminating Davis-Besse operations, socioeconomic impacts at a remote rural site could be LARGE, while impacts at a site in the vicinity of a more populated metropolitan area (e.g., Toledo) could be SMALL to MODERATE. FENOC assumed that the OPSB or comparable review process, including application of appropriate mitigation found to be needed as a result, would ensure that these construction impacts would not be destabilizing to local communities. At most alternate sites, coal and lime would be delivered by barge, although delivery is feasible for a location near a railway. Transportation impacts would depend upon the site location. Socioeconomic impacts associated with rail transportation would be MODERATE to LARGE. Barge delivery of coal and lime/limestone would have SMALL socioeconomic impacts. As noted in Section 4.17, communities in Ottawa County, particularly those within the tax jurisdiction of Carroll Township and the Carroll-Benton-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse closure, assuming the plant is constructed outside the area. Based on the above, FENOC considers that the overall socioeconomic impacts of construction and operation of the representative coal-fired plant at an alternate site would be MODERATE. Waste Management The representative coal-fired plant would produce substantial solid waste, especially fly ash and scrubber sludge. Based on emission factors and controls scaled from Beaver Valley (FENOC 2007, Section 7.3.2 and Table 7.2-2)*, the plant annual waste generation amounts would be approximately 300,000 tons/year of ash and 470,100 tons of flue gas desulphurization waste (dry basis), consisting primarily of hydrated calcium sulfate (gypsum) and excess limestone reactant. Although these wastes represent potentially usable products, FENOC assumed the total waste generated would be disposed of at an offsite landfill. Based on a fill depth of 30 feet and scaling from Beaver Valley (FENOC 2007, Section 7.3.2), approximately 644 acres would be required for the landfill over an assumed plant operating life of 40 years. The scale factor for coal is the ratio of total electric capability, 910 MWe/1980 Mwe, or 0.460. I Environmental Impacts of Alternatives Page 7.3-6 S.e~ptember 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Disposal of the waste could noticeably affect land use and ground water quality. In addition, the December 2008 failure of the dike used to contain fly ash at the Tennessee Valley Authority Kingston Fossil Plant in Roane County, Tennessee, and subsequent cleanup, highlight other waste management issues (USEPA 2009b). However, environmental impacts related to the location, design, and operational aspects of waste disposal for the plant would be subject to regulatory review under OPSB rules or similar programs. As a result, FENOC believes that with proper disposal siting, coupled with current waste management and monitoring practices, waste disposal would not destabilize any resources. On this basis, FENOC considers that waste management impacts from operation of the representative coal-fired plant at an alternate site would be MODERATE. Aesthetics Potential aesthetic impacts of construction and operation of the representative coal-fired plant include visual impairment resulting from the presence of a large industrial facility, including 500-foot-high stacks, and cooling towers up to approximately 500 feet high with associated condensate plumes. The stacks and condensate plumes from the cooling towers could be visible some distance from the plant. There would also be an aesthetic impact if construction of a new transmission line or rail spur were needed. Similarly, noise impacts associated with rail delivery of coal and lime/limestone if used would be most significant for residents living in the vicinity of the facility and along the rail route. These impacts, however, are highly site-specific. Site locations could reduce the aesthetic impact of a coal-fired generation, for example, if siting were in an area that was already industrialized versus locating at largely undeveloped sites. In view of the environmental review afforded under OPSB rules or a similar program, FENOC considers that the impacts to aesthetics from construction and operation of the representative plant at an alternative site would depend on location and be SMALL to MODERATE. Cultural Resources FENOC assumed that the representative coal-fired plant, associated infrastructure (e.g., roads, transmission corridors, rail lines, or other rights-of-way), and associated waste disposal site would be located with consideration of cultural resources afforded under OPSB or comparable rules. FENOC further assumed that appropriate measures would be taken to recover or provide other mitigation for loss of any resources discovered during onsite or offsite construction. I Environmental Impacts of Alternatives Page 7.3-7 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report On this basis, FENOC considers that the potential impact on cultural resources from construction and operation of the representative plant at an alternative site would be SMALL. 7.3.2 GAS-FIRED GENERATION This section presents the impact evaluation for the representative gas-fired generation alternative. As discussed in Section 7.2.1.2, FENOC assumed for purposes of this analysis that the representative plant would be located at a greenfield or (preferably) brownfield site in northwestern Ohio. This assumption is a result of the space limitation at the Davis-Besse site. Land Use Land-use requirements for gas-fired plants are relatively small, at about 100 acres for a 910 MWe plant (Section 7.2.1.2). An estimated 240 - 270 additional acres would be needed offsite at a greenfield location for new gas and electric transmission lines (FENOC 2007, Section 7.3.1, Land Use) and increased land-related impacts, which in turn would be location-specific. Land use in northwestern Ohio is predominantly rural agricultural cropland with scattered rural residences and woodlots. Located in a rural area, the change in land use would be locally apparent and could include displacement of cropland, which is highly productive for corn, wheat, and soybeans relative to other areas of the state; however, substantial buffer with respect to highly incompatible land uses (e.g., residential use) could be provided and destabilization of overall land use would not be expected. If the plant were located in an area designated for industrial use, associated land-use impacts would not be significant. Agricultural practices could continue along most of the area occupied by offsite rights-of-way. (FENOC 2007, Section 7.3.1, Land Use) Regardless of where the natural gas-fired plant is built, additional land would be required for natural gas wells and collection stations. Partially offsetting these offsite land requirements would be the elimination of the need for uranium mining to supply fuel for Davis-Besse. The GElS estimated that approximately one acre per MWe would be affected for mining and processing the uranium during the operating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for Davis-Besse uranium mining and processing, approximately 910 acres of land would be required, resulting in a net gain in reclaimed land for the representative natural gas-fired generation alternative. In view of the environmental review afforded under OPSB rules or a similar program, FENOC considers that the overall impacts of land use from construction and operation of the representative plant at an alternative site would depend on plant location and be SMALL to MODERATE. I Environmental Impacts of Alternatives Page 7.3-8 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Water Use and Quality - Surface Water Cooling water intake, evaporative losses, and discharge flows for the plant would be less than that of Davis-Besse, primarily because less power would be derived from a steam cycle (FENOC 2007, Section 7.2.2.1). During operation, cooling water and wastewater discharges would be regulated under the federal CWA and corresponding state programs by an NPDES permit. Construction activities would be similarly regulated to ensure protection of water resources. In addition, impacts on water use and quality would be subject to scrutiny in the planning stage under OPSB or similar governing authority rules. Overall, FENOC considers that the impacts from construction and operation of the representative plant at an alternative site on surface water use and quality would be SMALL. Water Use and Quality - Ground Water Impacts will depend on whether the plant will use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumes that a gas-fired power plant at an alternate site will not rely on ground water for plant cooling, and that regulations for ground water use for potable water will limit impacts to SMALL. Air Quality Natural gas is a relatively clean-burning fuel with nitrogen oxides being the primary focus of combustion emission controls. As noted in the GELS, air quality impacts for all natural gas technologies are generally less than for fossil technologies of equal capacity because fewer pollutants are emitted (NRC 1996, Section 8.3.10). As noted in Section 7.2.1.2, FENOC has assumed a plant design that includes controls to minimize emissions of regulated air pollutants effectively. Based on emission factors, estimated efficiencies for emission controls, and assumed design parameters listed in Table 7.2-2, operation of the plant would result in the following annual air emissions for criteria pollutants:

• Sulfur dioxide = 13.3 tons
• Nitrogen oxides = 205 tons

 "   Carbon monoxide = 311 tons

• Total filterable particulates = 39.4 tons The annual emissions of carbon dioxide, which is currently unregulated, would be approximately 2.28 million tons. See Table 7.3-2 for details.

