ML12339A652

Official Exhibit - NRC000141-00-BD01 - NUREG-1437, S33, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 33 Regarding Shearon Harris Nuclear Power Plant, Unit 1, Final Report

ML12339A652
Person / Time
Site:	Indian Point
Issue date:	08/31/2008
From:	Office of Nuclear Reactor Regulation
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 22166, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 NUREG-1437, S33
Download: ML12339A652 (79)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #: NRC000141-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn: NRC000141 Rejected: Stricken:

Other: Submitted: March 30, 2012 NUREG-1437 Supplement 33 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 33 Regarding Shearon Harris Nuclear Power Plant, Unit 1 Final Report Office of Nuclear Reactor Regulation

8 .0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES TO LICENSE RENEWAL In this chapter, U.S. Nuclear Regulatory Commission (NRC) staff examines the potential environmental impacts associated with alternatives to renewing the Shearon Harris Nuclear Power Plant, Unit 1 (HNP) operating license. NRC staff considers the following alternatives:

1) denying the renewal of an operating license (i.e., the no-action alternative); 2) implementing electric generating sources other than HNP; 3) relying on conservation to offset an amount of electric demand equal to HNPs capacity; 4) purchasing electric power from other sources; and

5) implementing a combination of generation and conservation measures. In addition, NRC staff briefly discusses other generation alternatives that they deemed incapable of individually replacing the power generated by HNP. As NRC staff determined in the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999)(1), NRC staff will assume that Progress Energy requires power generation capability to meet system generating needs beyond the end of the current HNP operating license.

Since the GEIS assumes that CP&L needs the power currently generated by HNP, NRC staff assumes that CP&L would resort to other forms of power supply or demand reduction (i.e.,

conservation) if NRC elects the no-action alternative. NRC staff discusses the impacts of these alternatives in Section 8.2. The alternatives considered in Section 8.2 represent other, distinct alternatives to license renewal that allow CP&L to meet future system needs. Though the environmental impacts of these alternatives may also be considered potential consequences of the no-action alternative, they provide options that CP&L may elect to pursue regardless of whether NRC renews the HNP license.

The NRC staff evaluated environmental impacts across 11 categories (land use, ecology, water use and quality, air quality, waste, human health, socioeconomics, transportation, aesthetics, historical and archaeological resources, and environmental justice) using the NRCs three-level standard of significanceSMALL, MODERATE, or LARGE. NRC staff outlines these standards in the footnotes to Table B-1 of Title 10, Part 51, of the Code of Federal Regulations (10 CFR Part 51), Subpart A, Appendix B:

SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.

MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize important attributes of the resource.

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the GEIS include the GEIS and its Addendum 1.

August 2008 8-1 NUREG-1437, Supplement 33

Alternatives LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

The impact categories NRC staff used in this chapter are the same categories NRC staff used in the GEIS, with the additional impact category of environmental justice.

8.1 No-Action Alternative NRC regulations implementing the National Environmental Policy Act (NEPA) of 1969 require NRC staff to discuss the no-action alternative in any NRC environmental impact statement (EIS, see 10 CFR Part 51, Subpart A, Appendix A(4)). For license renewal, the no-action alternative means that NRC does not renew the HNP operating license. The HNP operating license would then expire in 2026, causing CP&L to cease plant operations.

If, after performing safety and environmental reviews of HNPs license renewal application, NRC acts to renew HNPs operating license, then CP&L may choose to continue operating HNP throughout the renewal term. If this occurs, then shutdown of the unit and decommissioning activities would be postponed for up to an additional 20 years. NRC staff expects that the impacts of decommissioning after 60 years of operation would not differ significantly from those that would occur after 40 years of operation.

NRC staff addresses the environmental impacts of decommissioning in several documents, including the Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 (NRC 2002); the license renewal GEIS (chapter 7; NRC 1996); and Chapter 7 of this supplemental environmental impact statement (SEIS). These analyses either directly address or bound the environmental impacts of decommissioning whenever CP&L ceases operating HNP.

These documents do not, however, address environmental impacts that occur after plant shutdown and before the actual decommissioning process begins. In the following section, NRC staff considers the immediate impacts from plant shutdown. The impacts are summarized in Table 8-1.

• Land Use Onsite land use would not be affected immediately by the cessation of operations. Plant structures and other facilities would likely remain in place until decommissioning. CP&L plans to keep transmission lines associated with the project in service after the plant stops operating. As a result, maintenance of the rights-of-way would continue as before. Since the NRC staff concluded in Chapter 4 that continued operations would have no impact on land use, and as plant shutdown would have little or no immediate effect on land use NUREG-1437, Supplement 33 8-2 August 2008

Alternatives practices, the NRC staff concludes that the impacts to land use from plant shutdown would be SMALL.

• Ecology Ecology would be minimally affected by plant shutdown. HNP utilizes a cooling tower rather than once-through cooling, which makes aquatic ecology impacts from operations SMALL.

CP&L would continue to maintain Harris Reservoir after shutdown. CP&L staff may allow access to the auxiliary reservoir following shutdown, which would increase fishing pressure on this impoundment and may introduce invasive species. Impacts to ecology in the auxiliary reservoir, though, would probably not be noticeable. Decreased withdrawals from Harris Reservoir may increase flows to Buckhorn Creek and the Cape Fear River. These effects would be positive, though also likely SMALL. CP&L would continue to use HNPs transmission lines and maintain right-of-way corridors. CP&L would generally continue to maintain the site until decommissioning. Since NRC staff determined that continued operation of HNP into the license renewal term would have SMALL impacts to ecology, and since few changes would occur to ecological resources following shutdown, the NRC staff concludes that ecological impacts from shutdown of the plant would be SMALL.

• Water Use and QualitySurface Water When the plant stops operating, consumptive water use for cooling tower makeup would immediately decrease and HNP would discharge much less blow-down water to Harris Reservoir. As CP&L would maintain Harris Reservoir even in the event of plant shutdown, this net reduction in consumptive water use would increase the amount of water flowing out of Harris Reservoir and into Buckhorn Creek, as well as to the Cape Fear River. This would have a positive impact to surface water use and quality. Since NRC staff determined in Chapter 4 that continued operation would have a SMALL impact on surface water quality and use, cessation of a portion of these impacts would also be SMALL.

• Water Use and QualityGroundwater HNP currently relies on surface water from Harris Reservoir for all domestic, process, and makeup water. Though construction crews developed 20 wells between 1973 and 1981, none of the wells remain in use. If CP&L shuts the plant down, it is possible that water flows out of Harris Reservoir and into Buckhorn Creek would increase, and groundwater recharge from the stream may also increase. It is unlikely, however, that this effect would be noticeable. Since NRC staff determined in Chapter 4 that continued operation of HNP would have no impact on groundwater resources, a small, positive impact from plant shutdown would result in a SMALL overall impact to groundwater use and quality from plant shutdown.

August 2008 8-3 NUREG-1437, Supplement 33

Alternatives

• Air Quality When the plant stops operating, there would be a reduction in emissions from activities related to plant operation such as use of diesel generators and workers vehicles. In Chapter 4, NRC staff determined that these emissions would have a SMALL impact on air quality during the renewal term. Therefore, if the emissions decrease, the impact to air quality would also decrease and would be SMALL.

• Waste When the plant stops operating, it would stop generating high-level waste, and it would generate fewer low-level and mixed waste from plant operation and maintenance. Since the NRC staff determined in Chapter 6 that continued low-level and mixed waste generation would have a SMALL impact, a reduction in waste generation would have an even smaller impact. Therefore, the NRC staff concludes that waste impacts from plant shutdown would be SMALL, and less than during operation.

• Human Health After shutdown the plant would release smaller amount of radioactive gaseous and liquid materials to the environment than it did while operating. In addition, the variety of potential accidents at the plant would decline to a limited set associated with shutdown events and fuel handling. Since NRC staff determined in Chapter 4 that continued plant operations would have a SMALL impact on human health, and since NRC staff also determined in Chapter 5 that potential accidents during the renewal term would have a SMALL impact, then reducing the amounts of gaseous and liquid releases while simplifying and limiting the types of potential accidents the plant may experience would further reduce impacts to human health. Impacts to human health from plant shutdown, then, are SMALL.

• Socioeconomics There would be immediate socioeconomic impacts associated with the shutdown of the plant due to the elimination of jobs at the plant. These effects would likely not be noticeable, however, given the regions rapid growth rate and variety of economic activities.

Decommissioning activities or construction and operation of an alternative at the current site would offset these impacts. There also may be a relatively small reduction in property tax revenues for Wake County, which could also be offset by an alternative. In Chapter 4, the NRC staff determined that continued plant operations would have no effect on socioeconomic conditions in the vicinity of HNP. Since the socioeconomic effects of plant shutdown would likely not be noticeable, plant shutdown would have a SMALL impact. See NUREG-1437, Supplement 33 8-4 August 2008

Alternatives Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional discussion of the potential socioeconomic impacts of plant decommissioning.

• Transportation Cessation of operations would be accompanied by reduced traffic in the vicinity of the plant.

This reduction would occur largely because the post-shutdown workforce would be smaller than the operating workforce. Shipments of materials to and from the plant would also decrease. As the NRC staff determined in Chapter 4 that continued operational transportation impacts would have no additional impact, a reduction in traffic means that impacts would remain SMALL if the plant shuts down.

• Aesthetics Plant structures and other facilities are likely to remain in place until decommissioning.

Plumes from the cooling tower would cease or greatly decrease after shutdown. Therefore, the NRC staff concludes that the aesthetic impacts of plant closure would be SMALL.

• Historic and Archaeological Resources Onsite lands and underlying archaeological resources would not be affected immediately by shutdown, as plant structures and other facilities are likely to remain in place until decommissioning. CP&L would continue to operate the plants transmission lines and maintain Harris Reservoir. Transmission line right-of-way maintenance would continue. As NRC staff determined in Chapter 4 that these practices would have a SMALL impact on historic and archaeological resources, then continuation of these practices after plant shutdown would also have SMALL impacts.

• Environmental Justice Impacts on minority and low-income populations due to the shutdown of HNP would depend on the number of jobs and the amount of tax revenue lost to the communities surrounding the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it is likely that these losses would be replaced by the development of new businesses and new sources of tax revenue in the region. Since CP&Ls tax payments represent a small percentage of Wake Countys total annual property tax revenue, it is unlikely that social services would be seriously affected. Therefore, minority and low-income populations in the August 2008 8-5 NUREG-1437, Supplement 33

Alternatives vicinity of HNP would not likely experience any disproportionately high and adverse socioeconomic impacts from the shutdown of HNP.

The environmental effect of plan shutdown would reduce the amount of operational impacts on the environment. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse environmental impacts from the shutdown of HNP.

Table 8-1. Summary of Environmental Impacts of the No-Action Alternative Impact Category Impact Comment Land Use SMALL Impacts are expected to be SMALL because plant shutdown is not expected to result in changes to onsite or offsite land use.

Ecology SMALL Impacts from shutdown are expected to be SMALL because aquatic impacts are generally reduced and terrestrial impacts are not expected because there would not be any land use or maintenance changes.

Water Use and Quality SMALL Impacts are expected to be SMALL because surface Surface Water water intake and discharges would decrease.

Water Use and Quality No Change The current plant uses no groundwater and no more Groundwater would be extracted if CP&L shuts the plant down.

Air Quality SMALL Impacts are expected to be SMALL because emissions related to plant operation and worker transportation would decrease.

Waste SMALL Impacts are expected to be SMALL because generation of high-level waste would stop, and generation of low-level and mixed waste would decrease.

Human Health SMALL Impacts are expected to be SMALL because radiological doses to workers and members of the public, which are currently within regulatory limits, would be reduced.

Socioeconomics SMALL Impacts are expected to be SMALL because of small relative decreases in employment and tax revenues.

Regional growth would likely offset most, if not all, impacts.

Socioeconomics SMALL Impacts are expected to be SMALL because of the (Transportation) decrease in commuter traffic to the plant.

Aesthetics SMALL Impacts are expected to be SMALL because plant structures would remain in place.

Historic and Archaeological SMALL Impacts are expected to be SMALL because shutdown Resources of the plant would not change land use or disturbance.

NUREG-1437, Supplement 33 8-6 August 2008

Alternatives Impact Category Impact Comment Environmental Justice SMALL Impacts are expected to be SMALL because plant shutdown is unlikely to disproportionately affect minority or low-income populations.

8.2 Alternative Energy Sources In this section, NRC staff discusses the environmental impacts of alternatives to license renewal that would meet system energy needs after the expiration of HNPs current license or whenever CP&L elects to cease operating HNP. These alternatives include alternate sources of electric power (generation alternatives and purchased power), as well as an equivalent amount of conservation. If NRC renews the HNP operating license, the decision of whether to continue operating HNP or whether to rely on an alternative is left to Progress Energy and state-level energy decision makers.

The NRC staff considers the following generation alternatives in detail:

• Supercritical coal-fired generation at the HNP site and at an alternate site (Section 8.2.1)

• Integrated gasification combined-cycle coal-fired generation at the HNP site and at an alternate site (Section 8.2.2)

• Natural gas combined-cycle generation at the HNP site and at an alternate site (Section 8.2.3)

• New nuclear generation at the HNP site and at an alternate site (Section 8.2.4)

The NRC staff considers the following non-generation alternatives to license renewal in detail:

• Utility-sponsored conservation programs (Section 8.2.5)

• Purchased power (Section 8.2.6)

The order of alternatives does not imply which alternatives the NRC staff considers most likely or most environmentally benign.

The NRC staff addresses other alternatives considered and found not to be reasonable replacements for HNP in Section 8.2.7. Section 8.2.8 presents the environmental impacts of a combination of generation and conservation alternatives. This combination includes several alternatives that the NRC staff determined to be insufficient as stand-alone alternatives to HNP license renewal.

Each year the Energy Information Administration (EIA), a branch of the U.S. Department of Energy (DOE), issues the updated Annual Energy Outlook (AEO). The AEO is a forecasting document that analyzes trends and issues in energy production, supply, and consumption in August 2008 8-7 NUREG-1437, Supplement 33

Alternatives order to project future energy developments. The projections in the AEO vary from year to year based on current events. Its comprehensiveness and policy-neutrality is unique among forecasting documents. In the Annual Energy Outlook 2007 with Projections to 2030, EIA projects a continued nationwide increase in energy consumption and generating capacity (DOE/EIA 2007). Early in this period, through 2010, EIA projects that gas-fired combined-cycle or combustion turbine technology will account for most generating capacity additions. As natural gas prices increase, coal-fired generation begins to account for the largest share of capacity additions. EIA projects that coal will account for the majority (54%) of new capacity through 2030. EIA also projects that advanced coal technologies, like coal-fueled integrated gasification combined-cycle generation, will decline in cost relative to improved natural-gas-fired combined-cycle technologies. EIA projections indicate that U.S. generators will increase total nuclear and renewable generation capacity throughout the forecast term, due partly to tax credits and other incentives. As a proportion of installed capacity, however, nuclear generation will decrease slightly through 2030, while renewables share will remain relatively constant (DOE/EIA 2007). EIA indicates that changes in electricity generation costs, which are highly dependent on emissions-control costs, will drive utilities choices in generating technologies.

EIA asserts that oil-fired plants will account for virtually no new generation capacity in the U.S.

through 2030, and furthermore projects a 0.6% annual decrease in electric sector oil consumption because of higher fuel costs and lower efficiencies relative to other technologies (DOE/EIA 2007). Given EIAs analysis, NRC staff will not consider an oil-fired alternative for HNP.

HNP has a net rating of 900 megawatts electric output (MWe) net. To simplify alternatives analysis in the HNP ER, CP&L developed a set of fossil-fueled alternatives that would approximately, but not exactly, replace this capacity (Progress Energy 2006b). CP&L selected alternative capacity based on the commercially available combined-cycle gas generators that would best approximate HNPs capacity. After reviewing several manufacturers product lines (e.g., Siemens and General Electric), NRC staff determined that CP&Ls approximation of 879 MWe provides an adequate estimate of potential environmental impacts and also noted that this approximation may understate impacts by approximately 2.4% in cases where plant output and environmental impact correlate directly and linearly. NRC staff also employed this capacity as a suitable approximation of both supercritical and integrated gasification combined-cycle coal-fired alternatives.(2)

(2) While supercritical coal-fired plants rely on conventional boiler technology operated at higher pressures and temperatures, integrated gasification combined-cycle (IGCC) plants use coal (or other solid or liquid feedstocks) to produce syngas that burns in a combined-cycle plant similar to that used for natural gas. Thus, an approximation of this sort is also necessary for the IGCC alternative. Boiler-based coal plants of this size are typically built-to-specifications.

NUREG-1437, Supplement 33 8-8 August 2008

Alternatives In the HNP ER, CP&L identified several possible alternatives, all of which would be constructed at the current HNP site. Given that the current site includes approximately 4370 ha (10,800 ac),

of which 1680 ha (4150 ac) is Harris Reservoir, (Progress Energy 2006b) as well as cooling water, plant auxiliary buildings and infrastructure, and transmission lines, NRC staff believes that the HNP site allows adequate area for construction of all proposed alternatives. CP&L also owns additional land around the HNP site that it does not consider part of the site. NRC staff notes that CP&Ls potential plans for two additional nuclear units at the site would raise the reservoir level to flood an additional 1540 ha (3800 ac). Even if CP&L raises the Harris Reservoir level to support two potential new nuclear plants onsite, NRC staff believes sufficient land would exist to construct an alternative to the existing unit, though it may be necessary to convert nearby CP&L-owned land to plant use to support some of the more land-intensive alternatives. In addition to considering impacts from alternatives at the HNP site, the NRC staff will also generally characterize impacts for alternate sites.

8.2.1 Supercritical Conventional Coal-Fired Generation In this section, NRC staff analyzes a new supercritical coal-fired boiler, the first of two coal-fired alternatives. Supercritical coal-fired plants are similar to conventional coal boilers, except they operate at slightly higher temperatures and higher pressures, which allows for greater thermal efficiency. Supercritical coal-fired boilers are commercially proven and represent an increasing proportion of new coal-fired power plants. In Section 8.2.2, NRC staff presents the second coal-fired alternative, a new integrated gasification combined-cycle (IGCC) coal-fired plant.

NRC staff considers constructing a supercritical coal-fired power plant at both the HNP site and at an alternate site. Construction of a coal-fired plant at an alternate site may necessitate the construction of new transmission lines to transmit power to CP&Ls system. Transmission line length would vary with distance to suitable existing lines. In addition, construction at an alternate site would necessitate the construction of an appropriate railroad spur (or other transportation infrastructure) for coal and lime deliveries.

NRC staff has re-evaluated CP&Ls analysis assuming a better plant efficiency or heat rate of 8844 British thermal units (BTU) of heat per kilowatt-hour (kWh), the value EIA reports as the heat rate for new, scrubbed coal plants in 2005, the most recent year for which NRC staff identified data (DOE/EIA 2006b). This would reduce by approximately 13.3% the level of emissions CP&L calculated in the HNP ER for some impact areas. NRC staff accepts CP&Ls proposed coal-fired alternative configuration, which consists of two 439.5 MWe net coal-fired units (approximately 468 MW gross electric power each, assuming 6% onsite power consumption). NRC staff notes that this may understate some impacts, like air emissions, by 2.4% versus a plant equal in output to HNP. The NRC staff compared this information to environmental impact information in the GEIS, as well as to reference information available from EIA, the Environmental Protection Agency (EPA), and electric industry sources.

August 2008 8-9 NUREG-1437, Supplement 33

Alternatives Although the operating license renewal period is only 20 years, NRC staff analyzed the impact of operating the coal-fired alternative for 40 years, as this is a reasonable projection of the operating life of a coal-fired plant. This means that only half of certain impacts (land use for waste disposal and coal mining, for example) are directly attributable to the 20 year license renewal period.

The supercritical coal-fired plant, with a gross output of slightly more than 935 MWe would consume approximately 2.27 million metric tons (MT) (2.50 million tons) per year of pulverized bituminous coal with an ash content of approximately 11.6 percent (based on averages for North Carolina coal consumption) (EIA/DOE 2006c) and sulfur content of 0.88 percent. As in Progress Energys analysis, NRC staff assumed a capacity factor(3) of 0.85 for the supercritical coal-fired alternative (Progress Energy 2006b).