I Environmental Impacts of Alternatives Page 7.3-9 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC expects that these emissions may result in a noticeable reduction in local air quality. However, FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions will be subject to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add to regional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions, at least during the ozone season (FENOC 2007, Section 7.3.1, Air Quality). The representative plant would add to regional concentrations of other pollutants, including the criteria pollutants carbon monoxide and particulates; hazardous air pollutants such as mercury; and carbon dioxide, which is presently unregulated. Subject to regulatory controls, FENOC anticipates that the overall air quality would be noticeable, but not destabilizing. As a result, FENOC considers that the impacts to air quality from operation of the representative plant at an alternative site would be MODERATE, but smaller than those of coal-fired generation. EcoloQical Resources As noted in the Land Use subsection above, development of the representative combined-cycle natural gas-fired plant may require approximately 100 acres for the plant site and approximately 240 - 270 additional acres for offsite infrastructure. Although the GElS noted that land-dependent ecological impacts from construction from gas-fired plants would be smaller than for other fossil fuel technologies of equal capacity (NRC 1996, Section 8.3.10), the type and quality of terrestrial habitat that would be displaced is location-specific. However, FENOC considers it likely that most of the area required for construction would consist of agricultural cropland with relatively low habitat value. Stream crossings and wetland disturbance, if any, would be subject to provisions of a USACE permit (CWA Section 404) and relevant state and local requirements. (FENOC 2007, Section 7.3.1, Ecology) The most significant potential impacts to aquatic communities relate to operation of the cooling water system. However, the cooling system for the plant would be designed and operated in compliance with the CWA, including NPDES limitations for physical and chemical parameters of potential concern and provisions of CWA Sections 316(a) and 316(b), which are respectively established to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. Also, the siting, design, and operation of the plant would be subject to the environmental protections under OPSB rules. Overall, FENOC expects that development of the representative natural gas-fired plant would likely have little noticeable impact on ecological resources of the area. As a result, FENOC considers that the overall impacts to ecology resources from I Environmental Impacts of Alternatives Page 7.3-10 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report construction and operation of the representative plant at an alternative site would depend on plant location and be SMALL to MODERATE. Human Health The GElS cites risk of accidents to workers and public health risks (e.g., cancer, or emphysema) from the inhalation of toxics and particulates associated with air emissions as potential risks to human health associated with the gas-fired generation alternative (NRC 1996, Table 8.2). However, regulatory requirements imposed on facility design, construction, and operations under the authority of the Occupational Safety and Health Act, Clean Air Act, and related statutes are designed to provide an appropriate level of protection to workers and the public. Additionally, regulatory agencies, including the USEPA, USOSHA, and state agencies, set air emission standards requirements for workers and the public based on human health impacts. Given the extensive health-based regulatory control, FENOC considers that operating the representative gas-fired plant at an alternate site, regardless of plant location, would be SMALL. Socioeconomics Major sources of potential socioeconomic impacts from the representative gas-fired generation alternative include temporary increases in jobs, economic activity, and demand for housing and public services in communities surrounding the site during the construction period. Countering these increases are losses in permanent jobs, tax revenues, and economic activity attributable to gas-fired plant operation and termination of operations of Davis-Besse. The estimated number of peak construction workers expected to build a gas-fired plant with a capacity of 910 MWe is 1,092 - 2,275 (NRC 1996, Tables 8.1). To operate the plant would require 137 workers (NRC 1996, Tables 8.2). Although northwestern Ohio is predominantly rural, most areas are within commuting distance of the metropolitan areas like Toledo and Cleveland, Ohio. Considering the proximity of these sources of labor and services, FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. Communities in Ottawa County, however, particularly those within the taxing jurisdiction of Carroll Township and the Benton-Carroll-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse closure that could constitute MODERATE impact (see Section 4.17). FENOC believes that these impacts, although noticeable, would not be destabilizing. As a result, FENOC considers that the overall socioeconomic impact of construction I Environmental Impacts of Alternatives Page 7.3-11 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report and operation of the representative gas-fired at an alternative site would be MODERATE. Waste Management Gas-fired generation would result in minimal waste generation, producing minor (if any) impacts (NRC 1996, Section 8.3.10). As a result, FENOC considers waste management impacts from the operation of the representative plant at an alternative site would be SMALL. Aesthetics Potential aesthetic impacts of construction and operation of a gas-fired plant include visual impairment resulting from the presence of a large industrial facility, including multiple exhaust stacks at least 150 feet high, and mechanical-draft cooling towers with associated condensate plumes. Considering the flat topography in northwestern Ohio, the stacks and condensate plumes would likely be visible for several miles from the site; new transmission lines constructed to connect the plant to the grid would also be relatively visible for the same reason, though would not be out of character for the rural northwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics) FENOC expects that the plant likely would be located in a rural area, and assumed that adequate buffer and vegetation screens would be provided at the plant site as needed to moderate visual and noise impacts. In view of the environmental review afforded under OPSB rules, FENOC considers that the impacts to aesthetics from construction and operation of the representative plant at an alternative site would depend on location and be SMALL to MODERATE. Cultural Resources FENOC assumed that the representative gas-fired plant and associated gas-supply pipeline and transmission line would be located with consideration of cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of the representative plant at an alternative site, regardless of location, would be SMALL. I Environmental Impacts of Alternatives Page 7.3-12 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 7.3.3 RENEWABLE ENERGY This section presents the impact evaluation for wind power in the form of interconnected wind farms and/or solar photovoltaic power, in combination with CAES. To be specific, FENOC evaluated for purposes of this NEPA analysis electricity generation coming from: wind power in the form of interconnected wind farms: or wind power in the form of interconnected wind farms with CAES: or solar (photovoltaic) power with CAES: or a combination of interconnected wind farms and solar power with CAES, as described in Sections 7.2.1 and 7.2.1.3. Wind and solar energy are renewable energy sources that produce electricity without releasing air or water pollutants: however, these advantages are offset by environmental impacts such as large land requirements (both wind and solar), potential harm to birds and bats (wind), aesthetic concerns (wind and solar), noise concerns (wind): radar interference (wind), and generation of hazardous waste streams (solar). In addition, there would be environmental impacts associated with the construction and operation of new transmission lines associated with new renewable energy sources. These impacts are not evaluated as part of this analysis because the scope of new transmission would not be determined until the energy sources were sited. The environmental impacts related to interconnected wind farms are discussed in Section 7.3.3.1. The environmental impacts of interconnected wind farms with CAES are discussed in Section 7.3.3.2. The environmental impacts of solar PV power with CAES are discussed in Section 7.3.3.3. Finally, a summary of the combined environmental impacts of wind farms, solar PV power, and CAES are provided in Section 7.3.3.4. 7.3.3.1 Interconnected Wind Energy Using the assumptions and disclaimers in Section 7.2.1, development of a series of wind farms would be required to provide replacement power for Davis-Besse. Transmission impacts associated with an interconnected grid that would serve renewable energy sources would have to be evaluated once the renewable energy sources have been sited. Development of large-scale, land-based wind power facilities could have MODERATE to LARGE impacts on aesthetics, land use, and terrestrial ecology. The environmental impacts of a large-scale wind farm are described in the GElS (NRC 1996, Section 8.3.1). In summary, the construction of roads and turbine tower supports would result in short-term impacts, such as increases in noise, erosion, and sedimentation, and decreases in air quality from fugitive dust and equipment emissions. Construction in undeveloped areas would have the potential to disturb and impact cultural resources or habitat for sensitive species. During operation, some land near wind turbines could be I Environmental Impacts of Alternatives Page 7.3-13 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report available for compatible uses such as agriculture. There is some continuing noise from wind turbine operation, light flicker caused by reflection of the sun, and aesthetic impacts, although whether a wind farm improves the landscape is in the eye of the beholder. Wind farms generate very little waste and pose limited human health risk other than from occupational iniuries. There is a potential for bird and bat collisions with turbine blades, which is discussed in this subsection. Although most environmental impacts associated with a single wind farm are SMALL or can be mitigated, the cumulative impacts from the many wind farms that would be needed to support an interconnected grid system, such as impacts to sensitive habitats and endangered species, could be LARGE, depending on the locations. The incorporation of offshore wind resources from Lake Erie could reduce the amount of land use impacts: however, a new set of impacts related to offshore wind would be created. Placing wind farms offshore eliminates some of the obstacles encountered when siting wind farms on shore and limits conflicts with other planning interests. However, other impacts are created, including influence on birds, marine life, hydrography, and marine traffic. (IEAWIND 2002) A detailed discussion of impacts is presented below. Land Use The land use requirement for interconnected wind farms in open and flat terrain is about 50 acres per megawatt (MW) of installed capacity. Approximately 5% (2.5 acres) of this area is occupied by turbines, access roads, and other equipment. The remaining land area can be used for compatible activities such as farming or ranching (AWEA 2002), except if the wind farms are located offshore. The Roscoe Wind Farm near Roscoe, Texas has the capacity of 209 MW and is spread-out across 30,000 acres (RWC 2010), or 143 acres per MW. When complete, the entire Roscoe Wind Complex project is expect to have the capacity of 781 MW on approximately 100,000 acres (CBS 2010) or 128 acres per MW. Assuming the use of interconnected wind as the only renewable source to generate the equivalent of Davis-Besse's net output of 910 MWe base-load power plus 910 MWe of energy storage to be used when wind power is not available, a series of wind farms with 2.0-MWe turbines with an average capacity factor of 30% as specified by PJM and USDOE (PJM 2011 and USDOE 2011) would require approximately 3030 turbines to produce 1820 MWe. At 50 acres per MW, the land use potential would be as much as 91,000 acres (142 square miles), with about 4550 acres (7.1 square miles) occupied by turbines and support facilities. Land use in Ohio, where additional wind generation would likely be developed, is predominantly rural agricultural cropland with scattered rural residences and woodlots. I Environmental Impacts of Alternatives Page 7.3-14 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report In such a location, the change in land use would be locally apparent and could include some initial displacement of highly productive cropland for corn, wheat, and soybeans. However, a substantial buffer with respect to highly incompatible land uses (e.g., residential use) could be provided, and destabilization of overall land use would not be expected. Agricultural practices could continue along most of the area occupied by offsite rights-of-way. (FENOC 2007, Section 7.3.1, Land Use) Offshore impacts have been extensively studied in Europe. An environmental impact report has been Prepared by the Cape Wind Project (CWP) and a feasibility study was conducted by the Great Lakes Wind Energy Center (GLWEC) for an offshore area in Lake Erie near Cleveland, Ohio (GLWEC 2009). Based on the findings in the CWP Environmental Impact Report (EIR) (CWP 2007) and the study completed by GLWEC, land use impacts associated with offshore wind generation would be SMALL. Regardless of where the wind generation facilities are built, additional land would be required for an interconnected grid system as described in Section 7.2.2.3. Partially offsetting these offsite land requirements would be the elimination of the need for uranium mining to supply fuel for Davis-Besse. The GElS estimates that approximately one acre per MWe would be affected for mining and processing the uranium during the operating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for the uranium mining and processing associated with fuel for Davis-Besse, approximately 910 acres of land would be required, resulting in a net avoidance of potentially disturbing 3640 (4550-910) acres of land when compared to wind generation land use. Based on these data, FENOC considers that the overall impacts of land use from construction and operation of interconnected wind farms would depend on their locations, and be MODERATE to LARGE. Water Use and Quality - Surface Water Wind generation does not require cooling water or intake structures. Therefore, there would be no impact on water use and the only potential impact on local water quality would be erosion or sedimentation issues during construction. These impacts would be minimized by using best management practices during construction activities and are considered SMALL. Water Use and Quality - Ground Water A limited amount of ground water may be used during construction activities if other potable water supplies are limited. Minor amounts of water may be needed for operating wind generation facilities if surface water resources were not available. The potential impact to ground water is SMALL. I Environmental Impacts of Alternatives Page 7.3-15 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Air Quality There are no air quality impacts associated with the operation of onshore or offshore interconnected wind farms. The construction of roads and turbine tower supports would result in short-term impacts in air quality from fugitive dust and equipment emissions and the overall impacts would be SMALL. Ecological Resources As noted in the Land Use subsection above, development of onshore interconnected wind farms would have a MODERATE to LARGE impact on land resources which could have a LARGE impact on the ecological resources, especially durinq construction. Migratory bird, eagle and raptor, and bat mortality are potential impacts related to wind turbines. The deaths of birds and bats at wind farm sites have raised concerns by fish and wildlife agencies and conservation -groups. United States Fish and Wildlife Service (USFWS) estimates indicate that wind turbine rotors kill 33,000 birds annually (USFWS 2002). Concerns of the potential impacts of wind power deployment have led the USFWS to release draft guidance that provides agency employees, developers, federal agencies, and state organizations information for reviewing and selecting sites for interconnected and community-scale wind energy facilities to avoid and minimize negative impacts to fish, wildlife, plants and their habitats (USDO1 2011). Direct effects include blade strikes, barotrauma, loss of habitat, and "displacement". Indirect effects occur later in time and include introduction of invasive vegetation that result in alteration of fire cycles: increase in predators or predation pressure: decreased survival or reproduction of the species: and decreased use of the habitat that may result from effects of the proiect or resulting "habitat fragmentation." (USFWS 2011) Although wind turbine/bird collision studies seem to indicate that wind generating facilities in some locations of the United States have a minor impact on birds compared to other sources of collision mortality, one cannot assume that similar impacts would occur among birds using wind-generating sites built in Ohio or offshore in Lake Erie. Based on a feasibility study conducted by Great Lakes Wind Energy Center (GLWEC) the avian morality rate of this proposed offshore project is expected to be minimal. (GLWEC 2009) FENOC assumed that construction best management practices and awareness of critical habitat during operations would minimize impacts to ecological resources. Therefore, impacts to migrating species would depend on the location of the wind farms and could be SMALL to MODERATE. Human Health The only major health risk for the construction and operation of a series of wind farms (onshore or offshore) would be accidents. FENOC assumed that all Occupational I Environmental Impacts of Alternatives Page 7.3-16 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Safety and Health Act requirements would be complied with during construction and operation of these facilities and the impacts should be SMALL. Socioeconomics Major sources of potential socioeconomic impacts from interconnected wind farms include temporary increases in lobs, economic activity, and demand for housing and public services in communities surrounding the sites during the construction period. These impacts would be spread throughout the region. Countering these increases are losses in Permanent jobs, tax revenues, and economic activity attributable to the termination of operations of Davis-Besse. Typically, renewable energy sources are not subject to the tax rate of conventional energy-generating facilities, so the loss of Permanent gobs and tax revenue could be significant to the communities near Davis-Besse and thus have a SMALL to MODERATE impact. Communities in Ottawa County, however, particularly those within the taxing jurisdiction of Carroll Township and the Benton-Carroll-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse closure that could constitute MODERATE impacts. The number of peak construction workers expected to build the wind farms is unknown at this time: however, it is likely similar to a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Tables 8.1). To operate and maintain the wind farms would reguire approximately 150 to 200 workers. FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. Waste Management Construction of wind farms could result in generation of large amounts of vegetation from land clearing activities. If this material is managed correctly (e.g., recycled or composted) the impacts should be SMALL. Minor amounts of waste may be generated during the operations and maintenance of the wind turbines (onshore or offshore) which, ifwaste streams are managed correctly, the impacts would likely be SMALL. Aesthetics Most wind farms are located in remote areas and may generate large aesthetic concerns, particularly if sited on highlands or in recreational areas and could have some effect on the local aesthetic quality. The aesthetic impacts from wind farms located in flat-lvina rural areas would likely be SMALL. Offshore wind turbines would likely have a lesser aesthetic impact than onshore wind turbines and be limited to those individuals who reside close to the shoreline or I Environmental Impacts of Alternatives Page 7.3-17 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report participate in recreational activities close to the wind facilities. There have been concerns related to the related to aesthetic impacts. (CA 2011) The overall aesthetic impacts from wind turbines would be SMALL to MODERATE. Cultural Resources Due to the large amount of land needed to construct the necessary wind farms, the potential for impacting cultural resources could be LARGE. To minimize these impacts, FENOC assumed construction activities would consider cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures for both onshore and offshore construction activities would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of the wind farms, regardless of location, would be SMALL. 7.3.3.2 Wind with Compressed Air Energy Storage Environmental impacts associated with wind farms are discussed above in Section 7.3.3.1, and are not repeated here in detail. Impacts associated with the compressed air energy storage (CAES) facility are discussed below. By combining CAES with interconnected wind farms, the anticipated environmental impacts would be greater than the impacts from interconnected wind farms alone. Therefore, wind farms with CAES generating 1820 MW

• of power are expected to have greater environmental impacts than Davis-Besse during the proposed 20 year license extension.

Land Use The overall land use impact for wind generation in this energy alternative, as discussed in Section 7.3.3.1, is MODERATE to LARGE. Land use associated with the NES facility would be limited to the facility's 92 surface acres. There would be some land impacted during construction, but this site has been previously disturbed so the impact should be SMALL. However, if another site is

 . Wind generation source is assumed to be available for 12 hours every day, and a CAES facility assumed to be 100% efficient (i.e., 910 MWe of energy input from wind and/or solar to the CAES facility results in 910 MWe of generation from the CAES facility), would require that generation source to be rated at 1820 MW in order to Provide 24-hours of baseload electricity when integrated with a 910 MW CAES facility (i.e., 12 hours to provide 910 MW of base-load generation onto the grid, and the same 12 hours to provide 910 MW to recharge the CAES facility, so that the CAES facility could feed the grid the remainder of the day).

I Environmental Impacts of Alternatives Page 7.3-18 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report chosen for the CAES or an additional CAES facility is needed to meet base-load power requirements then there could be a MODERATE to LARGE land use impact. Water Use and Quality - Surface Water CAES facilities have cooling towers associated with the use of gas turbines to produce electricity and compressors to recharge the storage structure. These cooling towers are much smaller than those typically used for coal and gas generation plants. Cooling makeup water evaporative losses, and discharge flows for the plant would be considerably less than that of Davis-Besse, primarily because less power would be derived from a steam cycle. (FENOC 2007, Section 7.2.2.1) During CAES operation, cooling water and wastewater discharges would be regulated under the federal CWA and corresponding state programs by an NPDES permit. Construction activities would be similarly regulated to ensure protection of water resources. In addition, impacts on water use and quality would be subiect to scrutiny in the planning stage under OPSB or similar governing authority rules. Overall, FENOC considers that the impacts from construction and operation of interconnected wind farms (onshore and offshore) combined with a CAES facility on surface water use and quality would be SMALL. Water Use and Quality - Ground Water Impacts would depend on whether the plant would use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumed that the NES plant or a CAES plant at an alternate site would not rely on ground water for plant cooling, and that regulations for ground water use for potable water would limit impacts to SMALL. Air Quality CAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogen oxides being the primary focus of combustion emission controls. As noted in the GELS, air quality impacts for all natural gas technologies are generally less than for fossil technologies of equal capacity because fewer pollutants are emitted (NRC 1996, Section 8.3.10). FirstEnergy Generation Corp. has applied for and received an Air Pollution Permit to Install and Operate (PTIO) proposed emission units for the Norton CAES facility (Facility ID 1677105001) (see Table 7.2-3). The permit (Number P01 06714) was issued on September 7, 2010 by the Ohio EPA. The permit establishes emission limitations, air emission controls, monitoring., reporting., and recordkeeping requirements. The proposed emission units established in the PTIO are based on the original design of the I Environmental Impacts of Alternatives Page 7.3-19 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report facility and include six combustion trains and one cooling tower. Each combustion train includes a 589 mmBtu/hr (134 MWe) combustion turbine and a 1 mmBtu/hr in-line heater to remove moisture from the compressed air. (NES 2010) The combustion turbines and in-line heaters would fire only pipeline-quality natural gas. The only other sources associated with this facility are an emergency generator and a back-up firewater pump: both of these units would be diesel-fired. The permitted annual air emission limits from this facility with six combustion trains (i.e., 804 Mwe) are as follows:

• Sulfur dioxide (SO2) = 42.41 tons
• Nitrogen oxides (NOO) = 93.67 tons
• Carbon monoxide = 90.36 tons
• PMlo = 46.65 tons

       " Volatile Organic Compounds (VOCs) = 26.40 tons The annual emissions of carbon dioxide from all sources would be approximately 681,100 tons. These emissions are based on the current air permit for NES and could change if different equipment is used during plants operations. A list of air emissions for the six combustion trains is presented in Table 7.3-4.

FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions would be subiect to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add to regional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions, at least during the ozone season (FENOC 2007, Section 7.3.1. Air Quality). The plant would add to regional concentrations of other pollutants, including the criteria pollutants carbon monoxide and particulates: hazardous air pollutants such as mercury: and carbon dioxide, which is Presently unregulated. Subiect to regulatory controls, FENOC anticipates that the impacts to air quality from operation of the CAES plant at an alternative site would be MODERATE. Ecological Resources As noted in Section 7.3.3.1, development of the interconnected wind farms would have a MODERATE to LARGE impact on land resources which could have a LARGE impact on ecological resources, especially during construction. Since the NES has an existing underground storage space and only has 92 acres of land use at the surface, the potential impact to ecological resources is SMALL. However, if another CAES site with compressed air storage on the land surface is chosen or needed to provide additional stored energy capacity the ecological impacts could be MODERATE to LARGE. Sentember 2011 I IEnvironmental Impacts of Alternatives Impacts of Alternatives Page 7.3-20 Page 7.3-20 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report For an alternative CAES site, FENOC considers it likely that most of the area required for construction would consist of agricultural cropland with relatively low habitat value. Stream crossings and wetland disturbance, if any, would be subiect to provisions of a USACE permit (CWA Section 404) and relevant state and local requirements. (FENOC 2007, Section 7.3.1. Ecology) The most siqnificant potential impacts to aquatic communities relate to operation of the cooling water system. However, the NES site (or alternative site) cooling system for the plant would be designed and operated in compliance with the CWA. includinq NPDES limitations for physical and chemical parameters of potential concern and provisions of CWA Sections 316(a) and 316(b), which are respectively established to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. Also, the siting, design, and operation of the plant would be subject to the environmental protections under OPSB or other state agency's rules. Overall, FENOC expects that development of the CAES plant would likely have little noticeable impact on ecoloqical resources of the area. As a result, FENOC considers that the overall impacts to ecoloqy resources from construction and operation of the representative plant at an alternative site would depend on plant location and be SMALL to LARGE. Human Health The only maior health risk for the construction and operation of a series of wind farms (onshore or offshore) would be accidents. FENOC assumed that all Occupational Safety and Health Act requirements would be complied with during construction and operation of these facilities and the impacts should be SMALL. The NES or an alternative CAES facility would use natural gas in its power generation mode. The GElS cites risk of accidents to workers and public health risks (e.g., cancer, or emphysema) from the inhalation of toxics and particulates associated with air emissions as potential risks to human health associated with the gas-fired generation alternative (NRC 1996, Table 8.2). However, regulatory requirements imposed on facility design, construction, and operations under the authority of the Occupational Safety and Health Act, Clean Air Act, and related statutes are designed to provide an appropriate level of protection to workers and the public. Additionally, regulatory agencies, includinq the USEPA, USOSHA, and state aqencies, set air emission standards requirements for workers and the public based on human health impacts. Given the extensive health-based regulatory control, FENOC considers that human health impacts from operating a CAES plant at NES or an alternate site, regardless of plant location, would be SMALL. I Environmental Impacts of Alternatives Page 7.3-21 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Socioeconomics Major sources of potential socioeconomic impacts from interconnected wind farms with CAES would be similar to those discussed in Section 7.3.3.1. The number of peak construction workers expected to build the NES facility is unknown at this time: however, it is likely not to exceed the number for a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Table 8.1). FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. To operate and maintain the NES plant would require approximately 50 to 100 workers. FENOC believes that the construction impacts, although noticeable, would be spread throughout the State and should not impact any one local community over another. The financial impacts from closing Davis-Besse, however, could be significant to the areas surrounding the station. The addition of an operational workforce for the CAES facility and new tax revenue for the local community near the CAES facility would be a beneficial impact in that local community. As a result, FENOC considers that the overall socioeconomic impact of construction and operation of the NES or an alternative CAES site would be SMALL to MODERATE. Waste Management Construction of interconnected wind farms could result in generation of large amounts of vegetation from land clearing activities. If this material is managed correctly (e.g. recycled or composted) then the impacts should be SMALL. Like gas-fired generation, NES or an alternative CAES site would result in minimal waste generation, producing minor (if any) impacts (NRC 1996, Section 8.3.10). As a result, FENOC considers waste management impacts from the operation of a CAES plant at an alternative site would be SMALL. Aesthetics Most wind farms are located in remote areas and may generate large aesthetic concerns, particularly if sited on highlands or in recreational areas and could have some effect on the aesthetic quality. In general, impact on aesthetic quality for wind farms located in flat-lying rural areas would be SMALL Potential aesthetic impacts of construction and operation of NES or an alternative CAES Plant may include visual impairment resulting from the presence of a large industrial facility, including multiple exhaust stacks and mechanical-draft cooling towers with associated condensate plumes. Considering the flat topography in northwestern Ohio and other areas where an alternative CAES may be placed, the stacks and condensate plumes would likely be visible for several miles from the site: new transmission lines constructed to connect the plant to the grid would also be relatively visible for the same I Environmental Impacts of Alternatives Page 7.3-22 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report reason, though would not be out of character for most rural areas including the northwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics) The NES site is on a brownfield area located iust south of Norton, Ohio. The construction of the facility would cause a minor change in the appearance of the area, but aesthetic impacts would be SMALL. FENOC expects that an alternative CAES plant likely would be located in a rural area, and assumed that adequate buffer and vegetation screens would be provided at the plant site as needed to moderate visual and noise impacts. In view of the environmental review afforded under OPSB rules, FENOC considers that the impacts to aesthetics from construction and operation of interconnected wind farms and NES or an alternative CAES site would depend on location and be SMALL to MODERATE. Cultural Resources As discussed in Section 7.3.3.1, FENOC concludes that the potential adverse impact on cultural resources of the interconnected wind farms, regardless of location, would be SMALL. FENOC assumed that the NES facility or alternative CAES plant and associated gas-supply pipeline and transmission lines would be located with consideration of cultural resources under OPSB or comparable program rules, and the impact would be SMALL. 7.3.3.3 Photovoltaic Power Combined with CAES Environmental impacts of solar power systems can vary based on site-specific conditions. Land use and aesthetics are the primary environmental impacts of solar power. Land requirements for PV facilities are large, compared to the land currently used by Davis-Besse. During operation, however, PV technologies produce no air pollution, little or no noise, and require no transportable fuels. Land Use As stated in the GElS, land requirements are high: 35,000 ac (14,000 ha) li.e., 54.7 square milesi per 1,000 MWe for PV cells (NRC. 1996). An NREL study (for the western United States) has indicated the amount of land required depends on the available solar insolation and ranges from about 3.8 to 7.6 acres per MW for photovoltaic systems with a capacity factor ranging from 20 to 25%. (NREL 2002) Assuming an average capacity factor of 24% from NREL 2002, and 5 acres per MW, plus an additional 910 MWe needed for energy storage, and the estimated required land would be approximately 37,900 acres (59.2 square miles). I Environmental Impacts of Alternatives Page 7.3-23 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Unlike wind power generation, all the land used to construct the solar generation facilities would be Permanently disturbed and could not be used for other purposes. To reduce the amount of land use, the solar facilities could be placed in the same locations as the wind generation facilities, or brownfield locations assuming these are flat areas with sufficient sunlight. PV arrays are placed on the rooftops of businesses and residential dwellings to generate electricity or to heat water. These units are usually small and are designed to provide energy directly to the facility or residence to which they are attached. Only in a few cases are these PV arrays large enough to provide excess energy to the grid. Based on these data, FENOC considers that the overall impacts of land use from construction and operation of the representative solar power facilities alone would be LARGE. Land use associated with the NES facility would be limited to the facilities' 92 surface acres. There would be some land impacted during construction but this site has been previously disturbed so the impact should be SMALL. However, if another site is chosen for the CAES or an additional CAES facility is needed to meet base-load power requirements then the potential impacts to land resources could be MODERATE to LARGE. Water Use and Quality - Surface Water Solar generation using PV technoloqy does not require cooling water or intake structures. Therefore, there would be no impact on water use and the only potential impact on local water quality would be erosion or sedimentation issues during construction. These impacts would be minimized by using best management practices during construction activities. Significant amounts of water could be used to keep the solar panels clean so they remain effective in collecting the maximum amount of sunlight possible. Since the areas where these solar facilities would be located are not in a desert or semi-arid environment, the demands on water resources should be reduced. Overall, the impacts on water use and quality should be SMALL to MODERATE. Surface water impacts associated with the CAES cooling systems are discussed in detail in Section 7.3.3.2, and are SMALL. Overall, FENOC considers that the impacts from construction and operation of solar generation facilities and a CAES plant at alternative sites on surface water use and quality would be SMALL to MODERATE. 7.3-24 Seotember 2011 Page 7.3-24 of Alternatives Impacts of I IEnvironmental Impacts Alternatives Page September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Water Use and Quality - Ground Water Impacts would depend on whether the plant would use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumed that the NES plant or a CAES plant at an alternate site would not rely on ground water for plant cooling, and that regulations for ground water use for potable water would limit impacts to SMALL. Air Quality There are no air quality impacts associated with the operation of solar generation facilities. Potential emissions from NES are discussed in Section 7.3.3.2 and Table 7.3-3. FENOC considers that the impacts to air quality from operation of a CAES facility at an alternative site would be MODERATE. Ecological Resources As noted in the Land Use subsection above, development of solar generation facilities would have a maior impact on land resources, which could have a significant impact on the ecological resources durinq construction and operation of these facilities. As stated in the Land Use subsection, approximately 37,900 acres would be permanently disturbed, and with the possible loss of important habitat. Although FENOC assumed that construction best management practices and awareness to critical habitat during operations would minimize effects to ecological resources, the potential for significant impacts would be MODERATE to LARGE. As discussed in Section 7.3.3.2, since the NES is a former underqround limestone mine and only has 92 acres of land use at the surface, the potential impact to ecoloqical resources is SMALL. However, if another CAES site with compressed air storage on the land surface is chosen or needed to provide additional stored energy capacity, then the ecoloqical impacts could be MODERATE to LARGE. Human Health The health risks for the construction and operation of a series of solar qeneration facilities would be accidents and potential exposure to hazardous materials. FENOC assumed that all Occupational Safety and Health Act requirements would be complied with during construction and operation of these facilities and the impacts should be SMALL. Seotember 2011 Page 7.3-25 I IEnvironmental Impacts of Alternatives Impacts of Alternatives Page 7.3-25 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report As discussed in Section 7.3.3.2, given the extensive health-based regulatory control, FENOC considers that operating the CAES plant at NES or an alternate site, regardless of plant location, would be SMALL. Socioeconomics Maior sources of potential socioeconomic impacts from the solar power with associated NES or CAES facility alternative include temporary increases in iobs, economic activity, and demand for housing and public services in communities surrounding the sites during the construction period. These impacts would be spread throughout the state and should not impact any one local community over another. Countering these increases are losses in permanent mobs, tax revenues, and