At the HNP site, a coal-fired alternative would likely receive coal and lime (used to scrub sulfur oxides from flue gases) by rail. The coal-fired option would require approximately 5 coal unit trains per week (assuming each train has 100 cars with 100 tons of coal per car). CP&L would have to improve HNPs existing rail spur to allow for these deliveries. Impacts from improving the rail spur would be SMALL, as the area is already disturbed and used for industrial purposes.

In evaluating the supercritical coal-fired alternative, the NRC staff assumed that a new plant located at either the HNP site or an alternate site would use a closed-cycle cooling system, like the current HNP unit does. NRC staff discusses the overall impacts of the supercritical coal-fired generating alternative in the following sections and summarizes these impacts in Table 8-2. The extent of impacts at an alternate site would depend on the location and characteristics of the particular site selected.

• Land Use A supercritical coal-fired alternative would use the existing facilities and infrastructure at the HNP site to the extent practicable, limiting the amount of new construction. This alternative may be able to use the existing cooling tower system, switchyard, offices, and transmission line rights-of-way. Much of the land the new plant may use has been previously disturbed.

In the GEIS (NRC 1996), NRC staff noted that workers would need to convert roughly 700 ha (1700 ac) of land to industrial uses to support a 1000 MWe coal-fired plant. Since some of this area includes space for offices, parking lots, and other auxiliary structures that would be reused from the existing plant, a coal-fired power plant on the HNP site would require much less land than at a previously undeveloped site. A coal-fired alternative at the (3) The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy that could have been generated at continuous full-power operation during the same period.

NUREG-1437, Supplement 33 8-10 August 2008

Alternatives HNP site would likely require several hundred acres for new structures, rather than the 655 ha (1590 ac) calculated from the GEIS. CP&L, for example, estimated 102 ha (250 ac) in the HNP ER.

Mining operators would create additional land-use changes offsite in an undetermined coal-mining area to supply coal for the plant. Assuming a mix of coal supply similar to North Carolinas current coal supply, this land disturbance would occur mostly in West Virginia (EIA/DOE 2006c). In the GEIS, the NRC staff estimated that supplying coal to a 1000 MWe plant would disturb approximately 8900 ha (22,000 ac) of land for mining the coal and disposing of the wastes during the 40-year operational life. A coal-fired alternative to replace HNP would thus require approximately 8321 ha (20,600 ac) of land, 59.9 ha (148 ac) of which the plant would use for onsite waste disposal over the 40 year life(4). Coal mining would likely take place in existing coal-mining regions and in accordance with applicable mining regulations. Partially offsetting this offsite land use would be the elimination of the need for uranium mining to supply fuel for HNP. In the GEIS, the NRC staff estimated that approximately 400 ha (1000 ac) would be affected for mining the uranium and processing it during the operating life of a 1000 MW nuclear power plant.

Depending on when this land area would be needed, it would be possible that some would include areas previously disturbed by nuclear plant structures removed after shutdown or decommissioning, thus minimizing the extent to which any additional land would be required. Should CP&L move ahead with potential plans to construct new nuclear units on the HNP site, a coal-fired alternative may disturb areas that CP&L may not have previously disturbed because the nuclear units would be built first and use the area the coal plant otherwise may have used. Impacts from converting several hundred acres onsite, as well as up to 8321 ha (20,600 ac) for coal and limestone mining and disposal of coal waste, would occur mostly in previously disturbed areas or in existing mining land. NRC staff estimates that these impacts would be LARGE. Improving the rail spur to allow frequent coal and lime deliveries would incur short-lived impacts along the existing rail corridor.

These impacts would be SMALL. The overall impact on land use of a coal-fired generating unit at the existing HNP site would be best characterized as LARGE, and would be greater than the operating license renewal alternative.

Construction of the coal-fired generation alternative at an alternate site would impact up to 655 ha (1617 ac) for plant structures (NRC 1996) and 8321 ha (20,600 ac) for mining and waste disposal (59.9 ha [148 ac] of which would occur onsite for waste disposal), and impacts would be LARGE due not only to plant structures, but also construction of a rail spur, transmission lines, and their respective rights-of-way.

(4) Only half of the land area needed for mining and by-product disposal is directly attributable to providing an alternative to renewing HNPs operating license for 20 years.

August 2008 8-11 NUREG-1437, Supplement 33

Alternatives

• Ecology Locating a coal-fired plant at the HNP site would affect ecological resources, but existing site maintenance practices and the sites industrial nature would minimize additional impacts from a new supercritical coal-fired plant. Plant structures, coal storage, and waste disposal would create SMALL to MODERATE impacts. At an alternate site, constructing transmission lines and a rail spur would incur additional impacts, which would be MODERATE to LARGE, depending on the length of corridors required.

Aquatic impacts of a supercritical coal-fired alternative would likely be similar to the impacts of the existing HNP, as the on-site option would make use of the existing plants cooling, intake, and outflow structures. The lower heat rate of the coal-fired alternative compared to the existing nuclear unit means that less water would be consumed for cooling and blowdown than in the license renewal alternative. Since continued operation of the existing HNP unit would result in SMALL impacts to aquatic ecology, the supercritical coal-fired option would also result in a SMALL impact.

A coal plant at an alternate site would likely also make use of cooling towers, and would incur similar aquatic impacts, which would range from SMALL to MODERATE, depending on characteristics of the water body used for cooling makeup.

NUREG-1437, Supplement 33 8-12 August 2008

Alternatives Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation at HNP Site and an Alternate Site Using Closed-Cycle Cooling Impact HNP Site Alternate Site Category Impact Comments Impact Comments Land Use MODERATE Uses several hundred acres MODERATE to Uses nearly 2000 acres for for plant and waste disposal, LARGE plant and waste disposal.

though much of this would There would be additional have been previously land use impacts from disturbed; additional offsite transmission line, and rail land impacts for coal and spur, as well as coal and limestone mining affects limestone mining.

thousands of acres.

Ecology SMALL to Uses undeveloped areas at MODERATE to Impact depends on location MODERATE current HNP site, plus existing LARGE and ecology of the site, rail and transmission corridors; surface water body used for impacts also dependent on intake and discharge, and land used for coal and transmission line and rail limestone mining. routes; may cause habitat loss and fragmentation, as well as reduced productivity and biological diversity; impact also dependent on coal and limestone mining.

Water Use and SMALL Uses existing cooling tower SMALL to With closed-cycle cooling, QualitySurface system, while reduced heat MODERATE the impact would likely be Water rate means the supercritical SMALL, though it would coal-fired alternative requires depend on the volume of less water than the existing water withdrawn and plant. discharged and the characteristics of the surface water body; impacts would be MODERATE.

Water Use and SMALL A new plant onsite would likely SMALL to Impacts would depend on Quality continue to rely on Harris MODERATE the volume of water Groundwater Reservoir for all water. withdrawn and discharged and the characteristics of the aquifers, though groundwater would not likely be used for cooling tower makeup purposes.

August 2008 8-13 NUREG-1437, Supplement 33

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Air Quality MODERATE

• Sulfur oxides MODERATE Potentially the same impacts 1900 MT/yr as the Harris site, although (2090 tons/yr) pollution-control standards may vary.

• Nitrogen oxides 567 MT/yr (625 tons/yr)

• Total suspended particulates 132 MT/yr (145 tons/yr)

• PM10 30.3 MT/yr (33.4 tons/yr)

• Carbon monoxide 567 MT/yr (625 tons/yr)

• Small amounts of mercury and other hazardous air pollutants.

Waste MODERATE Total waste production would MODERATE Same impacts as at HNP be approximately site; waste disposal 249,000 MT/yr constraints may vary.

(274,000 tons/yr) of ash (after some is recycled) and scrubber sludge requiring approximately 59.9 ha (148 ac) for disposal during the 40-year life of the plant.

The plant would also generate relatively small amounts of conventional, hazardous, and universal wastes during operation.

Human Health SMALL Impacts are uncertain, but SMALL Similar impacts to those at considered SMALL as the the HNP site.

plant would comply with health-informed standards in the Clean Air Act and other relevant emissions regulations.

NUREG-1437, Supplement 33 8-14 August 2008

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Socioeconomics SMALL to During construction, impacts SMALL to Construction impacts MODERATE would be SMALL to LARGE depend on location, but MODERATE. Up to 2340 would be LARGE if the plant workers would be onsite is located in an area that is during the peak period of the rural or is growing less 4-year construction period, quickly than areas near the followed by a reduction from HNP site. Wake and the current HNP work force of surrounding counties may 720 to 234. Tax base would lose tax revenue and generally be preserved in employment, though Wake County. Impacts during economic growth would operation would be SMALL. likely offset much of this loss. Impacts at a site near to an urban area may be SMALL.

Socioeconomics SMALL to Transportation impacts would SMALL to Transportation impacts (Transportation) MODERATE likely be SMALL to LARGE could be SMALL to LARGE, MODERATE, primarily with primarily during construction activities. construction.

For rail transportation of coal For rail transportation of and lime, the impact would coal and lime, the impact is likely be SMALL, depending likely to be SMALL, but on the routing of coal trains. dependent on the routing of coal trains.

Aesthetics SMALL to Aesthetic impact due to plant MODERATE to The greatest impacts would MODERATE units and stacks would be LARGE be from new transmission SMALL to MODERATE given lines, plant stacks, and rail current site usage and lines to transport coal and structures. lime. Impacts range from MODERATE to LARGE Rail transportation of coal and depending on the nature of lime would likely have SMALL the site.

to MODERATE aesthetic impacts, depending on rail traffic routing and noise effects.

Plant noise impact would be SMALL given the size and usage of the HNP site.

August 2008 8-15 NUREG-1437, Supplement 33

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Historic and SMALL Most construction would affect SMALL to An alternate location would Archeological previously developed parts of MODERATE necessitate cultural resource Resources the HNP site; a cultural studies; construction would resource inventory and likely avoid highly sensitive mitigation measures would areas. Impacts likely would minimize any impacts on be managed or mitigated.

previously undeveloped lands.

Environmental SMALL Impacts on minority and low- SMALL to Impacts would vary Justice income communities would be MODERATE depending on population similar to those experienced distribution and location of by the population as a whole, the site.

which are SMALL. Some additional impacts on rental housing may occur during construction, though these likely would not be noticeable.

• Water Use and Quality Surface Water. NRC staff assumes that the coal-fired generation alternative at the HNP site would use the existing cooling tower system and rely on Harris Reservoir for all its water needs. Given the supercritical coal-fired alternatives heat rate, it would use less cooling makeup water than the existing HNP unit, and discharge smaller volumes of tower blowdown to Harris Reservoir. Surface-water impacts would be SMALL, and slightly smaller than the proposed action.

The supercritical coal-fired alternative at an alternate site would likely use a closed-cycle cooling system with cooling towers. For alternate sites, impacts on the surface water would depend on the volume of water needed for makeup volume discharge and the characteristics of the water body. Intake from and discharge to any surface body of water would be regulated by the North Carolina Department of Environment and Natural Resources (NCDENR), Division of Water Quality. These impacts would range from SMALL to MODERATE.

Groundwater. HNP currently uses no groundwater. A coal-fired alternative on the Harris site would likely continue to rely on Harris Reservoir for all water needs. Disposal of coal wastes, however, could have an impact on groundwater resources, especially if onsite disposal results in any leakage to groundwater. NRC staff expects, however, that the wastes would be handled in accordance with state and Federal law. This would keep impacts SMALL.

NUREG-1437, Supplement 33 8-16 August 2008

Alternatives At an alternate site, impacts to groundwater would depend on the extent to which the plant would utilize groundwater, though NRC finds it unlikely that a coal-fired plant would depend on groundwater for cooling purposes. Given that a plant would likely use groundwater only for domestic and some service purposes, the impact could be SMALL to MODERATE, depending on the nature of the aquifers used.

• Air Quality The air-quality impacts of coal-fired generation can be substantial and include emissions of sulfur oxides (SOx), nitrogen oxides (NOx), particulates, carbon monoxide, hazardous air pollutants such as mercury, and naturally occurring radioactive materials. Many of these pollutants, however, can be effectively controlled by various technologies.

Currently, Wake County and the neighboring counties of Johnston, Chatham, Durham, Franklin and Nash exceed Federal ozone standards, as so are nonattainment areas for ozone under the Clean Air Act (EPA 2007b). These counties are either in attainment or unclassified for other criteria pollutants(5) (EPA 2007b). A new supercritical coal-fired plant located in an ozone nonattainment area would need to purchase emissions credits from existing emitters of ozone-causing chemicals, including NOx.

A new supercritical coal-fired generating plant located at the HNP site would need a Non-Attainment Area permit and a Title V operating permit under the Clean Air Act. A new coal-fired generating plant would also need to comply with the new source performance standards for coal-fired plants set forth in 40 CFR 60 Subpart D(a). The standards establish limits for particulate matter and opacity (40 CFR 60.42(a)), SO2 (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)). A coal-fired power plant constructed elsewhere in North Carolina or CP&Ls territory would need to comply with applicable provisions of the Clean Air Act, as well, based on those areas attainment statuses.

Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing future and remedying existing impairment of visibility in mandatory Class I Federal areas when impairment results from man-made air pollution. EPA issued a new regional haze rule in 1999 (64 FR 35714) (EPA 1999). The rule specifies that for each mandatory Class I Federal area located within a state, the State must establish goals that provide for reasonable progress towards achieving natural visibility conditions. The reasonable progress goals must provide for an improvement in visibility for the most-impaired days over the period of the implementation plan and ensure no degradation in visibility for the least-impaired days over the same period (40 CFR 51.308(d)(1)). If a coal-fired plant were (5) Listed criteria pollutants are particulate matter, ground-level ozone, carbon monoxide, sulfur oxides, nitrogen oxides, and lead.

August 2008 8-17 NUREG-1437, Supplement 33

Alternatives located close to a mandatory Class I area, additional air pollution control requirements would be imposed. North Carolina contains five Class I areas, one of which, Swanquarter Wilderness Area, is potentially downwind of a coal-fired alternative at HNP (EPA 2007a).

Swanquarter, however, is approximately 298 km (185 mi) from the HNP site, and thus is unlikely to be affected by a coal-fired alternative. A coal-fired alternative located near Swanquarter or any of North Carolinas other Class 1 Areas may need to install additional emissions controls. EPA more generally protects visibility with regulations in 40 CFR 51, Subpart P.

In addition to Clean Air Act regulations, North Carolina restricts utilities aggregate emissions of NOx and SOx from coal-fired power plants (NC General Statutes 143-215.107D; known as the Clean Smokestacks Act). To date, CP&L has met the aims of the legislation by installing emissions controls technologies at older coal-fired plants (NCDENR and NCUC 2006). Constructing a new coal-fired power plant may result in emissions levels that require CP&L to install emissions controls on older coal-fired power plants in order to remain in compliance with the law.

The supercritical coal-fired alternative would produce the following quantities of air pollutants:

Sulfur oxides emissions. This coal-fired alternative at the HNP site would likely use wet, lime-based scrubbers to remove SOx. EPA indicates that this technology can remove up to 95% of SOx from flue gases (EPA 1998a). NRC staff projects total SOx emissions would be 1900 MT (2090 tons) per year.

SOx emissions from a new coal-fired power plant would be subject to the requirements in Title IV of the Clean Air Act. Title IV was enacted to reduce emissions of SO2 and NOx, the two principal precursors of acid rain, by restricting emissions of these pollutants from power plants. Title IV caps aggregate annual power plant SO2 emissions and imposes controls on SO2 emissions through a system of marketable allowances. EPA issues one allowance for each ton of SO2 that a unit is allowed to emit. New units do not receive allowances, but are required to have allowances to cover their SO2 emissions. Owners of new units must therefore purchase allowances from owners of other power plants or reduce SO2 emissions at other power plants they own. Allowances can be banked for use in future years. Thus, provided a new coal-fired power plant is able to purchase sufficient allowances to operate, it would not add to net regional SO2 emissions, although it might do so locally.

North Carolinas Clean Smokestacks Act restricts utility-level aggregate emissions of SOx from coal-fired power plants. A new coal-fired power plant in North Carolina may result in emissions levels that require CP&L to reduce emissions from other, older power plants.

Nitrogen oxides emissions. This new coal-fired plant would likely use a variety of NOx-control technologies, including low-NOx burners, overfire air, and selective catalytic NUREG-1437, Supplement 33 8-18 August 2008

Alternatives reduction. EPA notes that when these emissions controls are used in concert, they can reduce NOx emissions by up to 95% (EPA 1998a), for total annual emissions of 577 MT (625 tons).

Section 407 of the Clean Air Act establishes technology-based emission limitations for NOx emissions. A new coal-fired power plant would be subject to the new source performance standards for such plants as indicated in 40 CFR 60.44a(d)(1). This regulation, issued on September 16, 1998 (63 FR 49453) (EPA 1998b), limits the discharge of any gases that contain nitrogen oxides (expressed as NO2) in excess of 200 nanograms (ng) per joule (J) of gross energy output (equivalent to 1.6 lb/MWh), based on a 30-day rolling average.

NRC staff estimates that the total annual NOx emissions for a new coal-fired power plant would be approximately 11.2 percent of the new source performance standard emission rate. As HNP is located in an ozone non-attainment area, the plant operator would need to purchase emissions allowances to offset this amount of emissions.

EPA further restricts the total amount of NOx that can be emitted on a State level basis. In the 2007 ozone season (May 1-September 30) North Carolina may emit 150,000 MT (165,306 tons) of NOx. A new coal-fired power plant would need to offset emissions through credit purchases or from a set-aside pool.

North Carolinas Clean Smokestacks Law restricts utility-level aggregate emissions of NOx from coal-fired power plants. A new coal-fired power plant in North Carolina may result in emissions levels that require CP&L to reduce emissions from other coal-fired power plants.

Particulate emissions. This new coal-fired power plant would use fabric filters or electrostatic precipitators to remove particulates from flue gases. CP&L indicates that these technologies, in concert with emissions controls, would remove 99.9% of particulate matter (Progress Energy 2006b). EPA notes that filters or precipitators are each capable of removing in excess of 99% of particulate matter, and that SO2 scrubbers further reduce particulate matter emissions (EPA 1998a). As such, NRC staff believes CP&Ls removal factor is appropriate. Based on this, the new supercritical coal-fired plant would emit 132 MT (145 tons) of total suspended particulates and approximately 30.3 MT (33.4 tons) of particulate matter having an aerodynamic diameter less than or equal to 10 microns (PM10)

(40 CFR 50.6) annually. In addition, coal-handling equipment would introduce fugitive particulate emissions.

During the construction of a coal-fired plant, on-site activities would generate fugitive dust.

In addition, vehicles and motorized equipment would create exhaust emissions during the construction process. These impacts would be intermittent and short-lived, however. In addition, to minimize dust generation, construction crews would use applicable dust-control measures.

August 2008 8-19 NUREG-1437, Supplement 33

Alternatives Carbon monoxide emissions. Based on EPA emission factors (EPA 1998a), NRC staff estimates that the total carbon monoxide emissions would be approximately 567 MT (625 tons) per year.

Hazardous air pollutants including mercury. In December 2000, EPA issued regulatory findings on emissions of hazardous air pollutants from electric utility steam-generating units (EPA 2000b). EPA determined that coal- and oil-fired electric utility steam-generating units are significant emitters of hazardous air pollutants. Coal-fired power plants were found by EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000). EPA concluded that mercury is the hazardous air pollutant of greatest concern. EPA found that (1) there is a link between coal consumption and mercury emissions; (2) electric utility steam-generating units are the largest domestic source of mercury emissions; and (3) certain segments of the U.S. population (e.g., the developing fetus and subsistence fish-eating populations) are believed to be at potential risk of adverse health effects due to mercury exposures resulting from consumption of contaminated fish (EPA 2000). Accordingly, on March 15, 2005, EPA issued the Clean Air Mercury Rule to permanently cap and reduce mercury emissions from coal-fired power plants (EPA 2007c). A new coal-fired power plant would need to comply with performance standards contained in 40 CFR 60.45(a), requiring that the plant emit no more than 0.0025 nanograms per Joule output (20 x 10-6 lbs. per MWh). In addition, to the extent the plant would emit any mercury, the plant owners would need to purchase mercury allowances or reduce emissions to ensure that North Carolina emits no more than 1.133 tons of mercury containing gases in 2010, and 0.447 tons of mercury containing gases in 2018 (EPA 2006).

Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring elements. Alex Gabbard, a researcher at Oak Ridge National Laboratory, indicates that uranium concentrations are generally in the range of 1 to 10 parts per million (ppm) and thorium concentrations are generally about 2.5 times this level (Gabbard 1993). The U.S.

Geological Survey (USGS) indicates that Western and Illinois Basin coals contain uranium and thorium at roughly equal concentrations, mostly between 1 and 4 ppm, but also indicates that some coals may contain concentrations as high as 20 ppm of both elements (USGS 1997). Gabbard indicates that a 1000 MWe coal-fired plant would release roughly 4.7 MT (5.2 tons) of uranium and 11.6 MT (12.8 tons) of thorium annually (Gabbard 1993).

Both USGS and Gabbard indicate that almost all of the uranium, thorium, and most decay products remain in solid coal wastes, especially in the fine glass spheres that constitute much of coals fly ash. Modern emissions controls, such as those included for this coal-fired alternative, allow for recovery of greater than 99% of these solid wastes (EPA 1998a), thus retaining most of coals radioactive elements in solid form rather than releasing it to the atmosphere. Even after concentration in coal waste, the level of radioactive elements remains relatively low (typically 10 to 100 ppm) and consistent with levels found in naturally occurring granites, shales, and phosphate rocks (USGS 1997). The level of uranium and NUREG-1437, Supplement 33 8-20 August 2008

Alternatives thorium contained in coal wastes and disposed of in the environment exceed the levels of uranium and thorium released to the environment by the existing nuclear power plant.

Carbon dioxide. A coal-fired plant would also have unregulated carbon dioxide emissions during operations as well as during coal mining and processing, and coal and lime transportation. Burning bituminous coal in the U.S. emits roughly 205.3 lbs CO2 per million Btu (Hong and Slatick 1994). The supercritical coal-fired plant would emit approximately 6,320,000 tons of CO2 per year (5,730,000 MT).

Summary. The GEIS analysis did not quantify emissions from coal-fired power plants, but implied that air impacts would be substantial. The GEIS also mentioned global warming from unregulated carbon dioxide emissions and acid rain from SOx and NOx emissions as potential impacts (NRC 1996). The above analysis shows that emissions of air pollutants, including SOx, NOx, carbon monoxide, and particulates, exceed those produced by the existing nuclear power plant, as well as those of the other alternatives considered in this section. Operational emissions of carbon dioxide are also much greater under the coal-fired alternative.(6)

Adverse human health effects such as cancer and emphysema have also been associated with air emissions from coal combustion. NRC analysis for a coal-fired alternative at the HNP site and an alternative site indicates that impacts from the coal-fired alternative would have clearly noticeable effects, but given existing regulatory regimes, permit requirements, and emissions controls, the coal-fired alternative would not destabilize air quality. Thus, the appropriate characterization of air impacts from coal-fired generation would be MODERATE.

Siting a coal-fired generation plant at a site other than HNP would not significantly change air-quality impacts, although it would result in installing more- or less-stringent pollution-control equipment to meet applicable local requirements, or cause the plants owner to more- or less-actively participate in various emissions trading schemes. Impacts to air quality at an alternate site would be MODERATE.

• Waste Coal combustion generates waste in the form of ash, and emissions controls collect additional ash while converting gaseous pollutants to liquid or semisolid sludge. Two 439.5-MWe, net, coal-fired units would generate approximately 357,000 MT (393,000 tons) of this waste annually for 40 years. Of this waste, approximately 108,000 MT (119,000 tons)

(41% of the ash content) would be recycled, according to CP&L, leaving a total of (6) Table S-3 in 10 CFR 51.51 indicates that electrical energy consumed during the uranium fuel cycle to supply a 1000 MWe is equivalent to the electricity produced by a 45 MWe coal-fired power plant.

August 2008 8-21 NUREG-1437, Supplement 33

Alternatives approximately 249,000 MT (274,000 tons) that would be landfilled onsite. This waste would require approximately 59.9 ha (148 ac) of land area over the 40-year plant life (assuming a waste pile 9.15 m [30.0 ft] high). As mentioned in the air quality section, this waste would also contain levels of uranium and thorium in concentrations similar to those found in naturally occurring granites, shales, and phosphate rocks (USGS 1997). In addition to coal combustion wastes, a supercritical coal-fired alternative would also produce small amounts of domestic and hazardous wastes.

Waste impacts to groundwater and surface water would extend beyond the operating life of the plant if leaching and runoff from the waste storage area makes way into groundwater or surface water. Disposal of the waste would noticeably affect land use and groundwater quality if not properly managed, but with appropriate management and monitoring, effects on groundwater water resources would be prevented. After closure of the waste site and revegetation, the land would be available for other uses. Waste impacts from operating this coal-fired alternative, then, are MODERATE, as waste impacts would be noticeable, but they would not destabilize any resources.

Debris would be generated during construction activities. These would likely be disposed onsite, when possible. Overall, this amount of waste would be small compared to operational waste generated, and many construction wastes can be recycled. As such, construction-stage waste impacts would be SMALL.

For all of the preceding reasons, the appropriate characterization of impacts from waste generated by the supercritical coal-fired alternative would be MODERATE; the impacts would be clearly noticeable, but would not destabilize any important resource.

Siting the facility at a site other than HNPS would not alter waste generation, although other sites might have more constraints on disposal locations. If a coal facility was sited on a previously developed location, then there may also be fewer constraints on waste disposal, but the overall impact level would not likely change. Therefore, the impacts would remain MODERATE.

• Human Health Coal-fired power generation introduces worker risks from coal and limestone mining, from coal and lime transportation, and from disposal of coal combustion waste. In addition there are public risks from inhalation of stack emissions. Emission impacts can be widespread and health risks difficult to quantify. The coal-fired alternative also introduces the risk of coal-pile fires and attendant inhalation risks.

Regulatory agencies, including EPA and State agencies, set air emission standards and requirements based on human health impacts. These agencies also impose site-specific emission limits as needed to protect human health. As discussed previously, EPA has NUREG-1437, Supplement 33 8-22 August 2008

Alternatives concluded that certain segments of the U.S. population (e.g., the developing fetus and subsistence fish-eating populations) are believed to be at potential risk of adverse health effects due to mercury exposures from sources such as coal-fired power plants and has taken action to address mercury emissions from coal-fired power plants. In the absence of more quantitative data, human health impacts from radiological doses and inhaling toxins and particulates generated by burning coal would be characterized as SMALL.

• Socioeconomics Construction of the supercritical coal-fired alternative would take approximately 4 years (DOE/EIA 2006b). The NRC staff assumed that construction would take place while HNP continues operation and would be completed by the time it permanently ceases operations in 2026. The construction work force would be expected to include up to 2340 workers (NRC 1996). These workers would be in addition to the approximately 720 workers currently employed at HNP. During construction, the surrounding communities would experience an increased demand for rental housing and public services, though this would be moderated by the proximity of the site to urban areas. After construction, the communities may be affected by the loss of construction jobs, though this would likely be offset by the areas rapid growth.

If the coal-fired replacement plant were constructed at the HNP site and HNP were to be decommissioned, the area would experience a loss of approximately 486 permanent high-paying jobs (from 720 employees for HNP to 234 for the coal-fired plant), with a commensurate, relatively minor reduction in demands on socioeconomic resources and tax contributions to the regional economy. The coal-fired plant would provide a new tax base to offset the loss of tax base associated with decommissioning of the HNP unit in Wake County. Other counties would likely experience little impact, as HNP pays 90% of its local taxes to Wake County. Since the regions growing economy effectively mitigates most socioeconomic impacts of both construction and operation, the appropriate characterization of non-transportation socioeconomic impacts for a coal-fired plant constructed at the HNP site would be SMALL to MODERATE.

Construction of a supercritical coal-fired power plant at an alternate site would relocate some socioeconomic impacts, but would not eliminate them. The communities around HNP would experience relatively minor impacts of HNP operational job loss, and the communities around the new site would have to absorb the impacts of a large, temporary work force (up to 2340 workers at the peak of construction) and a permanent work force of approximately 234 workers. In the GEIS, the NRC staff stated that socioeconomic impacts at a rural site would be larger than at an urban site, because more of the peak construction work force would need to move to the area to work. The HNP site is in the Raleigh-Durham-Chapel Hill metropolitan area and is therefore not considered a rural site. Alternate sites would need to be analyzed on a case-by-case basis. Alternate industrial sites, however, tend to be close August 2008 8-23 NUREG-1437, Supplement 33

Alternatives to metropolitan areas, and may still have remaining transportation infrastructure nearby.

Socioeconomic impacts at a rural site would be LARGE, while impacts at previously developed industrial site would be SMALL to MODERATE.

• Transportation During the 4-year construction period of replacement coal-fired units, up to 2340 construction workers would be commuting to the site in addition to the current 720 workers at HNP. The addition of these workers would increase traffic loads on existing highways, particularly on surface roads in and around the plant. Given that the area has good access to highways, however, these impacts would be SMALL to MODERATE. Transportation-related impacts associated with commuting construction workers at an alternate site are site dependent, but would be SMALL to LARGE. Transportation impacts related to commuting of plant operating personnel would also be site dependent, but would be characterized as SMALL to MODERATE.

For transportation related to commuting of plant operating personnel, the impacts would be considered SMALL. The maximum number of plant operating personnel would be approximately 234 compared to the current HNP work force of 720. Therefore, traffic impacts associated with plant personnel commuting to a coal-fired plant would be expected to be SMALL, and smaller than the impacts of HNP license renewal.

For rail transportation related to coal and lime delivery to the HNP site, the impacts would be SMALL, depending on coal train routes. Approximately 250 coal unit trains per year (each with 100 cars carrying 100 tons of coal each) would be needed to deliver the coal and lime for the two coal-fired units. A total of 10 train trips would be expected per week, or nearly 2 trips per day on the spur leading to the plant, because for each full train delivery there would be an empty train returning from the plant. At an alternate site, coal and lime would likely be delivered by rail as well. Transportation impacts would depend upon the site location. Socioeconomic impacts associated with rail transportation would be SMALL.

Socioeconomic impacts associated with rail transportation on a previously developed site would be SMALL.

• Aesthetics If sited at the current HNP location, the coal-fired power plant units would be as much as 60 m (200 ft) tall and would likely not be visible offsite due to extensive forestation. The two exhaust stacks would be somewhere in the range of 120 to 185 m (400 to 600 ft) high and would be visible offsite for many miles. Given the current presence of a cooling tower and its plumes, as well as other plant structures on-site, the addition of plant stacks would not drastically increase visual impacts. These would be noticeable, but would not likely destabilize the resource. The units and associated stacks would also be visible at night NUREG-1437, Supplement 33 8-24 August 2008

Alternatives because of outside lighting. Visual impacts of a new coal-fired plant could be mitigated by landscaping and color selection for buildings that is consistent with the environment. Visual impact at night could be mitigated by reduced lighting where possible and appropriate shielding. Overall, the addition of a coal-fired unit and the associated stack at the HNP site would likely have a SMALL to MODERATE aesthetic impact.

Coal-fired generation would introduce mechanical sources of noise that would be audible offsite, although given the low population near the plants property, offsite noise is unlikely to be obtrusive. Sources contributing to total noise produced by plant operation would be classified as continuous or intermittent. Continuous sources include the mechanical equipment associated with normal plant operations. Intermittent sources include the equipment related to coal handling, solid-waste disposal, transportation related to coal and lime delivery, use of outside loudspeakers, and the commuting of plant employees. The incremental noise impacts of a coal-fired plant compared to existing HNP operations would be SMALL.

Noise impacts associated with rail delivery of coal and lime to a plant at the HNP site would be most significant for residents living in the vicinity of the facility and along the rail route.

Although noise from passing trains significantly raises noise levels near the rail corridor, the short duration of the noise reduces the impact. Given the frequency of train transport and the potential for many residents within hearing distance of the rail route, the impacts of noise would be SMALL to MODERATE, depending on train routes.

At an alternate site, plant buildings, exhaust stacks, cooling towers, and cooling tower plumes would create aesthetic impacts. There would also be an aesthetic impact associated with construction of a new transmission line to connect to other lines to enable delivery of electricity. Noise and light from the plant would be detectable offsite. Aesthetic impacts at the plant site would be mitigated if the plant were located in an industrial area adjacent to other power plants or industrial facilities. Noise impacts from a rail spur, if required, would be similar to the impacts at the existing site. Overall the aesthetic impacts associated with locating at an alternate site would be categorized as MODERATE to LARGE. Some of these issues would be rectified if the coal plant was sited at a previously developed site, as many contain some level of rail infrastructure, and would be in areas previously developed for industrial uses. Impacts at a previously developed site would be SMALL to MODERATE.

• Historic and Archaeological Resources At the HNP site or an alternate site, a cultural resource inventory would be needed for any onsite property that has not been previously surveyed. Other lands, if any, that are acquired to support the plant would also need an inventory of field cultural resources, identification and recording of existing historic and archaeological resources, and possible mitigation of August 2008 8-25 NUREG-1437, Supplement 33

Alternatives adverse effects from subsequent ground-disturbing actions related to physical expansion of the plant site.

Before beginning construction at an alternate site, surveys would likely be needed to identify, evaluate, and address mitigation of the potential impacts of new plant construction on cultural resources. The studies would likely be needed for all areas of potential disturbance at the proposed plant site and along associated corridors where new construction would occur (e.g., roads, transmission corridors, rail lines, or other rights-of-way).

Historic and archaeological resource impacts can generally be effectively managed and as such would be considered SMALL for the existing site and likely SMALL to MODERATE at a new site. For a previously developed site, most of which have already been intensively developed, impact on cultural and historic resources would also be SMALL. Previous development would likely have either removed or surveyed items of archaeological interest.

• Environmental Justice No environmental impacts were identified that would result in disproportionately high and adverse environmental impacts on minority and low-income populations if a replacement coal-fired plant were built at the HNP site. Some impacts on rental and other temporary housing availability and lease prices during construction might occur, and this could disproportionately affect the minority and low-income populations.

Impacts on minority and low-income populations due to the shutdown of HNP would depend on the number of jobs and the amount of tax revenue lost to the communities surrounding the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it is likely that these losses would be replaced by the development of new businesses and new sources of tax revenue in the region. Since CP&Ls tax payments represent a small percentage of Wake Countys total annual property tax revenue, it is unlikely that social services would be seriously affected. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse socioeconomic impacts from the shutdown of HNP.

The environmental effect of plant shutdown would reduce the amount of operational impacts on the environment. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse environmental impacts from the shutdown of HNP.

Impacts at other sites would depend upon the site chosen and the nearby population distribution, but would be SMALL to MODERATE for alternate sites. For previously NUREG-1437, Supplement 33 8-26 August 2008

Alternatives developed industrial sites, impacts would be slightly larger, depending on where low-income populations are located.

8.2.2 Coal-Fired Integrated Gasification Combined-Cycle (IGCC) Generation The second coal-fired option considered by NRC as an alternative to HNP license renewal is an integrated gasification combined-cycle (IGCC) plant. IGCC plants operate very differently from conventional coal plants, and were not considered by NRC staff in the GEIS. An IGCC coal-fired plant first heats coal in a gasifier with carefully controlled amounts of water and oxygen.

The resulting gas stream (called synthesis gas, or syngas) contains primarily carbon monoxide and hydrogen. Most coal impurities remain in gasifier waste material, called slag, while gasifiers convert sulfur-containing compounds to either elemental sulfur or sulfuric acid, both of which can be marketed as commodities. Gaseous pollutants, mercury among them, can be removed from the syngas stream prior to combustion. Following gasification and pollutant removal, the gas stream travels to a conventional combined-cycle power plant, similar in construction to a natural-gas-fired combined-cycle power plant. First, the gas stream burns in a combustion turbine. Then, the still-hot gas mixture gives up most of the remaining heat to water in a heat recovery steam generator. While IGCC plants can theoretically achieve thermal efficiencies approaching 50% (DOE/EIA 2006a), the technology is still relatively young from a utility-scale commercial perspective. No IGCC plant with a capacity as large as HNP has yet been constructed in the U.S., though NRC staff notes considerable utility interest in this technology for the ability to effectively reduce emissions of many air pollutants as well as to potentially produce a separate carbon dioxide stream for eventual sequestration. Given IGCCs limited commercial implementation in the U.S., EPA has not yet developed detailed emissions factors for the technology. In general, NRC staff has adopted emissions factors from DOE (DOE 1999) as cited in the HNP ER in order to characterize emissions from the IGCC coal-fired alternative.

In the HNP ER, CP&L adopts a heat rate of 6870 BTU/kWh for an IGCC coal-fired alternative.

NRC staff notes that this heat rate is significantly lower than the 8309 Btu/kWh reported by EIA for forecasting purposes (DOE/EIA 2006a). NRC staff will adopt EIAs assumed heat rate for this analysis, as it more-closely approximates existing IGCC plants (e.g., Tampa Electric Companys Polk Plant and the Wabash River Coal Gasification Repowering Project; see DOE 2004 and DOE 2000). CP&Ls analysis assumed three gas turbine units each with net outputs of 293 MWe each (nearly 326 MWe gross output assuming 10% onsite power consumption; this level of onsite consumption is consistent with experience at the Wabash River site) (DOE 2000).

Although the operating license renewal period is only 20 years, NRC staff analyzed the impact of operating the IGCC coal-fired alternative for 40 years, as this may be a reasonable projection of the operating life of an IGCC coal-fired plant and is consistent with the analysis NRC staff conducted for the supercritical coal-fired alternative.

August 2008 8-27 NUREG-1437, Supplement 33

Alternatives The IGCC coal-fired plant, with a gross output of 977 MWe, would consume approximately 2.23 million MT (2.45 million tons) per year of pulverized bituminous coal with an ash content of approximately 11.6 percent based on averages for North Carolina coal consumption (EIA/DOE 2006c). In an IGCC coal-fired-plant, the gasifier consolidates solid waste in vitrified slag, instead of producing ash as in a coal-fired boiler. For HNP, the IGCC coal-fired alternative would produce approximately 258,000 MT (285,000 tons) of slag and 19,200 MT (21,200 tons) of elemental sulfur in a year. CP&L indicated that the elemental sulfur as well as 90% of slag would be marketed. Based on IGCCs ability to remove wastes prior to syngas combustion, CP&L also indicated that no additional scrubbing of exhaust streams would be necessary (Progress Energy 2006b).

At the HNP site, coal would likely be delivered by rail, while slag and sulfur for reuse would likely be removed by rail or by truck. The IGCC coal fired option would likely require approximately 245 100-car unit trains per year, or roughly 5 trains or 10 trips per week. As such, the existing rail spur would need to be improved to allow for these deliveries. Impacts from improving the rail spur would be SMALL, as the spur already exists and is currently used for industrial purposes.

For purposes of this section, the NRC staff assumed that an IGCC coal-fired plant located at either the HNP site or an alternate site would use a closed-cycle cooling system, as the current HNP unit does. CP&L did not analyze an alternate site for an IGCC coal-fired plant in the ER.

The NRC staff discusses the overall impacts of the IGCC coal-fired generating system in the following sections and summarizes the analysis in Table 8-3. The extent of impacts at an alternate site would depend on the location of the particular site selected.

• Land Use The existing facilities and infrastructure at the HNP site would be used to the extent practicable, limiting the amount of new construction necessary. A new IGCC coal-fired plant may be able to use the existing cooling tower system, switchyard, offices, and transmission line rights-of-way. Much of the land that would be used has been previously disturbed. As noted above, a coal-fired plant on-site would require improvements to the existing rail line in order to support coal and lime deliveries.

NRC noted in the GEIS (NRC 1996) that a 1000 MW coal-fired alternative would necessitate converting approximately 700 ha (1700 ac) of land to industrial uses. NRC staff recognizes that, as IGCC plants tend to be more mechanically similar to gas-fired power plants than to coal-fired power plants. Therefore, the amount of land conversion required by a conventional coal plant is likely greater than the IGCC alternative would require. In addition, NRC staff recognizes that some amount of existing HNP auxiliary structures, like offices and parking lots, as well as intake and cooling tower systems, would also be used by the IGCC NUREG-1437, Supplement 33 8-28 August 2008

Alternatives alternative. NRC staff thus indicates that the IGCC alternative would likely require several hundred acres, but fewer than the supercritical coal-fired alternative (Progress Energy indicated that the IGCC option would require 80.9 ha [200 ac], which is 20.2 ha [50 ac] fewer than the conventional coal alternative) (Progress Energy 2006b).