economic activity attributable to operation of the alternative generation facilities and termination of operations of Davis-Besse. Typically, renewable energy sources are not subject to the tax rate of conventional energy generating facilities, so the loss of permanent iobs and tax revenue could be significant to the communities near Davis-Besse and thus the impacts could be SMALL to MODERATE. Communities in Ottawa County, however, particularly those within the taxing jurisdiction of Carroll Township and the Benton-Carroll-Salem School District, would experience losses in both employment and tax revenues due to Davis-Besse's closure that could constitute MODERATE impacts. The number of peak construction workers expected to build the solar power facilities and the NES facility is unknown at this time. However, it is likely not to exceed that of a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Table 8.1). To operate and maintain the solar facilities and NES plant would require approximately 150 to 200 workers. FENOC expects that most of the construction workforce would commute and relatively few would relocate into the area, and associated socioeconomic impacts during construction would be SMALL. In summary, FENOC considers that the overall socioeconomic impact of construction and operation of the representative solar generation combined with CAES generation facility would be SMALL to MODERATE. Waste Management PV technology creates environmental impacts related to manufacture and disposal. Chemicals used in the manufacture of PV cells include cadmium and lead. Potential human health risks also arise from the manufacture and deployment of PV systems because there is a risk of exposure to heavy metals such as selenium and cadmium. The cumulative and long-range impacts from transporting and disposing of hazardous waste could be SMALL to MODERATE. I Environmental Impacts of Alternatives Page 7.3-26 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Aesthetics Most solar facilities are located in remote areas and would likely not generate large aesthetic concerns and would likely meet minor public resistance. Overall, the impacts from the construction and operation of solar power facilities would be SMALL. Cultural Resources Due to the large land use to construct the necessary solar generation facilities and for the CAES facility, the potential for impacting cultural resources could be LARGE. To minimize these impacts, FENOC assumed construction activities would consider cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of the solar generating facilities, regardless of location, would be SMALL. FENOC assumed that the NES facility or alternative CAES plant and associated gas-supply pipeline and transmission line would be located considering cultural resources under OPSB or comparable program rules and, therefore, any impacts would be SMALL. 7.3.3.4 Combinations of Wind and Solar with CAES As discussed in Sections 7.2.1 and 7.2.1.3, FENOC evaluated a combination of wind and solar generation along with CAES as an alternative to replace the rated electrical output of Davis-Besse. The environmental impact results for interconnected wind farms and PV solar and CAES facilities are discussed in detail in Sections 7.3.3.1 through 7.3.3.3. A summary of these results is described below and listed in Table 8.0-1. Land Use The amount of territory required for the construction and operation of a series of wind farms and solar PV facilities would result in LARGE land use impacts. Most of this land would be in qreenfield or agricultural areas. Although some land used to develop wind farms could be used to generate solar power, there could be several issues including agriculture needs, transmission capacity and sunlight duration that may limit the multiuse of this land. Land use associated with the NES facility would be limited to the facility's 92 surface acres. There would be some land impacted during construction, but this site has been I Environmental Impacts of Alternatives Page 7.3-27 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report previously disturbed so the impact should be SMALL. However, if another site is chosen for the CAES or an additional CAES facility is needed to meet base-load power requirements, then the land use impact could be MODERATE to LARGE. Water Use and Quality - Surface Water Wind farms and solar generation using PV technology do not require cooling water or intake structures. Therefore, there would be no impact on water use and the only potential impact on local water quality would be erosion or sedimentation issues during construction. These impacts would be minimized by using best management practices during construction activities. Significant amounts of water could be used to keep the solar panels clean so they remain effective in collecting the maximum amount of sunlight as possible. Since the areas where these solar facilities would be located are not in a desert or semi-arid environment, the demands on water resources should be reduced. Overall, the impacts on water use and quality should be SMALL to MODERATE. CAES have cooling towers associated with the use of gas turbines to produce electricity and compressors to recharge the storage structure. These cooling towers are much smaller than those typically used for coal and gas generation plants. Cooling makeup water evaporative losses and discharge flows for the plant would be considerably less than that of Davis-Besse, primarily because less power would be derived from a steam cycle. (FENOC 2007, Section 7.2.2.1) During CAES operation, cooling water and wastewater discharges would be regulated under the federal CWA and corresponding state programs by an NPDES permit. Construction activities would be similarly regulated to ensure protection of water resources. In addition, impacts on water use and quality would be subiect to scrutiny in the planning stage under OPSB or similar governing authority rules. Overall, FENOC considers that the impacts from construction and operation of this combined energy alternative on surface water use and quality to be SMALL to MODERATE. Water Use and Quality - Ground Water Impacts would depend on whether the combined energy alternative facilities would use ground water for any purposes, as well as the characteristics of local aquifers. Regardless of location, FENOC assumed that the NES plant or a CAES plant at an alternate site would not rely on ground water for plant cooling, and that regulations for ground water use for potable water would limit impacts to SMALL. FENOC also assumed that construction of the facilities would employ best management practices to keep the impact to groundwater quality SMALL. I Environmental Impacts of Alternatives Page 7.3-28 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Air Quality The construction of roads and turbine tower supports would result in short-term impacts in air quality from fugitive dust and equipment emissions. There are no air quality impacts associated with the operation of wind farms and solar PV facilities, therefore the overall impacts would be SMALL. CAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogen oxides being the primary focus of combustion emission controls. The NES facility has been issued an air permit by the Ohio EPA, and emission details are discussed in Section 7.3.3.2 and Table 7.3-3. FENOC assumed that best management practices would be utilized during construction activities to minimize impacts to air quality. In addition, FENOC assumed that the NES or alternate CAES facility would comply with its air permit, thus impacts to air quality should be MODERATE. Ecological Resources As noted in the Land Use subsection above, development of wind farms and solar PV facilities and CAES would have a MODERATE to LARGE impact on land resources which could have a MODERATE to LARGE impact on the ecological resources during construction and operation of these facilities. FENOC assumed that construction best management practices and awareness to critical habitat during operations would minimize impacts to ecological resources. Human Health The only major health risk for the construction and operation of a series of wind farms and solar PV facilities, and a CAES plant would be accidents. There may be minor health impacts from reduced air quality during construction and the operation of the CAES facility and from handling potential hazardous substances or waste materials. FENOC assumed that all air permits and Occupational Health and Safety Act requirements would be complied with during construction and operation of these facilities, and the impacts should be SMALL. Socioeconomics Maior sources of potential socioeconomic impacts from wind farms and solar PV systems with an associated NES or CAES facility include temporary increases in obs. economic activity, and demand for housing and public services in communities surrounding the sites during the construction period. Socioeconomic impacts are similar to those discussed in Sections 7.3.3.1 to 7.3.3.3 and would be SMALL to MODERATE. I Environmental Impacts of Alternatives Page 7.3-29 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Waste Management PV technology creates environmental impacts related to manufacture and disposal. Chemicals used in the manufacture of PV cells include cadmium and lead. Potential human health risks also arise from the manufacture and deployment of PV systems because there is a risk of exposure to heavy metals such as selenium and cadmium. The cumulative and long range impacts from transporting and disposing of hazardous waste could be a MODERATE to LARGE impact. Minimal waste streams should be generated from the construction and operations of the wind power and CAES facilities. Therefore, the impacts should be SMALL. Aesthetics Most wind farms are located in remote areas and may generate large aesthetic concerns, particularly ifsited on highlands or in recreational areas. Solar PV generation requires relatively flat land, which limits the view to the public. However, presence of overhead transmission lines may cause some moderate public resistance. To minimize these impacts, the renewable generation facilities would likely be located in rural areas as much as possible. The proposed NES facility is located in a brownfield area and should not change the aesthetic view of the area. Overall, the aesthetic impacts from these facilities should be SMALL. Cultural Resources Due to the large amount of land needed to construct the necessary wind farms and solar PV facilities, and for the CAES facility, the potential for impacting cultural resources could be LARGE. To minimize these impacts, FENOC assumed construction activities would consider cultural resources under OPSB or comparable program rules. FENOC further assumed that appropriate measures would be taken to avoid, recover, or provide other mitigation for loss of any resources discovered during onsite or offsite construction. On this basis, FENOC concludes that the potential adverse impact on cultural resources of this combined energy alternative regardless of location would be SMALL. 7.3.3.5 Conclusions of Combining New Generation Power Sources with Storage The use of wind power in the form of interconnected wind farms and/or solar photovoltaic power, in combination with CAES to provide power to replace Davis-Besse's output by 2017 has been evaluated and discussed in the subsections above. The environmental impacts associated with renewable sources and CAES were evaluated in Subsections 7.3.3.1.7.3.3.2.7.3.3.3 and 7.3.3.4. The overall conclusion from this impact analysis is that the combination of these energy source alternatives has SMALL to LARGE impacts. These impacts are compared in Section 8.0 to the impacts from renewal of the Davis-Besse license for another 20 years as well as those for the alternative coal and natural gas fired plants. I Environmental Impacts of Alternatives Page 7.3-30 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.3-1: Air Emissions from Coal-Fired Alternative ParameterO) Calculation Result Heat Rate Total Gross Capability x Heat Rate x Conversion Factors x Capacity Factor tons/year Annual Coal Heat Value Consumption 910 MW x 9,800 Btu lb 1,000 kW 8,760 hr ton xx - x- x 0.80 2,543,644 kW x hr 12,285 Btu MW year year 2,000 lb Emissions Coal Consumption x Uncontrolled Emissions x Conversion Factors x [100 - removal efficiency (%)](2) tons/year 2,543,644 tons 130 lb ton 100-95 year ton 2,000 lb 100 NOx 2,543,644 tons 10lb ton 100-60 year ton 2,000 lb 100 CO 2,543,644 tons 0.51b ton 636 year ton 2,000 lb PM 2,543,644 tons 120 lb ton 100-99.9 year ton 2,000 lb 100 PM1 , 2,543,644 tons 27 lb ton 100- 99.9 year ton 2,000 lb 100 C02 2,543,644 tons 2,4,4 tor 6,000 lb x ton - 7,630,3 year ton 2,000 lb Btu = British thermal units CO = carbon monoxide CO 2 = carbon dioxide hr = hour kW = kilowatt lb = pound MW = megawatt NOx = nitrogen oxides PM = total filterable particulate matter PM10 = PM having a diameter less than 10 microns SOx = sulfur oxides Notes: (1) Source: Table 7.2-1 (2) There are no emission controls for CO and CO 2 . I Environmental Impacts of Alternatives Page 7.3-31 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.3-2: Air Emissions from Gas-Fired Alternative ParameterO) Calculation Result Gross Capability x Heat Rate x Conversion Factors x Capacity Factor MMBtu/year Annual Gas Heat inputHetInu910 1 MW Wxx 6,500 Btu x 1,000- kW x -- 8,760 hr x 0.80 41,452,320 kW-hr MW year Emissions Annual Gas Heat Input x Uncontrolled Emissions tons/year x Conversion Factors x [100 - removal efficiency (%)] (2) 41,452,320 0.00064 lb ton 13.3 year MMBtu 2,000 lb NOx 41,452,320 0.099 lb X ton 100 - 90 year MMBtu 2,000 lb 100 CO 41,452,320 0.015 lb ton year MMBtu 2,000 lb PM (all PM1o) 41,452,320 0.019 lb ton year MMBtu 2,000 lb 41,452,320 110 Ib ton CO 2 year MMBtu 2,000 lb Btu = British thermal units CO = carbon monoxide CO 2 = carbon dioxide hr = hour kW = kilowatt Ib/MMBtu = pounds per million British thermal units MW = megawatt NOx = nitrogen oxides PM = particulate matter PM1 o = PM having a diameter less than 10 microns SOx = sulfur oxides (mainly SO 2) Notes: (1) Source: Table 7.2-2 (2) There are no emission controls for SO2, CO, PM, and CO 2. I Environmental Impacts of Alternatives Page 7.3-32 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 7.3-3 Permifted Air Emissions from the Proposed Norton Energv Storage Project Parameter Quantity Volume S_. 42.41 tons/year* NO, 93.67 tons/year* CO 90.36 tons/year* all PM1 46.65 tons/year* Volatile Or-ganic 26.40 tons/year* Compounds C 681,100 tons/year* CO = carbon monoxide COz = carbon dioxide NOx = nitrogen oxides PM = particulate matter PM1 0 = PM having a diameter less than 10 microns SO = sulfur dioxide