Additional land-use changes would occur offsite in an undetermined coal-mining area to supply coal for the plant. Assuming a mix of coal supply similar to North Carolinas current coal supply, this land disturbance would likely occur mostly in West Virginia (EIA/DOE 2006c). In the GEIS, the NRC staff estimated that approximately 8900 ha (22,000 ac) would be affected for mining the coal and disposing of the waste to support a 1000 MWe coal plant during the operational life. An IGCC coal-fired alternative to replace HNP would thus require approximately 8700 ha (21,500 ac) of land, 4.37 ha (10.8 ac) of which the plant would use for onsite slag disposal over the 40-year life. Coal mining would likely take place in existing coal-mining regions and in accordance with applicable mining regulations. Partially offsetting this offsite land use would be the elimination of the need for uranium mining to supply fuel for HNP. In the GEIS, the NRC staff estimated that approximately 400 ha (1000 ac) would be affected for mining the uranium and processing it during the operating life of a 900 MW nuclear power plant.

As mentioned earlier, while the existing rail spur could be used to deliver coal to the site, it would be likely that the spur would require improvements to support the significant increase in traffic involved in servicing the IGCC.

The impact of an IGCC coal-fired generating unit on land use located at the existing HNP site would be best characterized as MODERATE, and would be greater than the proposed action.

Construction of the IGCC coal-fired generation alternative at an alternate site would impact significantly more than 80.9 ha (200 ac) for plant and auxiliary structures, as well as tens to thousands of acres for transmission lines and a rail spur. Waste disposal would require 4.37 ha (10.8 ac). An IGCC alternative at a different site would also require approximately 8700 ha (21,500 ac) for coal mining. Thus, impacts would range from MODERATE to LARGE, depending on length of transmission line corridors and the rail spur.

• Ecology Locating an IGCC coal-fired plant at the HNP site would affect ecological resources, but existing site maintenance practices and the sites industrial nature would minimize additional impacts from the new plant. Given the IGCC plants easily-marketed waste streams, impacts from onsite waste disposal are smaller than for the supercritical coal-fired plant.

Impacts to terrestrial ecology would be SMALL to MODERATE. At an alternate site, constructing transmission lines and a rail spur would incur additional impacts, along with the August 2008 8-29 NUREG-1437, Supplement 33

Alternatives land used to construct plant facilities and infrastructure. These impacts would be MODERATE to LARGE.

Aquatic ecology impacts would be smaller than the impacts of the HNP unit, as the lower heat rate of the IGCC coal-fired option means less water would be consumed for cooling.

The on-site option would make use of the existing plants cooling, intake, and outflow structures. Since the existing HNP unit already has a SMALL impact on aquatic ecology, and the IGCC alternative has a smaller impact, the impact level remains SMALL. An IGCC coal-fired plant at an alternate site would likely also make use of cooling towers, and would incur similar aquatic impacts, which would range from SMALL to MODERATE, depending on the characteristics of the water body used for cooling.

Table 8-3. Summary of Environmental Impacts of IGCC Coal-Fired Generation at HNP Site and an Alternate Site Using Closed-Cycle Cooling Impact HNP Site Alternate Site Category Impact Comments Impact Comments Land Use MODERATE May use 80.9 ha (200 ac) for MODERATE Uses several hundred plant structures and 4.37 ha to LARGE acres for plant, offices, (10.8 ac) for waste disposal; parking, and plant facilities.

impact would be less than the Transmission line, rail supercritical coal-fired spur, and coal mining alternative; additional offsite require additional land.

land impacts for coal mining.

Ecology SMALL to Uses undeveloped areas at MODERATE Impacts depend on the MODERATE current HNP site, plus existing to LARGE location and ecology of the rail and transmission corridors. site, characteristics of the surface water body used for intake and discharge, and transmission line and rail routes. Construction may result in habitat loss and fragmentation; reduced productivity and biological diversity.

Water Use and SMALL Uses existing cooling tower SMALL to With closed-cycle cooling, QualitySurface system, and uses less water MODERATE impact likely to be SMALL, Water than the existing HNP. though it would depend on the volume of water withdrawn and discharged, as well as the characteristics of the surface water body.

NUREG-1437, Supplement 33 8-30 August 2008

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Water Use and SMALL A new plant onsite would likely SMALL to Impact would depend on Quality continue to rely on Harris MODERATE the volume of water Groundwater Reservoir for all water. NRC withdrawn and discharged staff expects groundwater and the characteristics of impacts only if coal slag the aquifers, though NRC contaminates groundwater. staff assumes groundwater would not be used for cooling makeup water.

Air Quality MODERATE

• Sulfur oxides MODERATE Potentially the same 466 MT/yr (514 tons/yr) impacts as at the HNP site, although pollution-control

• Nitrogen oxides standards may vary.

658 MT/yr (725 tons/yr)

• Total suspended particulates 52.1 MT/yr (57 tons/yr)

• PM10 52.1 MT/yr (57 tons/yr)

• Carbon monoxide 822 MT/yr (906 tons/yr)

• Mercury removed by syngas-stage controls Waste SMALL Total slag disposed onsite SMALL to Same impacts as at the would be approximately MODERATE HNP site; waste disposal 25,800 MT (28,500 tons) per constraints may vary.

year, since most slag, 232,000 MT/yr (256,000 tons/yr), would be reused. Over the plants lifespan, 4.37 ha (10.8 ac) would be required for waste disposal.

Human Health SMALL Impacts are uncertain, but SMALL Similar impacts as at the considered SMALL as the plant HNP site.

would comply with health-informed standards in the Clean Air Act and other relevant emissions regulations.

August 2008 8-31 NUREG-1437, Supplement 33

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Socioeconomics SMALL to During construction, impacts SMALL to Construction impacts MODERATE would be MODERATE. LARGE depend on location, but Between 1170 and 2440 would be LARGE if the workers during the peak period plant is located in an area of the 4-year construction that is rural or is growing period, followed by reduction less quickly than areas from current HNP work force of near the HNP site. Wake 720 to between 147 and 244 and surrounding counties workers. Tax base would may lose tax revenue and generally be preserved in Wake employment, though County. Impacts during economic growth would operation would be SMALL. likely offset much of this loss. Impacts at a site near to an urban area may be SMALL.

Socioeconomics SMALL to Transportation impacts would SMALL to Transportation impacts (Transportation) MODERATE be SMALL to MODERATE, LARGE would be SMALL to primarily due to construction LARGE, primarily due to activities. construction activities.

For rail transportation of coal For rail transportation of and lime, the impact would coal, the impact would be likely be SMALL, depending on SMALL, but dependent on the routing of coal trains. the routing of coal trains.

Aesthetics SMALL to Aesthetic impact due to plant SMALL to Overall impacts could vary MODERATE units and stacks would be LARGE widely, with the greatest SMALL. impacts from new transmission lines, rail lines Rail transportation of coal would to transport coal, and have a SMALL to MODERATE cooling towers.

aesthetic impact.

Noise impact would be SMALL given the size of the site.

Historic and SMALL Some construction would affect SMALL to Alternate location would Archeological previously developed parts of MODERATE necessitate cultural Resources the HNP site; cultural resource resource studies; inventory would minimize any construction would likely impacts on undeveloped lands. avoid highly sensitive areas. Impacts would be managed.

NUREG-1437, Supplement 33 8-32 August 2008

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Environmental SMALL Impacts on minority and low- SMALL to Impacts would vary Justice income communities would be MODERATE depending on population similar to those experienced by distribution and location of the population as a whole. the site.

Some impacts on rental housing may occur during construction; loss of 476 to 573 operating jobs could reduce employment prospects for minority and low-income populations, though this would likely be offset by economic growth.

• Water Use and Quality Surface Water. The IGCC coal-fired generation alternative at the HNP site is assumed to use the existing cooling tower system, which would minimize incremental water-use and quality impacts. Given the IGCC coal plants heat rate, it would likely use less water than the existing HNP unit. As such, impacts to surface water use and quality would be SMALL.

Alternate sites would likely use a closed-cycle cooling system with cooling towers. For alternate sites, the impact on the surface water would depend on the volume of water needed for makeup water, the discharge volume, and the characteristics of the water body used for intake and discharge. Intake from and discharge to any surface body of water would be regulated by NCDENR. The impacts would be SMALL to MODERATE.

Groundwater. HNP uses no groundwater. An IGCC coal-fired alternative on the HNP site would likely continue to rely on Harris Reservoir for all water needs and not use any groundwater. Provided operators properly landfill leftover slag, the impact to groundwater would be SMALL.

At an alternate site, impacts to groundwater would depend on the extent to which the plant utilizes groundwater, though NRC finds it unlikely that a coal-fired IGCC plant would depend on groundwater for cooling purposes. Given that a plant would likely use groundwater only for domestic and some service purposes, the impact could be SMALL to MODERATE, depending on the nature of the aquifers used.

August 2008 8-33 NUREG-1437, Supplement 33

Alternatives

• Air Quality The air-quality impacts of IGCC coal-fired generation can be substantial, though markedly less than conventional coal technologies in several important areas. These include lower emissions of mercury as well as particulate matter. Pre-scrubbed levels of sulfur oxides (SOx) and nitrogen oxides (NOx) are also typically much lower than conventional coal technologies. In addition, naturally occurring radioactive materials would likely remain in slag much as they remain in solid ash products in conventional coal plants.

Currently, Wake County and the neighboring counties of Johnston, Chatham, Durham, Franklin and Nash are ozone nonattainment areas under the Clean Air Act (EPA 2007b).

These counties are either in attainment or unclassified for other criteria pollutants (EPA 2007b). A new IGCC coal-fired plant located in an ozone non-attainment area would need to purchase emissions credits from existing emitters of ozone-causing chemicals, including NOx.

A new IGCC coal-fired generating plant located at the HNP site would also need a Nonattainment Area permit and a Title V operating permit under the Clean Air Act. A new coal-fired generating plant located at an alternate site would also need to comply with the new source performance standards for coal-fired plants set forth in 40 CFR 60 Subpart D(a).

The standards establish limits for particulate matter and opacity (40 CFR 60.42(a)), SO2 (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)). A coal-fired power plant constructed elsewhere in North Carolina or CP&Ls territory would need to comply with applicable provisions of the Clean Air Act, as well, based on those areas attainment statuses.

Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing future and remedying existing impairment of visibility in mandatory Class I Federal areas when impairment results from man-made air pollution. EPA issued a new regional haze rule in 1999 (64 FR 35714) (EPA 1999). The rule specifies that for each mandatory Class I Federal area located within a state, the State must establish goals that provide for reasonable progress towards achieving natural visibility conditions. The reasonable progress goals must provide for an improvement in visibility for the most-impaired days over the period of the implementation plan and ensure no degradation in visibility for the least-impaired days over the same period (40 CFR 51.308(d)(1)). If a coal-fired plant were located close to a mandatory Class I area, additional air pollution control requirements would be imposed. North Carolina contains five Class I areas, one of which, Swanquarter Wilderness Area, is potentially downwind of a coal-fired alternative at HNP (EPA 2007a).

Swanquarter, however, is approximately 298 km (185 mi) from the HNP site, and thus is unlikely to be affected by a coal-fired alternative. A coal-fired alternative located near Swanquarter or any of North Carolinas other Class 1 Areas may need to install additional emissions controls. EPA more generally protects visibility with regulations in 40 CFR 51, Subpart P.

NUREG-1437, Supplement 33 8-34 August 2008

Alternatives In addition to Clean Air Act regulations, North Carolina restricts utilities aggregate emissions of NOx and SOx from coal-fired power plants (NC General Statutes 143-215.107D; commonly known as the Clean Smokestacks Act). To date, Progress Energy has met the aims of the legislation by installing emissions controls technologies at older coal-fired plants (NCDENR and NCUC 2006). Constructing a new IGCC coal-fired power plant may result in emissions levels that require CP&L to install emissions controls on older coal-fired power plants in order to remain in compliance with the law.

The IGCC coal-fired alternative would produce the following quantities of air pollutants:

Sulfur oxides emissions. DOE indicated that a coal-fired IGCC plant would emit 0.0077 kg (0.017 lb) of SOx per million BTU of thermal input (DOE 1999). Based on this emissions rate, NRC staff projects total SO2 emissions are of 466 MT (514 tons) per year without any additional emissions control technology.

A new coal-fired power plant would be subject to the requirements in Title IV of the Clean Air Act. Title IV was enacted to reduce emissions of SO2 and NOx, the two principal precursors of acid rain, by restricting emissions of these pollutants from power plants. Title IV caps aggregate annual power plant SO2 emissions and imposes controls on SO2 emissions through a system of marketable allowances. EPA issues one allowance for each ton of SO2 that a unit is allowed to emit. New units do not receive allowances, but are required to have allowances to cover their SO2 emissions. Owners of new units must therefore purchase allowances from owners of other power plants or reduce SO2 emissions at other power plants they own. Allowances can be banked for use in future years. Thus, a new coal-fired power plant would not add to net regional SO2 emissions, although it might do so locally.

North Carolinas Clean Smokestacks Law restricts utility-level aggregate emissions of SOx from coal-fired power plants. A new coal-fired power plant in North Carolina may result in emissions levels that require CP&L to reduce emissions from other, older power plants.

Nitrogen oxides emissions. In the absence of additional control technologies, the IGCC alternative would produce 658 MT (725 tons) of NOx per year, based on DOE emissions projections (DOE 1999).

Section 407 of the Clean Air Act establishes technology-based emission limitations for NOx emissions. The market-based allowance system used for SO2 emissions is not used for NOx emissions. A new coal-fired power plant would be subject to the new source performance standards for such plants as indicated in 40 CFR 60.44a(d)(1). This regulation, issued on September 16, 1998 (63 FR 49453) (EPA 1998b), limits the discharge of any gases that contain nitrogen oxides (expressed as NO2) in excess of 200 ng/J of gross energy output (1.6 lb/MWh), based on a 30-day rolling average.

August 2008 8-35 NUREG-1437, Supplement 33

Alternatives Even without additional control technologies, NRC staff estimates that the total annual NOx emissions for a new coal-fired power plant would be approximately 658 MT/yr (725 tons/yr) or approximately 12.4 percent of the new source performance standard emission rate. This level of NOx emissions would be greater, however, than the operating license renewal alternative.

EPA further restricts the total amount of NOx that can be emitted on a State level basis. In the 2007 ozone season (May 1-September 30) North Carolina may emit 150,000 MT (165,306 tons) of NOx. A new IGCC coal-fired power plant would need to offset emissions through credit purchases or from a set-aside pool.

North Carolinas Clean Smokestacks Law restricts utility-level aggregate emissions of NOx from coal-fired power plants. A new IGCC power plant in North Carolina may result in emissions levels that require CP&L to reduce emissions from other coal-fired power plants.

Particulate emissions. NRC staff estimates that the total annual stack emissions would include approximately 52.1 MT (57 tons) of filterable total suspended particulates, all of which have an aerodynamic diameter less than or equal to 10 m (PM10) (40 CFR 50.6). In addition, coal-handling equipment would introduce fugitive particulate emissions.

Particulate emissions would be greater under the coal alternative than the operating license renewal alternative.

During the construction of an IGCC coal-fired plant, fugitive dust would be generated. In addition, exhaust emissions would come from vehicles and motorized equipment used during the construction process. These impacts are intermittent and short-lived. To minimize dust generation, construction crews would use applicable dust-control measures..

Carbon monoxide emissions. In the absence of DOE or EPA emissions data, NRC staff adopts CP&Ls emissions rate, which indicates that the total carbon monoxide emissions would be approximately 822 MT (906 tons) per year. This level of emissions would be greater than the operating license renewal alternative.

Hazardous air pollutants including mercury. In December 2000, EPA issued regulatory findings on emissions of hazardous air pollutants from electric utility steam-generating units (EPA 2000b). EPA determined that coal- and oil-fired electric utility steam-generating units are significant emitters of hazardous air pollutants. Coal-fired power plants were found by EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000b). EPA concluded that mercury is the hazardous air pollutant of greatest concern. EPA found that (1) there is a link between coal consumption and mercury emissions; (2) electric utility steam-generating units are the largest domestic source of mercury emissions; and (3) certain segments of the U.S. population (e.g., the developing fetus and subsistence fish-eating populations) are believed to be at potential risk of adverse health effects due to mercury exposures resulting NUREG-1437, Supplement 33 8-36 August 2008

Alternatives from consumption of contaminated fish (EPA 2000b). Accordingly, EPA added coal- and oil-fired electric utility steam-generating units to the list of source categories under Section 112(c) of the Clean Air Act for which emission standards for hazardous air pollutants will be issued (EPA 2000b). Accordingly, on March 15, 2005, EPA issued the Clean Air Mercury Rule to permanently cap and reduce mercury emissions from coal-fired power plants (EPA 2007c). A new IGCC coal-fired power plant would need to comply with performance standards contained in 40 CFR 60.45(a), requiring that the plant emit no more than 0.0025 nanograms per Joule output (20 x 10-6 lbs. per MWh). In addition, to the extent the plant would emit any mercury, the plant owners would need to purchase mercury allowances or reduce emissions to ensure that North Carolina emits no more than 1.133 tons of mercury containing gases in 2010, and 0.447 tons of mercury containing gases in 2018 (EPA 2006).

IGCC units minimize mercury emissions by allowing control technologies to extract mercury from syngas prior to combustion in the combined-cycle power plant.

Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring elements. Alex Gabbard, a researcher at Oak Ridge National laboratory, indicates that uranium concentrations are generally in the range of 1 to 10 parts per million (ppm) and thorium concentrations are generally about 2.5 times this level (Gabbard 1993). The USGS indicates that Western and Illinois Basin coals contain uranium and thorium at roughly equal concentrations, mostly between 1 and 4 ppm, but also indicates that some coals may contain concentrations as high as 20 ppm of both elements (USGS 1997). Gabbard indicates that a 1000 MWe coal-fired plant would release roughly 4.7 MT (5.2 tons) of uranium and 11.6 MT (12.8 tons) of thorium annually (Gabbard 1993). Both USGS and Gabbard indicate that almost all of the uranium, thorium, and most decay products remain in solid coal wastes, especially in the fine glass spheres that constitute much of coals fly ash.

Modern emissions controls allow for recovery of greater than 99% of these solid wastes (EPA 1998a), thus retaining most of coals radioactive elements in solid form rather than releasing it to the atmosphere. In an IGCC plant, uranium and thorium would remain in slag material. Even after concentration in coal slag, the level of radioactive elements remains relatively low (typically 10 to 100 ppm) and consistent with levels found in naturally occurring granites, shales, and phosphate rocks (USGS 1997). The level of uranium and thorium contained in coal wastes and disposed of in the environment exceed the levels of uranium and thorium released to the environment by the existing nuclear power plant.

Carbon dioxide. A coal-fired IGCC plant would also have unregulated carbon dioxide emissions during operations of the plant itself as well as during coal mining and processing, as well as coal transportation. Burning bituminous coal in the U.S. emits roughly 205.3 lbs CO2 per million Btu (Hong and Slatick 1994). The IGCC plant would emit approximately 6,200,000 tons of CO2 per year (5,630,000 MT)

Summary. The GEIS analysis did not quantify emissions from coal-fired power plants, but did imply that air impacts would be substantial. The GEIS also mentioned global warming August 2008 8-37 NUREG-1437, Supplement 33

Alternatives from unregulated carbon dioxide emissions and acid rain from SOx and NOx emissions as potential impacts (NRC 1996). Adverse human health effects such as cancer and emphysema have been associated with the products of coal combustion. NRC staff analysis for an IGCC coal-fired alternative at the HNP site and an alternative site indicates that impacts from the coal-fired alternative would have clearly noticeable effects, but would not destabilize air quality. Thus, the appropriate characterization of air impacts from coal-fired generation would be MODERATE.

Siting an IGCC coal-fired generation plant at a site other than HNP would not significantly change air-quality impacts, although it would result in installing more or less stringent pollution-control equipment to meet applicable local requirements. Therefore, the impacts would be MODERATE.