• Based on rolling, 12-month permits Emissions are li~tp.d hased on Permit information, and are from units PO01 - POO6.

E~mbisinsae inulistdbae otrinPermi~toinfomaio iare~ andr~ trom unit P00(14 -W P006i Eouipment

Description:

Each Combustion Train - 589MMBtu/hr Dresser Rand natural gas fired combustion turbine (134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, water injection, and selective catalytic reduction. As exolained in Serction 7 213. FirstEnermv estimates that only unto four units Section 7 2 1 3 FirstEnerav estimates that onIv un to four units As 536 MW)incould (i.e.,exnlained be online by 2017. Source: NES 2010 7.3-33 September 2011 Page I IEnvironmental Impacts of Alternatives Impacts of Alternatives Page 7.3-33 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report [This page intentionally blank] Seotember 2011 Page 7.3-34 I IEnvironmental Impacts of of Alternatives Alternatives Page 7.3-34 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report

7.4 REFERENCES

Note to reader: This list of references identifies web pages and associated URLs where reference data were obtained. Some of these web pages may likely no longer be available or their URL addresses may have changed. FENOC has maintained hard copies of the information and data obtained from the referenced web pages. ,AEP 2011. AEP Ohio to Partner with Turning Point Solar on the Development of the - - - Deleted: EERE 2008. Advantages

                                                                                            - - -        J and Disadvantages of Wind Energy, Turning Point Solar Generatinq Facility in MNoble County, Website:                                         U.S. Department of Energy, Office of

.httr:/lwww.prnewswire.com/. ... oartner-with-tturning-point-on-the-development-of-the- Energy Efficiency and Renewable turning-point-solar-generation-facility-in-noble-county-125021444.html, accessed .[ Energy, Website: September 6. 2011. Deleted: http:/Mvwwl .eere.energy.go vtwindandhydro/wind_ad.html AWEA 2002. Most Frequently Asked Questions About Wind Energy, American Wind Energy Association, May 2002. AWEA 2011. Wind Energy Facts: Ohio, American Wind Energy Association, July 2011. CA 2011. Machines of the Ocean: The Aesthetics od Wind Farms, Contemporary Aesthetics. Website: http://www.contempaesthetics.org/newvolume/pages/article.php?articlelD=247, accessed September 7. 2011. CBS 2010. World's Largest Wind Farm Churns in Texas, CBS News, Website: cbsnews.com/stories/2009/10/02/tech/livinggreen/main5358287.shtm, accessed September 1. 2011. CWP 2007. Cape wind Energy Proiect Final Environmental Impact report/Development of Regional Impact, Cape wind Project, February 2007. EERE 2009a. Ohio Wind Resource Map, U.S. Department of Energy, Energy Efficiency and Renewable Energy, available at http://www.windpoweringamerica.gov/astate-template.asp?stateab=oh, accessed June 30, 2009. EERE 2009b. Pennsylvania Wind Resource Map, U.S. Department of Energy, Energy Efficiency and Renewable Energy, available at http://www.windpoweringamerica.gov/astate-template.asp?stateab=pa, accessed June 30, 2009. EIA 2010. Electric Power Annual 2008, DOE/EIA-0348(2008), U.S. Department of Energy, Energy Information Administration, January 2010. References Page 7.4-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report FENOC 2007. FirstEnergy Nuclear Operating Company, Beaver Valley Power Station Unit Nos. 1 and 2, License Renewal Application, Appendix E, Applicant's Environmental Report - Operating License Renewal Stage, Facility Operating License No. DPR-66 and NPF-73, Akron, OH, ADAMS Accession No. ML072470523. FirstEnergy 2008a. 2008 Annual Report, FirstEnergy Corp., Akron, Ohio, Website: http://www.firstenergycorp.com/financialreports/index.html, accessed January 12, 2010. FirstEnergy 2008b. FirstEnergy Generation System, 6/25/08, Website: http://www.firstenergycorp.com/corporate/Corporate-Profile/FirstEnergyGeneration_Sy stem.html, accessed July 13, 2009. FirstEnergy 2009a. FirstEnergy Boston Investor Meetings, June 11, 2009, Website: http://investors.firstenergycorp.com/phoenix.zhtml?c= 102230&p=irol-presentations, accessed June 21, 2009. FirstEnergy 2009b. FirstEnergy to Repower R.E. Burger Plant With Biomass, News Release, FirstEnergy Corp., Akron, Ohio, April 1, 2009. GLWEC 2009. Final Feasibility Report, Great Lakes Wind Energy Center, April 2009. IEAWIND 2002. Summary of lEA R&D Wind - Topical Expert Meeting #40, Environmental issues of Offshore Wind Farms, September 2002. INEEL 1998. U.S. Hydropower Resource Assessment Final Report, Document DOE/ID-10430.2, Idaho National Engineering and Environmental Laboratory, December 1998. NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008. ISEP 2011. Iowa Stored Energy Park Proiect Terminated, Press Release, July 28. 2011. JACM2007. Supplying Baseload Power and Reducing Transmission Requirements by Interconnected Wind Farms, Journal of Applied Meteorology and Climatotology, November 2007. LEEDco 2011. About LEEDco Lake Erie Energy Development Corporation, Website. www.leedco.org/about-us/about-leedco, accessed August 10, 2011. NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008. NERC 2009. 2009 Long Tern Reliability Assessment, North American Electric Reliability Corporation, October 2009. References Page 7.4-2 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report NES 2010. Norton Energy Storage, LLC, Final Air Permit-To-Install and Operate, Ohio EPA, September 2010. NRC 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, May 1996. NRC 2002. Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, NUREG-0586 Supplement 1, Volume 1, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, November 2002. NRC 2009a. Combined License Applications for New Reactors, Website: http://www.nrc.gov/reactors/new-reactors/col.html, accessed July 13, 2009. NRC 2009b. Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GELS), NUREG-1437, Supplement 36, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, May 2009. NRC 2010. _Combined License Applications for New Reactors, Website: http://www.nrc.gov/reactors/new-reactors/col.html, accessed June 18, 2010. S2002. Fuel from the Sky - Solar Power's Potential for Western EnergySul. _ - -S Deleted: NREL 1986. Wind Energy National Renewable Energy Laboratory, July 2002. Resource Attas ofofthe U.S. Department UnitedDOEJCH Energy, States, 10093-4, Pacific Northwest National NREL 2010. Large-Scale Offshore Wind Power in the United States, National Laboratory, October 1986, Website: http:llrredc.nrel.govtwind/pubs/atlas/a Renewable Energy Laboratory, June 2010. tlasindex.html, accessed July 13,

                                                                                                               %2009.11 NREL 2010a. Assessment of Offshore Wind Energy for the United States, National Renewable Eneraqy Laboratory, September 2010.

NREL 2011. Eastern Wind Integration and Transmission Study, National Renewable Energy Laboratory, February 2011. NREL 2011a. Estimates of Windy Land Areas and Wind Energy Potential by State, National Renewable Energy Laboratory, Updated April 13, 2011. OHPUCO 2009. Alternative Energy Portfolio Standard, Chapter 4901: 1-40, Ohio Public Utilities Commission, December 2009. PEI 2008. Compressed Air Energy Storage,: Theory, Resources, and Applications for Wind Power Energy Systems Analysis group, Princeton Environmental institute, Princeton Universitv. Adril 2008. ..................... I I " -F ........ PMJ 2011. State of the Market report for PJM, Monitoring Analytics, LLC, August 2011. References Page 7.4-3 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report POST 2006. Carbon Footprint of Electricity Generation, Parliamentary Office of Science and Technology, October 2006, available at http:/lwww.parliament.ukldocuments/upload/postpn268.pdf, accessed July 8, 2009. PSEG 2010. Governor Strickland Helps Dedicate Ohio's Largest Solar Farm, Media Release from Public Service Enterprise Group, August 19, 2010. REN 2005. Assessing the Life Cycle of Wind turbine Production, Renewable Energy World, Website. www.renewableenerqvworld.com/rea/news/article/2005/04/assessinq - the-life-cycle-of-wind-turbine-production-25113, accessed Auqust 6, 2011. RES 2005. The Economic Impact of CAES on Wind in TX, OK. and NM, Ridge Enerqy Storage & Grid Services, L.P., June 2005. RWC 2010. Roscoe Wind Council, Website: http://www.roscoewind.org/roscoe wind farm/php. accessed September 11, 2011. SWAY 2010. Norway to Build the World's Largest Wind Turbine, Website. http://inhabitat.com/norway-to-build-the-worlds-largest-wind-turbine, accessed September 1,2011. TBM 2011. lberdrola Sells Energy from Blue Creek Wind Farm project, Times Bulletin Media, February 9. 2011. Website: http://www.timesbulletin.com/main.asp?SectionlD=2&SubsectionlD=4&ArticlelD=16433 9. TEP2006. Photovoltaic Power Experience at Tucson Electric Power, Sandia National Laboratories and Tucson Electric Power Company, April 2006. USDOE 1999. Executive Summary, Clean Coal Technology Evaluation Guide - Final Report, December 1999, available at http://www.netl.doe.gov/technologies/coalpower/cctc/ccpi/bibliography/program/bibp-ev. html, accessed June 26, 2009. USDOE 2009a. Installed U.S. Wind Capacity and Wind Project Locations, Website: http://www.windpoweringamerica.gov/windinstalledcapacity.asp, accessed July 9, 2009. USDOE 2011. A national Offshore Wimd Strategy: Creating an Offshore Wind Energy Industry in the United States, U.S. Department of Energy, February 2011. USDOI 2011. News Release - Salazar Announces Additional Steps Towards Smarter Develooment of Renewable Energy on U.S. Public Land, United States Department of Interior, February 8, 2011. References Page 7.4-4 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report USDOE 2009b. Future Fuel Cells R&D, U.S. Department of Energy, Office of Science and Technology, Website: http://www.fossil.energy.gov/programs/powersystems/fuelcells/, accessed June 30, 2009. USDOE 2010. Monthly Nuclear Generation by State and Reactor, 2008, U.S. Department of Energy, Energy Information Administration, Website: http://www.eia.doe.gov/cneaf/nuclear/page/nucgeneration/gensum.html, accessed January 12, 2010. USEPA 2009a. Electricity from Municipal Solid Waste, U.S. Environmental Protection Agency, Website: http://www.epa.gov/cleanenergy/energy-and-you/affectlmunicipal-sw.html, accessed June 30, 2009. USEPA 2009b. EPA's Response to the TVA Kingston Fossil Fly Ash Release, U.S. Environmental Protection Agency, Region 4, May 11, 2009. USFWS 2002. Migratory Bird Mortality, United States Fish and Wildlife Service, January 2002. USFWS 2011. United States Fish and Wildlife Service - Draft Land-Based Wind Energy Guidelines, February 2011. WGA 2011. Timber Road Wind Farm in Ohio, Wind Action Group, Website. http://waqengineering.blogspot.com/2011/05/timber-road-wind-farm-in-ohio.html, accessed September 1. 2011. WTE 2007. 2007 Directory of Waste-to-Energy Plants in the United States, Waste-to-Energy Resources, Energy Recovery Council, Website: http://www.wte.org/waste-energy-resources-a2985, accessed June 30, 2009. References Page 7.4-5 September 2011

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Davis-Besse Nuclear Power Station License Renewal Application Environmental Report 8.0 COMPARISON OF ENVIRONMENTAL IMPACT OF LICENSE RENEWAL WITH THE ALTERNATIVES Regulatory Requirement: 10 CFR 51.45(b)(3)

       "To the extent practicable, the environmental impacts of the proposal and the alternatives should be presented in comparative form." as adopted by 10 CFR 51.53(c)(2)."