• Waste IGCC combustion of coal generates waste in slag, a vitreous, sand-like material. The IGCC alternative would generate 258,000 MT (285,000 tons) of slag annually for 40 years. Of this waste, approximately 232,000 MT (256,000 tons) (90%) would be recycled, according to CP&L, leaving a total of approximately 25,800 MT (28,500) tons that would be landfilled onsite. Slag disposal would require 4.37 ha (10.8 ac) of land area over the 40-year plant life. Waste impacts to groundwater and surface water would extend beyond the operating life of the plant if leachate and runoff from the waste storage area occurs, though proper management can prevent this pollution. In addition, the small size of the waste disposal area makes other waste impacts less likely. IGCC slag would need to be handled in accordance with state and national regulations. After closure of the waste site and revegetation, the land would be available for other uses Debris would be generated during construction activities. This would likely be disposed onsite, when possible. Overall, this amount of waste would be small compared to operational waste generated, and many construction wastes can be recycled. As such, construction-stage waste impacts would be SMALL.

For all of the preceding reasons, the appropriate characterization of impacts from waste generated by a coal-fired IGCC plant located at the HNP site would be SMALL.

Siting the facility at a site other than HNP would not alter waste generation, although other sites might have more constraints on disposal locations. If a coal facility was sited on a previously developed location, then there may also be fewer constraints on waste disposal.

Therefore, the impacts would likely be SMALL to MODERATE.

NUREG-1437, Supplement 33 8-38 August 2008

Alternatives

• Human Health IGCC coal-fired power generation introduces worker risks from coal mining, from coal transportation, and from disposal of slag as well as transportation of reusable byproducts.

In addition there are public risks from inhalation of stack emissions. Emission impacts can be widespread and health risks difficult to quantify. The coal-fired IGCC alternative also introduces the risk of coal-pile fires and attendant inhalation risks.

In the GEIS, the NRC staff stated that there would be human health impacts (cancer and emphysema) from inhalation of toxins and particulates, but it did not identify the significance of these impacts (NRC 1996).

Regulatory agencies, including EPA and State agencies, set air emission standards and requirements based on human health impacts. These agencies also impose site-specific emission limits as needed to protect human health. As discussed previously, EPA has recently concluded that certain segments of the U.S. population (e.g., the developing fetus and subsistence fish-eating populations) are believed to be at potential risk of adverse health effects due to mercury exposures from sources such as coal-fired power plants, though these emissions are likely to be smaller from IGCC plants than from conventional coal-fired plants. In the absence of more quantitative data, human health impacts from radiological doses and inhaling toxins and particulates generated by burning coal would be characterized as SMALL.

• Socioeconomics Construction of the IGCC coal-fired alternative would take approximately 4 years (DOE/EIA 2006b). The NRC staff assumed that construction would take place while HNP continues operation and would be completed by the time it permanently ceases operations in 2026.

The work force would be expected to include between 1170 and 2440 workers (based on estimates for natural gas and coal-fired power plants in NRC 1996). These workers would be in addition to the approximately 720 workers currently employed at HNP. During construction, the surrounding communities would experience an increased demand for rental housing and public services, though this would be moderated by the proximity of the site to urban areas. After construction, the communities would be impacted by the loss of the construction jobs, though rapid economic growth in the area would mitigate these impacts.

If the coal-fired IGCC plant were constructed at the HNP site and HNP were decommissioned, there would be a loss of approximately 473 to 576 permanent high-paying jobs (720 for HNP to between 147 and 244 for the IGCC coal-fired plant), with a commensurate reduction in demand on socioeconomic resources and tax contribution to the regional economy. The coal-fired IGCC plant would provide a new tax base to offset the loss of tax base associated with decommissioning of the HNP unit in Wake County. Other August 2008 8-39 NUREG-1437, Supplement 33

Alternatives counties would likely experience little impact, as HNP pays 90% of its local taxes to Wake County. Since the regions growing economy effectively mitigates most socioeconomic impacts of both construction and operation, the appropriate characterization of non-transportation socioeconomic impacts for an IGCC coal-fired plant constructed at the HNP site would be SMALL to MODERATE During the 4-year construction period of the IGCC coal-fired units, between 1172 and 2440 construction workers would be commuting to the site in addition to the 720 workers at HNP. The addition of these workers would increase traffic loads on existing highways, particularly on surface roads in and around the plant. These transportation impacts would be SMALL to MODERATE.

Construction of a replacement coal-fired IGCC power plant at an alternate site would relocate some socioeconomic impacts. The communities around HNP would experience the relatively minor impact of HNP operational job loss, and the communities around the new site would have to absorb the impacts of a large, temporary work force (up to 2440 workers at the peak of construction) and a permanent work force ranging from 147 to 244 workers.

In the GEIS, the NRC staff stated that socioeconomic impacts at a rural site would be larger than at an urban site, because more of the peak construction work force would need to move to the area to work. The HNP site is in the Raleigh-Durham-Chapel Hill metropolitan area and is therefore not considered a rural site. Alternate sites would need to be analyzed on a case-by-case basis. Alternate industrial sites, however, tend to be close to metropolitan areas, and may still have remaining transportation infrastructure nearby.

Socioeconomic impacts at a rural site would be LARGE, while impacts at previously developed industrial site would be SMALL to MODERATE.

• Transportation For transportation related to commuting of plant operating personnel, the impacts would be considered SMALL. The maximum number of plant operating personnel would be approximately 244. The current HNP work force is approximately 720. Therefore, traffic impacts associated with plant personnel commuting to an IGCC coal-fired plant would be expected to be SMALL, and smaller than the impacts of renewing the license for HNP.

For rail transportation related to coal delivery to the HNP site, the impacts would be considered SMALL. NRC staff estimates that approximately 245 unit trains per year would deliver coal for IGCC alternative, while trains or trucks would remove sulfur and slag for marketing. Approximately 5 unit trains would deliver coal each week, or more than one trip per day on the spur leading to the plant, because for each full train delivery there would be an empty train.

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Alternatives Transportation-related impacts associated with commuting construction workers at an alternate site are site dependent, but could be SMALL to LARGE. Transportation impacts related to commuting of plant operating personnel would also be site dependent, but would be best characterized as SMALL.

At an alternate site, coal would also likely be delivered by rail. Transportation impacts would depend upon the site location. Socioeconomic impacts associated with rail transportation would likely be SMALL, though dependent on coal train routing. Socioeconomic impacts associated with rail transportation on a previously developed industrial site would likely be SMALL.

• Aesthetics If sited at the current HNP location, the IGCC coal-fired power plant units would be as much as 60 m (200 ft) tall. Given the sites heavy forestation, these units would likely not be visible offsite. The two exhaust stacks would be similar in height to those of a natural gas-fired combined cycle plant, and shorter than the 122 to 183 m (400 to 600 ft) estimated for a supercritical coal-fired plant. Given the current presence of a cooling tower and its plume, as well as other plant structures on-site, the addition of plant stacks would not drastically increase visual impacts. The units and associated stacks would also be visible at night because of outside lighting. Visual impacts of a new coal-fired plant could be mitigated by landscaping and color selection for buildings that is consistent with the environment. Visual impact at night could be mitigated by reduced lighting and appropriate shielding. The visual impacts at the HNP site would be SMALL.

Coal-fired IGCC generation would introduce mechanical sources of noise at the site. Given the low population offsite of the plants property and the screening effect of trees onsite, offsite noise would be unlikely to be obtrusive. Sources contributing to total noise produced by plant operation are classified as continuous or intermittent. Continuous sources include the mechanical equipment associated with normal plant operations. Intermittent sources include the equipment related to coal handling, solid-waste disposal, transportation related to coal and lime delivery, use of outside loudspeakers, and the commuting of plant employees. The incremental noise impacts of a coal-fired plant compared to existing HNP operations would be considered SMALL.

Noise impacts associated with rail delivery of coal to a plant at the HNP site would be most significant for residents living in the vicinity of the facility and along the rail route. Although noise from passing trains significantly raises noise levels near the rail corridor, the short duration of the noise reduces the impact. The number of people affected by transportation would depend on the rail route. As such, the impacts of train noise on residents in the vicinity of the facility and the rail line would be SMALL to MODERATE.

August 2008 8-41 NUREG-1437, Supplement 33

Alternatives At an alternate site, there would be an aesthetic impact from the buildings, exhaust stacks, cooling towers, and the plume associated with the cooling towers. There would be a significant aesthetic impact associated with construction of a new transmission line to connect to other lines to enable delivery of electricity. Noise and light from the plant may be detectable offsite, depending on plant characteristics. Aesthetic impacts at the plant site would be mitigated if the plant were located in an industrial area adjacent to other power plants. Noise impacts from a rail spur, if required, would be similar to the impacts at the existing site. Overall the aesthetic impacts associated with locating at an alternate site could range from SMALL to LARGE, depending on site characteristics. Some of these issues would be rectified if the IGCC coal plant were sited at a previously developed site, as many contain some level of rail or transmission infrastructure, and would be in areas accustomed to industrial uses. Impacts at a previously developed site would be SMALL to MODERATE.

• Historic and Archaeological Resources At the HNP site, a cultural resource inventory would likely be needed for any onsite property that has not been previously surveyed. Other lands, if any, that are acquired to support the plant would also likely need an inventory of field cultural resources, identification and recording of existing historic and archaeological resources, and possible mitigation of adverse effects from subsequent ground-disturbing actions related to physical expansion of the plant site.

Before construction at an alternate, undeveloped site, studies would be needed to identify, evaluate, and develop mitigation measures for the potential impacts of new plant construction on cultural resources. The studies would be needed for all areas of potential disturbance at the proposed plant site and along associated corridors where new construction would occur (e.g., roads, transmission corridors, rail lines, or other rights-of-way). Historic and archaeological resource impacts can generally be effectively managed and as such would be considered SMALL for the existing site and would be SMALL to MODERATE at a new site. For a previously developed site, impacts on cultural and historic resources would be SMALL, as the area has previously been developed, and previous development either removed or surveyed items of archaeological interest.

• Environmental Justice No environmental impacts were identified that would result in disproportionately high and adverse environmental impacts to minority and low-income populations if a replacement IGCC coal-fired plant were built at the HNP site. Some impacts on housing availability and lease prices during construction would occur, and this could disproportionately affect the minority and low-income populations.

NUREG-1437, Supplement 33 8-42 August 2008

Alternatives Impacts on minority and low-income populations due to the shutdown of HNP would depend on the number of jobs and the amount of tax revenue lost to the communities surrounding the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it is likely that these losses would be replaced by the development of new businesses and new sources of tax revenue in the region. Since CP&Ls tax payments represent a small percentage of Wake Countys total annual property tax revenue, it is unlikely that social services would be seriously affected. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse socioeconomic impacts from the shutdown of HNP.

The environmental effect of plan shutdown would reduce the amount of operational impacts on the environment. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse environmental impacts from the shutdown of HNP.

Impacts at other sites would depend upon the site chosen and the nearby population distribution, but would be SMALL to MODERATE for alternate sites. For previously developed industrial sites, impacts would be larger, depending on the locations of low-income populations.

8.2.3 Natural Gas-Fired Combined-Cycle Generation In this section, NRC staff examines the environmental impacts of the natural gas-fired alternative at both the HNP site and at an alternate site. The NRC staff assumed that a natural gas-fired plant would use a closed-cycle cooling system. At the HNP site, the NRC staff assumed that the new plant would make use of the existing cooling system, including cooling tower, intake, and outlet.

If a new natural gas-fired plant were built on the existing property to replace HNP, approximately 3.2 km (2 mi) of new, 20-cm (8-in.) gas pipeline would be necessary to connect the plant to existing gas pipelines north of the plant (Progress Energy 2006b). This would require a 15-m (50-ft) wide corridor, resulting in disturbance to as much as 4.9 ha (12 ac) of land. CP&L indicates that this new pipeline may necessitate additional improvements to the statewide pipeline system.

NRC staff assumed that a replacement natural gas-fired plant would use combined-cycle technology. Compared to simple-cycle combustion turbines, combined cycle plants are significantly more efficient, and thus provide electricity at lower levelized costs. Typically, they support intermediate loads, but they are capable of supporting a baseload duty cycle and thus provide an alternative to the renewed operating license.

August 2008 8-43 NUREG-1437, Supplement 33

Alternatives In a combined-cycle unit, hot combustion gases in a combustion turbine rotate the turbine to generate electricity. Waste combustion heat from the combustion turbine is routed through a heat-recovery steam generator, which then powers a steam turbine electrical generator.

In the HNP ER, CP&L asserts that three units based on existing Siemens combined cycle systems would be constructed to replace HNP (Progress Energy 2006b). After reviewing commercially available combined cycle power plant, the NRC staff assumed that these units would be Siemens SCC6-5000F units with heat rates of 5990 Btu/kWh. NRC staff believes these units appropriately reflect modern combined-cycle power plant technology, and also note that examining these units for the purpose of environmental impact analysis does not mean that they are the units most likely to be chosen by CP&L or other relevant authorities should they choose to implement a gas-fired alternative.

The NRC staff reviewed this information and compared it to environmental impact information in the GEIS. Although the operating license renewal period is only 20 years, the impact of operating the natural gas-fired alternative for 40 years is considered (though this may modestly exceed the expected lifetime of a combined-cycle plant, it is consistent with impacts for the other fossil-fueled alternatives).

NRC staff discusses the overall impacts of the natural gas-fired generating system in the following sections and summarizes them in Table 8-4. The extent of impacts at an alternate site would depend on the location of the site selected.

• Land Use For siting at HNP, existing facilities and infrastructure would be used to the extent practicable, limiting the amount of new construction that would be required. Specifically, the NRC staff assumed that the natural gas-fired replacement plant alternative would use the cooling tower system, switchyard, offices, and transmission line rights-of-way. Much of the land that would be used has been previously disturbed. NRC staff in the GEIS asserted that a 1000 MWe gas-fired plant would require 45 ha (110 ac). As such, a plant of the size proposed for replacing HNPs capacity would require 40 ha (100 ac). NRC staff notes that by using structures from the existing HNP unit, land use impacts would be minimized. CP&L estimated a land-use impact of 24 ha (60 ac) for a gas-fired alternative constructed on the HNP site (Progress Energy 2006b). There would be an additional impact of up to approximately 4.9 ha (12 ac) for construction of a gas pipeline.

For construction at an alternate site, the NRC staff assumed that 40 ha (100 ac) would be needed for the plant and associated infrastructure. In addition, anywhere from tens to thousands of acres would be disturbed by installing gas pipelines and electric transmission lines. NRC staff expects that this area would be reduced if a gas-fired alternative was constructed on a previously-developed industrial site. Many former industrial sites have easier access to pipelines and transmission capacity than undeveloped sites.

NUREG-1437, Supplement 33 8-44 August 2008

Alternatives Regardless of where a gas-fired alternative is built, additional land would be required for natural gas wells and collection stations. According to the GEIS, a 1000 MWe gas-fired plant requires approximately 1500 ha (3600 ac) for wells, collection stations, and pipelines (NRC 1996). Much of the land area necessary for the gas-fired alternative would be in existing gas-extraction areas. Partially offsetting these offsite land requirements would be the elimination of the need for uranium mining to supply fuel for HNP. In the GEIS (NRC 1996), the NRC staff estimated that approximately 400 ha (1000 ac) would be affected for mining the uranium and processing it during the operating life of a 1000 MWe nuclear power plant. Overall, land-use impacts would be SMALL to MODERATE for an alternative at the HNP site. Impacts would generally be similar at an undeveloped site, as the primary driver for these impacts would be the large area of land necessary for natural gas infrastructure.

At an alternate site, additional pipelines or transmission lines may also be necessary. As such, impacts would be SMALL to LARGE.

Table 8-4. Summary of Environmental Impacts of Natural Gas-Fired Generation at HNP Site and an Alternate site Using Closed-Cycle Cooling Impact HNP Site Alternate Site Category Impact Comments Impact Comments Land Use SMALL to Less than 40 ha (100 ac) for SMALL to Approximately 40 ha MODERATE powerblock, offices, roads, and LARGE (100 ac) for power block, parking areas, some of which offices, roads, and parking would be reused from the areas. Power line and gas existing HNP site. Additional pipeline impacts may vary impact of up to approximately widely, from tens of acres 4.9 ha (12 ac) for construction to thousands of acres.

of an underground gas pipeline. Previously developed sites would experience lower impacts than undeveloped sites.

Ecology SMALL As the alternative would use SMALL to Impact depends on location undeveloped areas at the MODERATE and ecology of the site, current HNP site, terrestrial surface water body used impacts would be minimal. for intake and discharge, Relatively little land would be and transmission and disturbed for a pipeline, though pipeline routes; potential actual land characteristics habitat loss and would drive pipeline impacts. fragmentation; reduced Aquatic ecology actually productivity and biological benefits from gas-fired diversity. These issues alternative, as the combined- would be much smaller on cycle plant requires significantly a previously developed less makeup water and site.

August 2008 8-45 NUREG-1437, Supplement 33

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments discharges less blowdown than HNP.

Water Use and SMALL Uses a closed-cycle cooling SMALL to Impact depends on volume QualitySurface system with natural gas-fired MODERATE of water withdrawn and Water combined-cycle units. This discharged, as well as would result in a significant characteristics of the reduction in water use due to surface water body.

lower levels of heat rejection.

Water Use and SMALL HNP uses no groundwater. A SMALL to Impact depends on volume Quality combined-cycle alternative MODERATE of water withdrawal, though Groundwater would continue to use Harris it is not likely to be used for Reservoir for all water needs cooling makeup.

rather than use groundwater.

Air Quality SMALL to Emissions: SMALL to Same emissions as at HNP MODERATE MODERATE site.

• Sulfur oxides 62.3 MT (69 tons/yr)

• Nitrogen oxides 200 MT (220 tons/yr)

• Carbon monoxide 41.5 MT (46 tons/yr)

• PM10 particulates 34.8 MT (38 tons/yr)

• Small amounts of hazardous air pollutants Waste SMALL Solid waste primarily due to SMALL Same waste produced as emission controls and plant at the HNP site.

operations.

Human Health SMALL Impacts are uncertain, but SMALL Similar impacts to those at considered SMALL as the plant the HNP site.

would comply with health-informed standards in the Clean Air Act and other relevant emissions regulations.

NUREG-1437, Supplement 33 8-46 August 2008

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Socioeconomics SMALL During construction, impacts SMALL to During construction, would be SMALL. Up to 1090 MODERATE impacts would be SMALL additional workers during the to MODERATE, depending peak of the 3-year construction on site. Up to 1090 addi-period, followed by reduction tional workers during the from current HNP work force of peak of the 3-year 720 to 136; tax base preserved. construction period. Wake Impacts during operation would county would lose jobs and be SMALL. tax base, while other counties would lose jobs.

Impacts during operation would be SMALL.

Socioeconomics SMALL to Transportation impacts would SMALL to Transportation impacts (Transportation) MODERATE likely be SMALL to MODERATE could be SMALL to MODERATE, primarily with MODERATE, primarily with construction activities. construction activities.

Aesthetics SMALL Aesthetic impact due to plant SMALL to Greatest impact would be units and stacks would be minor MODERATE from the new transmission compared to exiting HNP line and pipeline right-of-structures. way that would be needed.

Overall impact would be SMALL for previously developed sites and SMALL to MODERATE for undeveloped sites.

Historic and SMALL Any potential impacts could be SMALL to Any potential impacts Archeological effectively managed given the MODERATE would be effectively Resources plants small footprint. managed, though pipeline and transmission line may have SMALL to MODERATE impacts.

Environmental SMALL Impacts on minority and low- SMALL to Impacts would vary Justice income communities would be MODERATE depending on population similar to those experienced by distribution and location of the population as a whole, the site.

which are SMALL. Some additional impacts on rental housing may occur during construction, though these would not be noticeable.

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Alternatives

• Ecology At the HNP site, there would be ecological impacts to land use for siting of the gas-fired plant, though these are likely to be small since the disturbed area of the plant would likely accommodate a new combined-cycle gas plant. There would also be some ecological impacts associated with bringing a new underground gas pipeline to the HNP site, though this is dependent upon habitat disturbed during construction, which is, in turn, dependent on pipeline routing. Since CP&L estimates this pipeline would require only 4.9 ha (12 ac) to reach the plant, this impact is unlikely to noticeably affect important ecological features.

Aquatic ecology actually benefits from gas-fired alternative, as the combined-cycle plant requires significantly less makeup water and discharges less blowdown than HNP.

Ecological impacts at an alternate site would depend on the nature of the land converted for the plant and the possible need for a new gas pipeline and/or transmission line.

Construction of the transmission line and construction and/or upgrading of the gas pipeline to serve a plant at an alternate site would have temporary ecological impacts, though these would be substantial. Ecological impacts to the plant site and utility rights of way would include impacts on threatened or endangered species, wildlife habitat loss and reduced productivity, habitat fragmentation, and a local reduction in biological diversity. At an alternate site, the cooling makeup water intake and discharge would have aquatic resource impacts. These impacts would be smaller at a previously developed site, owing to generally closer access to pipelines and transmission lines than at greenfield sites. Overall, the ecological impacts would be considered SMALL at the HNP site and SMALL to MODERATE at a different location.

• Water Use and Quality Surface Water. Combined-cycle gas-fired plants are highly efficient and require less cooling water than other generation alternatives, including the existing plant. Plant discharge would consist mostly of cooling tower blowdown, with the discharge having a slightly higher temperature and increased concentration of dissolved solids relative to the receiving body of water, as well as intermittent low concentrations of biocides (e.g.,

chlorine). In addition to the cooling tower blowdown, process waste streams and sanitary waste water would also be discharged, though these discharges would be much smaller than at the existing plant since a gas-fired alternative would employ many fewer people. All discharges would be regulated through a NPDES permit, which is administered by NCDENR. Finally, some erosion and sedimentation would probably occur during construction (NRC 1996), though the GEIS indicates this would be SMALL. Overall, the impacts to water use and quality at the HNP site from a gas-fired alternative would be considered SMALL, and would be less than the proposed action.

A natural gas-fired plant at an alternate site is assumed to use a closed-cycle cooling system with cooling towers. The NRC staff assumed that surface water would be used for cooling makeup water and discharge. Intake and discharge would involve relatively small NUREG-1437, Supplement 33 8-48 August 2008

Alternatives quantities of water compared to once-through cooling. The impact on the surface water would depend on the volume of water needed for makeup water, the discharge volume, and the characteristics of the receiving body of water. Intake from and discharge to any surface body of water would be regulated by the NCDENR. The impacts would be SMALL to MODERATE.

Groundwater. HNP currently uses no groundwater. It is likely that a gas-fired alternative would also not use groundwater. Impacts at the HNP site would thus be SMALL.

Groundwater impacts at an alternate site may vary widely depending on whether the plant uses groundwater for any of its water needs, though it would be unlikely that a plant on an alternate site would use groundwater for cooling system makeup water. Impacts at an alternate site would be SMALL to MODERATE.

• Air Quality Natural gas is a relatively clean-burning fuel. The gas-fired alternative would release similar types of emissions, but in lesser quantities, than the coal-fired alternative.

Currently, Wake County and the neighboring counties of Johnston, Chatham, Durham, Franklin and Nash are non-attainment areas for ozone under the Clean Air Act (EPA 2007b). These counties are either in attainment or unclassified for other criteria pollutants (EPA 2007b). A new gas-fired plant located in an ozone non-attainment area would need to purchase emissions credits from existing emitters of ozone-causing chemicals, including NOx.

A gas-fired alternative at the HNP site or another non-attainment area site would require Non-Attainment Area permit and a Title V operating permit under the Clean Air Act. A new combined-cycle natural gas power plant would also be subject to the new source performance standards for such units at 40 CFR 60, Subparts Da and GG. These regulations establish emission limits for particulates, opacity, SO2, and NOx.

EPA has various regulatory requirements for visibility protection in 40 CFR 51, Subpart P, including a specific requirement for review of any new major stationary source in an area designated attainment or unclassified under the Clean Air Act.

Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing future and remedying existing impairment of visibility in mandatory Class I Federal areas when impairment results from man-made air pollution. EPA issued a new regional haze rule in 1999 (64 FR 35714) (EPA 1999). The rule specifies that for each mandatory Class I Federal area located within a State, the State must establish goals that provide for reasonable progress towards achieving natural visibility conditions. The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and ensure no degradation in visibility for the least-August 2008 8-49 NUREG-1437, Supplement 33

Alternatives impaired days over the same period (40 CFR 51.308(d)(1)). If a natural gas-fired plant were located close to a mandatory Class I area, additional air pollution control requirements would be imposed. North Carolina contains five Class I areas, one of which, Swanquarter Wilderness Area, is potentially downwind of a coal-fired alternative at HNP (EPA 2007a).

Swanquarter is approximately 298 km (185 mi) east of the HNP site. A gas-fired alternative at HNP may need additional pollution controls to keep from impairing visibility in this area.

Additionally, a gas-fired plant at an alternate site nearer to a Class I area may require even more stringent controls.

NRC staff projects the following emissions for a gas-fired alternative based on EPA emissions factors (EPA 2000a):

o Sulfur oxides - 62.3 tons/yr o Nitrogen oxides - 200 tons/yr o Carbon monoxide - 41.5 tons/yr o PM10 particulates - 34.8 tons/yr The total amount of nitrogen oxides which can be emitted by North Carolina in the 2007 ozone season (May 1-September 30) is set out at 40 CFR 51.121(e). For North Carolina, the amount is 150,000 MT (165,306 tons). A new gas-fired power plant would need to buy credits if it was likely to cause North Carolina to exceed this amount.

A natural gas-fired plant would also have unregulated carbon dioxide emissions. An IGCC plant would emit approximately 2,330,000 tons of CO2 per year (2,110,000 MT) (DOE/EIA 2007a).

In December 2000, EPA issued regulatory findings on emissions of hazardous air pollutants from electric utility steam-generating units (EPA 2000b). Natural gas-fired power plants were found by EPA to emit arsenic, formaldehyde, and nickel (EPA 2000b). Unlike coal and oil-fired plants, EPA did not determine that emissions of hazardous air pollutants from natural gas-fired power plants should be regulated under Section 112 of the Clean Air Act.

Construction activities would also result in some air effects, including those from temporary fugitive dust, though construction crews would employ dust-control practices to limit this impact. Exhaust emissions would also come from vehicles and motorized equipment used during the construction process, though these emissions are likely to be intermittent in nature and will occur over a limited period of time. As such, construction stage impacts would be SMALL.

The overall air-quality impact for a new natural gas-fired plant sited at HNP or at an alternate site would be SMALL to MODERATE, depending on control technology employed during the operating stage.

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Alternatives

• Waste Burning natural gas fuel generates small amounts of waste, though a plant using selective catalytic reduction (SCR) to control NOx will generate spent SCR catalyst from NOx emissions control and small amounts of solid-waste products (i.e., ash). In the GEIS, the NRC staff concluded that waste generation from gas-fired technology would be minimal (NRC 1996). Waste-generation impacts would be so minor that they would not noticeably alter any important resource attribute.

Constructing a gas-fired alternative would generate small amounts of waste, though many construction wastes can be recycled, and land-clearing debris would be disposed of onsite.

Overall, the waste impacts would be SMALL for a natural gas-fired plant sited at HNP or at an alternate site.

• Human Health In Table 8-2 of the GEIS, the NRC staff identifies cancer and emphysema as potential health risks from gas-fired plants (NRC 1996). The risk may be attributable to NOx emissions that contribute to ozone formation, which in turn contribute to health risks. NOx emissions from any gas-fired plant would be regulated as mentioned in the Air Quality section. Human health effects would not be detectable or would be sufficiently minor that they would neither destabilize nor noticeably alter any important attribute of the resource.

Overall, the impacts on human health of the natural gas-fired alternative sited at HNP or at an alternate site would be considered SMALL.

• Socioeconomics Construction of a natural gas-fired plant would take approximately 3 years (DOE/EIA 2006b). Peak employment would be approximately 1090 workers (NRC 1996). NRC staff assumed that construction would take place while HNP continues operation and would be completed by the time it permanently ceases operations. During construction, the communities surrounding the HNP site would experience an increased demand for rental housing and public services that would have SMALL impacts given the areas population.

These impacts could be reduced by construction workers commuting to the site from other parts of the Raleigh-Durham-Chapel Hill area. The natural gas-fired plant would provide a new tax base to offset the loss of tax base associated with decommissioning of the HNP unit in Wake County. Other counties would likely experience little impact, as HNP pays 90% of its local taxes to Wake County. Since the regions growing economy effectively mitigates most socioeconomic impacts of both construction and operation, the appropriate characterization of non-transportation socioeconomic impacts for a natural gas-fired plant August 2008 8-51 NUREG-1437, Supplement 33

Alternatives constructed at the HNP site would be SMALL to MODERATE. For siting at an alternate site, impacts in Wake County would be SMALL from loss of tax base.

Compared to the coal-fired and nuclear alternatives, the smaller size of the construction work force, the shorter construction time frame, and the smaller size of the operations work force would mitigate socioeconomic impacts. In addition, the communities around HNP would experience relatively minor impacts of HNP operational job loss and loss of tax revenue. For these reasons, socioeconomic impacts associated with construction and operation of a natural gas-fired power plant would be SMALL for siting at HNP, and SMALL to MODERATE at an alternate site.

• Transportation Transportation impacts associated with construction and operating personnel commuting to the plant site would depend on the population density and transportation infrastructure in the vicinity of the site. The impacts would be SMALL to MODERATE for siting at either HNP or an alternate site.

• Aesthetics At the HNP site, the two turbine buildings (100 ft tall) and four exhaust stacks (approximately 150 ft tall) would not be visible during daylight hours from offsite due to extensive site forestation. The gas pipeline compressors may be visible if they are located near roads, though they are relatively small. Noise and light from the plant may be detectable offsite, but would also be screened by the sites trees. The visual impact, then from a new combined-cycle plant on the current HNP site, would be SMALL.

At an alternate site, the buildings, cooling towers, cooling tower plumes, and the associated transmission line and gas pipeline compressors may be visible offsite. Visual impacts from new transmission lines or a pipeline right-of-way would also be significant, though these may be minimized by building near transmission or on previously-developed land.

Additionally, aesthetic impacts would be mitigated if the plant were located in an industrial area adjacent to other power plants. Unlike the coal-fired alternatives, the gas-fired plant lacks a coal pile, rail spur, and frequent coal deliveries. Overall, the aesthetic impacts associated with an alternate site would be SMALL to MODERATE.

• Historic and Archaeological Resources At HNP, a cultural resource inventory would likely be needed for any onsite property that has not been previously surveyed. Other lands, if any, that are acquired to support the plant would also need an inventory of cultural resources, identification and recording of existing NUREG-1437, Supplement 33 8-52 August 2008

Alternatives historic and archaeological resources, and possible mitigation of adverse effects from subsequent ground-disturbing actions related to physical expansion of the plant site. Since the gas-fired alternative uses little land, and most of it would have been previously disturbed, the impact of the gas-fired alternative at the HNP site would be SMALL.

Before construction at an alternate site, studies would likely be needed to identify, evaluate, and address mitigation of the potential impacts of new plant construction on cultural resources. The studies would be needed for all areas of potential disturbance at the proposed plant site and along associated corridors where new construction would occur (e.g., roads, transmission and pipeline corridors, or other rights-of-way). Building on a previously developed site would minimize the likelihood of affecting historical or archaeological resources, as previous development either removed these resources or previous studies identified their locations. At an alternate, undeveloped site, the impact would be SMALL to MODERATE.

• Environmental Justice No environmental impacts were identified that would result in disproportionately high and adverse environmental impacts on minority and low-income populations if a replacement natural gas-fired plant were built at the HNP site. Some impacts on housing availability and lease prices during construction might occur, and this could affect minority and low-income populations.

Impacts on minority and low-income populations due to the shutdown of HNP would depend on the number of jobs and the amount of tax revenue lost to the communities surrounding the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it is likely that these losses would be replaced by the development of new businesses and new sources of tax revenue in the region. Since CP&Ls tax payments represent a small percentage of Wake Countys total annual property tax revenue, it is unlikely that social services would be seriously affected. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse socioeconomic impacts from the shutdown of HNP.

The environmental effect of plan shutdown would reduce the amount of operational impacts on the environment. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse environmental impacts from the shutdown of HNP.

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Alternatives Impacts at an alternate site would depend upon the site chosen, nearby population characteristics, and economic opportunity. These impacts would range from SMALL to MODERATE, depending on the distribution of low-income and minority population.

8.2.4 New Nuclear Generation Since 1997 the NRC has certified four new standard designs for nuclear power plants under 10 CFR 52, Subpart B. These designs are the 1300 MWe U.S. Advanced Boiling Water Reactor (10 CFR 52, Appendix A), the 1300 MWe System 80+ Design (10 CFR 52, Appendix B), the 600 MWe AP600 Design (10 CFR 52, Appendix C), and the 1100 MWe AP1000 Design (10 CFR 52, Appendix C). One additional design is awaiting certification, and five others are undergoing pre-application reviews. All of the designs currently certified or awaiting certification are light-water reactors. Several designs in pre-application review are not light water reactors; these include the helium-cooled Pebble Bed Modular Reactor and the heavy water moderated and cooled Advanced Candu Reactor, ACR-700. Although NRC has received no applications for a construction permit or a combined license based on certified designs, NRC has received several early site permit (ESP) applications, and has approved the first ESPs at the Clinton site near Clinton, Illinois (ESP issued on March 15, 2007), and the Grand Gulf site, in Claiborne County, Mississippi (ESP issued on March 27, 2007). These ESP applications and design certification applications indicate continuing interest in the possibility of licensing new nuclear power plants. In addition, recent escalation in natural gas and electricity prices have made new nuclear power plant construction more attractive from a cost standpoint, though academic and investment communities remain uncertain as to what new nuclear plants will actually cost. Given current uncertainty and expressed industry interest in new nuclear construction, NRC staff will evaluate the new nuclear generation option in depth for both the HNP site and an alternate site. CP&L did not consider a new nuclear reactor at an alternate site in the HNP ER.

The NRC staff assumed that the new nuclear plant would have a 40-year lifetime. This allows for comparisons between a new nuclear plant and other alternatives, and also coincides with the initial licensing period for a new nuclear plant.

NRC has summarized environmental data associated with the uranium fuel cycle in Table S-3 of 10 CFR 51.51. The impacts shown in Table S-3 are representative of the impacts that would be associated with a replacement nuclear power plant built to one of the certified designs, sited at HNP or an alternate site. The impacts shown in Table S-3 are for a 1000-MWe reactor and NUREG-1437, Supplement 33 8-54 August 2008

Alternatives would need to be adjusted to reflect impacts of 900 MW of new nuclear power.(7) The environmental impacts associated with transporting fuel and waste to and from a light-water cooled nuclear power reactor are summarized in Table S-4 of 10 CFR 51.52. NRC staff summarize findings on National Environmental Policy Act (NEPA) issues for license renewal of nuclear power plants in Table B-1 of 10 CFR 51 Subpart A, Appendix B.

NRC staff notes that this analysis addresses the potential impacts of a reactor constructed at the current HNP site for the purposes of replacing the existing HNP unit. This analysis is not meant to be indicative of the impacts one would expect from the two units that CP&L has indicated they may possibly construct at the HNP site should they file a combined construction and operating license (COL) application and receive approval from NRC. NRC staff would initiate a separate, detailed environmental impact statement to address the design-specific and site-specific impacts from those units if and when CP&L submits a COL.

NRC staff discusses the overall impacts of a new nuclear generating alternative in the following sections, and summarizes impacts in Table 8-5. The extent of impacts at an alternate site would depend on the location of the particular site selected.

• Land Use The existing facilities and infrastructure at the HNP site would be used to the extent practicable, limiting the amount of new construction that would be required. Specifically, the NRC staff assumed that a replacement nuclear power plant would use the existing cooling tower system, switchyard, offices, and transmission line rights-of-way. Much of the land that would be used has been previously disturbed.

A replacement nuclear power plant at the HNP site would alter approximately 200 to 400 ha (500 to 1000 ac) of land to plant use (NRC 1996). Some of this land may already have been converted into parking lots or other auxiliary structures and can be modified to support the new plant. There would be little net change in land needed for uranium mining because land needed for the new nuclear plant would offset land needed to supply uranium for fuel HNP, though the GEIS indicates that new reactor designs may require more uranium than existing plants.

The impact of a replacement nuclear generating plant on land use at the existing HNP site would be best characterized as MODERATE. This impact would be greater than the (7) NRC staff notes that while Table S-3 does not estimate impacts from unregulated CO2 emissions during the nuclear fuel cycle, Table S-3 does indicate that energy consumed during the cycle is roughly equal to that generated by a 45 MWe conventional coal-fired plant, and thus provides a means of approximating unregulated CO2 emissions.

August 2008 8-55 NUREG-1437, Supplement 33

Alternatives operating license renewal alternative, as well as greater than the gas-fired alternative and likely similar to that of the coal-fired alternatives.

Land-use impacts at an alternate site would be similar to siting at HNP except for the land needed for transmission lines necessary to connect to existing lines, and a rail spur to allow deliver of major components and fuel. Depending on the site, anywhere from tens to thousands of acres may be necessary. The need to construct transmission and rail capacity would likely be reduced at a previously developed industrial site, though it would not necessarily be eliminated. Depending particularly on transmission line routing and rail spur siting, siting a new nuclear plant at an alternate site would result in MODERATE to LARGE land-use impacts.

• Ecology Locating a new nuclear unit at the HNP site would affect ecological resources, but existing site maintenance practices and the sites industrial nature would minimize additional impacts from the new plant on terrestrial ecology.

Siting at HNP would have a SMALL to MODERATE ecological impact that would be greater than renewal of the HNP operating license. Impacts become greater if more undeveloped land is converted to industrial uses.

At an alternate site, there would be construction impacts and new incremental operational impacts. Even assuming siting at a previously disturbed area, the impacts may include wildlife habitat loss, reduced productivity, habitat fragmentation, and a local reduction in biological diversity, depending on the degree to which the site was previously disturbed and how much remediation has taken place. A new nuclear plant at an alternate site would likely also make use of cooling towers, and would incur similar aquatic impacts to the existing HNP unit. At a new site, these impacts would likely be MODERATE, due primarily to terrestrial impacts, but also depending on the characteristics of the water body used for cooling.

Table 8-5. Summary of Environmental Impacts of New Nuclear Power Generation at the HNP Site and an Alternate Site Using Closed-Cycle Cooling Impact HNP Site Alternate Site Category Impact Comments Impact Comments Land Use MODERATE Requires approximately 200 to MODERATE Same as HNP site plus 400 ha (500 to 1000 ac) for the to LARGE land for transmission line plant. Fuel cycle effects are and rail spur.

similar to the current plant.

Ecology SMALL to Uses undeveloped areas at MODERATE Impact depends on location current HNP site and may use and ecology of the site, NUREG-1437, Supplement 33 8-56 August 2008

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments MODERATE offsite Progress Energy-owned surface water body used areas. Aquatic ecology impacts for intake and discharge, would be similar to existing and transmission line route; plant. potential habitat loss and fragmentation; reduced productivity and biological diversity.

Water Use and SMALL Uses existing cooling tower SMALL to Impact would depend on QualitySurface system. MODERATE the volume of water water withdrawn and discharged and the characteristics of the surface water body.

Water Use and SMALL Would likely use Harris SMALL to Impact would depend on Quality Reservoir for all onsite water. MODERATE the volume of water Groundwater A new nuclear plant would also withdrawn, as well as use the existing cooling system. characteristics of the aquifer. Groundwater would not be used for cooling system makeup water.

Air Quality SMALL Fugitive emissions and SMALL Same impacts as HNP site.

emissions from vehicles and equipment during construction; small amount of emissions from diesel generators and possibly other sources during operation.

Waste SMALL Waste impacts for an operating SMALL Same impacts as HNP site.

nuclear power plant are set out in 10 CFR 51, Appendix B, Table B-1. Debris would be generated and removed during construction.

Human Health SMALL Human health impacts for an SMALL Same impacts as HNP site.

operating nuclear power plant are set out in 10 CFR 51, Appendix B, Table B-1.

August 2008 8-57 NUREG-1437, Supplement 33

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments Socioeconomics SMALL to During construction, impacts SMALL to Construction impacts MODERATE would be MODERATE, with up LARGE depend on location.

to 2250 workers during peak Impacts at a rural location period of the 6-year construc- would be LARGE. Wake tion period. The operating work County would experience a force assumed to be similar to loss of tax revenue while HNP; tax base preserved in surrounding counties would Wake County, but may change lose employment, though in surrounding counties if rapid growth in the region workers dont transfer from one would offset these impacts.

plant to another. Impacts Impacts during operation during operation would be would be SMALL to SMALL. MODERATE.