FENOC presents its evaluations of the environmental impacts of Davis-Besse license renewal in Chapter 4 and reasonable alternatives in Chapter 7. In this chapter, FENOC provides a comparative summary of these impacts. Table 8.0-1 summarizes environmental impacts of the proposed action (license renewal) and the alternatives, for comparison purposes. The environmental impacts compared in Table 8.0-2 are those that are either Category 2 issues for the proposed action or are issues that the GElS (NRC 1996) identified as major considerations in an alternatives analysis. For example, although the NRC concluded that air quality impacts from the proposed action would be small (Category 1), the GElS identified major human health concerns associated with air emissions from alternatives (Section 7.2.2). Therefore, Table 8.0-1 compares air quality impacts from the proposed action to the alternatives. Table 8.0-2 is a more detailed comparison of the alternatives. As shown in Table 8.0-1 and Table 8.0-2, environmental impacts of the proposed action (Davis-Besse license renewal) are expected to be SMALL for all impact categories evaluated. In contrast, FENOC expects that environmental impacts in some impact categories would be MODERATE or MODERATE to LARGE for the no-action alternative (NRC decision not to renew Davis-Besse operating license), considered with or without development of replacement generation facilities. As codified in the NRC regulations at 10 C.F.R. ý 51.95(c)(4). "the NRC staff.--------. -- Deleted: As a result, adiudicatory officers, and Commission shall determine whether or not the adverse environmental impacts of license renewal are so great that preservinq the option of license renewal for energy planning decision makers would be unreasonable." The Commission explained this standard as follows: Given the uncertaintiesinvolved and the lack of control that the NRC has in the choice of energy alternativesin the future, the Commission believes that it is reasonableto exercise its NEPA authority to reiect license renewal applicationsonly when it has determined that the impacts of Comparison of Environmental Impact of Page 8.0-1 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report license renewal sufficiently exceed the impacts of all or almost all of the alternativesthat preservinq the option of license renewal for future decision makers would be unreasonable. Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, 61 Fed. Reg. 28,467, 28,473 (June 5. 1996). FENOC concludes that the environmental impacts of the continued operation of Davis-Besse, providing approximately 910 MWe of base-load power generation through 2037, when compared to alternatives discussed in Section 7.0 of this Environmental Deleted: are superior to impacts associated with the best case among Report, demonstrate that preservingq license renewal as an option is not unreasonable. reasonable alternatives. Davis-Besse continued operation would create significantly less environmental impact than the construction and operation of new base-load generation capacity. Additionally, Davis-Besse continued operation will have a significant positive economic impact on the communities surrounding the station Comparison of Environmental Impact of Page 8.0-2 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-1: Impacts Comparison Summary 1 No-Action Alternatives( ) Proposed Impact( 2 ) Action Base With With (License (Decommissioning) With Coal-Fired With Gas-Fired Interconnected Renewable & Renewal) Generation Generation Wind CAES Generation Land Use SMALL SMALL MODERATE to SMALL to MODERATE LARGE to LARGE LARGE MODERATE SMALL SMALL MODERtEto Water Quality SMALL SMALL SMALL SMALL MODERATE Air Quality SMALL SMALL MODERATE MODERATE(3" SMALL MODERATE Ecological SMALL SMALL MODERATE SMALL to SMALL to LARGE MODERATE to Resources MODERATE LARGE Human Health SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL MODERATE MODERATE SMALL to SMALL to Socioeconomics MODERATE MODERATE Waste Magee SMALL SMALL MODERATE SMALL SMALL SMALL Management SMALL to SMALL to SMALL to Aesthetics SMALL SMALL MODERATE MODERATE MODERATE SMALL Cultural Resources SMALL SMALL SMALL SMALL SMALL SMALL Seotember 2011 Comparison of Environmental Impact of Page 8.D~3 Page 8.073 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Notes: (1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at a greenfield site would exceed those for a coal-fired or gas-fired plant located at a brownfield, i.e., existing disturbed site. (2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-1, Footnote 3:

    - SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.
    - MODERATE - Environmental effects are sufficient to alter noticeably, but not destabilize, any important attribute of the resource.
    - LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

(3) Moderate, but less than with coal-fired generation. Comparison of Environmental Impact of Page 8.0-4 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail No-Action Alternatives(1 )'(2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Wind Generation Gnato Generation Alternative Descriptions Davis-Besse license Decommissioning New construction at New construction at New construction at New construction renewal for 20 years, following expiration of greenfield (but greenfield (but .reenfield locations, at ,reenfield (wind, followed by current Davis-Besse preferably brownfield) preferably brownfield) and solar) CAES at decommissioning license. Adopting by site. site. brownfield site. reference, as bounding Davis-Besse Pulverized coal units, Combined-cycle units, Wind generation Assume CAES with decommissioning, GElS 910-MW (equivalent 910-MW (equivalent units, 910-MW natural gas units at description (NRC 1996, to Davis-Besse); to Davis-Besse); (equivalent to electrical output of Section 7.1). capacity factor 0.80. capacity factor 0.80. Davis-Besse); 804 MW (6 trains). capacity factor 0.80. Closed-cycle cooling Closed-cycle cooling No cooling required. Closed-cycle with 500-foot-tall with mechanical-draft cooling with natural-draft cooling cooling towers. mechanical-draft towers, cooling towers for CAES. Coal and limestone Delivery of natural gas No fuel delivery Delivery of natural delivery via waterway via a new 10-mile- system required. gas via a new or rail. long pipeline. 10-mile-lonq pipeline for CAES. Seotember 2011 Comparison of Environmental Impact of Page 8.0-5 Page 8.0-5 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternativest1t (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Wind Generation &eCaEo Generation Air emission controls: Air emission controls: No air emission Air emission Particulates: fabric Nitrogen oxides: dry controls required. controls: Nitrogen filter (99.9% removal) low-NOx burners; oxides: dry low-Sulfur oxide: wet selective catalytic NOx bumers: limestone scrubber reduction (90% selective catalytic (95% removal) removal). Particulate reduction (90% Nitrogen oxide: matter and carbon removal). low-NOx burners, monoxide emissions Particulate matter overfire air, selective limited through proper and carbon catalytic reduction combustion controls. monoxide (95% removal), emissions limited through proper combustion controls for CAES. Emissions dispersed Exhaust dispersed via No emissions or Exhaust dispersed via 500-foot-tall 150-foot-tall stacks. heat plume exhaust, via 150-foot-tall (or stacks. less) stacks. 825 permanent and Estimated workforce: Estimated workforce: Estimated Estimated 60 contract workers Construction: 1,092 - Construction: 1,092 - workforce: workforce: (Section 3.4) 2,275; Operation: 228 2,275; Operation: 137 Construction: 1,200 Construction: 1,200

                                                                                              - 1,500a Operation:     - 1,500: Operation:

150. 150. Comparison of Environmental Impact of Page 8.0-6 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(1 )' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Wind Generation &eCaES Generation Land Use Impacts SMALL - Adopting by SMALL - Adopting by MODERATE to SMALL to MODERATE to LARGE - up to reference Category 1 reference applicable LARGE - 1,547 acres MODERATE - 100 LARGE - Would be 91,000 acres issue findings NRC impact conclusions required for the acres for facility and dependent on how required for wind (Table A-i, Issues 52, in the GElS Section 8.4 powerblock and 240 to 270 additional many wind farms and 37,900 acres 53). and Supplement 1 to associated facilities; acres for gas pipeline onshore verses for solar generation NUREG-0586. assumed 10 miles of and electric offshore and associated 345-kV transmission transmission lines (Section 7.3.3). facilities: line on a 150-foot (Section 7.3.2). (Section 7.3.3). right-of-way; 22 acres/MW for mining and disposal (Section 7.3.1). Seotember 2011 Comparison of Environmental Impact of. 8.0-7 Page 8.0-7 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Repor Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternativest 1 )'(2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation GenertionGeneration Wind Generation GCato Water Quality Impacts SMALL - Adopting by SMALL - Adopting by SMALL - SMALL - SMALL - SMALL to reference Category 1 reference Category 1 Construction impacts Construction impacts Construction MODERATE - issue findings (Table issue finding (Table A-i, minimized by minimized by impacts minimized Construction A-i, Issues 1-3, 6-11, Issue 89) in the GElS regulatory controls; regulatory controls; by regulatory impacts minimized and 31). Five Chapter 7 and operation-phase cooling water and controls by reaqulatory Category 2 water Section 8.4, and in impacts similar to wastewater (Section 7.3.3). controls: coolinq quality issues do not Supplement 1 to those of Davis-Besse; discharges subject to water and apply: Section 4.1, NUREG-0586. cooling water and regulatory controls wastewater Issue 13; Section 4.6, wastewater (Section 7.3.2). discharges subject Issue 34, Section 4.5, discharges subject to to regulatory Issue 33; Section 4.7, regulatory controls controls Issue 35; and (Section 7.3.1). (Section7.3.3). Section 4.8 Issue 39. Comparison of Environmental Impact of Page 8.0-8 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(')' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Wind Generation Gnato Air Quality Impacts SMALL - Adopting by SMALL - Adopting by MODERATE - MODERATE - SMALL - MODERATE - reference Category 1 reference Category 1 8,267 tons SOx/year 13.3 tons S0 2/year Construction 42.41 tons issue finding issue findings 5,087 tons NOx/year 205 tons NOx/year impacts minimized S02/vea (Table A-1, Issue 51). (Table A-i, Issue 88) in 636 tons CO/year 311 tons CO/year by regulatory 93.67 tons One Category 2 issue the GElS Chapter 7 and 153 tons PM/year 39.4 tons PM/year controls NOx/vear does not apply: Section 8.4, and in 34.3 tons PM 1o/year 2.28x106 tons (Section 7.3.3). 90.36 tons CO/year Section 4.11, Supplement 1 to 7.63x10 6 tons C0 2/year 46.65 tons PE/year Issue 50. NUREG-0586. C0 2/year (Section 7.3.2). 26.40 tons (Section 7.3.1). VOQs/year 681.1 x10 tons of C0t/yea ) (Section 7.3.3). SeDtember 2011 Comparison of Environmental Impact of Page 8.0-9 8.0-9 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Repoo Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives1 '( 2 ) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Geneatio Generation I_____________ Wind Generation &CaES Generation Ecological Resource Impacts SMALL- Adopting by SMALL- Adopting by MODERATE - SMALL to SMALL to MODERATE to reference Category 1 reference Category 1 Potential loss or MODERATE - MODERATE - LARGE- Potential issue findings issue finding alteration of more Approximately 100 Habitat and loss or alteration of (Table A-i, Issues (Table A-i, Issue 90) in than 1,500 acres of acres onsite and 240 migratory impacts more than 90,000 14-24, 28-30, 41-43, the GElS Chapter 7 and habitat (e.g., to 270 acres offsite of would be greater for acres of habitat and 45-48). Three Section 8.4, and in transmission, waste largely agricultural land based wind (e.g., wind and Category 2 issues do Supplement I to disposal landfill); land would be farms then offshore solar facilities, not apply: NUREG-0586. facilities siting would converted to industrial wind farms (e.g., transmission)* Section 4.2, Issue 25; be subject to use for plant site and wind facilities, facilities siting Section 4.3, Issue 26; regulatory controls offsite infrastructure, transmission)@ would be subiect to and Section 4.4, limiting impacts to respectively; facilities facilities siting would regulatory controls Issue 27. ecological resources, siting would be be subject to limiting impacts to including wetlands subject to regulatory regulatory controls ecological and threatened or controls limiting limiting impacts to resources, endangered species. impacts to ecological ecological including wetlands Impact on aquatic resources, including resources, including and threatened or habitats and biota wetlands and wetlands and endangered from dredging (e.g., threatened or threatened or species for intake and endangered species. endangered species (Section 7.3.3). discharge structures Potential for impacts (Section 7.3.3). and, if applicable, to aquatic resources barge terminal), from construction and cooling water operation (e.g., withdrawal, and cooling water discharge would be withdrawal and Comparison of Environmental Impact of Page 8.0-10 September 201-1 License Renewal with the Alternatives

Davis-LenseNulewar PAppr Station License Renewal Application Environmental Repoo Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives1 )'(2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Wind Generation &eCaEo Generation subject to regulatory discharge) reduced by controls best management (Section 7.3.1). practices and regulatory controls (Section 7.3.2). Threatened or Endangered Species Impacts SMALL - Federally SMALL - Not an impact SMALL - Federal and SMALL - Federal and SMALL - Federal SMALL - Federal and state threatened evaluated by the GEIS. state laws prohibit state laws prohibit and state laws and state laws or endangered destroying or destroying or prohibit destroying prohibit destroying species are protected adversely affecting adversely affecting or adversely or adversely through company and protected species and protected species and affecting protected affecting protected plant procedures. their habitats. their habitats. species and their species and their (Section 4.10, habitats, habitats. Issue 49) Comparison of Environmental Impact of Page 8.0-11 September 2011 License Renewal with the Alternatives

Daviq-BeRse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(1t ' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Wind Generation &CaES Generation Human Health Impacts SMALL - Adopting by SMALL - Adopting by SMALL - Some risk of SMALL - Similar to SMALL SMALL - Similar to reference Category 1 reference Category 1 cancer and the coal-fired (Section 7.3.3). the gas-fired issues (Table A-i, issue finding (Table A-i, emphysema from air alternative alternative (CAES Issues 54-56, 58, 61, Issue 86) in the GElS emissions and risk of (Section 7.3.2). plant) 62). One Category 2 Chapter 7 and accidents to workers, (Section 7.3.3). issue does not apply: Section 8.4, and in as the NRC notes in Section 4.12, Supplement 1 to the GELS. Issue 57. Risk due to NUREG-0586. Assumed that transmission-line regulatory controls induced currents would reduce risks to minimal due to acceptable levels conformance with (Section 7.3.1). consensus code (Section 4.13, Issue 59). Seotember 2011 Comparison of Environmental Impact of 8.0-12 Page 8.0-12 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Repot Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives1 ' (21 Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Geneatin Generation j_____________ Wind Generation &CaES Generation Socioeconomic Impacts SMALL -Adopting by SMALL -Adopting by MODERATE to MODERATE - MODERATE - MODERATE - reference Category 1 reference Category 1 Reduction in Reduction in Reduction in Reduction in issue findings issue finding (Table A-i, permanent work force permanent work force permanent work permanent work (Table A-1, Issues 64, Issue 91) in the GElS and tax base at and tax base at force and tax base force and tax base 67). Two Category 2 Chapter 7 and Davis-Besse would Davis-Besse would at Davis-Besse at Davis-Besse issues do not apply: Section 8.4, and in adversely affect adversely affect would adversely would adversely Section 4.16, Issue 66 Supplement 1 to surrounding surrounding affect surrounding affect surrounding and Section 4.17.1, NUREG-0586. communities. communities. communities. communities. Issue 68. Location in Construction and Impacts from Impacts from Impacts from high population area operational impacts construction would be construction would construction would with no growth would depend upon mitigated by siting be miti-gated by be mitigated by controls minimizes the site location, plant within sitinq renewable siting renewable potential for housing Regulatory controls commuting distance facilities within facilities within impacts (Section 4.14, and appropriate of large metropolitan commuting distance commuting Issue 63). mitigation would areas (Section 7.3.2). of metropolitan distance of Capacity of public ensure that impacts areas when possible metropolitan areas water supply as well are not destabilizing (Section 7.3.3). when possible as education and (Section 7.3.1). (Section 7.3.3). transportation infrastructures minimizes potential for related impacts (Section 4.15, Issue 65; Section 4.16, Issue 66; and Section Comparison of Environmental Impact of Page 8.0-13 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternatives(1 }'( 2

                                                                                                                    )

Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation GenertionGeneration Wind Generation Gnato 4.18, Issue 70). Plant tax payments range from <10% to nearly 20% of local jurisdictions tax revenues (Section 4.17.2, Issue 69). Waste Management Impacts SMALL - Adopting by SMALL - Adopting by MODERATE - Annual SMALL - Solid waste SMALL - Solid SMALL - Solid reference Category 1 reference Category 1 waste of is minimal (Section waste is minimal waste is minimal issue findings issue finding Table A-i, approximately 7.3.2). (Section 7.3.3). (Section 7.3.3). (Table A-i, Issue 87) in the GElS 300,000 tons ash and Issues 77-85). Chapter 7 and 470,000 tons flue gas Section 8.4, and in desulphurization Supplement 1 to waste, requiring NUREG-0586. disposal offsite in a 644-acre landfill over an assumed 40-year plant life (Section 7.3.1). Seotember 2011 Comparison of Environmental Impact of Page 8.0-14 8.0-14 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Table 8.0-2: Impacts Comparison Detail (continued) No-Action Alternativest 1' (2) Proposed Action Base With Renewable (License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R ae Generation Generation Wind Generation GCato Aesthetic Impacts SMALL- Adopting by SMALL - Adopting by SMALL to SMALL to SMALL to SMALL - Aesthetic reference Category 1 reference conclusions in MODERATE - Highly MODERATE - Highly MODERATE - impacts are issue findings (Table the GElS Section 8.4 dependent on dependent on Highly dependent on minimal A-1, Issues 73, 74). and Supplement 1 to location. Stacks, location. Stacks, location of wind (Section 7.3.3). NUREG-0586. cooling tower plumes cooling tower plumes farms likely would be visible would be visible (Section 7.3.3). for several miles. offsite (Section 7.3.2). Operation of waste disposal site would have adverse impact potential (Section 7.3.1). Cultural Resource Impacts SMALL -License SMALL - Adopting by SMALL - Siting of SMALL - Same as SMALL - Cultural SMALL - Cultural renewal does not reference conclusions in plant and offsite the coal-fired resource impacts resource impacts require additional land the GElS Section 8.4 infrastructure (e.g., alternative (Section are minimal are minimal disturbance (Section and Supplement 1 to transmission line, 7.3.2). (Section 7.3.2). (Section 7.3.2). 4.19, Issue 71). NUREG-0586. natural gas pipeline) would be subject to regulatory review, and mitigation measures would be implemented (Section 7.3.1). Comparison of Environmental Impact of Page 8.0-15 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report Btu = British thermal unit CO = carbon monoxide CO 2 = carbon dioxide ft 3 = cubic foot GElS = Generic Environmental Impact Statement (NRC 1996) kWh = kilowatt hour lb = pound MM = million MW = megawatt NOx = nitrogen oxides PM = particulate matter PM10 = particulates having diameter less than 10 microns Notes: (1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at a greenfield site would exceed those described in the table for a coal-fired or gas-fired plant located at a brownfield, i.e., existing disturbed site. (2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-i, Footnote 3:

      - SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.
      - MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize, any important attribute of the resource.
      - LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

Comparison of Environmental Impact of Page 8.0-16 September 2011 License Renewal with the Alternatives

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report

8.1 REFERENCES

NES 2010. Norton Enerqy Storage, LLC, Final Air Permit-To-Install and Operate, Ohio EPA, September 2010. NRC 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, May 1996. References Page 8.1-1 September 2011

Davis-Besse Nuclear Power Station License Renewal Application Environmental Report [This page intentionally blank] Page 8.1-2 September 2011 I References}}