Socioeconomics MODERATE Transportation impacts would SMALL to Transportation impacts (Transportation) be MODERATE, due primarily LARGE would be MODERATE to to construction activities. LARGE, primarily with Transportation impacts of construction activities.

commuting plant personnel Transportation impacts of would be SMALL even if their commuting plant personnel commuting patterns differ from would be SMALL to current plant employees. MODERATE.

Aesthetics SMALL No new exhaust stacks or MODERATE Greatest impact is likely cooling towers would be to LARGE from new cooling towers.

needed. New containment and Also, transmission lines or turbine buildings would be a rail spur would also have visible in the immediate vicinity significant impacts.

of the plant. Visual impact at Impacts from containment night would be mitigated by and other buildings would reduced use of lighting and also be noticeable.

appropriate shielding. Noise impacts would be relatively small and would be mitigated.

Historic and SMALL Any potential impacts can likely SMALL to Any potential impacts can Archeological be effectively managed. Any MODERATE likely be effectively Resources offsite land acquired would managed. Land would need to be surveyed. need to be surveyed.

Impact likely smaller at previously developed site.

Environmental SMALL Impacts on minority and low- SMALL to Impacts would vary Justice income communities would be MODERATE depending on population similar to those experienced by distribution and location of the population as a whole. the site. Impacts to Some impacts on rental minority and low-income NUREG-1437, Supplement 33 8-58 August 2008

Alternatives Impact HNP Site Alternate Site Category Impact Comments Impact Comments housing may occur during populations from the construction, though most closure of HNP would likely personnel are expected to to be offset by the areas travel from nearby urban areas. economic growth.

• Water Use and Quality Surface Water. The replacement nuclear plant alternative at the HNP site is assumed to use the existing closed-cycle cooling tower system, which would minimize incremental water-use and quality impacts. Harris Reservoir would likely remain the source of other water required by the plant. Surface-water impacts are expected to remain SMALL.

Cooling towers would likely be used at alternate sites. For alternate sites, the impact on the surface water would depend on the volume of water needed for makeup water, the discharge volume, and the characteristics of the water body. Intake from and discharge to any surface body of water would be regulated by the DENR. The impacts would be SMALL to MODERATE.

Groundwater. The NRC staff assumed that a new nuclear power plant located at HNP would continue to obtain all water from Harris Reservoir.

Use of groundwater for a nuclear power plant located at an alternate site is a possibility.

Any groundwater withdrawal would require a permit from the local permitting authority. A new plant is unlikely to use groundwater for cooling makeup water, however, given the volume of water necessary.

Overall, groundwater impacts at the current site would be SMALL, and at an alternate site would be SMALL to MODERATE.

• Air Quality Construction of a new nuclear plant sited at HNP or an alternate site would result in fugitive dust emissions during the construction process. These impacts are intermittent and short-lived. To minimize dust generation, construction crews would use applicable dust-control measures. Exhaust emissions would also come from vehicles and motorized equipment used during the construction process, but these would also be of limited duration. An operating nuclear plant would have minor air emissions associated with diesel generators and other small-scale intermittent sources. Overall, air emissions and associated impacts would be SMALL.

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Alternatives

• Waste The waste impacts associated with operation of a nuclear power plant are set out in Table B-1 of 10 CFR 51, Subpart A, Appendix B. Construction-related debris would be generated during construction activities and removed to an appropriate disposal site.

Overall, waste impacts would be SMALL.

Siting the replacement nuclear power plant at a site other than HNP would not alter waste generation. Therefore, the impacts would be SMALL.

• Human Health Human health impacts for an operating nuclear power plant are set out in 10 CFR Part 51 Subpart A, Appendix B, Table B-1. Overall, human health impacts would be SMALL.

Siting the replacement nuclear power plant at a site other than HNP would not alter human health impacts. Therefore, the impacts would also be SMALL.

• Socioeconomics The construction period and the peak work force associated with construction of a new nuclear power plant are currently unquantified (NRC 1996). In the absence of quantitative data, NRC staff assumed a construction period of 6 years (based on DOE/EIA 2006b) and a peak work force of 2250 (based on peak workforce for a 1000 MWe coal-fired plant and extrapolated to the current plant size). The NRC staff assumed that construction would take place while the existing nuclear unit continues operation and would be completed by the time HNP permanently ceases operations. During construction, the communities surrounding the HNP site would experience an increase demand for rental housing and public services that would have SMALL to MODERATE impacts. These impacts could be reduced by construction workers commuting to the site from other parts of the Raleigh-Durham-Chapel Hill area or from other counties. After construction, the communities would be impacted by the loss of the construction jobs. An alternative site would experience SMALL to LARGE impacts, depending on characteristics of the surrounding community and local economy.

The replacement nuclear unit is assumed to have an operating work force comparable to the 720 workers currently working at HNPS. The replacement nuclear unit would provide new tax revenue to offset the loss of revenue associated with the decommissioning of HNP.

New employment, as well as the areas economic growth, would also likely offset loss of HNP jobs. For all of these reasons, the appropriate characterization of non-transportation socioeconomic impacts for a replacement nuclear unit constructed at HNP would be NUREG-1437, Supplement 33 8-60 August 2008

Alternatives SMALL; the socioeconomic impacts would be noticeable, but would be unlikely to destabilize the area.

Construction of a replacement nuclear power plant at an alternate site would relocate some socioeconomic impacts, but would not eliminate them. The communities around the HNP site would still experience the impact of operational job loss, though this would be offset by economic growth. The communities around the new site would have to absorb the impacts of a large, temporary work force (up to 2250 workers at the peak of construction) and a permanent work force of approximately 720 workers. In the GEIS (NRC 1996), the NRC staff indicated that socioeconomic impacts at a rural site would be larger than at an urban site because more of the peak construction work force would need to move to the area to work. The HNP site is within commuting distance of the Raleigh-Durham-Chapel Hill urban area and is therefore not considered a rural site. Alternate sites would need to be analyzed on a case-by-case basis. Non-transportation socioeconomic impacts at a rural site would be LARGE.

• Transportation During the 6-year construction period, up to 2250 construction workers would commute to the HNP site in addition to the 720 workers at HNP. The addition of the construction workers, equipment, and material would increase traffic loads on existing roads around the plant. Such impacts would be MODERATE. Transportation impacts related to commuting of plant operating personnel would be similar to current impacts associated with operation of HNP and would be SMALL.

Transportation-related impacts associated with commuting construction workers at an alternate site are site dependent, but would be MODERATE to LARGE. These may be mitigated somewhat if built on a previously developed site nearer to population.

Transportation impacts related to commuting of plant operating personnel at an alternate site would also be site dependent, but would be characterized as SMALL to MODERATE.

• Aesthetics The containment building for a replacement nuclear power plant sited at HNP, existing cooling tower, and as other associated buildings would be visible in daylight hours over many miles, though extensive forestation on site may help screen these structures. The replacement nuclear unit may be visible at night because of outside lighting. Visual impacts could be mitigated by landscaping and selecting a color for buildings that is consistent with the environment. Visual impact at night could be mitigated by reduced use of lighting and appropriate use of shielding. No exhaust stacks would be needed. Visual impacts would likely be SMALL.

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Alternatives Noise impacts from a new nuclear plant would be similar to those from the existing HNP unit. Given the land area available around the plant, and potential noise mitigation measures, such as reduced use of outside loudspeakers, the impact of noise would be SMALL.

At an alternate site, there would be an aesthetic impact from the buildings, cooling towers, and the plume associated with the cooling tower. There would also be a significant aesthetic impact associated with construction of a new transmission line to connect to other lines to enable delivery of electricity to Progress Energys transmission system. Noise and light from the plant would be detectable offsite. The impact of noise and light would be mitigated if the plant is located in an industrial area adjacent to other power plants or industrial land uses. Overall the aesthetic impacts associated with locating at an alternative site would be categorized as MODERATE to LARGE, depending on the sites characteristics. The greatest contributor to this categorization would be the aesthetic impact of the cooling towers and transmission lines.

• Historic and Archaeological Resources At the HNP site, a cultural resource inventory would likely be needed for any onsite property that has not been previously surveyed. Other lands, if any, that are acquired to support the plant would also need an inventory of field cultural resources, identification and recording of existing historic and archaeological resources, and possible mitigation of adverse effects from subsequent ground-disturbing actions related to physical expansion of the plant site.

Before beginning construction at an alternate site, studies would be needed to identify, evaluate, and address mitigation of the potential impacts of new plant construction on cultural resources over the 200 to 400 ha (500 to 1000 ac) necessary for plant construction.

The studies would be needed for all areas of potential disturbance at the proposed plant site and along associated corridors where new construction would occur (e.g., roads, transmission corridors, rail lines, or other rights-of-way). Historic and archaeological resource impacts can generally be effectively managed and as such would be. Effects at an undeveloped site would be SMALL to MODERATE.

• Environmental Justice No environmental impacts were identified that would result in disproportionately high and adverse environmental impacts on minority and low-income populations if a replacement nuclear plant were built at the HNP site. Some impacts on housing availability and lease prices during construction might occur, and this could disproportionately affect the minority and low-income populations.

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Alternatives Impacts on minority and low-income populations due to the shutdown of HNP would depend on the number of jobs and the amount of tax revenue lost to the communities surrounding the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it is likely that these losses would be replaced by the development of new businesses and new sources of tax revenue in the region. Since CP&Ls tax payments represent a small percentage of Wake Countys total annual property tax revenue, it is unlikely that social services would be seriously affected. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse socioeconomic impacts from the shutdown of HNP.

The environmental effect of plant shutdown would reduce the amount of operational impacts on the environment. Therefore, minority and low-income populations in the vicinity of HNP would not likely experience any disproportionately high and adverse environmental impacts from the shutdown of HNP.

Impacts at other sites would depend upon the site chosen and the nearby population distribution, but would be SMALL to MODERATE.

8.2.5 Utility-sponsored Conservation In the following section, NRC staff will evaluate the environmental impacts of a conservation(8) alternative to license renewal. Though CP&L currently employs a variety of conservation, energy efficiency, and other demand-side management measures, the NRC staff finds it reasonable to consider a conservation-based alternative to HNP license renewal based on several recent developments. First, in May 2007, CP&L announced plans to institute utility-based energy efficiency programs aimed at eliminating the need for 2000 MW of electrical generating capacity in the North and South Carolina service territories (Murawski 2007, Beattie 2007). Second, earlier in the same month, North Carolinas largest utility, Duke Energy Carolinas, indicated that an energy efficiency program would allow it to retire 800 MW of coal capacity, and would allow it to offset up to 1700 MW of capacity over four years (Fordney 2007).

Duke also indicated that the cost of the program would be less than the cost of constructing new generation capacity. Third, the North Carolina Utilities Commission released a report in December 2006 indicating that North Carolina has a statewide potential to reduce projected energy consumption by 32.7% of total projected utility sales per year by 2017. The report deemed approximately 25,132 gigawatt-hours (GWh) of this savings (13.9% of statewide (8) NRC staff notes that conservation typically refers to all programs that reduce energy consumption, while energy efficiency refers to programs that reduce consumption without reducing services. For this section, NRC staff will use the terms interchangeably.

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Alternatives electricity sales) to be cost-effectively achievable(9) (GDS Associates 2006). Though much of this savings potential likely exists during peak demand times, the magnitude of potential savings significantly exceeds HNPs capacity, and several major efficiency measures identified in the GDS Associates report would affect baseload generation needs. These announcements all indicate robust opportunities for energy efficiency or conservation in North Carolina, as well as costs consistent with other alternatives. As such, NRC staff will evaluate utility-sponsored conservation as a feasible and commercially-available alternative to HNP license renewal.

Given the terminology used in the GDS Associates report, in announcements from CP&L, and in the GEIS, NRC staff will use conservation and energy efficiency interchangeably.

The GEIS notes that a conservation alternative would have mostly SMALL or negligible environmental impacts. NRC staff, in the GEIS, established that resource extraction and material disposal would be the most visible lifecycle impacts, and that some conservation measures may also affect indoor air quality. The GEIS noted, however, that studies had not identified direct impacts from conservation measures to indoor air quality, and that pre-existing contamination is a major determinant in determining post-weatherization pollution levels. The GEIS also noted that production of conservation measures would not require large amounts of materials, and those it does require are common to many manufacturing processes. In addition, the GEIS established that disposal involves normal procedures with sufficiently effective disposal methods and small enough amounts of hazardous compounds that no adverse health effects would result (NRC 1996).

According to the GDS Associates in their A Study of the Feasibility of Energy Efficiency as an Eligible Resource as Part of a Renewable Portfolio Standard for the State of North Carolina, conducted for the North Carolina Utilities Commission, energy efficiency potential varies across residential, commercial, and industrial building sectors (GDS Associates 2006). In each sector, GDS provided technical potential (an indication of complete and total implementation of all possible efficiency measures); achievable potential (an implementation level achieved by an aggressively funded and sustained campaign); and achievable cost-effective potential (an implementation level achieved by targeting aggressive and sustained implementation campaigns toward efficiency measures with a lifetime cost of $.05 per kWh or less).

In the residential sector, GDS Associates determined that most achievable cost-effective potential energy savings result from a combination of building insulation and weatherization, Energy Star windows, Energy Star programmable thermostats, and compact fluorescent light installation. Other energy reductions come from low-flow shower heads, water heater blankets, and insulation and weatherization programs targeted toward low-income populations. In the commercial sector, improved HVAC controls and motors, higher efficiency lighting and lighting controls, improved refrigeration, better compressed air systems, and upgraded transformers (9) GDS Associates determined $.05 per lifetime kWh produced to be the cost-effectiveness threshold.

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Alternatives reduce energy consumption. In the industrial sector, improved lighting, motors, pumps, lubricants, controls, and system designs, as well as system optimization and upgraded transformers contribute to increased efficiency (GDS Associates 2006).

GDS Associates analysis assumed that program administrators would have ten years to implement the programs, reaching full effect by 2017. NRC staff notes that HNPs operating license expires in 2026, and thus would allow for sufficient time to develop a suitable energy efficiency program.

NRC staff discusses the overall impacts of a new nuclear generating alternative in the following sections, and summarizes impacts in Table 8-6.

• Land Use Since CP&L would continue to use the existing transmission lines, and would continue to maintain Harris Reservoir, land use impacts of an energy efficiency alternative would be SMALL. It would be possible that equipment replacements would increase waste generation and increased resulting landfill disposal, but given a ten-year timeline for program development and implementation, it would be likely that some proportion of replacements would occur at the end of the existing equipments life (especially in the case of frequently replaced items, like lightbulbs). Many replaced items (like home appliances or industrial equipment) have substantial recycling value and would likely not be landfilled.

• Ecology Ecological impacts would be SMALL, but positive, as withdrawals from and discharges to Harris Reservoir would cease. As no power generation alternative would take the plants place, water levels in Harris Reservoir may rise and contribute additional water to Buckhorn Creek, which currently is nearly dry for part of the year, and to the Cape Fear River downstream of Harris Reservoir. These impacts would be SMALL, however. Also, there would be SMALL, but positive effects if plant staff stops controlling vegetation at the plant site. If CP&L allowed boat access to the auxiliary reservoir after plant shutdown, aquatic ecology may be affected by potential introduction of invasive species and increased boat traffic as well as fishing access, though this effect would be SMALL, as well.

Table 8-6. Summary of Environmental Impacts of a Conservation Alternative Impact Category Impact Comments Land Use SMALL Existing reservoir, transmission lines remain in use; possible minor, speculative effects on landfill area.

Ecology SMALL Withdrawal from and discharge to reservoir ceases; some land may August 2008 8-65 NUREG-1437, Supplement 33

Alternatives Impact Category Impact Comments revert to other habitats; fishing may increase in former auxiliary reservoir and invasive species may be introduced, though this would have SMALL effects.

Water Use and SMALL Water withdrawal and discharge would cease; additional water may QualitySurface flow into Buckhorn Creek downstream of Harris Reservoir, perhaps Water reducing stream intermittency.

Water Use and SMALL Plant currently uses no groundwater; increased flow may affect Quality groundwater around Buckhorn Creek, but aquifers are not currently Groundwater used for water supply.

Air Quality SMALL Commuter vehicle emissions and diesel emissions would decrease, positively affecting air quality. This effect would be SMALL.

Waste SMALL Waste volumes generated by conservation programs would be mitigated by lengthening the program implementation timeline and through recycling. In addition, significance of other waste streams would likely swamp waste generated by an energy efficiency program.

Human Health SMALL Changes may occur to indoor air quality, but these are not well-established, and usually stem from pre-existing air quality issues.

Socioeconomics SMALL Loss of jobs offset by economic growth in area; speculative potential for additional contractor employment across North Carolina.

Socioeconomics SMALL Commuter traffic to the plant would decrease; additional traffic (Transportation) associated with efficiency programs would be widely distributed and would likely not be noticeable.

Aesthetics SMALL The existing plant would be decommissioned and an alternative structure would replace it; no noticeable impacts from energy efficiency improvements.

Historic and SMALL No known effects.

Archeological Resources Environmental SMALL Depending on program design and enrollment, minority and low-Justice income populations could benefit from energy efficiency programs.

• Water Use and Quality Impacts to water use and quality from an energy efficiency program would be SMALL but positive, as withdrawals from Harris Reservoir would cease. Additional water may be available downstream from HNP in both Buckhorn Creek and the Cape Fear River as the plant would no longer evaporate water for cooling. As the plant uses no groundwater, a conservation alternative would not directly affect groundwater, though increased flow to Buckhorn Creek may affect groundwater in the immediate vicinity. As no one uses this groundwater, the effect would not be noticeable.

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Alternatives

• Air Quality Air quality impacts from a utility-sponsored energy efficiency program would be SMALL and positive. Emissions from commuter vehicles and diesel generators would decrease. The GEIS noted that indoor air quality may suffer from weatherization programs that fail to balance air quality concerns. The GEIS also noted that indoor air quality after weatherization is most strongly affected by pre-existing air quality issues.

• Waste Waste impacts from energy efficiency programs would likely be SMALL, but somewhat dependent on the nature of the program. Improvements to heating and cooling systems would generate construction wastes, while appliance replacements may also generate wastes. Some of these replacements may occur in the course of normal retirement over the 10-year implementation period and thus constitute no change to normal waste streams.

This would be particularly the case for frequently replaced items like light bulbs.

While projections of waste amounts from a conservation program are speculative, statewide equipment replacements and upgrades spread over 10 or more years, many of which would generate several pounds of waste per resident (e.g., lightbulbs, new shower heads, new thermostats), along with some which would generate hundreds to thousands of pounds of waste spread over many residents (replacing commercial ventilation systems or industrial motors), would keep impacts SMALL when compared to the 1.23 MT (1.36 tons) of waste disposed per resident in fiscal year 2005-2006 (NCDENR/DWM 2006). Furthermore, many replacements or upgrades generate waste materials with substantial recycling value (such as metal scrap from appliances, ductwork, and motors) and would thus not increase the burden on landfills. Some wastes, like fluorescent light bulbs, would need to be recycled as they contain hazardous compounds, though they generally operate much longer than their incandescent counterparts. The GEIS noted that amounts of hazardous compounds are small, and disposal methods are effective. Also, facilities to recycle these items currently exist in North Carolina. Waste impacts from the conservation alternative, then, would be SMALL.

• Human Health An energy efficiency program is unlikely to have a significant effect on human health.

Changes to most building appliances would not affect health, though upgrades to HVAC systems, insulation, and weatherization (including windows) may affect indoor air quality.

The GEIS noted that this issue has not been sufficiently studied, but that mitigation measures would be available to correct problems. The GEIS also noted that hazardous chemicals in the waste stream would not affect human health. As such, NRC staff determines that these effects would be SMALL.

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Alternatives

• Socioeconomics Socioeconomic effects of an energy efficiency program would be SMALL. As in the no-action alternative, loss of jobs at HNP would be offset by economic growth in the area.

Additionally, a conservation program would likely employ additional workers, as noted in the GEIS. Low-income populations could benefit from weatherization and insulation programs.

This effect would be greater than the effect for the general population because low-income households experience home energy burdens more than four times larger than the average household (OMB 2007).

• Transportation Transportation impacts would also be SMALL as fewer employees commute to the plant site. Any transportation effects from the energy efficiency alternative would be widely distributed across the state, and would not be noticeable.

• Aesthetics Impacts from energy efficiency programs would be positive, though small, as the plant is decommissioned and no alternative would replace it. The transmission lines and Harris Reservoir would remain after plant decommissioning. Traffic to the plant would decrease, however, as would the attendant noise and emissions. Noise impacts would occur in instances of upgrades to major building systems, though this impact would be highly intermittent and short-lived.

• Historic and Archaeological Resources Impacts to archaeological resources from energy efficiency programs would be SMALL, if any, as a conservation alternative would not affect land use or the historical or cultural resources contained onsite or elsewhere in the state.

• Environmental Justice GDS Associates identified weatherization programs targeting low-income residents as a cost-effective energy efficiency option (GDS 2006). Since low-income populations tend to spend a larger proportion of their incomes paying utility bills (according to the Office of Management and Budget, low income populations experience energy burdens more than four times as large as those of average households [OMB 2007]). Impacts to environmental justice from energy efficiency programs would be SMALL, depending on program design and enrollment.

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Alternatives 8.2.6 Purchased Electrical Power CP&L currently relies on purchased power from a variety of generators. In the summer of 2007, CP&L indicated a net purchased power capacity of 1442 MW. Through 2016, CP&L anticipates at least 1147 MW of purchased capacity (Progress Energy 2006a). Thus, NRC staff believes purchased power represents a reasonable alternative to license renewal. In the HNP ER, CP&L indicated that purchased power capacity would likely be available within the Carolinas. Impacts would likely be similar to those of the above generating options; if CP&Ls purchased power causes currently existing capacity to operate at higher capacity factors, rather than triggering new construction, then construction stage impacts would be eliminated. It is possible, however, that purchased power would then come from older, less efficient plants, plants with once through cooling, or plants without modern emissions controls. In addition, if power purchased to replace HNPs capacity came from plants built specifically to supply CP&Ls needs, the impacts would be the same as for the alternatives already discussed and constructed at alternate sites.

As such, impacts are difficult to quantify, though likely similar to other alternatives considered in Sections 8.2.1 through 8.2.5 in this SEIS, as well as in the GEIS.

Given the location of HNP, it would be unlikely that CP&L would be able to purchase power from Canada or Mexico to replace HNPs capacity, regardless of whether either country has sufficient existing export capacity.

Since purchased power may come from a variety of generating resources, including coal, natural gas, nuclear, hydroelectric, and perhaps oil-fired installations, NRC staff believes impacts from the purchased power alternative would be generally greater than the impacts of license renewal, and similar to impacts of the other generation alternatives staff considered in this section.

8.2.7 Other Alternatives Other generation technologies NRC staff considered but determined to be individually inadequate to serve as alternatives to HNP are discussed in the following paragraphs.

8.2.7.1 Oil-Fired Generation EIA projects that oil-fired plants will account for very little of the new generation capacity in the United States during the 2007 to 2030 time period, and overall oil consumption for electricity generation will decrease because of higher fuel costs and lower efficiencies (DOE/EIA 2007).

Oil-fired generation is more expensive to operate than nuclear or coal-fired plants, though it is less expensive than either to construct. Future increases in oil prices are expected to make oil-fired generation increasingly more expensive than coal-fired generation. The high cost of oil August 2008 8-69 NUREG-1437, Supplement 33

Alternatives has prompted a steady decline for use in electricity generation. For these reasons, oil-fired generation will not be evaluated at an alternative to HNP license renewal.

8.2.7.2 Wind Power Wind power, by itself, is not suitable for large base-load capacity. As discussed in Section 8.3.1 of the GEIS, wind has a high degree of intermittency, and average annual capacity factors for wind plants are relatively low (of the order of 30 to 40 percent). Wind power, in conjunction with energy storage mechanisms or another, readily dispatchable power source, like hydropower, might serve as a means of providing base-load power. However, current energy storage technologies are too expensive for wind power to serve as a large base-load generator, and opportunities to pair a sufficient volume of wind with hydropower do not exist in North Carolina (INEEL 1997).

The State of North Carolina is mostly a wind power Class 1 region, though some areas, particularly along ridgelines in the western part of the state, contain wind resources in Classes 4 through 7. Offshore areas in the east also offer wind power potential, and some areas provide wind classes ranging from 4 to 6 (DOE/NREL 2007a). While wind turbines tend to be economical in wind resources Class 4 and above, both ridgeline and coastal areas of the state are protected by state law, under the Mountain Ridge Protection Act (MRPA) and the Coastal Area Management Act, respectively (Bell 2006). La Capra Associates, in its 2006 report to the North Carolina Utilities Commission, indicated 500 MW of practical wind potential in North Carolina if one excludes prohibited western wind resources (La Capra 2006). Should interpretation of the MRPA change in the future, 1000 MW of additional practical wind potential is available in western North Carolina.

Given limitations on potential wind power sites, as well as relatively low capacity factors, NRC staff does not consider wind power to be a suitable stand-alone alternative to HNP license renewal. NRC staff does, however, recognize that North Carolina likely has utility-scale wind resources, and will include wind power in a combination alternative addressed in Section 8.2.8.

8.2.7.3 Solar Power Solar technologies use the sun's energy to produce electricity. Currently, the HNP site receives an average of 4.5 to 5 kWh of solar radiation per square meter per day, as does much of the state of North Carolina (DOE 2007). Since photovoltaic cells, the most likely alternative given North Carolinas potential, tend to be roughly 15% efficient, a solar-powered alternative would require approximately at least 2390 ha (5910 ac) to provide an equivalent amount of electricity to that generated by gas- and coal-fired alternatives (DOE/NREL 2006). In the GEIS, the NRC staff noted that solar power is intermittent; therefore, additional collectors would be necessary to account for shading. In addition, a solar powered alternative would require energy storage or a backup power supply to provide electric power at night. Solar power is currently significantly NUREG-1437, Supplement 33 8-70 August 2008

Alternatives more costly than most other alternatives for a given amount of capacity, and as adding energy storage technologies only increases the cost of solar power, NRC staff will not evaluate solar power in-depth as a feasible alternative to license renewal of HNP.

8.2.7.4 Hydropower The Idaho National Energy and Environmental Laboratory (INEEL) estimates that North Carolina has 508 MW of technically available, undeveloped hydroelectric resources (INEEL 1997). This amount occurs entirely in installations of 100 MW or less. This potential is 44%

less than HNPs capacity, and thus is insufficient to serve as an alternative to license renewal.

As such, hydropower would not be considered as a feasible alternative to HNP license renewal.

8.2.7.5 Geothermal Energy Geothermal plants are most likely to be sited in the western continental United States, Alaska, and Hawaii where hydrothermal reservoirs are prevalent (NRC 1998). There is no feasible eastern location for geothermal capacity to serve as an alternative to HNP. As such, NRC staff concludes that geothermal energy would not be a feasible alternative to renewal of the HNP operating license.

8.2.7.6 Wood Waste DOE notes that North Carolina has good biomass resource potential (DOE 2007). Pulp, paper, and paperboard industries in North Carolina consume wood and wood waste for energy production.

In 1999, DOE researchers estimated that North Carolina has biomass fuel resources consisting of urban, mill, agricultural and forest residues, as well as speculative potential for energy crops.

Excluding potential energy crops, DOE projected that North Carolina had 8,367,600 MT (9,223,700 tons) of plant-based biomass at $50 a ton delivered (Walsh et al. 1999; costs are in 1995 dollars). The National Renewable Energy Laboratory estimates that each dry ton of wood residue produces approximately 1100 kWh of electricity (DOE/NREL 2004). Assuming this conversion efficiency, using all biomass available in North Carolina at $50 per ton would generate roughly 10 TWh of electricity. This is greater than the output of HNP (operating at a 0.9 capacity factor) by roughly 43%. Walsh notes, however, that these estimates of biomass capacity contain substantial uncertainty, and that potential availability does not mean they would actually be available at the prices indicated or that resources would be free of contamination.

Some of these plant wastes already have reuse value, and would likely be more costly to deliver. Others, such as forest residues, may prove unsafe and unsustainable to harvest on a regular basis.

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Alternatives While the GEIS notes that wood-waste plants are able to operate in a baseload duty cycle, the larger wood-waste power plants are currently only 40 to 50 MWe in size. Thus, up to 23 wood waste plants may be necessary to replace the capacity of HNP. Estimates in the GEIS suggest that the overall level of construction impact per MW of installed capacity would be approximately the same as that for a coal-fired plant, although facilities using wood waste for fuel would be built at smaller scales. Like coal-fired plants, wood-waste plants require large areas for fuel storage and processing and involve the same type of combustion equipment.

NRC staff believes North Carolina has utility-scale wood waste resources, but given uncertainties in supply estimates, as well as the small size and high number of installed facilities necessary to replace HNP, NRC staff does not believe wood biomass is a suitable alternative to HNP license renewal. NRC staff will include wood waste facilities in a combination alternative addressed in Section 8.2.8.

8.2.7.7 Municipal Solid Waste Currently there are approximately 89 waste-to-energy plants operating in the United States.

These plants generate approximately 2700 MWe, or an average of approximately 30 MWe per plant (Integrated Waste Services Association 2007). Assuming average size waste incinerators, approximately 30 plants would be necessary to replace HNP.

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

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

Regulatory structures that once supported municipal solid waste incineration no longer exist.

For example, the Tax Reform Act of 1986 made capital-intensive projects such as municipal waste combustion facilities more expensive relative to less capital-intensive waste disposal alternative such as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v.

Town of Clarkstown struck down local flow control ordinances that required waste to be delivered to specific municipal waste combustion facilities rather than landfills that may have had lower fees. In addition, increasingly stringent environmental regulations have increased the NUREG-1437, Supplement 33 8-72 August 2008

Alternatives capital cost necessary to construct and maintain municipal waste combustion facilities (DOE/EIA 2001).

Given the small average installed size of municipal solid waste plants and unfavorable regulatory environment, NRC staff does not consider municipal solid waste combustion to be a feasible alternative to license renewal.

8.2.7.8 Other Biomass Derived Fuels In addition to wood and municipal solid-waste fuels, there are several other concepts for fueling electric generators, including burning crops, converting crops to a liquid fuel such as ethanol, and gasifying crops (including wood waste). In the GEIS, the NRC staff points out that none of these technologies has progressed to the point of being competitive on a large scale or of being reliable enough to replace a baseload plant such as HNP. For these reasons, such fuels do not offer a feasible alternative to renewal of the HNP operating license.

8.2.7.9 Fuel Cells Fuel cells work without combustion and the accompanying environmental side effects. Power is produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) over a cathode and separating the two by an electrolyte. The only by-products are heat, water, and carbon dioxide. Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically used as the source of hydrogen.

At the present time, fuel cells are not economically or technologically competitive with other alternatives for baseload electricity generation. EIA projects that by 2008, fuel cells will cost

$3,787 per installed kW, and projects a 10 MWe unit size (DOE/EIA 2006b). While it may be possible to use a distributed array of fuel cells to provide an alternative to HNP, it would be extremely costly to do so.

8.2.7.10 Delayed Retirement CP&L has no plans to retire any generating units at this time (Progress Energy 2006a), and thus delayed retirement would not be a feasible alternative to license renewal.

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Alternatives 8.2.8 Combination of Alternatives Even though individual alternatives to license renewal might not be sufficient on their own to replace the capacity of HNP due to the small size of the resource or lack of cost-effective opportunities, it is conceivable that a combination of alternatives might be cost-effective.

There are many possible combinations of alternatives. NRC staff believes a combination that includes, for example, 293 MWe of combined-cycle natural gas-fired capacity, six 50-MW biomass-fired plants, a 100 MWe wind park, and 250 MW of conservation programs would provide an alternative that roughly approximates the amount of power produced by HNP with some degree of overcapacity to compensate for wind capacity factors. The biomass-fired plants would operate on wood residues and would exist throughout the state, while the natural gas combined-cycle plant would operate at the HNP site or at an alternate site.

The GEIS indicates that wood-fired plants would serve baseload capacity, but that they tend to operate at low efficiencies and are economic only when feedstocks are very inexpensive. In addition, the GEIS notes that gathering fuel for wood-fired plants can have significant environmental impacts. NRC staff believes it is likely that 300 MWe of wood-fired generation would have SMALL to MODERATE impacts, depending on the fuel source. If the plants were widely distributed and feedstocks were primarily pre-existing waste streams, operational impacts would be SMALL. Construction impacts of six wood-fired plants would be SMALL to MODERATE depending on plant cooling configurations and plant locations. These impacts would be mitigated by locating plants on previously disturbed land near other industrial applications, including paper/pulp mills or other forest-products operations.

Siting a single, 293 MWe gas-fired unit at the HNP site would likely have SMALL impacts, similar to, but smaller than those of the gas-fired alternative NRC staff considered in Section 8.2.3. Initiating 250 MW of conservation programs would have overall SMALL impacts, as determined for a larger amount of conservation capacity in Section 8.2.5.

NRC staff notes that it may be difficult to site 100 MW of wind capacity in North Carolina (Bell 2006), but such a project may be possible in unrestricted areas, such as land on the western sides of North Carolinas sounds. A 100 MW wind park using 1.5 MW turbines (a common commercially available size) would require roughly 6.9 to 14 ha (17 to 35 ac) of land for turbine footprints based on DOEs Wind Farm Area Calculator (DOE/NREL 2007b), with some additional land use for infrastructure. The total area for the park would be larger, but land between turbines would continue to be used for agricultural purposes. Construction impacts for the 67 turbines required would be SMALL to MODERATE, depending on the amount of land disturbance required for installation.

The impacts of this alternative would be mostly SMALL, though potential exists for several MODERATE impacts. Therefore, the impact of this combination alternative would be greater than impacts of continued HNP operation or of the conservation alternative.

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Alternatives 8.3 Summary of Alternatives Considered NRC staff considered alternative actions including the no-action alternative (discussed in Section 8.1), new generation or conservation alternatives (coal-fired supercritical and IGCC generation, natural gas, nuclear, and conservation alternatives discussed in Sections 8.2.1 through 8.2.5, respectively), purchased electrical power (discussed in Section 8.2.6), alternative technologies NRC staff considered inadequate to serve as alternatives (discussed in Section 8.2.7), and a combination of alternatives (discussed in Section 8.2.8).

As established in the GEIS, the need for power from HNP is assumed by NRC in the license renewal process. Should NRC not renew HNPs license, this amount of generating capacity or load reduction would have to come from an alternative to license renewal. In addition, even if NRC renews the HNP operating license, CP&L could elect to meet this need with an alternative other than continued HNP operation. Decisions about which alternative to implement, regardless of whether NRC renews the HNP operating license, are left to utility and state-level decisionmakers (or non-NRC Federal level decisionmakers) where applicable.

The environmental impacts from most alternatives to license renewal that NRC staff considered would be greater than the impacts of continued HNP operation under a renewed license, which would have all SMALL impacts except for collective offsite radiological impacts from the fuel cycle and from high-level waste (HLW) and spent fuel disposal. The conservation alternative to HNP renewal, however, also has all SMALL impacts, and some of these impacts are likely to be smaller than the impacts of HNP license renewal.

The NRC staff concludes, then, that conservation has the lowest levels of environmental impact among all alternatives considered. Thus, conservation is the environmentally preferred alternative to the proposed federal action of renewing the HNP operating license.

8.4 References 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic Licensing of Production and Utilization Facilities.

10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Functions.

10 CFR 52. Code of Federal Regulations, Title 10, Energy, Part 52, Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants.

40 CFR 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, National Primary and Secondary Ambient Air Quality Standards.

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Table 9-1. Summary of Environmental Significance of License Renewal, the No Action Alternative, and Other Alternatives No-Action Coal-Fired Generation IGCC Coal-Fired Generation Alternative August 2008 Impact Proposed Action Denial of HNP Site Alternate Site HNP Site Alternate Site Category License Renewal Renewal SMALL to SMALL to Land Use SMALL SMALL SMALL SMALL MODERATE MODERATE SMALL to SMALL to Ecology SMALL SMALL SMALL SMALL MODERATE MODERATE Water Use and SMALL to MODERATE to SMALL to Quality - Surface SMALL SMALL SMALL to LARGE MODERATE LARGE MODERATE Water Water Use and SMALL to SMALL to SMALL to Quality- SMALL SMALL SMALL to LARGE MODERATE LARGE MODERATE Groundwater SMALL to SMALL to SMALL to Air Quality SMALL SMALL SMALL to LARGE MODERATE LARGE MODERATE 9-7 (a)

Waste SMALL SMALL SMALL SMALL SMALL SMALL SMALL to Human Health SMALL SMALL MODERATE MODERATE SMALL MODERATE Socioeconomics SMALL SMALL MODERATE MODERATE MODERATE MODERATE SMALL to SMALL to Transportation SMALL SMALL SMALL SMALL MODERATE MODERATE SMALL to SMALL to Aesthetics SMALL SMALL SMALL SMALL MODERATE MODERATE Historic &

SMALL to MODERATE to SMALL to MODERATE to archaeological SMALL SMALL MODERATE LARGE MODERATE LARGE Resources Environmental MODERATE to MODERATE to SMALL SMALL MODERATE MODERATE Justice LARGE LARGE NUREG-1437, Supplement 33 Summary and Conclusions (a) Except for collective offsite radiological impacts from the fuel cycle and from HLW and spent fuel disposal, for which a significance level was not assigned. See Chapter 6 for details

Table 9-1. Summary of Environmental Significance of License Renewal, the No Action Alternative, and Other Alternatives Combination Natural Gas-Fired Generation New Nuclear Power Generation Impact of Conservation Category Alternatives HNP Site Alternative Site HNP Site Alternate Site SMALL to SMALL to MODERATE to Land Use SMALL SMALL to LARGE MODERATE MODERATE MODERATE LARGE SMALL to SMALL to Ecology SMALL SMALL SMALL MODERATE Summary and Conclusions MODERATE MODERATE NUREG-1437, Supplement 33 Water Use and SMALL to SMALL to Quality - SMALL SMALL SMALL SMALL MODERATE MODERATE Surface Water Water Use and SMALL to SMALL to Quality- SMALL SMALL SMALL SMALL MODERATE MODERATE Groundwater SMALL to SMALL to SMALL to Air Quality SMALL SMALL SMALL MODERATE MODERATE MODERATE 9-8 Waste SMALL SMALL SMALL SMALL SMALL SMALL Human Health SMALL SMALL SMALL SMALL SMALL SMALL SMALL to SMALL to Socioeconomics SMALL SMALL SMALL SMALL to LARGE MODERATE MODERATE SMALL to SMALL to SMALL to Transportation SMALL MODERATE SMALL to LARGE MODERATE MODERATE MODERATE SMALL SMALL SMALL SMALL to MODERATE to Aesthetics SMALL MODERATE LARGE Historic & SMALL SMALL to SMALL to archaeological SMALL SMALL SMALL MODERATE MODERATE Resources Environmental SMALL to SMALL to SMALL SMALL SMALL SMALL Justice MODERATE MODERATE August 2008 (a) Except for collective offsite radiological impacts from the fuel cycle and from HLW and spent fuel disposal, for which a significance level was not assigned. See Chapter 6 for details.

Summary and Conclusions

9.3 NRC Staff Conclusion

s and Recommendations Based on (1) the analysis and findings in the GEIS, (2) the ER submitted by CP&L, (3) consultation with Federal, State, and local agencies, (4) the NRC staffs own independent review, and (5) the NRC staffs consideration of public comments received, the recommendation of the NRC staff is that the Commission determine that the adverse environmental impacts of license renewal for HNP are not so great that preserving the option of license renewal for energy planning decision makers would be unreasonable.

9.4 References 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions.

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

Progress Energy Carolinas Inc., (Progress Energy). 2006. Shearon Harris Unit 1, Applicants Environmental Report, Operating License Renewal Stage. Raleigh, North Carolina. Accessible at ML063350276.

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

U.S. Nuclear Regulatory Commission (NRC). 1983. Final Environmental Statement Related to the Operation of Shearon Harris Nuclear Power Plant. NUREG-0972. Office of Nuclear Reactor Regulation, Washington, D.C. Accessible at ML071340292.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants Main Report, Section 6.3 - Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.

NUREG-1437, Volume 1, Addendum 1. Office of Nuclear Regulatory Research, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555, Supplement 1, Washington, D.C.

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